ML20126H613
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MEMORANDUM FOR: John T. Collins, Regional Administrator
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FROM:
W.d.Seidle, Chief,EngineeringInspectionBranch
SUBJECT:
RESPONSE TO CONGRESSMAN UDALL'S LETTER, DATED
.0CTOBER 31, 1981 In response to your request of November 9, 1981, regarding the ' subject letter, the following information is provided:
1.
When was the Quadrex report started? Completed?
f In January 1981, Houston Lighting and Power Company initiated a techni-cal review of portions of the engineering design work performed by Brown and Root, Inc., for the South Texas Project Electri'c Generating Station (STP). The purpose of this review was to ascertain the overall technical adequacy of the STP design.
Quadrex Corporation was asked to assist HL&P in this review of the following B&R technical disciplines:
Civil / Structural L
Computer Programs and Codes Electrical / Instrumentation and Control Geotechnic HVAC Mechanical i
l Nuclear Analysis Piping and Supports / Stress and Special Stress Radiological Control The licensee met with Quadrex Corporation for the first time on January 16, 1981, and several other times in January and Feburary 1981 to plan the review. The Quadrex Review involved 12 engineering con-sultant personnel who spent more than six weeks in reviewing B&R design i
engineering documents and interviewing various B&R discipline engineers.
This represented more than one manyear of design consultant review effort.
l The report was issued May 7, 1981. The report was composed as follows:
Volume I Introduction, 1.0 Introduction 2.0 Design Review Program Methodology 3.0 Generic Findings 4.0 Technical Discipline Adequacy Assessment 8506100369 840620 i
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i Volume II Questions, Responses and Assessments g.
(Civil thru Mechanical)
Volume III Questions, Responses and Assessments (Nuclear thru Radiological Control) 2.
When did Region IV learn about'the report'and how?
During discussions with the NRR Project Manager (PM), it has been determined that the licensee informed him in January 1981 that an audit was to be per-formed of B&R engineering design by an independent firm. The activity was not considered at that time to involve more than a normal or routine audit performed of the AE by the licensea.
Mr. Goldberg, Vice President, HL&P, alluded to the audit in'his testimony during the ASLB. hearing in Bay City, Texas, in mid May 1981. However, it was not known at that' time that he was referring to the Quadrex Report nor was the scope or status of the audit known. On May 13 or 14,1981, the STP SRI was privy to a discussion (s) that the NRR PM held with Mr. Goldberg in which Mr. Goldberg again described the audit by HL&P of the B&R engineering design activity and offered to give the NRR PM a copy of the findings. The name of the independent auditing firm did not surface during the discussion (s) and HL&P was in the process of reviewing / evaluating the findings of the report at that time.
Subsequently, the licensee has reported three construction de/fiq[ncies I
which were the result of the Quadrex Review / Report; however, the nature i
of these deficiencies do not suggest that design was fundamentally flawed, rather they concerned:
Faulted heat load conditions not considered in design of portions of safety related HVAC.
Computer verification programs do not provide evidence that program versions have been verified.
Some safety-related shielding calculation verifications inconsistent with verification requirement.
During an investigation on August 18, 1981, the SRI requested all HL&P audits, consultant reports,' and applicable correspondence that related to B&R design engineering organizations. At this time, the licensee produced the Quadrex Report but restricted the physical review to the HL&P QA Manager's office.
A brief look at the subject report indicated that serious questions had been raised. The SRI told the licensee that the report raised some' serious concerns and a more extensive review was necessary. The licensee stated that a copy would be made available at the site.
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John T. Collins,
On August 24, 1981, the Region IV staff contacted the SRI after they learned of the SRI's concerns about the Quadrex Report. The SRI stated that the review of the report was incomplete; therefore, an adequate briefing on the subject would not be possible until-the review was complete. The SRI completed his review and gave a briefing to the RIV staff on August 27, 1981.. The SRI highlighted the questions raised by Quadrex and stated that if an NRC inspection confirmed such questions 4
or concerns to be facts, then B&R design engineering would need help from ~
another AE or, if this were not possible, may need to be replaced. The SRI recommended a special team, composed of engineers capable of validating computer programs, models, and design systems to confirm or deny the Quadrex Report findings.
The SRI requested that someone in Region IV, who currently works with Architect Engineers, review the report to determine if the NRC should perform an indepth review.
On August 31, 1981, Region IV sent the Vendor Inspection Branch Section Chief to the site to review and evaluate the subject report. He confirmed that the report raised questions that would be serious if such questions were indeed found to be factual.
l On September 8,1981, the SRI attended a RIV Licensee Management meeting on the subject report.
An NRC Headquarters represerative also attended the meeting. The licensee' briefed Region management and attendees relative l
to the background, significance, and actions to be taken as a result of the subject report. Meeting highlights were documented in NRC meno for j
file, dated September 11, 1981 (Attached).
On September 23, 1981, the licensee announced that STP responsibilities would be reallocated and Bechtel Power Corporation would be responsible for engineering, design, and coristruction management services necessary to complete the project.
3.
What action did the Region IV staff take when they learned of the Quadrex
' Report?
The Region IV staff had identified problems in the B&R engineering activities l
prior to and at the time of the Quadrex Report.
A trend relative to design problems began to appear in late 1980 and early 1981. The Region IV SRI identified this trend to RIV construction supervision in April 1981 and documented the apparent trend in a meno dated May 27, 1981 (Attached).
i This trend was identified independent of the licensee's efforts in this area three acnths after the licensee initiated a consultant's review on January 16, 1981. The Quadrex Review was completed March 31, 1981, and was documented in'a report dated May 7, 1981.
It appears that NRC inspectors identified questionable areas in a timely manner and were tracking the situation for further developments before learning of the Quadrex Review or Report.
l On July 20-24, 1981, RIV Vendor Inspection Branch subsequently performed an inspection at the B&R engineering offices and documented the inspection in NRC Report 99900502/81-03, dated August 19, 1981 (Attached).
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John T. Collins It should be pointed out that design work is not performed on site; therefore, the design work could not possibly be monitored on site and is not the responsibility of the SRI or regional inspectors who inspect con-struction activities on site.
4.
What is the Region IV staff's view of the report contents?
The report does not conclude that STP design is fundamentally flawed in that no conclusions were reached.
Report findings described a lack of a documented program in many instances.
If true, this does not necessarily mean that required engineering reviews were not made or does it prove flawed structures. Another example of a finding, a lack of integration and overview functions, does not prove that first line engineering design / review decisions were necessarily inadequate. The lack of communications between disciplines was stated to be a problem, i
but this could be said of any organization. - The finding thit written guidelines were not available does not show FEMA and Single Failure Criterion Analysis to be inadquate. Many of the findings were character-ized as "may have serious impact on plant licensability." Plant Design Basis, Equipment Reliability, Final Design Verification, and Nuclear Related Analysis fell into this category.
This characterization extends to or applies to most other areas of the subject report.
These are really not findings but are questions. While the report contains some serious questions or concerns, the report did nothing more than identify indications of potentially weak areas in B&R design engineering.
Only a more indepth review, to be performed by HL&P and Bechtel during the next 6-8 months will allow conclusions to be reached as to the significance of the Quadrex Report.
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NUCLEAM MEGULATORY COMMISSION O'
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ARL9NG10tf. TEXAS 499F
'l May 27, 1981 Docket Nos. 50-498 50-499 MEPDRANDUM FOR: File THRU:
G. L. Madsen, Chief Reactor Projects Branch j
W. A. Crossman, Chief. Projects Section 3
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'FROM:
H. S. Phillips, Resident Reactor Inspector South Texas Project i
SUBJECT:
BROWN & ROOT ENGINEERINS On April 25, 1981, the Resident Inspector was contacted by a Brown 8 Root, l
Inc. (BER) Engineer who stated that the single biggest problem on the South i
Texas Project is with work done hr Design Engineerino (AE).
The individual i
elaborated on the statement and said, however, everything is under control as evidenced by the 1600 hold tags at the B&R Cress Park facility in Houston, Texas.
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This inforestion was given to Mr. Crossman in a telephone conversation on April 30,1981, and it was classified as routine since the engineer stated 1
it was controlled.
I connented to Mr. Crossman that I would be sensitive to any additional inforination on this subject and would pass it along.
On May 6,1981, I learned that BLR is planning to lay off appvuximately j
230 people.
In this conversation with R. A. Frazar, Manager Quality Assur-ance Site, he said it was because of problems in B&R Engineering (AE). On i
May 6,1981. Graham Painter NL&P Public Relations, told me it would be announced that 177 people (157 construction and 22 QA/QC) would be laid off and Stated it was because of insufficient work activity.
I asked him to notify C. Wisner, Region IV, Public Relations Office.
Additional information in two articles in the newspaper (see two enclosures) i increase my concerns that the B&R Engineering is causing construction delays that may affect the quality of constroction activities.
In an article -in the Bay City Tribune, April 26, 1981, Dave Barker, ML8P Project Manager, is j
quoted, "And to be perfectly honest, we have got to regroup ourselves in i
those arves--get our engineering inforination together, then proceed ahead i
on a quarterly basis and then rehire the force. That's our plan....I'd f
say our major problem in being able to increase production is getting engi-neering infersnation." The other article in the Houston Post in early 1980 l
also stated that HL&P had found problems with B&R Engineering.
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Memo for File 2
May 27,1981 5(
- Recent NRC Inspections perfomed by D. Fox, it. Hubacek and H. S. Phillips have identified / evidenced similar problems that may be symptoniatic of larger problems in SSR Engineering. Nessrs. Hubacek and Phillips reviewed audits of BAR Engineering which indicated problems with engineering reviews.
All of this Jaforination indicates that an adverse trend may be developing or has developed.
In all cases, the licensee has stated that the situatiort is under contml, however, I recomwnd that a special team from the RlY Yendor Group inspect and audit the area to' assum the licensee is contmiling and/
or correcting the situation.
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H. S. Phil ips. Resident Reactor Inspector i
South Texas Project
Enclosure:
Bay City Tribune article, dated 4/26/81 Houston Pos't article 9
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T November 4,1981 y
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MEMORANDUM FOR:
K. V. Seyfrit, Director j
FROM:
W. C. Seidle, Chief, Engineering Inspection Branch
SUBJECT:
DRAFT COMMENTS - CEV PETITION TO SUSPEND CONSTRUCTION 0F THE STP, FILED OCTOBER 28, 1981, WITH THE COMMISION x
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The following information is provided in response to E. J. Reis' note to
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T-Don Sells, dated October 29, 1981:
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3 INTRODUCTION f
t The Quadrex Corporatioh Report is a consultant's technical review of design.
a As such, the report is written in an advisory style rather than a classical i
F scientific and/or engineering style. That is, the report does not reach conclusions but merely gives findings.
Page 1 of the subject report states 2 in part, "The purpose of this review was to ascertain the overall adequacy of the STP design." However, paragraph 2 1
on page 1 recognizes the limitations of achieving the stated purpose since it states, in part, "An exhaustive review of the design work accomplished by each B&R technical discipline was neither feasible nor desired; rather, Quadrex was i
requested to carefully devise a sampling program to determine the B&R engi-neering response to known unique nuclear industry issues and problem areas.
Implicitly, it was expected that such a sampling program would provide suffi-cient insight regarding the adequacy of the te::hnical work performed by each discipline." The words " implicitly" and " expected" indicate at the onset that the review would not be expected to result in conclusions.
One must also
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recognize that such a sampling does not describe the sample size nor the inher-
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ent dangers of findings based on an inadequate sample. The sampling is cer-tainly not statistical.
v The last paragraph on page 1 states, in part, " Ordinarily it is difficult to I
draw generalizations from particular responses to specific questions.
On the T
other hand, the chosen sampling approach does et provide indications of poten-tially weak areas in the engineering design of the STP plant." In this para-graph, the report recognizes not only the difficulty of drawing a conclusion, but also the difficulty of drawing a generalization.
Granted this, the report g
states that only " indications of potentially weak areas" are provided by this approach and only'further review by HL&P would allow HL&P to conclude that i
these questionable design areas are inadequate now or will be in the future t
if not corrected.
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y K. V. Seyfrit November 4, 1981 The NRC staff and interested intervenor groups must consider the limitations of the report as well as the areas which were considered questionable.
In other words, one cannot lift parts of the report and present them as absolute fact and reach conclusions when the report itself refuses to reach conclusions.
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Although some areas may be found deficient, nothing short of a full review by HL&P and Bechtel can detemine the validity of Quadrex's " indications of I
potentially weak areas." Until such a review produces at least preliminary
'y or perhaps final conclusions, there is no basis for. concluding that the fundamental design is flawed. This is not to imply that the same deficiency will not be found, since no system, including the design system, is perfect.
In fact, construction deficiencies reported to date by HL&P indicate some
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deficiencies will be identified. NRC reviews of design activities during the life of the project have not identified such generic problems. Therefore, i-design must be considered adequate until a full indepth review concludes other-wise.
1.
What is the Staff position on the Quadrex Report?
The Quadrex Report addresses many concerns in the area of engineering design. While many of the concerns appear to be subjective opinions.
the Staff will review the HL&P/Bechtel evaluation of each finding and 4
a reach a final conclusion based on their own evaluation.
Does the report conclude that the design of the South Texas Project a.
is fundamentally flawed?
From our review of the Quadrex Report, we have determinad that it does not conclude that the plant design is fundamentally flawed.
The findings in the report are wortied such that many of them reach conclusions cased on opinion or limited observation and scope.
b.
Does the Staff on the basis of the report believe that the design of STP is flawed?
Based on detailed inspections / investigation of the STP construction, the Staff does not believe that the STP design is flawed.
Although the Quadrex Report identified many areas of concern, it does not present a basis that would lead us to believe otherwise.
It must be kept in mind, however, that the OIE does not review desf gn in detail.
Construction inspection and enforcement are predicated on a prelimi-nary design which when completed will fulfill NRC regulatory require-ments. The Quadrex Report no doubt will result in numerous open items which the Staff must evaluate, but presently there is no evidence that any of these items have a detrimental impact on the adequacy of the existing structures.
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- k. V. Seyfrit November 4, 1981 1
2.
Does Jordan (CEU) correctly characterize the findings of the Quadrex Report in his pleading? Go through the pleading and each time the Quadrex Report is characterized state:
a.
Why it is inaccurate or, if accurate, the significance.
It is the opinion of the RIV staff that although the excerpts from e
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the report are quoted or paraphrased accurately in the pleading, the characterization of these quotes is not.necessarily accurate.
Page 1-1 of the report states, " Ordinarily, it is difficult to 9
draw generalizations from particular responses to specific questions.
On the other hand, the chosen sampling approach does provide indi-cations of potentially weak areas in the engineering design of the STP plant.
Consequently, these indications are being brought to t
the attention of HL&p so that they may inquire further into specific details and characterizations regarding each issue with Brown and Root, Inc." Mr. Jordan has taken-these " indications of potentially weak areas". identified through a sampling program effort and charac-terized them as being factual findings and, frem these, he has drawn generalizations which, without the benefit of a technical evaluation,
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may or may not be accurate.
It would be impossible for the RIV staff to detemine the accuracy of Mr. Jordan's findings without the benefit of such an evaluation.
As to the significance of Mr. Jordan's findings, it is the position E
of the RIV staff that, based on the risk criteria effort described in Mr. Oprea's letter to Karl Seyfrit, dated October 16, 1981, the findings are insignificant for those proposed contruction activities described in Attachments A and B of the October 16 letter. The RIV staff considers Bechtel's evaluation of the Quadrex Report findings in question to be a very important factor in making this finding.
It is the RIV staff's understanding that documentation of Bechtel's evaluation will be provided prior to proceeding with construction activities identified in the October 16 letter.
E b.
Why the construction proposed by HL&P's letter of 10/16/81 is not
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affected by the Quadrex findings?
As discussed in the answer to Question 3 below, a review of the
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proposed work activities reveals that any conceivable design inadequacies would have only a minimal impact on the project.
In only one case (Item F below) does there appear to be any significant risk in proceeding with the proposed work, and even a
in this instance, the risk potential appears too low to preclude the continuation of construction.
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K. V. Seyfrit November 4,1981 3.
Specifically, does the Staff believe that each of the construction activities listed in Attachmer.t A to HL&P's letter of 10/16/81 may proceed? What is the effect of uncertainties concerning the accuracy of the Quadrex Report on this answer?
The specific activities identified in Attachment A have been categorized and discussed below:
a.
Site operational (caretaking)' activities - Any expressed uncertain-ties in the design aspects of the facility would have no apparent impact on these activities. Work activities have been in process, and if they were to be halted, a negative impact on the facility could occur. There is no apparent negative safety impact poten-tial from continuation of these activities.
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Maintenance of the dewatering system - Jobsite Maintenance Maintenance of installed equipment - Jobsite Maintenance Receiving /Wamhousing - Material Handling Preventive maintenance of stomd equipment - Material Handling Maintain records vault and continue document control Maintain fire protection system b.
Repair and rework of previously completed or in-process work -
All work is considered reversible. _ Any expnssed uncertainty from the Quadrex Report would have no impact beyond the possible impact upon all previously completed work in the same ama.
Repair and rework only brings the work activities into confonn-ance with curmntly established requirements.
Rework of Q Class items - Fabrication Shop Applying of coatings in all areas Continue m work and repair of ASME/AWS welding - FHB Unit 1 Rework and repair ASME and AWS welds - RCB Unit 1 Continue mpair and installation of ECW aluminum bronze piping including Ama D plus hydro. - BOP Rework and repair of-ASME/AWS welding - MEAB Unit 1 e
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c.
Completion of work activities in process and so close to completion as to make completion imaterial to the overall condition - Expressed uncertainties from the Quadrex Report would not affect the remainder of the work.
Even if there were detemined to be corrective redesign, completion of the remaining work would not significantly impact on the defined mwork.
1 Continue containment dome concrete to completion - RCB Unit 1-i Install Diesel Generator sole plates - DGB Unit 1 d.
Continuation of work activities previously approved by NRC, or never stopped, which have well established and implemented procedures -
Any uncertainties expressed in the Quadrex Report concerning design adequacy would conceivably only have a remote impact. All work activ-ities are either reversible, or repair / modification methods am readily available.
Conen te batching for approved structures - Concrete Production Fabrication of conduit and cable tray supports - Fabrication Shop 1
Continuation of operations for roof concrete placements -
FHB Unit 1 Continue concrete placements - DGB Unit 1 Continue installation of cable tray supports - MEAB Unit 1 Continue installation of conduit and supports - MEAB Unit 1 Continue installation of structural steel - MEAB Unit 1 Continue installation of pemanent lighting - MEAB Unit 1 e.
New work for which B&R did not do design work, and for which work practices am well known based on similar designs by Westinghouse -
i The Quadrex Report recomendations are not applicable to this work.
Continue reactor coolant loop welding - RCB Unit 1 f.
New work, not nomally reversible, for which equivalent work has been completed for Unit 1 - ArW potential mwork required because of inadequacies referred to ir. the Quadrex Report would only 1
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' K. V. Seyfri t November 4, 1981 remotely require rework; and if required, rework of both units would be required.
Completion of Unit 2 work would be at some added economic risk which could be offset by an accelerated design review by Bechtel. Additionally, the basic design of the Containment Building was completed prior to completion of Unit 1.
There is little likelihood for any needed changes or significant revisions in the design.
Continue centainment shell concrete placements - RCB Unit 2 Start installation of basemat foundation - DGB Unit 2 It is the considered opinion of the NRC that the specified activities may all proceed. Any added risk would appear to be offset by the probable benefits to the project discussed in the HMP proposal letter, dated October 16, 1981, from G. W. Oprea to Karl Seyfrit, particularly the retention of special skills, e.g.
qualified welders and weld machine operator;.
4.
What evaluations were made by the Staff to assure the work proposed in i
H MP's 10/16/81 letter could go forward?
On October 15, 1981, the Region IV staff met with repmsentatives of HMP and with the take-over Bechtel management AE team to discuss the transition from Brown and Root to Bechtel. ~During this meeting, the continuation of selected site work during the transition was discussed.
As a result of this discussion, H MP in their letter of October 16, 1981, proposed selected work activities in both the safety-mlated and nonsafety-related areas. Following receipt of this proposal, the regional staff evaluated each proposed work activity. The evaluation of the safety-related work is sumarized in paragraph 3 above. Addi-tionally, it:was confinned that the list of nonsafety-mlated work did not involve any safety-related activities. Based on this review, it was recomended by Region IV that the described work activities be approved for the transition period.
This evaluation was perfonned, and the decision to resume certain con-struction activities is supported by the following past NRC activities related to the STP design and construction programs.
a.
Following issuance of the Quadrex Report, selected members of the regional staff reviewed the report, including C. J. Hale, Chief, Reactor Systems Section, Vendor Inspection Branch, and S. H.
Phillips, STP Resident Reactor Inspector. Based on thase reviews, l'
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K. V. Seyfrit November 4, 1981 it was determined that there did not exist a need for immediate action pending HL&P/Bechtel evaluation of the conclusions and recommendations of the Quadrex evaluation.
b.
In the past several years, NRC personnel have conducted audits of
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STP design and programatic procedures which control design.
No violations have been identified which would justify stopping design or construction work other than those resulting from the Show Cause Order.
A Region IV Task Force has devoted over 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> follow-up inspec-c.
tion relative to the licensee's implementation / corrective QA program deficiencies or weaknesses described in the NRC Show Cause Order of April 30, 1980. The follow-up inspections include indepth inspection of civil / structural and welding activities in the areas of cormctive actions and augmented inspections of implementation during restart of concreting and welding activities.
d.
Two hundred'and twenty-five of two hundred and thirty-six licensee commitments to correct the deficiencies or improve the QA program have been implemented by the licensee and have been closed by the NRC inspectors. The balance of these commitments are nearly all ready to close based on recent licensee actions.
NRC follow-up inspections indicate that the QA program has been corrected /
improved and the safety-related work activity,. proposed by the licensee's letter (Appendix A), would be adequately controlled.
sf WL W. C. Se h, Chief Engineering Inspection Branch cc:
J. T. Collins G. L. Madsen W. A. Crossman R. E. Hall H. S. Phillips l
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