ML20039E207
| ML20039E207 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/29/1974 |
| From: | Skovholt D US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Boyd R US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML111090060 | List:
|
| References | |
| FOIA-80-515, FOIA-80-555 NUDOCS 8201070016 | |
| Download: ML20039E207 (1) | |
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UNITED STATES fd'/
ATOMIC ENERGY COMMISSION 96*
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wasmuoTon, o.c. ns s
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t.Pa 2 9 1974 Y"
Ibcket No. 50-289
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Roger S. Boyd, Assistant Deputy Director for Reactor Projects, L INDEPENDENCE OF QA FOR VIREE MILE ISLAND NUCLEAR STATION, INIT 1 We have reviewed end evaluated Metropolitan Edison Company's (MEC) Ictter of Feoruary 21, 1974, and referenced material, which is in response to our 1ctter of January 22, 1974. 'Ihe infonnation provided by MEC relates to the authority and organizational freedom of QA personnel within MEC, General Public Utility Service Company, Babcock and Wilcox, Gilbert Associates, and United Engineers and Constructors perfonning work on the design and construction of the Three Mile Island Nuclear Station, Unit 1.
'Ihis review and evaluation considered the duties, responsibilitics, and authority vested in persons responsible for verification of quality by testing, inspecting, and auditing. We also reviewed the organizational arrangement and the administrative control and technical direction exercised over these persons with particular attention given to freedom and independence from
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the pressures of costs and schedules.
Based on our evaluation, we conclude that sufficient authority and organizational freedom exists ro enabic QA personnel to perform their critical functions effectively and without reservation for the design and construction of the Three Mile Island Nuc1 car Station, Unit 1.
',,$ ',hb bV D
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ovholt, Assistant Director for Quality Assurance and Operations Directorate of Licensing ec: 11. Berkow R. Bernero S. Cunnins V. Moore A. Schwencer
- 11. Thornburg a201070016 010403 dDDE Ob-515 PDR
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- !etropolitan Edison Ccrpany a
Mr. Ro'ert C. Arnold M r:!:
o Vice President - Canaration P.
O. Sox 542 teauing, Pennsylvanis 19603 d en t t e:aan:
cu :% rue ry 4,1974 w urote to you de. scribing the resuli s of our revieu of your propoaod Operatin3 qualit'; Assuranca Plan. Cur letter indicated that you should change your plan in t'io respects and refile it a.s an mnan me to your application. Va have received that amend:ent sud our revicu of the changes you cade does not fully reaolve our conceres; fuerher ceen&: rut in both areas vill be required.
This letter is intended to captify end clarify cur poaltion with respect to thesa tao ar> u, n:caly, the interface with Ceceral Public Utilities Service C::rporatice-(GPUSC) and the adoption of AMSI Standards and AEC Regulatory Guides.
We realize that GPUSC is a corporation in parallel with the operating cecpanies such na tietropolitan I:dison Campany (Met::d) in the GPU 3roup.
Ccnaequently, it is not unreasona'>1e to establish a unique quality a.uurance interface with them, which dif fers frcm that which you have with an ordinary vendor. Houever, that uniqueness should be. confined c0 the organizational level of interacticu, and should not include the tl '
benitored deleastion of cuality a_s.surance responsibildy. Met 2d vill i'
bor the Licensee for the Three Mile Inland 1: nit 1 (IMI-1) and cannot delegato quality assurance responsibility uithout restriction. Meted's J,e, 3/ operational quality nsaurance pro 3rca iu reviewed and approved by the AZC through the plan ve discuss here.
In any case where vork is delegated to a vendor, Mettd, through the Manager-Operational Quality Assurance, retains the responsibility to review, concur. and and!e tha quality assurance ef forts of that vendor as applied to TMI-1.
Similarly,
.here work is delegated to GPUSC, Meted aust retain the clear respgsfoility
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ta rmilev, concur, and audit the qualit>* asaurance efforts of GPUSC they apply to 'DtI-L.
The interface uith GPUSC you describe in your as i.in does not appear to us to define that review, concurrence, and audit m pousibility.
That rr.sponsibility ::.ust be defined, and exercised.
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Mob art C. l.rnold.
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Ta the varicua dzctions of the T iI-l Cperatin;', Quality Acauranca Plan, raferance la ruda to X:0 nc);ulatory Caldes and ASSI ncaudarda, nawly, the guidance contained in th: "Orannu Soch".
!ost of the references Indicate that n!I-l proceduren vill be " guided by" thase guidea and standards; few use tha r: ora rigorous reference of "cc ply with".
The use of Isa riprous raf arance tarninolo.sy sug,esta a t.;isunderstanding of the role of tha " Orange Eook" guidance and our intent in stating you nhould "connit to the ir:plenentation" of it.
Uhen an applicant in
'minhing a declaion with respect to dra.!ing up procedures, guidance 02 fared by the AEC through guides and standards may be accepted wholcaale or suitable altarnativea nay bc proposed. The opportunity for choice is not continuoun; once choice is Eale, an acceptable procedure is esta'311shd and that procedure ;.:unt be cor. plied with or followed. Therefore, in the.
'E!I-I Operating Quality Assurance Plan, you can provide your cun detailed procedurca for training, design control, docunent control, etc., or you can agree to conply with those covered by the various AEC guides and A;i31 standards.
L'e have previously indicated to you that the T.!I-l Cperating Quality
.\\asurance Plan.uut be approved and inplenented befora an operating licease la issued. Therefore, it is encential that our concerns in tha a two 7.atters he re.mlved a #one-t
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Sincerely, Odgin3t signed A. Schwencer, Chief Light Unter Reactors Er. 2-3 Directorate of Licensing cc: George 7. Troubridge, Esquire Shaw, Pittnan, Potts & Troubridge 910 17th Street,1:U Uaahington, D. C.
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