ML19308B932
| ML19308B932 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/31/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19308B928 | List: |
| References | |
| TASK-TF, TASK-TMR SECY-78-495, NUDOCS 8001170640 | |
| Download: ML19308B932 (48) | |
Text
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REVIEW 0F THE NUCLEAR REGULATORY C0 tit 11SSION'S LICENSEE CONTRACTOR AND VENDOR 1
INSPECTION PROGRAM 1
AUGUST 1978 l
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PREPARED BY:
Division of Reactor t
Construction Inspection Office of Inspection and Enforcement J
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Attachment IV 80~0l170 [ fO
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TABLE OF CONTENTS V
P e INTRODUCTION EXECUTIVE
SUMMARY
2 REVIEW 0F THE NUCLEAR REGULATORY C0fitilSSION'S LICENSEE AND CONTRACTOR VENDOR INSPECTION PROGRt.M Eection I - Introduction 4
Section II - Basis for Offsite Vendor Inspection 5
g Section III - Program Goals and Functions 7
l Section IV - Development of the Current Program 8
Section V - Description of LCVIP 9
Section VI - Benefits of the Vendor Inspection Program 11 Section VII - Evaluation of Alternatives 14 Appendix A - History of AEC/NRC Vendor Inspection Appendix B - Quality Problems Identified by Trial Inspection Program of Fuel Fabricators (1973-1974)
Appendix C - Analysis of Causes of Equipment Malfunctions Appendix 0 - Safety Significant Problems Identified by Vendor Inspection (1964-1974)
Appendix E - Significant Findings and Observations of the Current LCVIP (1974-1978)
Appendix F - Basis for Personnel and Funding Requirements m
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INTRODUCTION The Licensee Contractor and Vendor Inspection Program (LCVIP) is the program for direct NRC audit inspection of selected design and manu-facturing activities that occur away -- offsite -- from the site on which the reactor is constructed.
LCVIP complements and is founded on the same direct inspection philosophy as the more extensive onsite NRC inspection effort.
The LCVIP determines that nuclear steam system suppliers, architect-engineers, and selected fabricators of components important to safety have implemented quality :. wurance programs capable of producing a service or product sufficient for the safety needs of the The LCVIP -- as the other inspection activities of the NRC --
user.
includes both a preventive element and a reactive element.
The preven-l tive element consists of routinely planned and scheduled inspections; the reactive element consists of inspections and investigations conducted in response to events, incidents, occurrences, or allegations.
This study defines the bases and goals of the LCVIP; describes the existing program and reviews its development; examines benefits of the program; and, evaluates alternative ways of implementing a program of direct inspection of appropriate offsite design and fabrication activities.
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. EXECUTIVE
SUMMARY
with the construction of nuclear power plants e
on quality and ultimately on public safety.
Licensee Contractor and Vendor Inspection Program (LCVIP) -
An inspection program --
to cover these areas is an important part of the llRC safety conce t protection in depth.
Safety can only result from careful design p of quality component manufacture, quality construction, and proper p,la operation.
IIRC provides a system of rules and guides, licensing inspection that covers all of these phases.
, and and investigation of identified problems. audit inspection of t l
The LCVIP has precedence in the Navy Reactor and NASA programs of vendor. products, the need for knowledge abou The flRC ante capability, and the existence of early manufacturing quality problems.
The current LCVIP is an independent program with both preventive reactive capability.
to use 75% and 25% of the total LCVIP effort, respectively butions of effort are flexible.
These distri-1979 is projected to reach 35%.
In fact, the reactor workload for FY approved by the Comission in 1977.The current LCVIP was initia IIRC vendor ins Region IV (Dallas) perform all vendor inspections. pectors located in involves 21 inspectors covering five nuclear steam system suppliersT (NSSS), approximately 15 architect-engineering (AE) firms 1,000 suppliers.
Inspections are scheduled based on potential safety
, and about impact of each vendor.
NSSS and AE firms are inspected several times a year because of their impact on QA implementation at the design and procurement stages and, in some cases, their supervisory positions Product vendors are selected for inspection based on the importance o their product to safety'and based on reactor operating experience quality, as evidenced by a continuing decline in ad findings.
safety implications have been identified and corrected LCVIP efforts.
Also, vendors and licensees tend to concentrate their efforts in areas of NRC emphasis; this must occur if HRC sampling / au type inspections are to be fully effective.
Vendors comments reinforce C
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the idea that LCVIP provides substantial benefits at a relatively low direct cost.
LCVIP also benefits the Commission because of:
its effec-tiveness in dealing with generic problems (compared to the more fragmented efforts of individual licensees); its flexibility and versatility in the investigation of safety-related events and allegations to and compatability with other IE inspection programs;; and its effec-its relationship tiveness in feeding back independent information to the NRC staff and the ACRS.
Recent initiatives in utilizing third parties to supplement direct NRC inspection activities promises further improvement in the overall effectiveness of the NRC program.
Five alternatives relative to vendor inspection were considered in connection with this study:
No Vendor Program This alternative would eliminate the Vendor Inspection Program.
Host Concept Under this decentralized concept, regional-based IE inspectors would accompany utility representatives to audit the utility's performance in auditing its contractor.
at one time, but discarded it.
The agency used this tecnnique Reactive effort only This alternative would eliminate any centralized preventive (routinely scheduled) inspections but would provide for centralized reactive inspection or investigation of events, incidents, defects, or allegations at licensee contractors and vendors.
_ Current LCVIP This is the current minimum program that provides for both preventive and reactive inspection from a centralized office end continuation of the trial with ASME of third party inspection.
Auamented LCVIP This alternative involves a continuation of the current program for preventive inspection of vendors and contractors, an increase in resources for the reactive program, and additional resources to expedite efforts toward third party agreements with groups other than ASME.
The current LCVIP provides an essential contribution to accomplishment of the NRC mission with modest resources.
While GA0 has recently recommended an increase in LCVIP activities, IE staff sees no immediate need to significantly increase LCVIP staffing as long as third-party inspection is a reasonable expectation.
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4-REVIEW OF THE HUCLEAR REGULATORY COMMISSION'S LICENSE
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VENDOR INSPECTION PROGRAM
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Introduction The NRC conducts inspection programs as an integral part of its Included in this inspec-mission to protect health and safety.
tion activity is a program to directly inspect contractors and vendors that provide services and components '.o the nuclear This Licenree Contractor and Vendor Inspection Program industry.
(LCVIP) involves about five percent of NRC inspection resources.
Its purpose is to assure nuclear plant safety by determining that vendor-produced products and services meet quality requirements.
g HRC vendor inspections have been conducted for more than ten years.
In The present program was initiated on a trial basis for 1974 l
the LCVIP as a continuing part of the NRC inspection program.
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II.
Basis for Offsite Vendor Inspection (mV)
Inspections are needed to support many of the technical reviews performed by NRC.
In developing its inspection programs, an important issue is the extent of NRC inspection effort; that is, should inspection effort be limited to activities performed at facility sites or should it extend to activities performed away from facility sites?
fiany HRC rules apply to work that is performed offsite.
Examples of offsite activities include all major design and analysis work, the manufacture of materials and parts, and the assembly of major safety-related components and sub-assemblies.
Total offsite work amounts to about half the dollar cost of a nuclear plant.
Offsite inspection is justified by several other factors:
The continuing occurrence of problems related to offsite work.
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Recent examples include the use of unqualified electrical con-nectors, errors in computer design codes, and snubber problems.
The Commission's need for information for use in hearings, responses to public and Congressional inquiries, and interna-tional technical exchanges.
The inadvisability of relying exclusively upon onsite inspection of licensee's activities.
Such a practice would cost more to the licensee, require more and better records to support licensee statements, and cause potential delays in licensing actions.
Relying upon onsite inspection would also decrease the efficiency of the NRC inspection program, because additional manpower would be required to obtain eqe; valent information from licensees.
Offsite inspections are a natural extension of onsite inspections.
The current LCVIP has a significant preventive capability which is important because of the high list of correcting defects after a reactor goes into operation in terms of dollars and man rem of
. radiation exposure.
A recent independent study of the LCVIP completed by TWR, Incorporated i
(NUREG'CR 0217, enclosed) summarizes the need for independent offsite inspections by NRC as follows:
"The TRW study team believe NRC inspection of safety-rel?ted activities, away from the construction site, is fully justified by:
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The need -for an independent assessment of the quality of nuclear plants by the Director of IE prior to the award of the OLs to p(j the owners of such plants; The fact that many safety-related parts of nuclear plants are manufactured away from the construction sites; and The fraction of reportable events stemming from design errors and component failures."
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III. Program Goals and Functions The goal of the LCVIP is to assure (primarily by direct NRC field (V) inspection and investigation) that sendors and contractors provide quality services and products.
NRC achieves this goal by assessing the implementation of contractor and vendor quality assurance pro-grams and by obtaining broad generic corrective action in response to. reported problems. The program has four major functior.s:
A.
Inspect nuclear industry suppliers.
These suppliers include architect-engineers; nuclear steam suppliers; fuel fabri-cators; and manufacturers of mechanical, electrical and instru-mentation system components.
LCVIP inspections provide basic information for determining that offsite activities are conducted in accordance with appropriate quality assurance and othar NRC requirements.
This determination is essential to a finding that the Office of Inspection and Enforcement must j
make when determining that plants have been built in accordance i
with the licensee's application and will operate in accordance with applicable requirements.
B Investigate problems and allegations.
Investigations comprise a large part of the workload of the Office of Inspection and Enforcement.
IE must investigate to determine facts to enable resolution of generic problems and to provide bases for assessing the safety of continued operation of affected facilities.
C.
Investigate and develop improved methods for more effective and efficient inspection.
As part of the LCVIP,llRC is currently conducting a trial program to test the feasibility of using the AS!4E vendor certification / inspection system to supplement a portion of the NRC program.
The goal of this
" third-party" effort is to obtain broader coverage of the industry without requiring increases in the directly employed inspection staff.
D.
Improve the quality of design, fabrication and testing of new components by feedback of expericence from facilities in con-struction, test and operation to vendors and suppliers.
The LCVIP is essential for feedback of ope-ating experience.
A secondary function of the LCVIP is to provide a mechanism for reducing the duplicative inepection of vendors by licer.see represen-tatives that now occurs.
Scme reduction in redundancy in the area of quality assurance program evaluation and inspection is possible by giving licensees the option of relying on LCVIP for program evaluation; however, LCVIP is not designed to assure the adequacy of individual components or services (product acceptance).
Full responsibility for product acceptance continues to be placed upon licensees.
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Development of the Current Program As noted earlier, many safety-related activities take place offsite at design and manufacturing facilities.
It is estimated that products plant, and about 80 percent of the welding of sa takes place in vendor shops.
NRC did not conduct extensive vendor inspections until the early 19 because the agency thought that problems with vendor products and services could be identified during the reactor preoperational test phase.
encountered in the late 1960s with vendor products about the same time, NRC At which required licensees a(nd vendors to have qualit then AEC) developed 10 CFR 50, Appendix B Early vendor inspections used an indirect inspection strategy we call the host concept.
Construction inspectors evalu'ated vendor inspection programs of licensees as a part of HRC's review of the licensee's overall quality assurance program.
NRC inspectors periodically ac-companied licensees on their inspection of selected vendors.
The host concept proved ineffective for several reasons.
For example, a single licensee, selected as the host, was held responsible for cor-rection of generic problems that applied to all licensees.
- Also, coordination and administration of host inspections proved difficult.
Independence of inspections was impaired because licensees controlled the scope and depth of the inspections.
1 Most importantly, the host concept was ineffective in correcting problems.
A new approach to vendor inspection was considered necessary.
NRC initiated vendor inspections on a trial basis.
In 1973, The Commission ap-proved the formal LCVIP in 1977.
The current program uses independent coordinated inspections of vendors conducted by a centralized inspection group located in Region IV.
as Appendix A.
P 3etailed history of LCVIP is enclosed i
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O e V.
Description of LCVIP G
Approximately 1.000 vendors in this and other pountries produpe.an array of V
products and services in accordance with a variety of standards.
flows directly from NRC's authority over licenseesBecause vend There are several types of vendors:
1.
Nuclear Steam System Suppliers (NSSS) design and provide specifi-cations for the nuclear steam supply system and provide design input for many other related systems, components, and structures.
There are five NSSS firms:
General Electric, Westinghouse, Babcock and Wilcox, and Combustion Engineering.
2.
Architect-engineering (AE) firms design and provide specifications for the balance of plant and for other key components, systems, and structures.
Examples of the 15 AE firms currently active are l
Bechtel, Ebasco, Stone and Webster, and Burns and Roe.
3.
Product vendors produce all key components and materials used in the construction of a reactor.
Examples are reactor pressure vessels, steam generators, pumps, valves, piping, structural steel, control rods, control rod drives, reactor fuel, shock absorbers for piping systems, electrical cable, and electric
. motors.
NRC inspects about 160 major product vendors.
The current LCVIP has both preventive and reactive capability.
and reactive efforts were to be split 75%/25%.
Preventive In the preventive program, vendors are selected for inspection because of the importance of their product to safety and because of vendor and equipment performance data generated from nactor operating experience and feedback from the reactive and other NRC inspection programs.
Generally, NSSS and AE firms are inspet.ted the most frequently because of the significant impact of design on product quality and safety.
Reactive inspections involve investigation of allegations, malfunctions, l
problems and 10 CFR Part 21 Reports.
Reactive inspections currently l
comprise about 35% of the vendor program effort and are projected to reach 50% by the end of FY 1979.
LCVIP resources have been or are being used to respond to several problem areas:
environmental qualification of electrical connectors, problens with welding, I
Section 205 of the Energy Reorganization Act of 1974 and 10 CFR Part 21 implementi.ng Section 206 have provided some additional authority for con-ducting direct vendor inspections.
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Implementation
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is being backlogged.
As a part of the preventive program, NRC is currently conducting a two-year trial program with the American Society of Mechanical Engineers (ASME) to test the feasibility of formally using third-party inspection to supplement the NRC program.
If successful, this proaram would expand and strengthen the vendor inspection program without ad-ditional NRC resources by permitting NRC to benefit from the regular inspection activities of about 300 ASME inspectors.
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VI.
Benefits of the Vendor Inspection Program Lack of data makes precise evaluation of the worth of LCVIP difficult.
Also, no nuclear power plants now in operation have had the benefits of the current LCVIP.
Some of the tangible benefits of the earlier and present vendor programs are documented in Appendices D and E, respectively.
We believe that vendor inspection has had a salutary effect on safety.
observations:
Appendix D and Appendix E support the following 1.
Vendor inspection has identified and corrected significant quality assurance problems with safety implications.
2.
Under the current LCVIP, there has been an upgrading of quality pro-grams as reflected by a decrease in adverse inspection findings at vendor firms.
3.
LCVIP inspection effort focused in a given area has be l
by ensuing vendor and licensee attention in that area.gn multiplied As noted earlier, the LCVIP has responded to a number of recent technical problems.
The LCVIP has also investigated numerous allegations of quality assurance deficiencies at vendor firms.
An independent study performed by TRW, Incorporated supports the conclu-sion that LCVIP provides substantial benefits.
Among other findings, TRW discovered that LCVIP inspections are often communicated throughout the industry, causing a general upgrading of quality assurance programs.
TRW also found that:
- The LCVIP provides part of the basis for issuance of an operating license (because it provides for assurance of vendor quality).
- LCVIP inspections have generic impact at the management level.
- LCVIP " topical reports" are very useful.
- Both reactive and scheduled inspections are effective in identifica-tion and resolution of pr'oblems.
- The high quality of inspectors contributes to the effectiveness of the LCVIP.
~IAlso as a part of the IE Study,TRW performed a study of incentives that NRC inspection programs provide for licensee performance (Phase 1 Report -
Utility of Incentives Systems for Licensees) and found generally that licensees focus their attention on areas where IE concentrates its attention, resulting in an amplification effort.
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GA0 recently completed a review of the IE construction inspection p
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The GA0 draft report states:
"GA0 found that the Comission's Vendor Inspection Program has had a positive effect on the safety of nuclear power plants but that the program need to be improved before its full potential can be realized."
"The Commission, in particular, needs to assign more inspectors to its vendor inspection activity --
currently there are only 11 vendor inspectorsl who must review over160 suppliers of safety-related equipment."
The TRW study, the GA0 review, and related staff evaluations identified l
some improvements that will increase the efficiency and effectiveness of the present program.
However, the work performed by TRW and GA0 has confirmed our belief that the LCVIP has had a positive impact on quality assurance and the quality of vendor services and products.
Vendor services and products play a substantial role in nuclear power plant quality and safety.
The LCVIP also provides an important contribution to the required finding that a nuclear facility is properly completed.
This finding is a requisite to issuance of an operating license.
The benefits of the LCVIP are summarized below:
- Review of licensee reported events indicate that about 50% of safety-related equipment problems are attributable to contractor and vendor activities.
- Vendors and contractors contribute such a significant amount to overall plant safety that they must be inspected by NRC to discharge its mandate to protect the public.
- LCVIP is an integral part of the NRC concept of protection in depth.
- Experience has shown that licensees are not as effective in detecting and correcting generic problems as the LCVIP because licensees have l
limited perspective andl leverage with. vendors.'
- NRC must respond to safety-related events, reports, and allegations whether or not there is an LCVIP.
i IGA 0 is referring to the inspectors assigned to product suppliers, excluding i
supervision. __ Additional inspectors are assigned to the inspection of nuclear steam suppliers and architect engineers. I l
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- Problems corrected in the vendor shops will not require rework or repair after installation which can impact upon the construction OO or operation of the power plants.
Also, correction at the shops is less costly than at the sites both in terms of dollars and man rems of radiation exposure.
Finally, adequate correction at the site :nay not be possible.
- LCVIP inspection experience provides information to the standards and licensing processes that could not otherwise be obtained.
- Early vendor program experience indicates significantly more non-compliance at contractor and vendor plants than at reactor construction and operations sites.
The LCVIP has substantially reduced this level of noncompliance.
- The LCVIP appears to motivate contractors and vendors toward better performance.
The use of third party inspections has the potential of substantially improving tne effectiveness of the LCVIP with negligible cost to NRC.
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14 VII.
Evaluation of Alternatives This section identifies evaluation criteria and vendor program al-ternatives and presents an assessment of each alternative.
A.
Evaluation Criteria Each of the vendor program alternatives is evaluated on the basis of its e7fectiveness in supporting fiRC's safety goals with ef-ficient use of resources.
This section describes five evaluation criteria that are used to assess ti;e effectiveness of the alter-natives. These are:
1.
Impact on safety.
Would the alternative have a beneficial effect on the safety of nuclear power plants?
I 2.
Independent assurance of safety.
Does the alternative pro-l vide t{RC a sound basis for independently assuring the safety of plants?
3.
Preventive / reactive capabilities.
Does the alternative provide NRC the capability of preventing safety problems and responding to situations with potential safety impact?
4.
Demonstrated performance.
Is there any evidence in the experience of i4RC, other organizations, licensees, or other sources that demonstrates the effectiveness and efficiency of the alternative?
5.
Efficiency.
Does the alternative provide its capabilities at reasonable cost, within budget constraints, and with efficient use of resources?
B.
Vendor Inspection Program Alternatives This evaluation considers five vendor program alternatives:
(1)novendorprogram,(2)thehostconcept,(3) reactive ~
program only, (4) the current program, and (5) an augmented'~
program. These alternatives are ordered so that each offers increased capability over the preceding alternative.
The TRW study considers a greater number of alternative vendor program configurations (seven) because TRW distinguishes bet ~ ween
" certification" and " implementation" audits and evaluates A
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several combinations of having or not having each of these types n
of audits.
This in-house study does not consider the option of
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NRC conducting inspections to " certify" that vendor QA programs meet the requirements of 10 CFR 50, Appendix B.
With this ex-ception, the following five options are comparable to those considered by TRW.
Alternat' e 1 - No Vendor Program This alternative would eliminate the Vendor Inspection Program.
Alternative 2 - Host Concept Region-based construction inspectors would audit each licensee's vendor inspections as a part of the NRC Construction Inspection Program.
Reactive inspections would be made in response to al-I legations, malfunctions, incidents,10 CFR Part 21 Reports and special requests.
Alternative 3 - Reactive Program Only Inspections would be limited to reactive effort in response to allegations, malfunctions, incidents,10 CFR Part 21 Reports, or special requests.
The inspection force would be centralized to maintain adequate control and records of activities, and in-spections would be made without accompaniment by the licensee.
Alternative 4 - Current LCVIP This alternative includes both reactive and preventive inspections.
Reactive inspections respond to allegations, incidents, malfunctions, the most significant 10 CFR Part 21 Reports, and special requests.
Preventive Inspections cover most requirements, but are reduced somewhat to carry out the required reactive effort.
The inspection force is centralized to maintain adequate control and records of vendor activities.
Alternative 5 - Augmented LCVIP This alternative calls for full reactive and preventive inspections.
It involves all the current LCVIP requirements plus those preventive inspections that are being neglecte.d in the interest of the reactive program.
Personnel and funding requirements for each of these alternatives are summarized in Tables 1 and 2, respectively.
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tio vendor program 0
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Host concept 47 42 42 37 3.
Reactive program only 16 16 17 17 l
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Current LCVIP 29 29 34 34 5.
Augmented LCVIP 38 39 40 40 TABLE 2 VENDOR INSPECTION PROGRAM FUNDING REQUIREMENTS Total Funding (5 000)
Alternative FY79 FY80 FY81 FY82 1.
No vendor program 0
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Host concept 1725 1630 1540 1450 3.
Reactive program only 585 585 605 625 4.
Current LCVIP.
1065 1250 1370 1430 5.
Augmented LCVIP 1395 1615 1665 1680
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Evaluation of Alternatives f)
This section identifies advantages and disadvantages for each V
of the five vendor program alternatives.
These pro's and con's are related to the evaluation criteria described above.
Alternative 1 - No Vendor Program This alternative has one advantage - it would permit a savings of about 30 people and one million dollars currently authorized for the Vendor Inspection Program in FY 79.
The disadvantages of this alternative are many.
With no vendor program, the level of safety at nuclear power plants could diminish.
In any case, NRC would not be able to provide the public with an inde-pendent assessment of many safety issues, because without the vendor program, f1RC would have no direct basis for such assess-ments. This alternative would rely upon licensee inspections to prevent the occurrence of safety problems, and reactive capa-bility could only be achieved at the expense of flRC construction inspection activities.
Abandoning the vendor program would contradict the lessons learned from:
(1) the historical experience of the program, in which many significant safety issues have been identified and corrected, (2) the experience of licensees, who value the program, and (3) the experience of other organizations -
such as NASA and the Nuclear Navy Program - who have employed similar programs for similar purposes with notable success.
In summary, Alternative 1 is completely unsatisfactory, primarily because it would require an abrogation of important and necessary HRC responsibilities.
Alternative 2 - The Host Concept This alternative, while preferable to Alternative 1, shares some of its disadvantages, but does not offer the advantage of cost and manpower savings.
While the host concept provides some im-provement in terms of giving NRC some oversight of the adequacy of vendor activities, it does not provide for the active indeoendent involvement that would permit NRC to provide independent assurance of safety.
Some preventive capability would exist, but the content of the preventive program would be dictated by individual licensees, not by NRC.
Reactive capability would exist but be, carried out
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Inspections wou1T be non-uniform because NRC would be relying upon_a..large~ n' umber of different licensees to conduct the inspections.
This alternative is also unfair in some respects because individual licensees would have to be responsible for h'andling g'ener'iEissues beyond their own interests.
The~past experience of'NRC 'ha's shown this alternative
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to be ineffective and inefficient; a's shown in Tables 1 and 2,
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thif.alternati.ve is the most costly ~in terms'of people 'and dollars.
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Alternative 3 - Reactive Program Only vl This minimum level vendor program is limited in its capabilities, g
but it offers distinct advantages over Alternatives 1 and 2.
This alternative would recognize the mandatory nature of reactive effort, and would not require its accomplishment at the expense of other NRC programs.
Furthermore, this alternative would permit NRC to accomodate the increasing percentage of HRC's vendor effort that is devoted to reactive effort, and the current backlog of work associated with review of 10 CFR Part 21 report inquiries would be eliminated.
This alternative does, however, share some of the fundamental disadvantages of the previous alternatives.
A reactive program would not provide HRC the basis for independently assuring safety, because NRC would not be con-ducting preventive inspections focused on problems identified by licensee events and other substantive criteria.
Under NRC's present program, the preventive program is able to incorporate inspections of those persistent weaknesses identified in reactive efforts and encourage industry-wide correction of generic problems; these benefits would, for the most part, be sacrificed by Alternative 3.
However, a complete reactive program could be undertaken with about half the resources devoted to the current program.
Alternative 4 - Current LCVIP The current and augmented LCVIP Alternatives,4 and 5, share many advantages.
Both alternatives acknowledge the number and safety-significance of vendor activities.
Findings of the current program have been responsible for (qualitatively) demonstrable safety improvements.
Both alternatives recognize that it is both safer and less costly to correct problems prior to installation and preoperational testing of equipment.
The current and augmented programs both provide, as part of the OL decision process, a sound basis for independently assuring that a plant has been built properly.
Both programs provide preventive and reactive capability, and both accommodate the administration of third-party inspection efforts as part of the former.
The operational experience of NRC and other agencies reinforce the value of a full vendor program, and comments of licensees provide additional support for the program.
The current LCVIP requires between 29 and 34 people over a four-year period and bNen 1 and 1.4 million dollars annually. The disadvantage of he current program is its recent inability to complete the preventive program because of increases in the reactive workload, l
Alternative 5 - Augmented LCVIP t
j The augmented program incorporates all the advantages of the current program, and is also that alternative preferred by GA0.
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adding nine people in FY 79 to eliminate the backlog of work y) and to provide a full preventive vendor inspection program.
The additional cost of this alternative is about 5300,000 in FY 79.
D.
Summary IE believes that Alternatives 1, 2, and 3 do not provide a sound basis for fiRC to meet its regulatory responsibilities for assuring the safety of nuclear power plants.
The choice between Alternative 4, the current LCVIP, and Alternative 5, the augmented LCVIP, is based on a tradeoff between the value of having a full preventive program with no backlog and the costs and people required to support this augmented program.
The advantages and disadvantages of each of the five alternatives j
are summarized in Table 3.
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ADVANTAGES AND DISADVANTAGES OF LCVIP ALTERNATIVES Alternative Advantages Disadvantages 1
No Vendor Program o Save cost of program.
o Detrimental to safet,y.
o No basis for independent safety cssurance.
o Reactive inspection at_ the expense of other NRC programs.
o Counter to experience of HRC and others.
2 Host Concept o Provides some oversight of o Hasmost of the fundamental dis-
- vendors, advantages as Alternative 1.
o Extremely costly.
o Was tried once unsuccessfully.
o Unfair to licensees.
3 Reactive Program Only o Provides full reactive program.
o NRC would share responsibility o Relatively inexpensive program.
for safety, but would lack needed authority.
o No basis for independent safety assurance.
o No provision for systematic program or generic improvements.
4 Current LCVIP o Gives NRC needed authority over o Backlogging of preventive work important safety issues.
necessary, o Provides basis for independent NRC o Requires 29 people and $1,000,000 assessments of safety.
in FY79.
o Provides preventive and reactive capability.
o Supported by historical experience.
5 Augmented LCVIP o Same advantages as Alternative 4.
o Requires 38 people and $1,400,000 o Provides full preventive program in FY79.
(no backlogging).
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Appendix A History of AEC/NRC Vendor 1rsoection p
V A substantial amount of activity that virectly affects the safety of nuclear power plants takes place offsite at the design organization facilities and in the. manufacturing plants.
It is estimated that approximately 50% of the cost of a nuclear power plant is attributable to products and services from vendors.
Further, approximately 80% of the welding of safety-related piping takes place in the shops of vendors.
Prior to about 1969 agency inspection efforts of contractors and vendors we're minimal.
It was believed then that if problems occurred, startup testing at the reactor site would be sufficient to identify and lead to the correction of such problems.
The need to reevaluate this policy became evident with the problems identified at the Oyster Creek reactor during the late stages of its
}
construction.
Major quality problems were identified in the reactor pressure vessel and in piping systems.
Installation of many second hand valves of unknown quality was also identified.
Most of these problems were traceable back to faulty' designs, a failure to impose appropriate specifications and a general lack of quality assurance by lic'ensees, supplier shops, the project administrators, and the project constructors.
Problems having safety significance were also experienced at several other nuclear facilities during this. same time period.
The consequence of these adverse experiences was the realization that new nuclear standards needed to be written, old ones upgraded, and all standards enforced.
The most significant standard that subsequently evolved and which had the greatest impact upon industry was the 10 CFR Part 50, Appendix B, criteria which introduced the formalized quality assurance concept.
A second significant effect was the realization that to assure that quality is obtained, inspection of work and enforcement of standards, whether performed by licensees or the AEC (NRC), cannot always wait until final assembly at the site but must occur during ali stages of design, fabrication and erection, regardless of where or when that work is performed.
The primary reason for this second conclusion is that it is frequently impossible to make a repair of.a component on site without compromising the final quality of the component.
4
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Appendix B clearly placed the responsibility for assuring both program (V) and product quality upon each licensee or license applicant.
Since IE was insufficiently staffed to conduct an independent vendor inspection program, regional site construction inspectors were directed to evaluate licensee vendor inspection programs as a part of the licensees' overall assurance program and to periodically accompany selected licensees on their inspections of selected vendors.
This indirect inspection method was referred to as the " host-concept."
This concept was utilized during the early 1970's but did not work well in practice for a number of reasons.
It was discriminatory in that the one licensee selected as the host from several eligible licensee candidates for a specific inspection was expected to follow through on corrective action of generic type problems for all licensees.
Further, inspections were difficult to coordinate and administer and more importantly were I
ineffective in correcting problems, since the presence of the IE inspector tended to inhibit the identification of deficiencies.
It should be g
noted that during the host inspections the NRC inspector did not conduct the inspections, rather he observed the licensee's inspector who made the basic decisions as to the scope of the inspection, the depth of investigation and the determination of compliance with requirements by the vendor.
Under the present LCVIP this situation does not prevail since the HRC inspector conducts the inspection of the vendor directly without the presence of any licensee representative.
Since the host-concept appeared to be largely ineffective, a new approach to vendor inspection was clearly necessary.
In early 1973, a trial program of direct inspection of fuel fabricators by HRC inspectors was initiated.
This trial program was motivated by a series of reactor fuel failures attributed to quality problems at the manufacturing plants.
Inspections disclosed that some of the basic problems could also be attributed to design deficiencies.
This trial program proved to be highly successful in obtaining greater conformance to quality standards by the fabricators and a subsequent reduction in major fuel problems.
See Appendix B for additional details.
This program also served to demonstrate the soundness of the basic concepts subsequently adopted for LCVIP.
During this same time period (1971-1974) licensees of operating plants were required to report events and equipment malfunctions (referred to as Licensee Event Reports or LERs).
These reports. continued to increase both in number, significance, and variety as additional large power reactors progressed through the startup stage.
Analysis of the causes of these events indicated that a significant number could be traced to deficiencies in design or in fabrication -- work that had been perfonned offsite during th: design and construction stages.
See Appendix C for additional m. tails.
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l In the same time frame a study was perfonned by a special Regulatory (V
Task Force which noted an increase in the number of reported problems an'd the difficulties experienced in performing inspections in the vendor area.
As a consequence, the Task Force made numerous recommendations which supported the expansion of the trial inspection program.
Based upon the poor experience of the (indirect) host-concept of vendor inspection, the success of the trial' inspection program of fuel f abricators and the recommendations of the Task Force, IE initiated in 1974 a new two-year trial program of vendor inspection covering all types of offsite vendors and suppliers.
This program, the Licensee Contractor and Vendor Inspection (LCVIP), was conducted to determine if enhancea public health and satety could be achieved by assuring higher quality vendor products and services; to identify ana refine methods and procedures for conducting j
ve dor inspections; and to identify !{RC resource implications.
The pi aram met these goals.
g The contribution that independent ver Jor inspection makes to the accomplishment of the ilRC's overall mission has been recognized within the agency for many years.
ilumerous and significant safety problems have been independently identified and correction obtained through the efforts of individual vendor inspectors, problems that were frequently known by manufacturers and licensees but which were not properly addressed because of inherent conflicts of interest between schedules and costs.
Some of the more significar,t problems identified by flRC (then AEC) inspectors prior to the adoption of the LCVIP are described in Appendices B and D.
Additional and more recent problem areas id.entified by the current LCVIP are described in Appendix E.
It should be noted that the importance of vendor quality has been recognized by llASA in the Space Program and by flaval Reactors in the Nuclear flavy Program.
In both of these programs special attention has been given to the quality of the large number of components and services provided by a number of vendors because of their importance to program goals.
In the case of the NRC, which has the same general problem, the situation is made more complex by the larger number of vendors and components and the fact that the NRC is not the direct purchaser.
Nevertheless, the need for independent vendor inspection remains undiminished.
1"The Study of Quality Verification and Budget Impact" (the Ernst Report),
dated January 1974.
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Appendix B Quality Problems Identified by Trial Inspection Program of Fuel Fabricators (1973-1974)
V In the early 1970s as growth of the nuclear industry occurred and signi-ficant quantities of reactor fuel were used, a series of fuel failures and deficiencies were experienced (up to *0.8% of one fuel vendor's fuel failed in service).
Although the primary impact of these problems was I
economic rather than safety (i.e., plant restrictions, unscheduled shut-downs, lowered availability, etc.), high fuel failure rates violate a basic HRC requirement "to maintain or reduce radioactive materials in effluents to as low as reasonably achievable."
Early in 1973, a pilot QA inspection program of fuel vendors was initiated by IE to provide a means for obtaining infonnation relating to the problems and to establish an inspection capability in the fuel area.
Initial inspection findings of this trial program identified several comon deviations from requirements, problem areas and weaknesses in the I
fuel vendor's QA programs.
The most significant deficiencies were found in the following general areas:
1.
Failure to adequately staff, separate and define QA department (and personnel) responsibilities and authorities.
2.
Failure to provide adequate and definitive instructions and pro-cedures to QA and fabrication personnel at the production level.
3.
Failure to goalify personnel.
4.
Weak and deficient subvendor audit programs.-
5.
Weak, deficient and inadequate design control programs Numerous other deficiencies (91 specific items) were also identified but
~
are considered of less significance than the main categories listed above.
Fuel vendors were responsive to inspection findings by making correc-tions and overall improvements in quality assurance programs and in upgrading their staffs.
Considerable uniformity between vendor programs has been achieved.
Some of the most significant improvements were as i
follows:
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All vendors have now implemented specific detailed qualification procedures and practices for both process and personnel qualifications.
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2.
Generic fuel design control problems and weaknesses have been resolved.
As a result of the IE inspection program, more attention has been given to design quality assurance and a better balance between design and fabrication QA has been achieved.
3.
Through IE inspection efforts, strong quality assurance requirements are being extended to all sublevels supplying components, materials, or services.
Principal fuel vendors are currently verifying quality requirements by more extensive audits of subvendors.
4.
As a result of IE inspection findings and emphasis, more vendor management attention has been given to their internal audit programs with demonstrated improvements in this area.
l 5.
In cooperation with IE suggestions, efforts are underway at most l
fuel vendors to streamline and reduce the procedures to prevent.
+
duplication and unnecessary complexity.
This is helping to achieve better compliance with procedures.
6.
At fuel vendors where inadequate QA staffing and/or definition of authority and responsibilities was encountered, additional personnel were hired, more staff training was provided and, where necessary, the QA staff was given more authority and responsibility in the day-to-day operations.
Although current fuel performance experience is difficult to quantify and compare to earlier fuel failure data, current overall fuel failure rates are estimated to be at least a factor of two lower than when this inspection program was initiated.
Much of this improvement in perfor-mance can be directly related to improved QA programs motivated in part by the NRC inspection effort.
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Appendix C Analysis of Causes of Equipment Malfunctions N
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In March 1974, an analysis of 654 equipment malfunctions reported to the NRC in the preceding year was conducted to determine the relative distri-bution of product type malfunction and the basic sources or causes of the malfunctions. The latter were categorized into design, manufacture, construction or maintenanca functions.
Malfunctions or errors involving deficiencies in calculations, stress analysis, selection of material or misapplication of a component were attributed to design.
Defective materials, leaks, cracks or failure to functionally perform as designed were classified as manufacturing deficiencies.
Errors involving align-ment, orientation, handling, failure to provide adequate physical protec-tion were considered construction deficiencies.
Operational or maintenance deficiencies included corrosion, seal problems, calibration and others.
The results obtained were as follows:
Malfunction Cause Categories Design 152 or 23%
Fabrication 81 or 12%
Construction 131 or 20%
liaintenance and operations 290 or 45%
654 = 100%
Major Categories of Malfunctions 1.
Mechanical components or systems 268 or 41%
2.
Electrical components or systems -
161 or 25%
3.
Electronic and instrumentation 155 or 23%
4.
Personnel or procedural deficiencies 70 or 11%
654
= 100%
Malfunctions attributable to equipment type were as follows:
ASME Covered Components (Mechanical)
Valves (all types) 120 Piping 43 Pumps 18 Pressure vessels and tanks 15 Steam generators and heat exchangers 7
203 or 31 %
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Diesel generators 21 Control rods 35 Fuel 6
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Electrical Components Pump motors and valve operators 76 Switchgear, relays, etc.
85 16T or 25%
Electronic Equipment and Instrumentation Setpoint drift 80 Instruments, alarms, circuits 75, 155 er 23%
Personnel Errors
!.11 types 70 or 11%
Noteworthy is that 35% of the malfunctions of all types were traceable to design and fabrication, work which is performed by a vendor away from..the facility site.
We have compared these data to more LER data and find that generally the distribution of malfunctions indicated above for 1974 carry through and that the 35% figure is generally valid.
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Appendix D Safety Significant Problems Identified j
by Vendor inspection (1964-1974) 1.
Sensitization of reactor pressure vessel safe-ends Because the materials used in the reactor pressure vessel and the connecting reactor piping are different, a transition piece called the safe-end is attached to the vessel nozzles by the manufacturer.
The safe-end is usually made of a stainless steel which is compatible with.the piping material.
One of the stainless materials (Type 3041 frequently used is susceptible to sensitization, a condition which results in the meterial becoming more prone to stress corrosion cracking in the operating environment.
Safe-end sensitization may be caused by improper or untimely heat treatment during vessel manufacture.
These conditions were identified by an AEC (HRC) vendor inspector during the late 1960s.
Approximately 15 reactor vessels required subsequent replacement or repair of the safe-ends as a result of this finding.
The safety significance of stress corrusion of safe-ends relates to the critical location of these pieces in the reactor primary cooling system.
Since the safe-ends are located on the largest of the reactor vessel nozzles (22 inches to 28 inches in diameter),
breakage at this point in the reactor coolant system must be avoided.
(It is interesting to note that a German reactor facility was recently shutdown to investigate stress corrosion cracking in a reactor vessel nozzle safe-end.
The vessel was of the same vintage as those repaired in the U.S.
In this instance the safe-ends had not been repaired or replaced.)
Had the sensitized safe-end condition not been identified and corrected prior to placing these early vessels in service, a substantial cost in dollars and in personnel radiation exposures would have been incurred to accomplish the repairs after operation had commenced.
Furthermore, had the NRC (then AEC) not taken positive action in response to the vendor inspector's finding, the industry would not have taken timely independent action to perform the repairs or replacements.
2.
Use of a margirial welding process (electroslag)
Electroslag is a metal joining process which is somewhat analogous to casting.
Use of the process was observed in the manufacture of reactor pressure vessels.
The problem in applyin'g it to reactor i
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pressure vessels is that special heat treatment of the finished weld pd is required to assure acceptable tensile and impact properties.
The effectiveness of the heat treatment is limited to vessel wall thicknesses no greater than 6".
Since vessel wall thicknesses frequently exceed 6" and testing of the deposited weld metal is not required, application of the process to reactor pressure vessels was marginal.
Use of the process was subsequently discontinued.
The safety significance of marginal tensile and impact properties in weldments is to infringe upon the conservatism and safety margins required during operation of the vessels.
Specifically poor impact properties (a measure of brittleness) require more conservative operating limits governing the rate at which reactors can be heated up (startup) and cooled down (shutdown).
3.
Major discontinuities in pressure vessel nozzle welds l
During a two-man NRC inspection of a reactor pressure vessel manufacturer, both inspectors identifiea independently the fact that the manufacturer had been having difficulty in meeting weld acceptance standards on the main piping nozzles.
Investigation disclosed the problem to be generic to a number of vessels.
As acceptance of the welds is dependent upon-interpretation of radiographs, unacceptable defects are not always identified.
Subsequent to identification of the problem, one vessel (Hatch 1) which had been shipped to the facility site was found to have unacceptable defects.
Extensive repairs were made to the Hatch vessel at the field site as well as to others still in the shop.
As in item 1, the. safety significance of this finding relates to the critical importance of.the main reactor vessel nozzles to maintaining core cooling capability, both during normal operation and during any accident condition.
The optimum quality of workmanship must be obtained in the manufacture of pressure vessels since there is no redundancy associated with this critical component.
Again, the manufacturer would not have taken corrective action had not the NRC (AEC) identified the problem. Furthermore, individual owners were unable to identify This as a^ge~neric~ problem ~since their access to the manufacturer's records was limited to their individual vessels.-
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Access to all contractual records of a manufacturer is a unique advantage that only the-NRC inspector can take advantage of in the identification of generic problems.
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Improper heat treatment of materials Heat treatment is frequently necessary to permit fabrication or to (m")
f assure that material properties in the. final finished product are satisfactory.
Since heat treating is a special controlled process frequently tailored to the material or to the form being fabricated, adequate control is not always exercised or obtained.
Many instances of improper heat treatment have been identified by NRC inspectors.
The safety significance of improper heat treatment of materials is that those materials may not be capable of meeting the stress limits or other design parameters assumed by the designer.
Many welding problems can be traced to improper heat control during welding or heat treatment (stress relieving) following welding.
Sensitization of improper heat treatment whicn causes a higher stress corrosion cracking.
Recent examples (1978) of problems O
traceable in part to improper heat control are safety injection pump shaft failures at D. C. Cook 1, Trojan, Beaver Valley 1; weld cracking in vessel support structures at North Anna 3 & 4, Salem 2, and Beaver Valley 2; deficient bolts at Palo Verde 1.
The above problems were identified at reactor sites by licensees.
The deficient materials were-supplied from vendors who had not been inspected by the LCVIP.
One cannot concluc'e that the NRC inspector would have identified the specific problems had inspections of these firms been performed.
The conclusion can be made, however, that heat treatment problems are recurrent and that NRC inspections ir.
heat treatment procedures.this area cause suppliers to direct more atte 5.
Failure to meet nondestructive test acceptance standards A number of cases have been identified in the review of radiographs of components where acceptance standards have not been met.
deficiencies are usually associated with pump and valve castings and These in welds.
The safety consequences of defects in pump and valve castings is failure of the pressure boundary.and loss of function.
of failure depends upon the safety importance of the system in whichThe signif the pump or valve is installed.
have occurred in nuclear installations because of the high acce standards imposed.
Assurance that this record is maintained is in part dependent upon constant surveillance by the industry and NRC inspection.
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4 Cost Sionificance of Identified Problems O
d Since the llRC's jurisdiction is limited to public health and safety considerations, it is not possible for the flRC-IE to determine the costs of correcting identified problems or the saving incurred by the prevention of problems.
ilevertheless, by analogy it is evident that very large costs, both in dollars and personnel radiation exposure are incurred when vendor related problems are not discovered at the manufacturing stage resulting in reactor shutdowns and the need to conduct repairs in an irradiated environment.
The magnitude of this effort can be appreciated by considering that one lost day of production of a 1000 rnegawatt capacity reactor represents approximately $300,000 (at 20 mills /ki.owatt-hour) in lost revenue.
Expressed ici another way, interest costs alone on a 1000 megawatt reactor are approximately $200,000 per day (at a capital cost at $750/ kilowatt capacity at 10% interest rate).
Ij Real losses in prodn: tion have occurred in the past and are being i
experienced now. A c'urrent outage, expected to continue for several more weeks at the ruane Arnold plant is attributable in part to machining errors made in a sappliers shop.
The ability of this licensee to cover the multi-million dollar costs incurred for this single event is currently in question. The cost in personnel exposure is estimatedl to be between 600-800 man-rems, a very significant number.
To accomplish this repair will require the use of approximately 200-250 individuals to stay within the quarterly exposure limits.
Each of the described problems identified by direct fiRC inspection have thus resulted in significant cost savings, not only to the industry but to the power consuming public.
IExact values will not be available until completion of the repair.
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APPEllDIX E Significant Findings and Observations of the Current LCVIP (1974-1978) j
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Effect of LCVIP on ilSSS and AE Organizations as Measured by Chronological Trends in QA Audits and Staffing The information below was generated by LCVIP personnel in Region IV from field inspection data to indicate impact of that program on vendor performance.
Example 1 Figure i shows the number of audits and findings per audit over the time frame of LCVIP inspection, of an NSSS.
These data are typical of the data that exists for the other NSSS's and is quite similar to comparable data for AE's.
The following are connents relative to the data presented on Figure 1.
1.
Internal client audits include all 115S5 management audits and.
internal audits by the MSSS plus all audits of the !!SSS by their clients.
2.
The data presented do not reflect information from CY 1974, further the data for CY 1975 reflects approximately one year of the present program's impact.
3.
QA personnel staffing at the NSSS remained essentially constant throughout this time period.
4.
The 1978 total reflects activity from January through June, nor-malized to the end of the current year.
In summary, the deta shows a substantial overall drop in the number of adverse findings per inspection in both NRC and industry audits since 1975 after the initiation of our program. The data also shows sharp increase in the total number of NSSS audits after 1975, peaking in 1976 and followed by a decreasing audit frequency.
The recent (1978) increase in NRC inspection findings per audit may relate to the decreasing audit frequency.
(We made only two inspections in 1977).
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(V apparent by the conclusion of IE's second inspection (A the implementation of the QA program at this AE wa It became due principally to a lack of strength in the perso 5 that s significantly lacking and a relatively small QA staff.
In January 1976 IE met with the senior management of the AE's organization in the Region IV offi them that while the implementation of their QA p ces.
IE advised appeared to be self-limiting for the reasons given aboverogram w management agreed with IE's observation and replaced th i The AE's senior early 1976 and began increasing his staff.
e r QA Manager in During these early inspections (in 1975) identified.
, thirteen 13 finaings were being properly controlled or implementedThese findings rela perform design verifications, certain eng,ineeringsupervisors being anuals not not being properly trained, and manuals of internal ppersonnel
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not being controlled.
the division QA group of the AE was significa roject procedures j
re projects that the projects were controlling the a conclusion that y ineffective.
The division division QA surveillance and was somewhat isolat d nsibility to the programs without the division.
in the following types of findings identified:This delegation e
was manifested on audit findings they had made. Project QA was not get mely carrective actions their QA program commitments. Project QA was extending c
ons, contrary to -
Internal ar.d external audit findings made on one considered on other projects where the same problem wo ldp fact were found during VIB inspections onsite and in vendor shops. outdated specifications and speci u
exist and in projects at different times thrugh client and VIB insThis was id corrective action was not taken by the AE until the VIB f pections.
Effective Figures 2 and 3 graphically reflect the improveme t orced the issue.
change.
n s brought about by this 1.
The findings per audit began to decrease after th program.
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e initiation of IE's 2.
When the new QA Management was installed (noted b findings per audit increased and then began a steady the arrows) y decrease even fX
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Note:
Internal and client audits and findings relate to all audits conducted of the AE, except the VIB audits, e.g. management audits, project audits, and client audits.
The decrease in the number of audits in 1975 was due in part to a suspension of activities on one of-the AE's.
The total number of audits for 1978 was normalized for the second half of the year.
The greatest impact the LCVIP has had on AE's (and NSSS's) has been the focusing of senior management's attention on the importance of QA in g
their organizations.
This has resulted in stronger management support i
of the organization's QA groups whose basic responsibility is the effective I
implementation of their QA programs.
The problems attributable to AE's (and NSSS's) that are surfacing today such as:
Reactor pressure vessel being installed in the wrong orientation; (San Onofre 2)
Incorrect structural design of reactor control building; (Trojan) 1 Incorrect design and placement of pipe support base plates; (Millstone, Shoreham, N. Anna 1 & 2) and Errors in ECCS computer codes (Westinghouse);
will be reduced in the future due to the impact that the LCVIP has had since its beginning in 1975 with such findings as:
Design verifications not being performed according to requirements; Equipment specifications not being prepared, reviewed, and approved per system description requirements; Preparation and issuance of procedures for control of design activities; and Field design changes being made withou+ ter;30 rate engineering's approval.
The impact of LCVIP findings such as thess 'J r$ d above (each identified in t
1975) will not be realized until about c'9/0 :.' probably not fully until 1980 or 1981.
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Component and Instrumentation Manufacturing (C&IM) of GE San Jose is
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subject to the same QA program as the principal design and procurement functions of this major NSSS.
LCVIP has inspected the design and pro-curement functions routinely since 1975 with the results comparable to those shown in Figures 1 and 2.
LCVIP did not audit C&IM however until June 1977.
Fr~- inspectors participated in that audit and fourteen findings rest
.ed.
Subsequent to that inspection C&IM management instituted a compliance upgrade program" in that division involving all personnel in C&IM.
The program included division-wide emphasis on QA through training, indoctrination and employees newsletters.
The following is a chronology of GE's QA group's audits of C&IM and the single audit by LCVIP.
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1975 GE's audit of C&IM
-7 CARS (Corrective heports) 1976 GE's audit of C&IM
-6 CARS issued 1977 (June) LCVIP's audit of C&IM
-14 deviations identified 1977 (August-0ctober) GE's audit of C&IM
-19 CARS issued 1978 GE's audit of C&IM
-23 CARS issued From the foregoing, our first inspection of the C&IM division focused the attention of GE management and motivated the QA group as evidenced by the results of the subsequent audits which reflect a quality awareness that was not apparent in their earlier efforts.
It is interesting to note that this is the same QA group that inspects this NSSS's design and procurement functions.
Their QA effectiveness in these activities, routinely inspected by LCVIP since 1975, tracks very closely the same as indicated in Figures 1 and 2.
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Effect of LCVIP on Component Manufacturers as Shown by Chronological Trends in VIB Inspection Findings I
The following tabulation summarizes VIB inspection history for two typical w/
valve manufacturers.
The i sitial inspections of both companies resulted in a large number of adverse findings followed by a substantial improve-In case "B" the improvement was sufficient to reduce our inspection ment frequency to yearly audits.
In case "A" a bi-annual audit frequency is retained.
The types of findings in both cases are summarized below:
_ Company "A" Company "B" January 1975 March 1976 (6) Programmatic (3) Programmatic (3) Calibration (1) Manufacturing Control (1) Nonconforming liaterial (7) Process Control (1) Material Handling August 1975 (1) Audits (1) Drawing Control September 1976 (1) Welding (1) Procurement August 1976 (1) Design, Document Control (2) Process Control May 1977 April 1977 (3) Handling, Storage (1) Welding (2) Document Control (1) Handling, storage shipping November 1977 June 1978 (3) Welding (1) Calibration (2) Equipment Calibration (1) Training July 1978 (1) Calibration (1) Training l
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Summary of Typical Vendor Inspection Findings Having Direct Effect on Product Quality or Expected Performance
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1.
Inspection of a containment penetration assembly at a fabrication shop against applicable design requirements showed that inadequately sized fillets welds had been used and accepted by the Vendor's 1
Quality Assurance.
As a result of our findings a nonconformance report was initiated and the penetration assembly was re-worked to correct the defici-encies.
In addition, the vendor held a special managment/QA con-ference and added an inspection hold point to the fabrication sequence of the penetration assemblies.
I 2.
During a routine vendor inspection of a pipe fabricator our inspector noted that mechanical property tests had not been conducted on I
certain lots of welding materials as required by the ASME code and it could not be verified that materials used in some production l
welds complied with the code requirements.
Based on the inspector's findings, the vendor prepared a noncon-formance notice which subsequently resulted in weld replacement.
The required weld material qualification tests were performed and quality control as well as. production personnel were indoctrinated in the requ;rements for acceptance and use of welding material.
3.
During a rout ne inspection of a fabrication shop our inspector observed that welding procedures used for production welding had not been properly qualified in that mechanical test data did not account for the heat treatment given to the actual components.
The components manufactured using the unqualified procedures were placed on " Hold" status pending the results from additional qualifica-tion tests.
4.
During an inspection of a valve manufacturing facility, our inspector observed that stress calculations had not been performed on valve bonnet flanges, for valves of commercial design used fo AS!iE class 2 and 3 applications.
As a result of our inspection, the vendor performed calculations which verified the stated pressure-temperature ratings.
result of the inspection a standardized design calculation procedure Also as a was developed by the vendor ~for class 2 and 3 valves.
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During a recent inspection of a pipe assembly fabrication shop our inspector identified four main steam line spool pieces which had
-O been welded using a procedure which does not satisfy the ASME code l
V, pre-heat or post-weld heat treatment rec 'irements.
6.
During a routine inspection of a shipping cask vendor our inspector found that the construction commitments in the Certificate of Compliance were not being met.
The fabrication drawings used in construction contained significant changes which had not been approved.
As a result of this inspection all spent fuel shipping casks of this design were withheld from service pending review and approval of the identified deviations.
7.
During a routine inspection of a fuel fabricator our inspector found g
that sampling plans for fuel assembly gri.d characteristics (pitch and perpendicularity) did not assure the specified confidence levels.
As a result of this finding the sampling plans were revised and all grid assemblies in current production re-inspected to the new requirements.
8.
During a routine inspection of a major fuel manufacturer, the NRC inspector observed carbon steel chips inside the plastic envelope used to protect the fuel bundles.
It was determined that the steel chips were the results of drilling operation during a modification of the shipping containers to accommodate larger fuel bundles.
The metal chips had been sufficiently hidden to escape detection by the vendor's inspection prior to loading.
The moving of the inspected bundles from.a vertical position to a horizontal position and securing the bundles to a shipping support caused the metal chips to move sufficiently to become visible.
The safety significance of this finding is that movements of the fuel during shipment could distribute the metal chips onto the surfaces of the fuel pins, where they could become wedged between the surface of the fuel pin and the transverse spacing grids.
After installation, the flow of the coolant fluids could induce vibration or disturbances of sufficient magnitude to cause fretting 'which could result in penetrating the metal tube (s) containing the UO2 fuel pellets.
Breaching the metal barrier between the coolant and UG4 fuel, would provide a path for the UO2 to escape into the coolant Yluid.
The 302 could then be transported to all portions of the coolant flow path.
This finding resulted in the vendor reinspecting 78 containers - 24 of which were found rejectable.
The vendor also revised the container drawings to eliminate the need for modification, and revised his packaging and inspection procedures to include inspection for cleanliness after the fuel bundles are secured in the containers and retrained the inspectors assigned the responsibility for performing this final inspection.
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During a recent inspection of an NSSS in the routine area of Supplier Performance Evaluation, it was noted by the inspector that a particular High Pressure Safety Injection System valve was returned to the manufacturer from five different reactor sites ~ because they had failed flow tests on at least one site.
Based on the inspector's review of the HSSS's records, it appeared that all but one site had taken appropriate action relative to the return of these valves.
The HRC Regional office responsible for the one site in question was apprised of our findings and they found that the utility had not reported the valve problem as required by 10 CFR Part 50, paragraph 50.55e.
The Regional office took appropriate enforcement action; however, had our program not identified this problem it could have resulted in an unreviewed safety item concerning an essential com-ponent of a system essential for the mitigation of accidents postu-lated for the particular reactor facility.
l 10.
Approximately 56 deviations were identified during 3 LCVIP inspecticas l
of a major supplier of safety-related pumps.
The deviations could be classified as programmatic deficiencies and ommissions in the areas of design c,ontrol, procurement and vendor's surveillance, control of special processes including randestructive testing and deficiencies in equipment calibration.
While safety significance of these in terms of product performance can not be directly assessed, similar deficiencies have caused failure of safety related pumps during plent op ' ration (ex. pump shaft failure atcributed to procuremr.nt and Mceptance of improper material).
To achieve correction, the LCVIP enforcement accion included meetings betweet IE and the company management at the Vendor's facility and at NRC headquarters. As a part of the corrective action, the vendor completely revised and upgraded his QA manual, instituted additional training and indoctrination of QC personnel, upgraded his internal audit system and made re-assignments in and. additions to the QA staff.
Significant improvement was noted during the last LCVIP audit of this vendor.
All previously ioted deviations had been corrected and only 6 new items were identified.
11.
Approximately 75 deviations were identified during 6 inspections of a major fabricator of safety related pipe assemblies.
Most of the deviations were related to welding and can be classified as follows:
Failure to quality welding procedures to ASME Code requirements.
- Failure to qualify and control the use of welding materials.
Failure to follow welding procedure requirements.
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[m) to subsequent pipe failures in service or require restrictions in
\\~d plant operating limits or augmented inservice inspection.
(Examples:
Duane Arnold recirculatory system cracMag, B&W welding material mix-up, Surry primary loop ferrite problem, numerous instances of HAZ cracking.in BWRs, Hatch repair, etc.)
In addition to resolving the specifically identified deficiencies the vendor's corrective action included strengthening the QA program by personnel reassignments, hiring of additional QA personnel and increase in management awareness and support for the QA program.
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APPEliDIX F Basis For Pcrsonnel and Funding Request The oriainal version of the current LCVIP program was planned for 20 e(x) inspectors /section chiefs plus 1 branch chief, all in Region IV.
The reactive component of this original plan was assumed to be 10% or 2 positions, with the remaining 18 positions for the preventive program (plus 1 branch chief).
Currently, the reactive effort is much bigger -
the equivalent of 7. positions leaving only.13 positions for the pre-ventive effort.
Nevertheless, this reactive effort is only part of what it should be since it does not include responses to Part 21 reports.
Another 4 to 5 positions are estimated for adequate Part 21 response.
In the current progrcm IE would backlog most Part 21 report responses, picking them up in the course of scheduled preventive inspections.
Thus the. current program provides cutbacks both on the originally intended preventive effort and on current expectations for reactive effort.
A reactive only alternative would require the 7 current inspector positioris plus 4 to 5 positions for 10CFR21 and a branch chief.
The.aucmented l
program would have this full complement of 11 to 12 reactive effort inspectors, the originally planned 18 preventive-effort inspectors plus a branch chief.
The host concept assumes that NRC would audit each licensee's inspection of its vendors on a site basis:
2 per year for the AE and for the !!SSS; and one per year for 8 out of the 15 to 20 major component vendors.
These 12 inspections per year would be for each site where there are reactors in construction during the first 5 of the.6 year construction period.
Since the number of such sites declines over the FY79-FY82 period, the number of inspectors declines - from 25 inspectors for 44 sites and 73 reactors in FY79 to 1.i inspectors for 27 sites and 49 reactors in FY82.
To this is added the centralized reactive component of 11 to 12 inspectors plus a branch chief.
Regional support and Headquarters support follows the FY80 budget sub-mission.
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TABLE FY79 FY80 FY81 FY82 1.
No Vendor Proaram Total Personnel 0
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Total Funding 0
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7 7
7 Part 21 reports 4
4 5
5 Preventive Element 0
0 0
0 Branch Chief 0
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Licensee Accompaniment 25 21 20 15 7
6 6
6 Regional Support 4
4 4
4 HQS Support TOTAL PER50!iNEL 47 42 42 37 Operating Expenses *
$1725 S1630
$1540
$1450 0
0 0
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$1725 S1630
$1540 S1450 3.
Reactive Prooram Only Allegations, malfunctions 7
7 7
7 Part 21 Reports 4
4 4
4 Preventive Element 0
0 0
0 Branch Chief 1
1 1
1 Licensee Accompaniment 0
0 0
0-Regional Support 3
3 3
3 HQS Support i
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1 TOTAL PERSONNEL 16 16 17 17 Operating Expenses *
$585 S585 S605 S625 Program Support 0
0 0
0 TOTAL FUNDING
$585 S585 S605
$625 4.
Current LCVIP Allegations, malfunctions 7
7 7
7 Part 21 Reports **
0 0
1 1
Preventive Element 13 13 16 16 Branch Chief 1
1 1
1 i
Licensee Accompaniment 0
0 0
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6 6
6 6
Regional Support 2
2 3
3 HQS Support TOTAL PERSONNEL 29 29 34 34 o
- Salaries, benefits, and travel at $36,700 per full time position
- Backlogging reports to be looked into on scheduled preventive inspections.
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Current LCVIP, Cont'd.
Operating Expenses *
$1065
$1065 51155 51250 Program Support 0
185 215 180 TOTAL FUNDING S1065
$1250 S1370
$1430 5.
ggmentedLCVIP Allegations, malfunctions, special requests 7
7 7
7 Part 21 Reports 4
4 5
5 Preventive Element 18 18 18 18 Branch Chief 1
1 1
1 Licensee Accompaniment 0
0 0
0 Regional Support 6
6 6
6 HQS Support 2
3 3
3 TOTAL PERS0MilEL 38 39 40 40 Operating Expenses *
$1395
$1410 S1450
$1470 Program Support 0
205 215 210 TOTAL FUliDING
$1395
$1615
$1665
$1680 Manpower Factors Allegations, malfunctions - Alternatives 2-5 No change from FY 78 experience.
Part 21 Reports - Alternatives 2, 3, 5 Resources as requested in SECY.
Part 21 Reports - Alternative 4 No change from FY 78 backlog.
Preventive Element - Alternative 4 NSSS's (4 companies) 0.25 0.25 0.25 0.25 AE's (4 companies) 0.24 0.24 0.60 0.60 Fuel Suppliers (7 compani'_s) 0.14 0.14 0.14 0.14 ASME Vendors Level of Effort - 8 manyears NON-ASME Vendors (30 companies) 0.05 0.05 0.05 0.05 Preventive Element - Alternative 5 NSSS's (4 companies) 0.35 0.35 0.35 0.35 AE's (8 companies) 0.60 0.60 0.60 0.60 Fuel Suppliers (7 companies) 0.14 0.14 0.14 0.14 ASME Vendors Level of Effort - 8 manyears NON-ASME Vendors (65 companies) 0.05 0.05 0.05 0.05 Licensee Accompaniment - Alternative 2 0.56 manyears/ site 3gioi.al Support - Alternatives 2-5 0.22 manyears/ Inspector & Branch r
Chief I
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