IR 05000482/1981015
| ML20248E656 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/29/1989 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Garde B GARDE, B.P. |
| Shared Package | |
| ML20248E659 | List: |
| References | |
| NUDOCS 8910050374 | |
| Download: ML20248E656 (3) | |
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UNITED STATES o
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NUCLEAR REGULATORY COMMISSION
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SEP 2 9198g Ms. Billie Pirner Garde Garde Law Office 103 East College Avenue Appleton, Wisconsin 54911
Dear Ms. Garde':
Your letter of August 21, 1989 to Mr. James M. Taylor of the U.S. Nuclear Regulatory Commission (NRC) questioned NRC's knowledge and approval of a
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Construction Quality Control Department (CQCD) that existed during the construc-tion phase of the Wolf Creek facility.
In your letter you alleged that the CQCD functioned in the manner of a quality control organization but was not staffed by certified inspectors and did not keep inspection records and documenta-tion as required by 10 CFR Part 50, Appendix B.
A quotation highlighted from the Wolf Creek Final Safety Analysis Report indicates your belief that such an organization was active in the Wolf Creek quality assurance program.
Finally, you have referenced NRC Inspection Report 81-15, a report that examines the Wolf Creek quality control / quality assurance (QC/QA) program but makes no mention of a " quality control" function within the construction department.
While the NRC was aware of the CQCD and its general function, we have examined our records and we have not identified any documentation indicating that the NRC reviewed this program. However, in response to your letter, we have discussed your concerns with Wolf Creek management. The following information was obtained from the licensee and describes the formation and role of the CQCD.
During the construction phase of the Wolf Creek facility, the licensee (Kansas Gas & Electric or KG&E) had separate departments for construction and quality control. The quality control department performed the quality program required by 10 CFR Part 50, Appendix B, monitoring the approved quality programs of all contractors operating on site.
Before the operating license was issued, the Wolf Creek project was experiencing numerous scheduling delays and cost overruns.
It is our understanding that KG&E management decided that additional attention was needed in the QC/QA area.
Therefore, during 1984 KG&E hired a number of Bechtel employees who had QC backgrounds to bolster management oversight. These individuals formed the CQCD and they were part of KG&E's construction department. The CQCD performed a comercial activity for the licensee by examining work schedules and cost overruns, and by assessing the individual contractors working at the site.
According to the licensee, the CQCD did not perform QC functions or inspections required by 10 CFR Part 50, Appendix B.
Additionally, although the CQCD staff was primarily composed of QC experts, they were not required to be certified QC inspectors at'the Wolf Creek site.
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Ms.-Billie Pirner Garde-2-In sumary, the staff's review of the licensee's quality program required by 10 CFR Part 50, Appendix B makes no reference to the CQCD or a quality control function within the construction department nor did the staff rely on the CQCD's activities in assessing KG&E's compliance'with Comission requirements.
This is' consistent with the licensee's statement that the CQCD simply provided an advisory or consultant role and was independent of the QC program. According to the licensee's stated purpose of the CQCD, we would not expect the licensee Lto submit information to the staff relating to this program. Similarly, the staff would not normally review voluntary programs such as the CQCD that are not relied upon by the licensee during the licensing process.
Finally, clarification should be provided to two references made in your letter of August 21, 1989. First, the CQCD did not exist during the 1981 period covered by Inspection Report 81-15. Second, the reference to the Wolf Creek Final Safety Analysis Report corresponds to the gradual transfer of construction activities (e.g., procurement, maintenance) to startup and operations activities.
Such a transfer of responsibilities is a routine part of licensing and is independent of the CQCD concern.
Sincerely, Original signed by
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Thcsas E. EnricZ Thomas E. Murley, Director Office of Nuclear Reactor Regulation DISTRIBUTION Docket File PD4 Reading NRC PDR w/cy of incoming Local PDR w/cy of incoming EDO #0004707 ED0 Reading T. Murley/J. Sniezek J. Partlow PD4 Reading (w/cy of incoming)
G. Holahan F. Hebdon 0GC-Rockville GPA/CA (only when CA is on concurrence)
J. Taylor D. Mossburg, PMAS (ED0#0004707) w/cy of incoming D. Pickett w/cy of incoming P. Noonan PD4 Green Ticket File F. Miraglia D. Crutchfield F. Gillespie A. Gody
.E. Holler R. Martin, RIV DOCUMENT NAME: GT 4707
- See previous concurrences:
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iJames ML Taylor;
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? Acting DirectorLof: Operations
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Wolf 1 Creek;LDocket'50-482-
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Dear Mr." Taylor,
In connection with litigation. stemming from the Wolf Creek
- plant,,I ^ am-trying to determine if. the Nuclear Regulatory-
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- Commission-was aware _ of and. approved the existence of - a Construction Quality Control' Department at'the. Wolf Creek plant
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duringl' thel construction : phase of: that' plant'whichLfunctioned in
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the ~ same ' manner a s.
a quality control organization, i.e.,
performing; inspections-upon completion of-work by craft, but were-
- documentation a;as -required by L 10not1 certified inspectors andldid not keep inspe C.F.R.150 ' Appendix B.
-And if Lthe. program;was. approved, what'was the, basis of:the approval and.
' how.: did: the;. NRC insure that-it - was in compliance with 10 C.F.R.
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50' Appendix-B.
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I h a v e.- r e v i e w e d the. SAR's. and FSAR's for both the'SNUPPG Lplants: generally.and Wolf. Creek-specifically.
.FSAR, Chapter 17, Section 17;2-2 Rev. ' 1, - Page A-9 indicates that such a ' program existed. - :It states:
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- Construction organizations committed to the 1-The' program was essentially equivalent to the in process
- inspection ' program that was in place at the Midland Nuclear plant inf the
.1 9 8 1 / 8 2. t i m e frame and was the subject of enforcement-action, a. civil' penalty, and mandated rework.
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may1 hav'e ~ provided quality related activities to v
organization (s) ' committed to the requirements of the
, operating. Quality program.(e.g. procurement and receipt
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A description of'the QA Program elements controlling-these activities was located in the.
appropriate section(s) of the SNUPPS QA Programs for Design and Construction. Manual.
The construction.
organization which provided safety-related activity for the operations /startup ' applications assured that all personnel were qualified in accordance with the Design
'and Construction QA Program qualification requirements.
Both the Operating Agent Construction and Operations were responsible for. establishing procedures to control
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l-thef interface between the constructi.on organization (s)
a providing the activity and using organization (s).
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However',.a comprehensive review of the inspection reports
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done by.NRC inspectors into the functioning of the Wolf Creek
. Quality Control / Quality Assurance program do not make any references.to knowledge of or review of a " quality control" function within'the construction department.
See, in particular, Inspection Report 81-15 which examined in detail the site QA/QC program implementation.
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I.would appreciate a response to this letter in a timely p
manner.
If further discussion between myself and the staff
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person you assign this matter to will be helpful, please have
.them call me.
P Thank you for your attention to this matter.
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Sincerely, 0_
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Billie Pirner Garde
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