ML20069N251
| ML20069N251 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/07/1994 |
| From: | UNION ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20069N230 | List: |
| References | |
| NUDOCS 9406220309 | |
| Download: ML20069N251 (9) | |
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ATTACHMENT 1
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OQAM, CHANGE NOTICE 94-03 IDENTIFICATION OF CHANGES
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9406220309 DR 940607 ADOCK 0500o493 PDR
' Ma%3 OQAM 2483 10.6 An inspection personnel qualification program shall 2484 be established to assure inspection activities are l
2485 being performed by personnel trained and qualified the to a capability necessary for performance of i
activity. Plant procedures shall prescribe the qualification requirements of inspection personnel.
responsible The Superintendent, Training shall be t
l for providing related technical and quality training appropriate to the certification /qualifi-cation of UE personnel.
1851 10.7 Quality Control inspection personnel or other unit 2263 staff organizations who perform " inspection" 2479 activities shall be qualified within their respec- ;
2480 tive areas of responsibility. The qualification of !
2481 QC inspection personnel shall be defined in three 2482 levels of capability as described in ANSI N45.2.6.
2483 Other members of the unit staff performing "inspec- !
2484 tion" activities shall have appropriate experience, l training, and retraining to assure competence in i
2485 2994 accordance with ANSI /ANS-3.1. Inspection assign-ments shall be consistent with the qualification of an individual. In instances where the education and are not met by QC experience recommendations l inspection personnel who are to be certified to ANSI N45.2.6, UE shall demonst-ate by documented results of written examinations and evaluations of actual work proficiency that individuals possess comparable or equivalent competence.
2263 10.8 Personnel from outside organizations performing QC 2480 inspection activities associated with safety-2482 related items at the Callaway Plant shall be certi-2483 fied as required by ANSI N45.2.6. sassonnel Esom.
2484 cutcide crgenicatienc er UE percernel ehe are net 2485 rerber: Of the unit ct:ff rhc perform Other activ--
2 ceciated with cafety-r-elated iterc at the-299 itiec Plant chall either be certified as-Cf3 /j f 6 6[7 A -C:ll:U:y required by ?.MSI F45.2.5 er they chall =cet educatier and er.perience requircrente applicablethe the-to-ATT^ggM the equivalent position en the unit etaff for l ctivitiec chich they are performingy l 2482 10.9 When contractors or vendors are retained to perform 2484 work activities or to provide services associated Plant, 2485 with safety-related items at the Callaway the qualification of inspection personnel and the conduct of inspections associated with that contracted work activity or service shall meet the requirements stipulated in the applicable procure-ment documents. As an example, if a vendor was contracted to conduct eddy current examinations of the the Callaway Plant steam generators, then persons performing the examination would be qual-10-2 Rev. 16 6/93
l OGA M cue W 3 h l l
Attachment A l
Personnel from outside organizations or UE personnel u ho are not members of the unit staliselected to perform other actisitics associated with safety-related items at the Callaway Plant shall cither be certified l as required by ANSI N45.2.6, meet the education and experience requirements applicable to the position l .
for the activitics u hich they are performing, be qualified through UEs " systematic approach to training,"
l or be qualified through a vendor's training and qualification program, which has been approved by UE.
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Qd M4-0 3 ooAn 2483 personnel shall be under the direction and control 2484 of the Vice President, Nuclear Operations. The be shall 2485 qualification of QC testing personnel defined in three levels of capability as described N45.2.6. Other members of the unit appro- staff in ANSI performing " testing" activities shall have and . retraining to priate experience, training, assure' competence in accordance with ANSI /ANS-3.1.
Testing assignments shall be consistent with the
. qualification of an individual. In instances where are l
the education and experience recommendations QC testing. personnel who are to be not met by certified. to ANSI N45.2.6, UE shall demonstrate and by l documented results of written examinations ,
i evaluations of actual work proficiency that indi-compe-viduals possess comparable or equivalent
-tence.
2263 11.12 el from outside organizations or UE ff 2480 personnel who are not members of the unitociated I l2482 who perform other testing activitieallaway Plant 2483 with safety-related items at t 2484 shall either be certifiemeettheeducationandexpedrequired by ANSI N45.2.6 or they As Cggg q f3 ~1485 rience reg Wents applicable to the equivalent 7g ,g h g}- C
~7 positi the unit staff for the activities whic h the re performing.
2483 11.13 When contractors or vendors are retained to perform 2484 work activities or to provide services associated Plant, 2485 with safety-related items at the Callaway qualification of testing personnel and the the conduct of tests associated with that contracted require-work activity or service shall meet the procurement ments stipulated in the applicable were documents. As an example, if.a vendor contracted to conduct testing of the main steam line safety valves at the Callaway Plant, then the persons performing the testing / valve settingsquality would be qualified as required by the vendor's assurance program unless otherwise specified in the applicable procurement documents.
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' OQAM Ced 2 % oJ Attachment. C
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Personnel from outside organinitions or UE personnel who are not members of the unit stafT selected to perform other testing activitics associated with safety-related items at the Callaway Plant shall cither be certified as required by ANSI N45.2.6, meet the education and experience requirements applicable to the position for the activities u hich they are performing, be qualified through UEs "s3 stematic approach to training " or be qualified through a vendor's training and qualification prograni, which has been approved by UE.
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' Ca o C 3 -lb 00AM Hj APPENDIX A ad yp4d.
REGULATORY GUIDE 1.8 (cont.)
The experience, training, and education requirements for the positions of Shift Supervisor, Operating Supervisor, and Reactor l Operator, and personnel fulfilling the duties of Shift Technical Advisor shall meet or exceed the requirements and recommendations of ANSI /ANS 3.1-1981 as endorsed by the Regulatory Guide 1.8.
For all other positions, qualification and training shall comply with ANSI /ANS 3.1-1978 as clarified below:
Refer to Callaway-SA FSAR Section 13.1 for a discussion of the qualifications of personnel responsible for plant operation and support.
Personnel responsible for directing or supervising the conduct of safety-related preoperational and startup tests and for review and approval of safety-related preoperational and startup test procedures or results met the qualifications of the Regulatory Guide, but were not required to be certified.
With regard to Section 5.6 of ANSI /ANS 3.1 - 1978 titled Documen-tation: UE shall maintain records in accordance with and to meet t.he requirements of OQAM Section 17 and ANSI N45.2.9 as specified herein.
may use additional non-Callaway employees or con t perso 1 to augment the unit staff. These persons may o y not report t e Manager-Callaway Plant. These groups ude, but are not limi to, UE personnel from other p s as well as
?bupplemental EP a &C technicians and QC pectors. When used to perform safety-rela activities, se personnel shall meet p the education and experien requi ents of ANSI /ANS 3.1 - 1978 for equivalent UE staff posi . If no equivalent positions
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' M exist, these personne14au. quali by Union Electric or y Vendors with for assigned tasks either n Electric approved
/ dW g d
training and qua testing pers cation programs. Inspec
- 1 shall r,'et the requirements fo
, examination and certification JpcM A as inspe UE's on, examinatito and testing personnel as mmitmant to ANSI d45.2.6-1978 given elsewhere i forth in this L Y p cp ,
endix.
REGULATORY GUIDE 1.28 REVISION 2 DATED 2/79 Quality Assurance Program Requirements (Design and Construction)
(Endorses ANSI N45.2-1977)
DISCUSSION:
This Regulatory Guide is not applicable to the operating phase.
However, ANSI N45.2-1977 will be applied to suppliers of safety related items, components or services, as appropriate, as described under Regulatory Guide 1.123 (ANSI N45.2.13-1976).
A-2 Rev. 16 6/93
. . OQ/hM co bhaq-o3
' Y Attachment B r
UE may use additional Union Electric cmployces or contract personnel to augment the unit staff. These groups include, but are not limited to, UE personnel from outside the Nuclear Disision as well as supplemental HP and I&C technicians and QC inspectors. When used to perform safety-related activitics, these personnel shall meet the education and experience requirements of ANSI /ANS 3.1-1978 for equivalent positions or specified education and experience requirements for non-cquivalent positions. As an alternative these personnel may be qualified for assigned tasks either by UE through its systematic approach to training or by Vendors with UE approved training and qualification programs. Inspection cxamination and testing personnel shall meet the requirements for certification as in3pection, examination or testing personnel as set forth in UEs commitment to ANSI N45.2.6 1978 given clsewhere in this Appendix.
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ATTACHMENT 2
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OQAM, CHANGE NOTICE 94-03 l
EXPLANATIONS OF AND JUSTIFICATIONS FOR PROPOSED l CHANGES TO THE OQAM l l
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- l Attechmant 2 ULNRC-2976 Page 2 of 3
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l EXPLANATIONS OF AND JUSTIFICATIONS FOR PROPOSED CHANGE TO THE OPERATING QUALITY ASSURANCE MANUAL (OQAM)
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[1] Justification for changes to Sections 10.8 and 11.12 of the OQAM.
These sections were revised to reflect desired changes to Union Electric's commitment to Regulatory Guide 1.8 as stated in Appendix A. See the next section for specific changes and justification.
[2] Justification for changes to Union Electric's commitment to Regulatory Guide 1.8 (ANSI /ANS 3.1) as clarified in Appendix A to the OQAM.
ANSI /ANS 3.1-1978 contains requirements for the qualifications, responsibilities, and training of personnel in operating and support organizations for stationary nuclear power plants.
For all craft / technical positions, ANSI /ANS 3.1 requires a high school diploma or equivalent and three (3) years related experience in the craft or speciality area. UE believes that applicable training and examination are also effective in determining individual qualifications.
Therefore, alternate methods of qualifying personnel should be available.
With the changes proposed, all contract / vendor personnel performing safety-related tasks will continue to meet minimum qualification requirements specified by UE.
Contract / vendor personnel used to perform safety-related tasks will either:
. Meet the education and experience requirements of ANSI /ANS 3.1-1978 for equivalent positions,
. Meet specified education or experience requirements for non-equivalent positions,
. Be qualified by UE through its systematic approach to training, or
s .. s Attachment 2 ULNRC-2978 Page 3 of 3 5
- e ]Be qualified by vendors with UE approved training and' qualification programs.
l This change will provide added assurance that only qualified personnel will be performing work on safety-related equipment at Callaway. This level of
'. confidence will result from the fact that contract / vendor personnel will meet the training and qualification '
requirements of ANS 3.1 or will receive task specific
- training and will be evaluated on their retention of this
! training either by UE or a UE approved vendor training and l qualification program.
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