ML20247H441

Attempts to Determine If NRC Aware & Approved of Existence of Const QC Dept at Facility During Const Phase of Plant & If Dept Approved by Nrc,On What Basis NRC Approval Granted. Info Needed in Connection W/Litigation Re Facility

ML20247H441
Person / Time
Site:	Wolf Creek
Issue date:	08/21/1989
From:	Garde B ROBINSON, ROBINSON, PETERSON, BERK, RUDOLPH, CROSS
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
NUDOCS 8909190338
Download: ML20247H441 (2)

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. m Robinson, Robinson, Peterson, Berk, Rudolph, Cross & Garde g  : Mary Iou Robinson - Attorneys at Law N ' Nils Jean Robinson los East College Avenue N ' John C. Peterson Appleton, Wisconsin 64911 Avram D. Berk - (4s4)781-1817 Michael Rudolph Green Bay 494*oo

' Dan Cross P r 780 a841

- Billie Pirner Garde August 21, 1989 James M. Taylor Acting Director of Operations U.S. Nuclear' Regulatory Commission Washington, D.C. 20555-RE: Wolf Creek; Docket 50-482

Dear Mr. Taylor,

In connection with litigation stemming from the Wolf Creek plant I am trying to determine if the Nuclear Regulatory Commission was aware of and approved the existence of a Construction Quality Control Department at the Wolf Creek plant during the construction phase of that plant which functioned in the same manner as a quality control organization, i.e.,

performing inspections upon completion of work by craft, but were not certified inspectors and did not keep inspection rgeords and documentation as - required by 10 C.F.R. 50 Appendix B. And if the program was approved, what was the basis of the approval and how did the NRC insure that it was in compliance with 10 C.F.R. 50 Appendix B.

I have reviewed the SAR's and FSAR's for both the SNUPPS plants generally and Wolf Creek specifically. FSAR, Chapter 17, Section 17.2-2 Rev. 1, Page A-9 indicates that such a program existed. It states:

Construction organizations committed to the requirements of the Design and Construction QA Program may have provided quality related activities to organization (s) committed to the requirements of the operating Quality program (e.g. procurement and receipt i inspection). A description of the QA Program elements J controlling these activities was located in the 1

The program was essentially equivalent to the in process l inspection program that was in place at the Midland Nuclear plant I in the 1981/82 time frame and was the subject of enforcement i action, a civil penalty, and mandated rework.

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e .g appropriate' section(s) of the SNUPPS QA Programs for Design and; Construction Manual. The construction organization which provided safety-related activity for the operations /startup applications assured that all personnel were qualified in accordance with the Design and Construction QA Program qualification requirements.

Both the Operating Agent Construction and Operations were responsible for establishing procedures to control the . interface between the construction organization (s) providing the activity and using organization (s).

However, a comprehensive review of the inspection reports done by NRC inspectors into the functioning of the Wolf Creek

. Quality Control / Quality Assurance program do not make any references to knowledge of or review of a " quality control" function within the construction department. See, in particular, Inspection Report 81-15 which examined in detail the site QA/QC program implementation.

I.would appreciate a response to this letter in a timely

. manner. If further discussion between myself and the staff person you assign this matter to will be helpful, please have them call me.

Thank you for your attention to this matter.

Sincerely, N

Billie Pirner Garde o BPG/emh WC l

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