ML19263D820
| ML19263D820 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/28/1979 |
| From: | Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML19263D822 | List: |
| References | |
| NUDOCS 7904130290 | |
| Download: ML19263D820 (2) | |
See also: IR 05000423/1978005
Text
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Docket No. 50-423
M 2 8 1979
Northeast Nuclear Energy Company
ATTN:
Mr. W. G. Counsil
Vice President - Nuclear
Engineering Operations
P. O. Box 270
Hartford, Connecticut 06101
Gentlemen:
Subject:
Inspection 50-423/78-05
This refers to your letter dated October 23, 1978, in response to our
letter dated September 27, 1978.
This also refers to an inspection
conducted at the Millstone Point Unit 3 site on March 13-15, 1979.
Your letter acknowledged that an on-site contractor had accomplished
work contrary to applicable drawings, that the contractor had erroneously
accepted the nonconforming condition, and that our inspector identified
this as an item of noncompliance.
Your letter requests that the item be
reclassified to an unresolved item.
The basis for the request is that
the contractor had not presented the work for final inspection and
acceptance by your agent.
During a subsequent NRC inspection at the Millstone Point Unit 3 site on
March 13-15,1979, the NRC inspector reexamined the circumstances of
your agent's inspections and acceptance activities, and reviewed addi-
tional facts and corrective actions discussed in your letter.
The NRC inspector ascertained that the contractor was functioning under
his own quality assurance program, which was approved by your agent. We
also ascertained that the previously cited erroneous acceptance of a
nonconforming condition had included actions by the contractor's in-
dependent quality control inspector.
The NRC inspector noted that the
applicable Stone and Webster specification #2275:001-023 (M023) clarifies:
"It is not intended that the presence or activity of the engineer's shop
or field inspectors shall relieve the contractor in any~way whatsoever
of his obligation to maintain an adequate test, inspection, and documen-
tation program of his own..."
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Northeast Nuclear Energy
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Company
Such delegation of quality assurance work to the agent, and thence to
the contractor, is recognized by Criterion I of Appendix B to 10 CFR 50,
to the extent that responsibility therefor is retained by the licensee.
See also part 1.3 of the ANSI-N45.2-1971 referenced in the Millstone
Point Unit 3 PSAR, Section 3.1.3.28.
We consider that the item of
noncompliance, cited to the licensee for defects in implementation of
the cot. tractor's quality assurance program, is justified and consistent
with the above principles and regulatory requirements.
During our subsequent inspection, the inspector ascertained that the
contractor in question temporarily completed his work on-site, but that
he plans to return to the site for fabrication of refueling and demineral-
ized water storage tanks.
Based upon the information discussed in your
October 2S, 1978 letter, we understand that your agent plans to emphasize
review of this contractor's activities at that time.
This office will
examine these actions in a subsequent inspection.
Your cooperation with us is appreciated.
Sincerely,
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Robert T. Carlson, Chief
Reactor Construction and Engineering
Support Branch
cc:
K. W. Gray, Construction Quality Assurance Lead
H. R. Nims, Director of Nuclear Projects
J. F. Opeka, Station Superintendent
J. R. Himmelwright, Licensing Safeguards Engineer