ML19305A076
| ML19305A076 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1978 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Switzer D NORTHEAST UTILITIES |
| References | |
| NUDOCS 7901040093 | |
| Download: ML19305A076 (3) | |
Text
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DISTRIBUTI ON:
I Central sile Old Pro >ects O';.C S. l F3 QAB Ch on. File ding File DJSkovhol t, DPM Dross, DPli FLiederbach, QAB JGilray, QAB Mr. D. C. Switzer
'JSniezek, IE Vice-Chaiman llReinmuth, IE flortheast Utilities P.O. Box 270 Hartford, Connecticut 061 01
Dear Mr. Switzer:
SUBJECT:
HORTHEAST UTILITIES QUALITY ASSURNICE PROGRAM TOPICAL REPORT tie have reviewed the Northeast Utilities (NU) quality assurance program topical report, through Revision 2, dated October 23, 1978, as well as subsequent pages forwarded November 22, 1978. This topical report, which describes the QA program for NU's nuclear generating facilities, has been reviewed to detemine conformance with Appendix B to 10 CFR Part 50.
A request for additia%G infomation and staff positions relative to this report are enclosed. Your response should be submitted as an amendment (26 copies of affected page changes) to the original report.
Please call !!r. Fred J. Liederbach on (301) 492-7741 if you have any questions regarding this request.
Sincercly, Originat signed by O!
Wal P
laass, Chief D
Ub Quality Assurance Branch Division of Project ifanagement
Enclosure:
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Request for Additional Information and Staff Positions on Northeast Utilities Topical Report on Quality Assurance 1.
With regard to your response to question 6 of our August 3,1978 letter, we understand that, thus far in your ongoing detailed review of these later QA Regulatory Guides, you do not anticipate functional problems in implementing the regulatory positions of these guides. We understand, however, that since some of these may impact upon work of your present agent (Stone & Webster) on Millstone Unit 3, you may or may not find it necessary to notify us of some exceptions. Should such be the case, please specify the exceptions and provide and justify alternate solutions in 2quivalent detail.
2.
Your response to question 17 is acceptable if the we 1 " designee" used in the phrase " Manager QA/ designee" in the third paragiuph of the Introduction and elsewhere means that the designated person (designee) is a direct employee of the Manager of QA.
3.
The staff's position on your response to question 20 is the same as that for question 6, namely, work performed after NRC acceptance of the topical report should meet the regulatory positions of the Regulatory Guides listed in question 6, as well as the requirements of the ANSI Standard listed in ques tion 6.
4.
Your response to question 25 is unacceptable.
It is the staff's position that the QA organization should approve procurement orders to any organization (e.g., supplier) that has not been previously approved by the QA organization.
5.
Your response to question 26 is acceptable except that the response should specify / pendix D in lieu of Appendix C.
6.
Your response to question 27 is satisfactory except for drawings.
It is the staff's position that the QA organization, or an independent organization qualified in quality assurance, must review and concur with these documents with regard to QA-related aspects. Thus, with regard to design drawings or changes thereto on drawings generated by NUSCO and/or NUP0C, describe the controls implemented by NUSCO to ensure inclusion of proper quality req'airements in drawings, e.g., provisions for accessability and inspect-abili ty.
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- 7.
Please clari fy your response to question 36, i.e., Uhat is meant by
" qualified personnel representing NUSC0/NUP0C Quality Assurance?"
Your response is acceptable if it means "qualifled NUSC0/NUP0C Quality Assurance personnel."
8.
Your response to part a of question 43 is acceptable. However, your response to part b is unacceptable inasmuch as it does not indicate any involvement of the QA organization in controlling the release of nonconforming items and in the concurrence of dispositions. The only apparent involvement of QA is in an audit role. The staff's position is that the QA organization should 1) concur in disposition of noncon-fonnances and in decisions relative to release of nonconforming items prior to their disposition; or 2) should provide acceptable alternatives.
If the latter, please describe.
9.
Your response to question 44 appears acceptable except that the word
" items" should be changed to " reports." Also, please clarify whether or not the " materials receipt records" constitute part of the inspection records.
10.
Your response to question 46 needs clarification. Please delete the word
" major" or otherwise clarify what is meant by " major."
11.
Your response to question 49 is not acceptable.
It is the staff's position that all internal elements of the QA program be audited at least annually in accordance with the requirements of ANSI N45.2.12, Draft 3, Revision 4, February 1974.
12.
Please correct the grammatical problems in the first paragraph, page 3 of QAP 2.0, 13.
Please reinstate Appendix B to 10 CFR Part 50 in the fourth paragraph of 2.2.4 of the topical report or justify its revision.
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