ML20042C162
| ML20042C162 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/10/1982 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Johnston W Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8203300284 | |
| Download: ML20042C162 (4) | |
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MAR 10 1982 REcpg
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MEMORAMDUM FOR: William V. Johnston, AssistantDiirector aar e
b Materials and Qualifications Engineering s
Division of Engineering 4
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Robert L. Tedesco, Assistant Director
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Division of Licensing
SUBJECT:
QUALITY ASSURANCE BRANCH SAFETY EVALUATION REPORT INPUTS FOR THE PERRY NUCLEAR POWER PLANT, UNITS 1 and 2: REQUEST FOR ADDITIONAL INFORMATION AND CLARIFICATION Your memorandum, dated February 25, 1982, forwarded the Perry SER inputs prepared by the Quality Assurance Branch (QAB). We have reviewed the l
Q'B's evaluation and find that there are three areas, noted below, where it does not provide sufficient information to enable us to prepare the Perry final SER.
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l 1.
It does not appear that the QAB evaluation was fully performed in accordance with SRP, Rev. 2, as directed by H. R. Denton-in his memorandum to all AD's dated February 11, 1982. The QAB l
evaluation input specifically cites SRP, Rev.1 as the-basis for the QAB staff's review, and concludes that the applicant's Quality Assurance Program (QAP) for the Perry operation phase is committed to be in compliance with the provisions of NRC guidelines 'and regulations per SRP, P,ev.1; except for an outstanding issue (not discussed or detailed) relative to the documentation of structures, systems and components under the l
control of the QAP. The QAB staff apparently did perfom an i
additional review of the applicant's QAP per SRP, Rev. 2 (t" extent of which is not clearly paesented), which resulted '
list of eight (8) non-conformance items. This additional review concluded that the non-conformance items. "are not 1
considered of such importance as to' require their implementation i
for the Perry Nuclear Power Plant, Units 1 and 2"; and further
-that " adequate quality. assurance program controls exist without-these additional items" -- ref. page 4 of the QAB-SER inputs.
l A more convincing basis for these conclusions is needed, and a further explanation as to the extent the review was performed i
per SRP, Rev. 2 more specifically defined.
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s William V. Johnston 4 2.
The 'open issue cited on page 9 of the QAB-SER input, and proposed for deferral to the SSER, should be closed in the SER, since it is only a !1 sting of all items in the plant that should be maintained under the control of the applicant's QAP; and the QAB memo, dated March 5,1982, appears to already identify the deficiencies in the FSAR. We have alerted the applicant to these deficiencies, and are attempting to schedule a staff / applicant meeting to get them resolved. QAB has until April 10,1982 to resolve the issue and deficiencies for SER input.
3.
Finally, the QAB-SER inputs must address the QAP contention ruled on by the Atomic Safety and Licensing Board (the Board).
In its Order of July 28, 1981, the Board related Sunflower Alliance's (Sunflower's) allegation that the applicant has dcmonstrated, throughout the plant construction process, its inability to comply i
with the QAP, citing as evidence tha NRC stop work order issued in February,1978; and that Sunflower also alleged faulty quality assurance in the placing of concrete, and several other NRC reports of quality assurance deficiencies. The Board limited Sunflower's quality assurance contention to the February,1978 stop work order; however, in its recent Order of March 3,1982 on Sunflower's motion to enlarge its quality assurance contention, the Board disallowed Sunflower's motion, but deferred a ruling on enlargement of the issue subject to being more informed of the evidence made available to the Board.
It is cherefore essential that the QAB staff address this contention, especially in view of the possibility that the Sunflower contention may be enlarged beyond the stop work order of February,1978 and in anticipation of ACRS questioning.
It is suggested that the Region III staff and Resident Inspector at Perry be consulted in this regard.
The QAB staff's early submittal of its QA SER input is most appreciated and has afforded us this opportunity to ensure an adequate evaluation input for the Perry final SER. The applicant has been most conperative in meeting with the NRC review staff to resolve FSAR open items and issues. We accordingly encourage the QAB staff to meet with the applicant (and as necessary confer with the Region III staff) with the intent of limiting the number of open QAP items / issues in the final SER; and if they cannot be l
satisfactorily resolved prior to SER issue, to thoroughly document the staff l
and applicants' positions in the final SER.
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William V. Johnston If there are any questions concerning this request, please contact the Perry Project Manager. Mr. John J. Stefano on X29S36.
I Robert L. Tedesco, Assistant Director for Licensing Division of Licensing cc:
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