ML20138Q080
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- ' l U.S. NUCLEAR REGULATORY COMMISSION Office of Inspector and Auditor o.i..,ir.
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February 16, 1984 Reoort of Interview Vergil Brownlee, Chief, Project Section 2A, Division of Project and Resident Programs, Region II, U.S. Nuclear Regulatory Comission (NRC) was interviewed concerning the Quality Assurance (QA) and Quality Control (QC) Organizations of the Duke Power Company (DPC) at the Catawba Nuclear Station (NS), Rock Hill, South Carolina. During the interview, Brownlee provided the following information pertaining to an allegation by the Government Accountability Project (GAP) that DPC did not implement its 1974 comitment to separate the QA/QC function from Construction and Engineering until 1982.
Criterion I, Appendix B to 10 CFR 50 requires the QA organization performing QA functions have sufficient authority and organizational freedom to identify quality problems; to initiate, recomend, or provide solutions, and to verify implementation of solutions. Appendix B does not specifically address requirements for a QC organization.
Criterion X, however, addresses the organizational separation required for inspection activities affecting quality and requires that QC inspections be performed by individuals other than those who performed the activity being inspected.
Brownlee stated that the DPC QA/QC organization at Catawba has been in compliance with 10 CFR since 1973.
Brownlee then provided a chronology of significant events pertaining to NRC's review of the QA/QC organizations of DPC.
February 1973:
NRC initial QA audit for Catawba found that the Construc-tion Department QA manager was not independent of construction costs and schedules as required by 10 CFR 50, Appendix B, Criterion I.
May 29, 1973:
NRC met with DPC and discussed the DPC QA program, which showed QC personne1' reporting administratively to a line organization and functionally to the QA organization.
It was also noted that the Senior Vice President of Engineering and Construction was the acting Corporate QA Manager.
July 1973:
NRC completed its evaluation of the DPC QA program for Catawba. NRC received a comitment by DPC to fill the position of Corporate QA Manager before July 1974. With this comitment, NRC found the DPC QA program acceptable.
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October 12, 1973:
NRC issued the Safety Evaluation Report which concluded that the DPC QA organizational structure complied with the requirements of Criterion I of Appendix B, 10 CFR 50, and was acceptable and that the QA staff had been provided with adequate authority and guidance for the implementa-tion of the DPC QA program.
Additionally, the Safety Evaluation Report addressed DPC's QC organization and reviewed the independence, responsibilities, authorities, and specific duties of QC inspectors in the electrical, mechanical, welding, and civil disciplines. NRC concluded DPC's QC organizational structure was acceptable.
February 1, 1974:
The roles of the Senior Vice President of Engineering and Construction and the Corporate QA Manager were separated with the Corporate QA Manager reporting to the Senior Vice President of Engineering and Construction.
April 2, 1974:
DPC reported it was going to restructure its QA organiza-tion in May 1974 with the QA organization reporting directly to the Corporate QA Manager.
October 1, 1974:
DPC Topical Report reflects the ' A organization estab-Q lished on April 2,1974, which has the QA organization reporting to the Corporate QA Manager and the Corporate QA Manager reporting to,the Senior Vice President of Engineering and Construction.
The Topical Report on QA indicated the QA organization reviews and approves QC inspection procedures and records.
The QC staff reports directly to the Senior QC Engineer who reports " functionally" to the Project Senior QA Engineer within thb DPC QA organization.
February 14, 1975:
DPC Topical Report on QA adds the commitment that QC inspector certification procedures and certifications are approved by QA.
April 17, 1975:
NRC affirms the acceptability of the DPC Topical Report on QA.
The QA organization reports to the Corporate QA Manager who is under the Senior Vice President of Engineering and Construction.
August 7, 1975:
Construction Permits are issued for Catawba. With respect to DPC's QA program the Atomic Safety and Licensing Board Panel stated the DPC QA program meets the requirements established by the Commission.
February 9, 1981:
DPC informed NRC that the Site QC staff was being brought into the QA organization for administrative as well as functional control.
July 14, 1981:
NRC accepts DPC proposal to have DPC construction QC included in the DPC QC organization.
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February 3,1983:
NRC again affirms acceptability of DPC organization which shows QA organization reporting to the Corporate QA Manager who reports to the Senior Vice President Engineering and Construction.
Brownlee explained that DPC has not been in violation of Appendix B, 10 CFR 50, in the organization of its QA/QC program. The QC inspectors are full time inspectors who do not inspect any of their own work. Additionally, although prior to 1981, the QC inspectors received administrative support from the Project Engineer, functionally they have reported to the QA organization since 1973. The QC inspectors received all instructions and guidance concerning the implementation of the QA program and the conduct of inspections from QA.
In turn, the QA organization reports directly to the Corporate QA Manager who is independent of construction and engineering. The DPC QA organization at Catawba Nuclear Power Station has complied with 10 CFR 50, since 1973 in that the QA organization had sufficient authority and organizational freedom to identify problems.
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