ML19209D268
| ML19209D268 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 09/18/1979 |
| From: | Davis L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Farris J FELDMAN, HALL, FRANDEN, REED & WOODWARD |
| References | |
| NUDOCS 7910220292 | |
| Download: ML19209D268 (2) | |
Text
'M PUBLIC DOCUMEgy gogy
'.[Aanow*o UNITED STATES E\\
q NUCLEAR REGULATORY COMMISSION g J-
-t WASHINGTON, D. C. 20555
\\..v September 18, 1979
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Joseph R. Farris, Esq.
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Feldman, Hall, Franden, Reed k
and'Woodard k
c-816 Enterprise Building Ib:
C/^ -
%cQ.y Tulsa, Oklahoma 74103 In the Matter of Public Service Company of Oklahoma, Associated Electric Cooperative, Inc.
and Western Farmers Electric Cooperative, Inc.
(Black Fox Station, Units 1 and 2)
Docket Nos. STN 50-556 and STN 50-557
Dear Mr. Farris:
This letter is in response to your coments of July 16, 1979 on two letters concerning Black and Veatch's QA program obtained from the NRC's Public Document Room in Washington, D.C.
You asked whether the potential deficiencies in the Black and Veatch QA Program mentioned in the NRC Staff's April 30, 1979 letter affected the Staff's testimony or position taken at the now completed radio-logical health and safety hearings.
In addition, you asked whether the parties in Black Fox should have been served with this raterial. While there is an identity of some of the information contained in both the F' ack Fox FSAR and the document which prompted t! e Staff's April 30 letter, our Staff review has found the effect of this information to be de minimus. Therefore, for the reasons listed below and based on the notes Tn enclosure 1 of this letter, the answer to both questions is no.
First, it should be noted that the document which prompted the Staff's April 30, 1979 letter was a Black and Veatch topical report (BVTR-1-0) for which clarification was being required by the Staff.
Thus, a question concerning the Black and Veatch topical report is not necessarily a deficiency.
In addition, the Black and Veatch QA program is a " design only" QA program reviewed under Revision 0 of our Standard Review Plan (NUREG-75/087) while the Black and Veatch topical report is a " design and procurement" QA program which is being reviewed under Revision 1 of our Standard Review Plan which has been designated not to require "backfitting" into programs which have already been found acceptable. Thus, while the Black and Veatch topical report covers procurement, our review of Section 17B of the Black Fox PSAR did not cover procurement by Black and Veatch since that activity is performed by PSO.
In that regard, we have reviewed PS0's QA program under Appendix 17A of this PSAR and found it acceptable to the requirements contained in Revision 0 of our Standard. Review Plan.
1173 097 7910220 M b
. The Staff reviewed the questions on the topical report and found, as shown in enclosure 1, that only four of the questions are not attributable to either:
(a) changed scope of the program (from " design only" to
" design and procurement");
(b) changed review base (from Revision 0 to Revision 1 of our Standard Review Plan), or (c) changed wording (from Section 17B of the Black Fox PSAR to the Black and Veatch topical report).
As to these four items which are listed in enclosure 2, Black and Veatch has provided the clarification requested.
In general, while the response to these questions provide more detail t;an is in Section 17B of the Black Fox PSAR, the answer did not reveal any significant deficiency in the BFS PSAR.
In regard to the effect of the questions in the April 30 letter on the Black Fox Contentions, Board Questions, and Findings of Fact, as noted by Mr. Gallo in his letter of August 3,1979, Black and Veatch will neither procure nor supply material for Black Fox and tht:s there would be no effect. While the special process question of the Board Board Question 10-4) may go beyond the equipment supplied by GE, there is no rekvance for BFS since no equipment will be procured or supplied by Black and Veatch.
Regarding service of the Staff's April 30, 1979 letter to Black and Veatch on parties in Black Fox, we believed that the letter and its enclosed questions have minimal bearing on Black Fox and therefore were not served upon the Board and parties.
Because of the information given in this letter and its enclosures, we believe in retrospect that the decision was a correct one.
However, we thank you for bringing the matter to our attention.
Sincerely.
, - ~
L. Dow Davis Counsel for NRC Staff
Enclosures:
As Stated cc (w/o encl.):
Sheldon J. Wolfe, Esq.
Mr. Vaughn L.
Conrad Mr. Frederick J. Shon Alan P. Sielawski Dr. Paul W. Purdom Mr. Maynard Human Joseph Gallo, Esq.
Mr. T. N. Ewing Mrs. Ilene H. Younghein Atomic Safety & Licensing Board Michael I. Miller, Esq.
Atomic Safety & Licensing Appeal Board Mrs. Carrie Dickerson Docketing and Service Section Mr. Clyde Wisner Dr. M. J. Robinson Andrew T. Dalton, Jr., Esq.
Jan Eric Cartwright, Esq.
Lawrence Burrell Mr. Gerald F. DiddleJ3 C98 ..}}