ML13333A570
| ML13333A570 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/30/1987 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| NUDOCS 8711040031 | |
| Download: ML13333A570 (2) | |
Text
October 30, 1987 Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention: Mr. K. P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Gentlemen:
Subject:
Quality Assurance Program Description for San Onofre Units 1, 2 and 3 On August 31, 1987 you submitted Change Notice (CN) No. 21 to the Topical Report - Quality Assurance Program SCE-1-A. As you acknowledged, CN 21 represents a reduction in commitments previously accepted by the NRC.
In the current QA program, Section 17.1.5.2, the QA organization reviews and approves inspection plans; test, calibration, and special process procedures. In the proposed change, CN 21, these plans and procedures would not be reviewed by the QA organization prior to issuance but would be subject to review at QA's discretion during audit and surveillance activities. As a result of our review of CN 21, we have determined that additional justification or clarification is needed as is evident by the following concerns:
- a. What organizations are responsible for the review and approval of these plans and procedures if not QA?
- b. Since preventive QA is finding problems before the fact, and auditing is after, how do you justify the proposed reduction?
- c. CN 21 proposes a review of inspection procedures but not the inspection plan. Wouldn't it be more appropriate to review the inspection plan since it's the top tier document?
- d. Section 17.1.5.2, third paragraph, last sentence of CN 21 states that drawings and specifications are reviewed and approved by the QA organization. Is this a 100% review or at QA discretion?
If you feel that the current 100% review and approval of these procedures is adverse to quality, would you please provide the necessary justification in order for us to concur that your proposed change continues to satisfy the requirements of 10 CFR 50, Appendix B.
6711040031 871030 PDR ADOCK 05000206 PPDR d
Mr. K. P. Baskin 2
October 30, 1987 Please contact W. J. Wagner at (415) 943-3731 with any questions you have regarding this matter.
/5/
Dennis F. Kirsch, Director Division of Reactor Safety and Projects cc:
J. G. Spraul, QAB E. M. McKenna, NRR H. Rood, NRR R. F. Dudley, NRR R. Huey, RV P. Qualls, RV Section Chiefs Branch Chiefs RSB/Document Control Desk (RIDS)
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