ML20041B543

Responds to Re Util Compliance W/Reg Guide 1.58, Revision 1 & Reg Guide 1.146,discussing Qualification of Insp,Exam,Testing & Audit Personnel

ML20041B543
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/03/1982
From:	Lee O PUBLIC SERVICE CO. OF COLORADO
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 GL-81-01, GL-81-1, P-82042, NUDOCS 8202240214
Download: ML20041B543 (3)

Text

'

PUBLIC SERVICE COMPANY OF COLORADO P.

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BOX 840 DENVER. COLORADO 80201 OSCAlt it. LEE

,A February 3, 1982 /

v cc.cs.oc e Fort St. Vrain

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Unit No. 1 Mb P-82042

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CliftD G-9 Mr. Darrell G. Eisenhut U

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Division o' Licensing N%

Office of Nuclear Reactor Regulation 9

I U. S. Nuclear Regulatory Commision y

s, Washington, D.C. 20555 4

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Subject:

Qualification of Inspection, Examination, & Testing

& Audit Personnel

Reference:

NRC Generic Letter SI-01 dated 1-5-82 (G-82008)

Dear Mr. Eisenhut:

This letter is in response to your letter dated January 5,1982, wherein you requested PSC to comply with regulatory positions C.

5.6,7,8 & 10 of Regulatory Guide 1.58 Revision I & Regulatory Guide 1.146.

The following addresses PSC position regarding these natters.

Regulatory Guide 1.53 Regulatory Pesition C.5 This regulatory position makes reference to ANSI N45.2.6 - 1978 as well as indicating that level III personnel should be capable of reviewing and approving inspection examination and testing procedures ar.c al so De capable of evaluating tne adecuacy of such procedures to acccToli st. the inspec.icn, e>.amir.ation and test objectives.

Our FSAR committment (section S.5.19.7) is to achere to the guidance provided by ANSI N45.2.6 - 1973 and Regulate y Guice 1.58.

ANSI Nd5.2.6 - 1973 ciffers from ANSI N45.2.6 - 1978 in that Table I of y g 2,E ANSI N45.2.6 - 1973 specifies that minimum capability level for y

personrel approving inspection and test procedures as level III.

Table I of ANSI N45.2.6 - 1978 does not mirrcr this requirement.

In

/ o addition, FSV Administrative Procecure G-7, FSV Project Personnel Training and Qualification Programs, implements the ANSI N45.2.6 -

1973Property "ANSI code" (as page type) with input value "ANSI N45.2.6 -</br></br>1973" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. requi re: rent.

In addressing the examination portion of regulatory position C.5, the definition of examination contained within ANSI N45.2.6 - 1973 is used.

Note:

This definition is also contained in FSV Administrative 8202240214 820203 PDR ADOCK 05000267 V

PDR

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. Procedure G-1, Glossary of Abbreviations and Definitions.

FSV Administrative Procedure Q-9, Control of Special Processes, requires that Nondestructive Examination (NDE) personnel and procedures be appropriatly certified by an ANSI-TC-IA level III Examiner.

PSC is currently within the purview of regulatory position C.5 and contemplates no further action.

Regulatory Positicn C.6 PSC's FSAR committment is to ANSI N45.2.6 - 1973 in which are contained the educational requirements for level I, II and III.

FSV Administrative Procedure G-7, FSV Project Personnel Training and Qualification Programs, implements that ANSI N45.2.6 - 1973 educational requirements.

PSC is currently within the purview of regulatory position C.6 and contemplates no further action.

Regulatory Position C.7 ANSI N45.2.6 - 1973 (PSC FSAR Committment) section 4 requires that when inspections and tests are implemented by Teams or groups of individuals, the one responsible must participate and meet the minimum qualifications indicated.

FSV Administrative Procedure Q-10, Inspection, requires that QA Department Inspectors be qualified to a minimum level of II for the activities that they are to perform.

This requirement satisfys regulatory position C.7 Regulatory Position C.8 Currently, FSV QA/QC Inspection personnel receive Health Physics Training, with records of this training being maintained by the Training Department. There is, however, no procedural requirements that makes this type of Training mandatory for QA/QC inspection personnel.

PSC QA will revise the necessary procedures to assure that this type of training is provided to QA/QC inspectors.

The necessary revisions

(

to procedures should be complete by March 31, 1982.

In the event that PSC QA/QC personnel perform radiographic examinations, procedures and policies governing this activity shall be developed and will include the appropriate training in radiation prctection and radiation dose reduction considerations.

Regulatory Position C.10 I

FSV Administrative Procedure G-7, FSV Project Personnel Training and Qualification Programs, provide certification criteria based upon l

Education Experience, Professional Accomplishments and Management l

Evaluation.

Based upon the mandates of ANSI N45.2.6 - 1973, PSC's l

program is based upon the educational and experience requirements I

contained therein and, as a consequence, " comparable" or " equivalent" L

'N I',

o ccmpetence or the determination thereof is not discussed nor allowed in the FSV Administrative Precedure.

Our program satisfys the intent of Regulatory Position C.10.

Regulatory Guide 1.146 FSV Administrative Procedure Q-18, Quality Assurance Monitoring &

Audit Program, delineates the qualification requirement for auditors

& lead auditors.

The basis for this procedure was ANSI /ASME N45. 2.

23 - 1978 including the point accumulation system for lead auditor qualification. Our present program satisfys the intent of Regulatory Guide 1.146.

At the present time PSC is reeting the intent of Regulatory Guides 1.58 & 1.146.

Necessary procedure changes to include job related Health Physics Training, as a requirement for QA/QC Inspectors, will be accomplished by March 31, 1982.

fh' W

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Lee Vice President Production Electric Production ORL/rg