We have a structure of quals for our shippers that range from excepted qty 
shippers, LSA equipment shippers, and waste shippers.  When you bring in a 
contractor, they have to demonstrate they can follow your procedures to achieve 
the correct result.  Outside of the normal shipper quals from the vendor, the 
Technical Grp Mgr is responsible for assessing their ability to follow our 
procedures and complete a training form that the RPM signs attesting to the 
person's ability to have the same qual as the utility shipper.  I'm sure every 
utility has a process for equivalency assessments for qualifications and that 
is the process we use.  Our program has you explain why the person's vendor 
qual and experience are good enough to give them a utility qual.  If you and 
the RPM don't feel good enough to sign it, then you shouldn't sign it.  Very 
clear GO / NO-GO gate.  Depending on the experience of the Technical Mgr doing 
the evaluation, you can get varied results.  I considered shipping as a 
critical qual and made sure I was a qualified shipper to understand how to 
manage the program and shippers properly.  In the end, they should have the 
same looking quals as your normal utility shipper.  When the NRC comes in, they 
typically look at the names in a shipping pkg and ask to see their quals and 
they all look the same.

I used to have the vendor shipper explain our shipping procedures to me to 
demonstrate they knew the content of our procedures, asked them key techno 
questions about Radman, and had them do a couple of manifests of what we 
intended to ship.  They're not going back through all of the qual stuff for a 
new person that has never shipped, but I'm verifying this vendor-qualified 
person can follow my procedures and represent my utility.  I'm personally 
responsible for this person's performance, so I make sure they're as good or 
better than another acceptable shipper.

Even after giving a contractor a qual, you need to review their work before it 
is used to ensure they are implementing the right standard.  There have been 
multiple issues in the industry where people have come in to ship for Technical 
Mgrs who didn't understand shipping and the Technical Mgr didn't know the 
contractor was off track until an external stakeholder pointed it out.



Glen Vickers
Exelon Corp RP Technical Lead, CHP
815-216-2723 (work/cell)


From: [email protected] [mailto:[email protected]] On Behalf Of 
[email protected]
Sent: Thursday, August 28, 2014 7:22 PM
To: [email protected]
Subject: Powernet: Contractor shipping qualification program

SONGS would like to know if your site has a contractor shipping qualification 
standard you use to screen personnel coming to your site to perform, or assist 
in the performance, of shipping/packaging RAM? Or, do you rely solely on a QA 
audit or procurement agreement that addresses qualification? Or, do you simply 
run the incumbent through an in-house qualification process, normally designed 
for in-house personnel, to address this? If you have a qualification process 
specific to on-boarded contractors or an associated qual manual, would you be 
willing to share your process?

Thank you,
Jeff Carey
General Supervisor of Radiation Protection
San Onofre Nuclear Generating Station
Internal: 949-368-7545
External: 951-440-4250
x87545/86457
Pony mail:  SONGS-J72

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