ML20148J886

Ack Receipt of 871218 Response to Quality Verification Function Insp Repts 50-413/87-23 & 50-414/87-23.Continued Concern Expressed That QA Organization Not Meaningfully Contributing to Plant Safety & Reliability

ML20148J886
Person / Time
Site:	Catawba
Issue date:	03/25/1988
From:	Varga S Office of Nuclear Reactor Regulation
To:	Tucker H DUKE POWER CO.
References
TAC-67403, TAC-67404, NUDOCS 8803300420
Download: ML20148J886 (3)

See also: IR 05000413/1987023

Text

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WASHINGTON, D. C. 20555

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/ MAR 2 5 1988

Docket Nos. 50-413

and 50-414

Duke Power Company

ATTN: Mr. H. B. Tucker

Vice President

Nuclear Production Department

422 South Church Street

Charlotte, NC 28242

Gentlemen:

SUBJECT: NRC INSPECTION 0F CATAWBA NUCLEAR STATION, UNITS 1 AND 2

INSPECTION REPORT N0. 50-413/87-23, 50-414/87-23

(TACS 67403/67404)

Thank you for your letter dated December 18, 1987, which responds to the

Quality Verification Function Inspection documented in NRC Ir.spection Report

Nos. 50-413/87-23 and 50-414/87-23. We appreciate your having taken the

initiative to address the issues raised in the report. After a careful review

of your letter, we believe there are several areas of apparent misunderstanding

regardino the purposes and conclusions reached at that inspection.

The inspection was designed to assess the ability of your quality verification

(QV) organizations to identify, resolve, and prevent issues that affect plant l

safety and reliability. The inspection was performance based and concentrated I

on issues that affected plant safety and reliability. The planning and imple- I

mentation of the inspection emphasized those activities of safety significance. l

The inspection focused on areas of known or suspected technical problems;

where safety significant problems were confirmed to exist, the team assessed

the effectiveness of the activities of both your QV organizations and manage-

ment in identifying and resolving the issue. The inspection is intended to

influence your QV organizations to be more technically competent, effective,

and useful to plant management. For the purpose of these inspections, we have

defined QV organizations to include quality assurance (QA), quality control

(QC), quality engineering, independent review comittees, and other line

organizations that identify problems and take corrective action.

Your letter states that you do not agree with the report's generalization that

the c"ality verification organizations were not very effective in their

identification and prompt resolution of problems. To the contrary, we believe

that there were a sufficient number of indicators to support this conclusion.

These included the general operations inexperience of your QA staff, the

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programmatic nature of QA audits and surveillances, and a number of important

plant problems in which the QV organizations were either not involved or did

not contribute meaningfully to the final resolution.

Also discussed in your letter is your management philosophy regarding

responsibility for achieving and verifying quality. We endorse your

emphasizing quality achievement in the line organization. We also encourage

the line organization to identify problems and take corrective action. But,

when they take these actions, we see them acting in a quality verification

role. We disagree that the QA organization should not be involved in the tech-

nical resolution of identified problems. If the QA organization is technically

credible, it can and should help define the problem, provide insight into root

cause, and approve and confirm the resolution of the problem in a technically

meaningful way. This approval and confirmation should go beyond the classical

0A paper-oriented review and address the technical merits of the corrective

action. We do not agree that this presents a conflict of interest for any QV

organization or that it in any way diminishes the effectiveness of any QV

organization. To the contrary, we believe it enhances their effectiveness and

usefulness to plant management. Although we support your initiatives to improve

the QA organization's effectiveness, we continue to be concerned that your QA

organization is not meaningfully contributing to plant safety and reliability

as long as audits and surveillances are primarily programmatic in nature.

If we can answer any questions regarding either specific technical issues

discussed in the inspection report or the matters discussed in this letter,

please contact Mr. Frank Hawkins at (301) 492-1009.

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Sincerely, '

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Division of Reactor P , cts I/II

Office of Nuclear Reac Regulation

cc: J. W. Hampton, Station Manager

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Distribution:

PDR

QAB Reading

TMurley, NRR

FMiraglia,-NRR

JPartlow, NRR

RLSpessard, AE0D

Glainas, NRR

SVarga, HRR

WTroskoski, ED0

JARoe, NRR

JAZwelinski, NRR

SHWeiss, NRR

FCHawkins, NRR

WHill, SECY

KJabbour, NRR

CHaughney, NRR

JSmith, NRR

Reaien II Distribution:

LReyes, DRP

AGibson, DRS

VBrownlee, DRP

CJulian, DRS

ABelisle, DRS

PVanDoorn, SRI, Catawba

RII Docket Room

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FCHaWkins:nkp SHWe s JAZwolinski JARoe

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