ML19329E494

Final Deficiency Rept Re Design Control Procedures for Prototype Testing.Design Control Procedures for B&W Mfg Equipment Are Unnecessary,Since Design Reviews Are Performed

ML19329E494
Person / Time
Site:	Midland
Issue date:	03/01/1974
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML19329E491	List: ML19329E494
References
NUDOCS 8006160294
Download: ML19329E494 (2)

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General Offices: 212 West Mecnegen Avenue. Jackson, MicNgan 49201 March 1, 1974 MIDIAIG PIAIff Design Control - Prototype Testing Docket No 50-329 and 50-330 Dr. Donald F. Knuth, Director Directorate of Regulatory Operations US Atomic Energy Commission Washington, DC 20545

Dear Dr. Knuth:

On January 28, 1974 I sent you a is " lating to a possible deficiency which we considered to be reportabt under the requirements of 10 CFR 50. 55(e). Specifically this deficiency related on the inability of Babcock and Wilcox personnel to produce a procedure for the implemen-tation of the requirements in Criterion III of 10 CFR 50, Appendix B, which states: "When a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualification testing of a prototype unit under the most adverse design conditions."

The January 28, 1974 letter also contained the reasons for con-sidering the deficiency to be reportable, the corrective action which Consumers Power had recommended to Babecek and Wilcox, and a quotation from a response which had been received from Babcock and Wilcox. The letter closed by pointing out that the response from Babcock and Wilcox had been received too late to permit a full evaluation of it and that further eval-untion and clarifications would be required before this deficiency could be closed out.

Since January 28, 1974 further contacts with Babcock and Wilcox have clarified the situation relating to this deficiency. Apparently a distinction must be made between Babcock and Wilcox designed and manufac-tured equipment and Babcock and Wilcox procured equipment. For Babcock and Wilcox designed and manufactured equipment the option of using testing to verify design is never exercised because all designs are verified by performance of design reviews or the use of alternate or simplified ccicu-lational methods. Therefore, a procedure for Babcock and Wilcox testing to verify designs on equipment designed and manufactured within Babcock and Wilcox is not necessary.

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- ,- Dr. Donald F. Knuth, Director 2 l

Midland Plant - Design Control -

Prototype Testing  ;

March 1, 1974 For equipment being supplied to Babcock and Wucox by other suppliers, Babcock and Wilcox permits these suppliers to select their own methods of verifying de.ign. Suppliers can use testing and if they do they would have to have procedures to test under the most ad-verse design conditions. Babcock and Wilcox does have a procedure which requires that supplier design documents be reviewed for adherence to the applicable requirements of 10 CFR 50, Appendix B.

Based upon the above analysis it is apparent that Babcock and Wilcox need not provide additional procedures which require testing of prototypes under the most adverse design conditions. Therefore, no cor-rective action need be taken in this instance to bring the Babcock and Wilcoa program into compliance with 10 CFR 50, Appendix B and there are no safety implications related to this situation. Therefore, we submit this letter as a final report pursuant to the requirements of 10 CFR 50.55(e).

Yours very truly, m, m ,

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