ML19210B225
| ML19210B225 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/12/1974 |
| From: | Schwencer A US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Arnold R METROPOLITAN EDISON CO. |
| References | |
| NUDOCS 7911040168 | |
| Download: ML19210B225 (2) | |
Text
e.
0-289 Metropolitan Edison Company ATIN:
Mr. Robert C. Arnold Vice President - Generation P. O. Box 542 Reading Pennsylvania 19603 Centlemen:
On February 4,1974 we wrote to you describing the results of our review of your proposed Operating Quality Assurance Plan. Our letter indicated that you should change your plan in two respects and refile it as an amendment to your application. We have received that amendment and our review of the changes you made does not fully resolve our concerns; further amendment in both areas will be required. Ibis letter is intended to maplify and clarify our position with respect to these two areas, namely, the interface with General Public Utilities Service Corporation (GPUSC) and the adoption of ANSI Standards and AEC Regula*ory Guides.
We realize that CPUSC is a corporation in parallel with the operating companies such as Metropolitan Edison Company (Meted) in the CPU group.
Consequently, it is not unreasonable to establish a unique quality assurance interface with them, which differs from that which you have with an ordinary vendor. However, that uniqueness should be confined to the organizational level of interaction, and should not include the unmonitored delegation of quality assurance responsibility. Meted will be the licensee for the Three Mile Island Unit 1 (D11-1) and cannot delegata quality assurance responsibility without restriction. Meted's operational quality assurance program is reviewed and approved by the AEC through the plan we discuss here. In any case where work is delegated to a vendor, Meted, through the Manager-Operational Quality Assurance, retains the responsibility to review, concur, and audit the quality assurance efforts of that vendor as applied to THI-1.
Similarly, where work is delegated to GPUSC, Meted must retain the clear responsibility to review, concur, and audit the quality assurance efforts of GPUSC as they apply to 1MI-1.
The interface with GPUSC you describe in your plan does not appear to us to define that review, concurrence, and audit responsibility. Ihat responsibility must be defined, and exercised.
).n, qg
)() f
(. I U q
omes
- e s. e s a..a s4 7911040/ @ pJ
. s Mr. Robert C. Arnold h1213N In the various sections of the IMI-l Operating Quality Assurance Plan, reference is made to AEC Regulatory Guides and ANSI standards, namely, the guidance contained in the " Orange Book". Most of tho references indicate that IMI-l procedures will be " guided by" these guides and j
standards; few use the more rigorous reference of " comply with".
The use of less rigorous reference terminology suggests a misunderstanding of l
the role of the " Orange Book" guidance and our intent in stating you should " commit to t'e implementation" of it.
When an applicant is i
I weighing a decision with' respect to drawing up procedures, guidance I
offered by the AEC through guides and standards may be accepted wholesale or suitable alternatives may be proposed. The opportunity for choice is i
not continuous; once choice is made, an acceptable procedure is established L
and that procedure must be complied with or followed. Therefore,' in then TMI-l Operating Quality Assurance Plan, you can provide your own detailed i
j procedures for training, design control, document control, etc., or you can agree to comply with those covered by the various AEC guides and ANSI standards.
We have previously indicated to you that the TMI-1 Operating Quality l
Assurance Plan must be approved and implemented before an operating license is issued. Therefore, it is essential that our concerns in these two matters be resolved at once.
Sincerely, Originalsigned A. Schwencer, Chief Light Water Reactors Br. 2-3 Directorate of Licensing
~
George F. Trowbridge, Esquire cc:
Shaw, Pittman, Potts & Trowbridge l
910 17th Street, NW Washington, D. C.
20006 DISTRIBUTION:
AEC PDR RWKlecker WButler Local PDR OGC JStolz
}IdU]
2/~l Docket R0 (3)
ASchwencer LWR 2-3 Rdg RMBernero ACRS (16)
VAMoore EIGoulbourne RVollmer JIendrie KGoller 5 extra copies AKenneke KKniel nFi mmhu t DVassallo orrica n.
LW1.2.--A.......1-
]
._LIC/.WR 2.-3..
g % u.
41 L
t>
,RMBernero:kmf ollmer $,ASchwencer g,
_ f,
/74 3 / _ // _
/74 3/ _//
/74 3/
/
om ro.i. uc-n. mo.. 3n ucu ou.
,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,.,,,.,,,