ML20209B298
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'S UNITED STATES
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- j NUCLEAR REGULATORY COMMISSION
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DEC 161981 MEMORANDUM FOR:
Richard H. Vollmer, Director Division of Engineering l
FROM:
Walter P. Haass,. Chief, Quality Assurance Branch, Division of Engineering
SUBJECT:
QAB COMMENTS ON PG&E RESPONSE TO ITEMS 2 & 3 0F COMMISSION ORDER (CLI-81-30) 0F NOVEMBER 19, 1981 As requested by Eisenhut's memo of December 14, 1981, the QAB has reviewed the December _4,1981 letter from PG&E (Furbush) to. NRC (Denton) responding to the subject Commission Order. Our review focused primarily on the qualification of the contractors selected to perfonn the independent QA reviews, and on the program for evaluating the QA controls in effect and their implementation for all seismic service-related contracts prior to June 1978. We have the follow-ing comments:
1.
The major contractors for the verification program are R. L. Cloud Associates. Inc. and Teledyne Engineering Services, both of whom appear to be highly qualified to perform the needed technical reviews and evaluations.
R. F. Reedy, Inc. (RFR) has been retained as a sub-contractor to Cloud Associatas to perform the review of QA activities.
RFR also appears to be highly qualified in its assigned area of review and evaluation. However, two concerns are evident in regard to RFR.
a.
RFR should not be a subcontractor to Cloud, but rather should report directly to PG&E.
Deficiencies in the QA program are
_ generally recognized as the primary root cause of the Diablo Canyon problem, and therefore there should be greater assur-ance that the independent review by RFR will receive the nec-essary visibility and attention. Elevating the reporting level for QA effort to that of the other technical efforts is consis-tent with the staff's long standing interpretation of the QA criteria in Appendix B as reflected in the SRP Section 17.1/
17.2.
It is noted that Figure 1, referred to in the Overall Management Plan, has not been provided.
b.
There is no indication as to whether Mr. Reedy will perform this task himself or be assisted by others.
If others are involved, their qualifications should be presented.
2.
Sections 3.0, " Quality Assurance Review," and 4.0, " Review of Imple-mentation of. Quality Assurance Controls" of the Cloud Design Verifica-tion Program report (December 3,1981)_ need to be reviewed and revised to include all aspects of the QA program that are pertinent to the re-view and evaluation of seismic service-related contracts.
In addition
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o-Richard H. Vollmer.
DEC 161981 to design control (Criterion III), which appears to be addressed ade-quately, these sections should also address procurement document con-trol (Criterion IV); instructions, V); ' document control (Criterion VI) procedures, and drawings, (Criterion
- and auditing ~ (Criterion XVIII). -
3.
The review of QA controls in effect and their implementation for all seis-mic service-related contracts prior to June 1978 should result in an assess-ment of the adequacy of the QA program during that period of time.
It will provide a historical record of those design activities for which QA con-trols were adequate or deficient as the case may be. The review should also assure that any deficiencies have been eliminated in the operational j
QA program.
The technical verification activities under the Cloud program should identify those design areas that were correctly performed and those design areas that are in error.
For those design areas, including hardware in the field, requiring correction, it is understood that the operational QA program would be in effect to provide the necessary QA ~ controls for these activities.
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alter P. Haass, Chief Quality Assurance Branch Division of Engineering cc:
W. Johnston A
E. Sullivan 4 J. Spraul J. Knight F. Miraglia B. Buckley J
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