ML13330B520
| ML13330B520 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/21/1991 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| NUDOCS 9105300085 | |
| Download: ML13330B520 (3) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIA LANE, SUITE 210 0
WALNUT CREEK, CALIFORNIA 94596 MAY 21 19 Southern California Edison Company Irvine Operations Center 23 Parker Street Irvine, California 92718 Attention: Mr. Harold B. Ray Senior Vice President Nuclear Gentlemen:
Subject:
QUALITY ASSURANCE PROGRAM DESCRIPTION FOR SAN ONOFRE UNITS 1, 2 AND 3 We have reviewed the proposed changes addressed in Change Notice 38 to Topical Report SCE-1-A, "Quality Assurance Program," Amendment 13.
Change Notice 38 proposes to delete the in-line review and approval of procurement documents by the Nuclear Oversight Division (NOD).
This review and approval by NOD is to assure that procurement documents contain appropriate quality requirements.
Change Notice 38 proposes to replace NOD's method of in-line review of procurement with a program of audits and surveillances.
We also reviewed your reasons for this change including your basis for concluding that the change satisfies the criteria of 10 CFR 50, Appendix B.
The reasons provided are based upon an SCE evaluation which concluded:
(a) that continued in-line reviews of procurement documents are not identifying discrepancies that affect quality; and (b) that resources.can be more effectively utilized by oversight techniques which emphasize in-depth assessments of th-e entire procurement document control process.
These reasons provide acceptable justification to support deleting the in line reviews of procurement documents by NOD. Also, you included with Change Notice 38 a commitment to reinstate the in-line reviews if corrective actions taken to address unacceptable quality levels do not provide adequate results.
During our review we did note an proposed unacceptable change in Section 17.2.4.2 "Procurement Document Control," affected page 17.2-18. The responsibility for NOD to perform the quality assurance engineers review of procurement documents was deleted, along with specific verification of quality requirements. It is our understanding that thfs quality activity is to be delegated to the responsible engineer. Therefore, this paragraph should be reinserted with the term 9105300085 910521 PDR ADOCK 05000206 p
"quality assurance" deleted from the first sentence to reflect the "responsible engineers" review of procurement documents. This was discussed in a telephone conversation between W. Wagner (NRC/RV) and J. Harmon (SCE) on April 19, 1991.
Subsequently, on April 19, 1991, you submitted an addendum to Change Notice 38 which reflects the responsible engineers review of procurement documents as addressed in your currently approved quality assurance program.
Our review of Change Notice 38, as amended by your letter of April 19, 1991, reveals that Amendment 13 will continue to meet the requirements of 10 CFR 50, Appendix B; therefore the changes are acceptable. If there are any changes to other operative QA commitments existing in docketed correspondence outside of the SAR QA program description, you are obligated to notify this office.
Implementing such changes should be based on 10 CFR 50.54 (a)(3).
Should you have any questions regarding our review, please contact W. J.
Wagner at (415) 975-0313.
Sincerely, R. P. Zimmerman, Director Division of Reactor Safety and Projects cc:
J. Bradfute, NRR/PD5 G. Kalman, NRR/PD5 L. Kokajko, NRR/PD5 J. Spraul, NRR/LPEB C. Caldwell, RV F. Gee, RV Section Chiefs Branch Chiefs RSB/Document Control Desk (RIDS)
MAY 2 1 g 3
[ R ST COPY ]
REQUEST COPY REQUEST PY ] REQUEST
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[YEV/ NO 1
YES /
NO 1
YES 1
YES 0
WAGNER ROYACK FOR HUEY KIRSCH PERKINS 4/f3/r91 4/2 91
/91
/V91
[ REQUEST COPY I
[ SEN TO PDR YES /iNO 1
[
E NO I
ZIMMERMAN 4/ 7 91 RECORD NOTE:
JACK SPRAUL (NRR/LPEB) AGREED WITH OUR CONCLUSION THAT CN38 REPRESENTS AN ACCEPTABLE REDUCTION IN COMMITMENTS.