ML20041B470
| ML20041B470 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8202240076 | |
| Download: ML20041B470 (66) | |
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 BRIEFING BY INDUSTRY ON PLANS FOR 5
QUALITY ASSURANCE IMPROVEMENT 6
PUBLIC MEETING 7
8 Nuclear Regulatory Commission Room 1130 9
1717 H Street, N.
W.
Washington, D. C.
10 Thursday, February 4, 1982 11 The Cammission convened, pursuant to notice, at 12 2:05 p.m.
13 14 BEFOREa 15 NUNZIO PALLADINO, Chairman of the Commission VICTOR GILINSKY, Commissioner 16 PETER BRADFORD, Commissioner JOHN AHEARHE, Commissioner 17 THOMAS ROBERTS, Commissioner 18 STAFF MAKINC PRESENTATIONS AT MEETING:
19 S.
CHILK 20 L. BICKWIT 21 ALSO PRESENT:
l 22 B. PARRIS L. SILLIN 23 H. PARRIS W. LEE 24 E. WILKINSON B.
LEE 25 ALDERSoN REPORTING COMPANY,INC.
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DISCLAIMER This is an unofficial transcript of a meeting of the Urriited States Nuclear Regulatory Comission held on v bruary 4 1992 in the Comission's offices at 1717 H Street, N. W., Washington, D.
C.
The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
l The transcript is intended solely for general infomational purposes.
i As provided by 10 CFR 9.103, it is not part of the femaI cr infomal record of decision of the matters discussed.
Expressions of opiniori in this transcript do not necessarily reflect final deteminations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed to any statsmant or argument contained herein, except as the Comission may authorize.
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CHAIRMAN PALIADIN0s The meeting will please 3 come to order.
4 This af ternoon the Commission meets to hear 5 from senior industry officials on the industry's plans 6 for improvements in the area of quality assurance and 7 quality control.
8 The Commission is very interested in the 9 industry's initiatives in this area.
The NRC staff is to currently developing their action plan for improving
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11 quality assurance.
The Commission will certainly want 12 to consider the industry's program establishing the 13 final NRC action plan for quality assurance and quality 14 control.
I believe we should advantage of appropriate l
15 opportunities to dovetail and coordinate our respective 16 actions in this area.
17 The industry participants today are Mr. Bill 18 lee, Chairman of the Board, Institute for Nuclear Power 19 Operations, and President of Duke Power Company; Dennis l
l 20 Wilkinson, President, Institute for Nuclear Power 21 Operations.
22 Also attending are lelan F. Sillin, Jr.,
23 Chairman and Chief Executive Office, Northeast 24 U tilities; Hugh Parris, Manager of Power, TVA; and Byron 25 lee r Executive Vice President, Commonwealth Edison l
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2 Before I turn the meeting over to our industry 3 visitors I think General Counsel would like to make a 4 comment.
5' HR. BICKWITs Thank you, Mr. Chairman.
G I just wanted to note t!.2t the quality 7 assurance issue is an issue that is litigated in a 8 number of proceedings now before the Commission and the l
9 Commission's boards.
l to I understand it is not the intent of the 11 panelists to get into those proceedings.
If it should 12 happen, the guidance that we would offer would be that 13 it ought not to be pursued.
Discussion of'those issues 14 with respect to those particular proceedings ought not 15 to be pursued unless the case can be made that it is 16 important for the Commission 's general understanding of l
17 the QA/QC problem.
18 CHAIRMAN PALLADINO:
Do any other 19 Commissioners have comments?
20 (No response.)
21
' CHAIRMAN PALLADINO:
Thank you.
We will 22 proceed and turn the meeting over to Mr. Bill Lee.
23 HR. W. S.
(Bill) LEES Thank you, Mr. Chairman 24 and Members of the Commission.
25 We appreciate the opportunity to appear here ALDERSoN REPORTING COMPANY,INC, ETWITYPTG /XiL ELCL N RR KNO dRiF4) GO3 M
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1' and describe for you industry initiatives in the area of 2 nuclear plant construction quality evaluation programs.
3 Accompanying me, and my name is Bill Lee, are
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4 to my f ar right Byron lee, Executive Vice President of 5 Commonwealth Edison.
Byron is also Chairman of the 6 Atomic Industrial Forum Policy Committee on Nuclear 7 Regulation.
8 It is Byron's cosmittee and a companion 9 committee of the Edison Electric Institute that began to the initiative leading to this appearance today.
11 On my immediate right is Admiral Eugene P.
12 Wilkinson, better known as Dennis Wilkinson, who is 13 President of the Institute of Nuclear Power Operations.
14 On my far lef t is Lelan Sillin, Chief 15 Executive Of fice and Chairman of Northeast Utilities and 16 a member of the board of directors of INPO.
17 On my immediate left is Hugh Parris, G'eneral 18 Manager for Power of the Tennessee Valley Authority and 19 also a member of the board of directors of INPO.
20 As background to the initiatives we want to 21 describe it might be well to track very briefly the 22 history of the development of quality assurance.
23 We vill have slides that will have key phrases 24 and I believe the Commission has a copy of these key 25 phrases.
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(Slide presentation.)
2 First of all, the Commission established broad 3 and general quality assurance criteria known as the 18 4 criteria in 10 CFR 50.
Throughout the land various 5 members of t industry took various approaches to the 6 implementation of those 18 criteria.
7 In1 the interis NBC requirements have changed 8 extensively.
Industry and standards groups developed 9 expandin7 requirements much amplifying the 18 criteria, 10 including standards and daughter standards and even 11 granddaughter standard s.
The control of quality and 12 construction and design was complicated by those 13 changing requirements.
14 There is now a need go ensure that the 15 programs in effect nationwide meet the performance goals 16 as intended.
Several recent events in nuclear power 17 plant construction stimulated this industry initiative 18 and action.
19 An industry group met on December 17, 1981, 20 under Joint Atomic Industrial Forum and Edison Electric 21 Institute auspices to formulate plans to address the 22 need.
Byron Lee chaired the AIF group that started that l
23 meeting.
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24 A second meeting of that group now enlarged 25 was held on January 5 this year with representatives l
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1 from the Atomic Industral Forum, the Edison Electric 2 Institute, the American Public Power Association and 3 INPO, the Institute of Nuclear Power Operations, to 4 develop a proposed industry approach.
5 Follow-on industry meetings were held with the 6 INPO board of directors, with the Utility Nuclear Power 7 Oversight Committee renamed from the Three Mile Island 8 Oversight Committee that you may remember, and with 9 CE0 's of utilities f rom across the nation that were 10 meeting in Scottsdale, Arisona, two weeks ago.
11 As a result of those follow-on meetings a very 12 strong industry support of this initiative we are going 13 to describe has been marshalled.
14 We are here today largely representing INPO.
15 The industry has come to INPO to seek INPO's help in 16 implementing this inititive.
The requests vent out to 17 industry CE0's of the 33 nuclear utilities that now nave 18 nuclear power plants under construction.
19 The request asked will you support this 20 industry initiative and will you doin in asking INPO to 21 undertake its management.
The ansvers have been 22 received from 33 out of 33 CE0 '~s.
To a man the answer l
l 23 is unanimous.
Those 33 companies or government agencies 24 have requested INPO to undertake the program you are 25 about to see.
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1 COHNISSIONER GILINSKI Co uld I j ust ask you, 2 is this program directed to construction and is that why 3 rou limited your letter to the 33 companies that. vere 4 involved with construction programs?
5 HR. W. S.
(Bill) LEE:
Mr. Commissioner, every 6 utility, public, private or cooperatively owned, is a 7 member of INPO.
Up until this point in time INPO's 8 activities have been focused on operations.
This will 9 he a much enlarged scope for TMPO, what we are 10 presenting today.
Up to ne. Je have talked about 11 operations and getting ready for operations.
12 We appeared before you two-plus years ago to 13 describe INPO as it was then visualized and established 14 in late 1979.
The mission of INPO is to promote safety 15 in nuclear power plant operations, a lesson learned from 16 TMI.
INPO is a nonprofit independent organization.
It 17 has about 250 employees.
18 Membership, as I said, includes every United 19 States utility with an operating license, construction 20 permit or limited work authorization for any type of 21 nuclear plant and regardless of ownership.
22 Two workshops have been held at INPO for chief l
23 executive officers of all of'its members.
The first wa s 24 Hanaging For Safety.
The late Pat Haggarty opened that 25 workshop and made clear that each CEO realize two l
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22, you are in the boat with every other company that has 3 a nuclear plant and therefore you have an interest in 4 the success of every other one.
5 That uorkshop was closed by Irving Shapiro who 6 was then Chairman of dup 6nt who described how from his 7 perspective a CEO manages for safety and in that case l
8 achi'sves the preeminent industrial safety record in the 9 United States.
10 The second workship was held this last 11 September.
We had hoped to have one of you at that 12 workshop but your schedule would not persit.
But we'did 13 have former Commissioner Joe Hendrie.
Its title was 14 Initiatives For Safety, which is what initiatives can j
15 the CEO and muut the CEO take to assure safety in his l
16 company.
17 We have for you the proceedings of both of l
18 those workshops and we will leave them with your staff 19 so that you can find out everything that was said by all 20 of the participants.
l 21 de also at this point would invite'each of the 22 five Commissioners to participate in the next workship 23 of all nuclear CE0 's.
The date has not been established 24 b ut we want to go on record as saying that we would like i
25 you to attend and to participate.
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1 I believe these two workshops have been very 2 successful in clearly getting the attention of the CE0's 3 and equipping them with the tools that they must have in 4 order to both manage and show initiative 'or safety.
5 In addition, in INPO's history be have had 6 free workshops for all plant managers and a host of 7 other workshops where we attempt to bring the whole 8 nation up to the benchmarks of excellence which is the l
9 purpose for which IEPO was founded.
10 Now in responding to industry's stated need 11 for operational safety INPO developed criteria for plant 12 evaluations.
Let me pause here to explain the word 13 " evaluation" as we see it.
14 It is a great deal more than an audit.
As we 15 look at an audit it tends to be a check of the paper 18 tray.
An evaluation includes some audit functions and l
17 details where problem areas are found.
But evaluation 18 includes evaluating the performance of all aspects that 19 can be seasured of the plant and in assisting the 20 utility, transferring technology and management systems t
I 21 and procedural systems in the areas were the utility is 22 not as strong as a sister utility somewhere.
This is 23 both evaluation and uplifting or upgrading of specific 24 recommendations on how to achieve a higher level of 25 excellence.
ALDERSON REPORTING COMPANY,INC,
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So critaria for those evaluations were 2 developed and by year end just past INPO has completed 3 the evaluation of every operating power plant in the 4 country.
5 Beginning this year we have sta,rted assistance
& visits to plants approaching their initial fuel loading 7 and start-up,' the near-term OL type plants, where we are 8 trying to transfer to those plants the envelope of 9 excellence that has been developed in the criteria f rom 10 having evaluated all operating plants.
11 In addition, INPO has developed evalution 12 criteria for corporate evaluations.
What about the 13 management of the company and the interf ace and support 14 with the plant.
Those criteria are now in use by each 15 utility in a self-evaluation that will be reported to 16 INPO following which INPO will begin the evaluation 17 process on the criteria that may have been adjusted by 18 the feedback.
19-INPO has identified and analyzed and 20 connunicated information on significant events in a near 21 real-term situation through the Significant Event 22 Evaluation and Information Network nicknamed SEEIN.
23 INPO has initiated review and assistance 24 visits to aid utilities in emergency planning efforts.
25 It has coordinated transportation and fixed ALDERSON REPORTING COMPANY,INC,
o 11 1 f acility agreements to provide f or the assistance in the 2 event of an emergency in the transportation arena.
3 It has developad qualifications and training 4 guidelines for operations and support personnel, the E first of which was the qualifications and training 6 guidelines for the shift technical adviser when that 7 position was first invented.
8 It now has underway a broad job and task 9 analysis that will lead to a feedback and re-review of 10 the qualification and training guidelines for all posts 11 in nuclear plants.
12 It has surveyed the needs and developed a 13 manpower plan for the future of the nuclear utility l
14 industry.
If there are shortages in certain categories 15 on an action plan they will know what to do about it.
16 In all of these programs in the history of 17 INPO there has been close coordination and communication 18 with the NRC.
INPO thinks this coordination and l
19 communication has been constructive, NBC has 20 participated and witnessed some of the evaluations and 21 ve feel we are open with the Commission staff.and we 22 encourage them to give us guidance and we in turn hope 23 that we have been constructive in their programs.
24 We are confident that the track record of 25 coordination and cooperation can be carried forward into l
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12 1 now the quality assurance area.
2 To briefly describe the program which we have 3 called the " Nuclear Plant Construction Quality 4 Evaluation Prograa," it will be under the direction of 5 INPO.
The evaluations will assess individual utility 6 programs based upon best practices.
7 Again,these are not minimum thresholds for 8 saf ety.
These are best practicese and will assist 9 utilities in achieving a consistent level of excellence 10 and building quality into the nuclear plants.
The INPO 11 board of directors will provide policy direction and 12 guidance for the program.
13 The evaluation criteria to be used in this 14 program will be developed under INPO 's management.
An 15 ad hoc review group composed of senior utility managers 16 vill provide oversight to the development of those 17 criteria.
These criteria are to be of course used in 18 the evaluation process.
1 19 When they are completed utilities will 20 initiate the evaluations using those criteria as a basis l
l 21 and will report the results to INPO.
We vill get a 1
22 quick reading of plant status and of problems found and 23 be able to communicate again industry-wide in an effort 24 to uplif t and assist problems that are found anywhere.
25 Now following completion of the utility l
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13 1 initial evaluations the industry and INPO vill then 2 assess the effort and formulate detailed plans for an 3 ongoing evaluation program of all plants.
To describe both Phase I and Phase II of this 5 effort and how we are gaing to implement it I want to
'a call on Dennis Wilkinson but first with a worde 7
Re came aboard INPO two fears and three days 8 ago after a distinguished career serving our nation.
He 9 assembled and tesined the first nuclear crew for the 10 land-based' prototype.
He was the first skipper of the 11 N AUTI1US.. He proceeded to become Deputy Chief of Naval 12 Operations in charge of all submarine warfare.
We were 13 very fortunate to get him at INPO two years and three 14 days ago.
15 He has personally participated in the 16 evaluation of every nuclear plant that is in operation.
17 He has been from the pump room to the control room to 18 the executive rooo of every operating power plant.
I do 19 not know of any other person living who has even visited 20 every opere. ting power plant.
But Dennis personally was 21 there to participate with the large INPO team'in the 22 evaluation of every one.
23 We have now started the second cycle and I 24 hope for his health 's sake he won't keep up this pace, 25 but that is the sort of commitment we have in the l
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2 ADMIRAL WI1KINSON:
Mr. Chairman, gentlemen, I
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3 as pleased to be here.
I will discuss the plan of
& implementation for the program Mr. Lee has described.
5 First, and the most important thing, is to 8 develop the criteria by which we vill operate.
We 7 expect to form a criteria development group by the 1st 8 of March.
l 9
I would like to emphasize that professionals 10 in that group are mandatory.
We do not at INPO have 11 enough people or all the disciplines.
However, we have 12 already started acquiring such personnel.
I think that 13 the commitment we have received from industry where tne 14 expertise is to provide those professionals is most 15 important.
We will augment our personnel and the 18 personnel from industry with the hires of consultants 17 with managment evaluation expertise.
18 As you can see from the slide, our plan is to l
19 develop the first draf t criteria by the 15th of April.
20 That is a very tight schedule, but I have some 21 confidence that we can meet that schedule because INPC 22 has over the last two years developed some experience in 23 developing criteria.
l 24 We have already started developing th e 25 criteria for this plan.
We are tapping the experience i
ALDERSoN REPORTING CCMPANY,INC, j
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15 1 of utilities that have plans in being at the present 2 time and utilities that are doing it in different ways, 3 whether they control their design and construction 4 in-house or whether they control it through the use of 5 A/E's or contractors.
8 He also will tap the criteria chat NRC has 7 developed and is using, and we will have a group of 8 experienced professionals with expertise in all the 9 disciplines involved.. I believe we will have our first 10 strawman criteria out by that date of the 15th of April.
11 As for the pilots, we will choose different 12 utilities on which to do the pilots, some with problems, 13 some that we think are doing it fairly we'll at the j
14 present time and utilities that are doing it in i
15 different ways, whether it is all in-house or whether 16 A/E's and contractors are used.
17 Af ter the pilot evaluations we will revise and 18 define the criteria and we will coordinate many inputs, 19 the comments f rom the industry, comments from the NBC 20 and a review by an ad hoc experienced industry group.
I 21 think that review by some experienced management in the 22 industry will be most important.
23 May I have the next slide, please.
24 CEAIRMAN PALLADIN04 Will NRC be involved in 25 these criteria other than to comment ?
i ALDERSON REPORTING COMPANY,INC,
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ADMIRAL WILKINSON:
As I say, I have already 2 made contact at the working level with NRC and have had 3 some information on what you are presently using and we 4 expect to interact with the working people at NRC as we 5 go along as I will discuss in a little more detail later.
6 I hope to publish criteria then that have been 7 reviewed and then check the pilot evaluations by the 1st 8 of September.
I think at that point we will find that 9 that criteria vill be of value to all utilities to which to it will be distributed and to the NBC.
11 But the possession of criteria for evaluations 12 is not enough..
You must be able to use those criteria a
13 and the people must be experienced in doing evalutions.
14 So when we have those criteria ve expect to assemble 15 workshops of personnel from all the utilities involved.
16 COMMISSIONER GILINSKYa Could I just ask you, l
17 this is strictly focused on construction; is that right?
18 ADMIRAL WILKINSON: That is correct.
l 19 COMMISSIONER GILINSKY:
I didn't fully 20 understand Mr. Lee's answer.
2t MR. W. S.
(Bill) LEE Design.
22 COMMISSIONEB GILINSKY:
Well, pre-operation at 23 any rate.
24 MR. W. S.
(Bill) LEE:
Yes, and as you will 25 hear in a minute that is going to round out the whole l
ALDERSON REPORTING COMPANY,INC,
17 1 thing so that we will be talking about the whole life 2 cycle of a plant.
3 ADHIBAL WILKINSON4 I am going to try to tie it 4 in to the whole lif e cycle later, sir.
5 To use these criteria ve are going to develop 6 guidelines for use, hold workshops showing the utilities 7 how to use 'that criteria and train our own eve.luation 8 teams.
9 Then after those workshops we expect the 10 utilities, all utilities involved, to initiate a 11 self-evaluation.
Whether ther do it with an independent 12 group in-house or whether they contract it out, we would 13 hope that all utilities can have had a look by the end 14 of this calendar year.
15 I think as the program is laid out that is a 16 significant advantage because it lets all utilities 17 involved, all plants involved have a quick look by 18 year's end.
It lets the utility management involved 19 with these criteria get a quick look.
20 The response that we have had, and Mr. Lee 21 said 33 out of 33 utilities, the response of the CE0 's 22 to this proposal shows their real interest in having 23 such a look and taking any action that should be 24 required.
25 COMMISSIONER AHEARNE:
Admiral, could I ask ALDERSON REPCRTING COMAANY,INC,
18 1 what was the reason that led you to this approach which 2 is a self-evaluation as opposed to the approach you have 3 been taking with respect to the operating plants which 4 is an INPO evaluation?
5 ADRIRAL WILKINSON:
As I will discuss la ter, 6 ve plan to continue with an INPO evaluation, but we 7 couldn't look at everybody at once.
It would take a 8 considerable time to get through them all.
9 COHNISSIONER AHEARNE Of course.
10 ADHIRAL WILKINSON:
So if everyone takes a 11 self look and we follow that up with a continuing 12 program we will have had some look at them all in the 13 quickest possible way.
14 COMMISSIONER AHEARNE:
Wouldn't that same 15 logic though apply to the evaluation of operating plants 16 which you are currently doing?
17 ADMIRAL WILKINSON:
If we had had our criteria 18 and our methodology developed before we started back in l
19 the beginning th at would have been advantageous and, as l
20 I will discuss later, we are going to use that same 21 simultaneous look system for all utilities to look at 22 corporate.
But in the beginning we didn't have the 23 criteria developed to put out and ask all utilities to 24 d o tha t.
25 When the utilities report by year's end INPO ALDERSoN REPCRTING COMPANY,INC,
19 1 vill assess those reports f rom all utilities and if ther 2 are not, in our opinion, thorough, we vill go back to 3 any utility that that might be the case and ask them to 4 do better by looking f urther in some n.:ea.
5 We vill assess the trends of information that 6 ve acquire f rom those simultaneous looks.
We vill 7 review and revise our criteria, as that indicates, and 8 ve vill follow up where indicated to see that corrective 9 or responsive action is taken as may be indicated.
10 May I have the next slide, please.
11 COHNISSIONER GILINSKI Could I just ask you 12 something, or would you rather I waited until the end of 13 rour presentation?
14 ADMIRAL WI1KINSON:
No, sir.
15 COHHISSIONER GILINSKI:
You are dealing with i
18 many plants that are in various stages of design and 17 construction and the problems and what you can do about 18 them obviously differ.
How is that taken into account 19 in your process?
20 ADHIBAL WIlKINSON:
Unfortunately for INPO, we l
21 are coming in the middle of an ongoing program and it l
l 22 would have been nice if this had been started for 1
23 everybody back in the beginning but such as not the 24 case.
So we are going to try, as I said, to have a 25 quick look at everyone, as I described, and then start l
ALDERSON REPORTING COMPANY..NC,
20 1 evaluations with a prioritization dependent on different 2 utilities' situations, whether they have built a plant 3 bef ore or not, whether they all use the same A/E or not, 4 the percentage of construction and what-not.
5 But I would expect that in that' prioritization 6 ve would probably concentrate on people up to about 80 7 percent completed first and not try to go back to the 8 plant that is almost finished.
9 Does that answer your question?
10 COHNISSIONER GILINSKY:
Well, yes.
11 ADHIRAL WILKINSON:
Eventually as the program 12 develops it will really look at the whole life cycle' 13 f rom design, design control, construction, start-up and 14 eventually operation.
15 COMMISSIONER GILINSKY:
As a practical matter 16 I think what you are saying is you really are not going 17 to do a great deal with the plants that are due to be 18 completed this year or maybe next year.
19 ADHIHAL WIlKINSONs That is correct from INPO 20 managed evaluations because you can't start every one at 21 once.
But every one of those plants will have this own 22 look by the end of this year.
23 CHAIBHAN PALLADINO:
You are including the 24 near-term operating license applicants in your year-end 25 target?
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ADMIRAL WILKINSON:
Yes, sir.
2 MR. W.
S.
(Bill) LEE:
Parenthetical 1r a 3 utility's self-evaluation means that it is initiated and 4 managed or triggered by the utility.
The utility in 5 some cases may elect to have someone else do it for then 6 or the utility may have an independent group within the 1
7 utility do it.
So it can be done either way.
8 CHAIRHAN PALLADINO:
Yes, I want to come back 9 later and explore your thoughts on that.
10 ADMIRAL WILKINSON:
Let me repeat again that 11 we, INPO, are going to get copies of ali of those, look 12 at them, assess them and if additional effort is needed 13 get back to the utility and follow up, as I described, 14 with a review and revision of our criteria and a 15 follow-up on any items that appear to need action.
l 16 CHAIRNAN PALLADINO:
Will there be interaction 17 a t that stage or somewhere along the line with NBC?
18 ADMIRAL WILKINSON :
Yes, sir, and let me talk 19 to that later.
1 1
20 CHAIRMAN PALLADINO:
Go ahead.
21 ADMIRAL WILKINSONs That then at year end vill 22 complete Phase I, the criteria, the pilot look and the 23 self-evaluations, and where do we go from there.
24 Well, a program of what you are going to do 25 for years and years needs to be developed and modified l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
22 1 based on experience.
At the end of Phase I ve will 2 re-evaluate and see where we are, see what we have 3 learned and see what we need to do.
l But in advance at the end of Phase I for Phase 4
5 II let me discuss some possible alternatives.
l 6
We can continue with a continuing program of
'7 INPO evaluations similar and integrated in with thos'e we l
8 do on operating plants.
In those evaluations we would l
9 use INPO permanent personnel augmented still with loan 10 personnel from the industry with expertise in the areas 11 we are looking at and hire consultants.
Let me 12 emphasize those would be INPO evaluations similar to 13 those we do for operating and NTOL plants.
The 14 advantage of that would be a uniformity in what we do.
15 As an alternate you could have utilities do 18 their own, whether they do it with an in-house 17 independent group or whether they do it with a third 18 party.
Or we would have some modification of those two 19 alternatives with some by utilities and some done by 20 INPO.
But in any case INPO should review them all.to 21 see that they are done adequately, should identify 22 trends and any modification in the program that is 23 required and should do follow-up on any corrective 24 action indicated and needed.
25 I believe where we go from Phase II should be ALDERSoN REPORTING COMPANY,INC,
$9 MIIIDR$ R@g @lt2 t]GHINGWN, @),@. 20024 G202k554-2345 9
23 1 worked out at that time dependiag on our experience up 2 to that time.
3 COMBISSIONEB AHEARNE Admiral, could I ask 4 rou, are you also beginning to consider as an 5 alternative to take the current operational evaluation 6 program and perhaps make that also a utility initiated 7 evaluation?
8 ADMIRAL WIlKINSON:
No, sir.
We plan to 9 continue that.-
I can say that is our direction from our i
10 board of directors.
We plan to continue that as it is 11 now being done, except that I believe we are getting 12 better and that our evaluations will become more l
13 eff ective as time goes on.
I 14 In our present evaluations we require the 15 utility to commit to corrective action when that is l
l 16 shown to be nr.ce ssa ry, and we require them to commit to 17 corrective action on a time schedule.
We get a 18 follow-up from the utility in the form of a written 19 report and we check on that corrective action in our 20 next evaluation cycle.
21 The utilities have been very responsive in 22 taking corective action.
Our board of directors has 23 laid out a program of coercive action if such were not 24 the case, but in f act in all of our evaluations to date 25 we have found a very responsive attitude when the need ALDERSoN REcoRTING COMPANY,INC,
24 1 for corrective action was indicated.
2 COMMISSIONER GILINSKYa Can I ask you, what is 3 it that would be evaluated?
We are kind of talking to a 4 level of generality and I wonder if we could pierce for 5 a acaent.
For example, is it a matter of checking 6 compliance with our Appendix, or is that too narrow a 7 way of looking at it?
8 ADMIRAL WILKINSON:
That is too narrow a way 9 of looking at it.
In our evaluations we do not look to just at the law in the safety-related items.
We really 11 look at the entire plant.
We have now completed our 12 first evaluation of all the plants and I had some 13 involvement in all of them and you might be interested 14 in some of my impressions in what I have found.
15 COMMISSIONER GILINSKY:
Sure.
16 ADMIRAL WILKINSONs But if I could talk to 17 tha t separate from this program, if you are interested.
18 COMMISSIONER AHEARNE:
Very much.
19 COMMISSIONER GILINSKY:
If I could just back 20 to this, those are the standard regulations.
Now if 21 they are insuf ficient or wrongly directed ---
22 COMMISSIONER AHEARNE:
I think what you are 23 just asking the Admiral is could they recommend 24 additional regulations.
25 (Laughter.)
ALDERSON REPORTING COMPANY,INC, murv;mm_mm_ cm - rm m m;n erwervn
a 25 1
COMMISSIONER GILINSKYa No, I don't think so.
2 ADMIRAL WILKINSON:
Sir, are you talking about 3 our general operational evaluations or are you talking 4 about the various disciplines we would look at here?
5 CHAIRMAN PALLADIN0s Perhaps if we could have 6 an example or two of the kind of things you might look 7 into it would help.
8 ADEIRAL WILKINSONs We would need to get 9 expertise to help us develop the criteria which we are 10 in the process of doing and we will look at such areas 11 as management involvement and concitment, project 12 control and planning, design control, procurement 13 control, construction control, both mechanical and 14 electrical, conformance of the project activities to l
15 regulatory requirements, problem identification, action 18 tracking, quality assurance and those kinds of 17 breakdowns in the overall problem of proper design, 18 control and construction of a plant.
19 COMMISSIONER GILINSKYs Let me ask you this.
20 Does Appendix B tocether with whatever staf f guidance 21 has gone with it, is that a sound and good program that i
22 would lead to a well built plant if carried out the way 23 it was intended?
l 24 ADMIRAL WILKINSON:
The 18 requirements in 25 tha t guidance are in rather general terms and I believe i
1 ALDERSoN REPORTING COMPANY. INC,
l 26 1 that the criteria are required to amplify those and get 2 the results that the NRC would. like to have.
3 COMMISSIONER GILINSKY Has our guidance been 4 insufficient or poor?
5 MR. BYRON LEE:
I think the whole industry hs 8 been learning, as Bill said originally, that the 7 Appendix B is general.
I think we believe it covers all 8 of the things that need to be in a general ters.
The 9 industry has gone off since they came out over the years to and developed varieties of programs to try to comply 11 with those criteria.
12 COHMISSIONER GILINSKY:
I as trying to 13 understand whether you are trying to put more detail on 14 that or going off in a different direction?
15 ER. BYRON LEE:
I guess the answer to your 16 question is that it is trying to be responsive to all of 17 those, but there is some detail that needs to be looked 18 at within those areas and within the existing programs.
19 I think we are saying we came to the 20 conclusion that the industry in total has pretty well 21 developed good programs from experience over the years 22 and from learning curves as such.
23 Again, like the original concern with INPO, 24 they haven't been uniformly applied for a whole variety 25 of reasons in spite of the standards eff orts, the codes ALDERSON REPORTING COMPANY,INC,
/v.~a Mrrivmv\\NTL am_ t~rGTrf6ir6m f6uel K.wn ag4FRmFEvva
27 1 effects, the NBC's erf octs and the industry 's efforts.
2 They are not in uniformity.
3 Somebody asked a question about the difference 4 between this and the operating side of the house.
I 5 think because of Appendix B and some of the guidance 6 that has evolved from it we are in a better position and 7 quicker to develop the criteria than we were on the 8 operating side of the house.
9 There was a lot of education and there were a 10 lot of unknowns there and that took a longer time.
11 Dennis, I think, has done a remarkable job in the short 12 period of time he has had to develop this.
13 CONHISSIONER GILINSKYa We ultimately look for 14 compliance with our regulations.
Now if our regulations 15 aren 't the righ t regulations, then I want to change them.
16 MR. BYRON LEE:
We don't want anything more 17 specific.
18 (Laughter.)
19 MR. W. S. (Bill) LEE:
INPO has the freedom to 20 go much further than you do.
You have to establish 21 certain minimum thresholds for licenses and for saf ety.
22 INPO can get into the areas that don't have anything to 23 do with the nuclear side of the plant.
For example, 24 something that night be symptomatic of lack of 25 management systems and management controls on the ALDERSoN REPORTING COMPANY,INC,
28 1 turbine side of the plant.
INPO has that freedom and 2 has actually done that in operating plants and CE0's and 3 other management have expressed gratitude for INPO doing 4 that.
If you stepped over on that side of the plant 5 they would call for a lawyer.
6 (Laughter.)
T NR. W. S.
(Bill) LES:
So Appendix B is simply 8 one of the elements that INPO vill. have the freedom to 9 look at.
10 COHRISSIONER GIIINSKY:
Taken, you know, 11 within its confines do you regard it as a pretty sound 12 guide to quality assurance?
13 HR. W. S.
(Bill) LEE:
Yes.
I think it is l
14 sort of like the.18 commandments.
15 (Laughter.)
16 HR.W.S. (Bill) LEEa There are a whole lot 17 of other documents that follow from those 18.
They are 18 very broad and they are very comprehensive and I know of 1
l 19 nothing that I would do to broaden them.
20 (Laughter.)
21 ADMIRAL WILKINSON:
If,I can say, those are 22 very general statements, those 18 criteria.
If I were a 23 utility and you required me to do a third-party check of 24 my performance against those criteria, I could not hand 25 those criteria to my contract people and say write me a ALDERSON REPORTING COMPANY,INC,
29 1 contract to get an independent firm to come and look at 2 those things.
You would need more specificity in what 3 you needed to do.
It is such criteria that I am talking
& about that would amplif y how you would check compliance 5 with those 18 general requirements.
6 COMMISSIONER GILINSKYs Of course, that is 7 elaborated to a certain extent in applying the 8 regulations to a number of cases.
9 But let me ask you this.
Since we are talking 10 about a solution here, you know, what I sense is the 11 question to which this is the answer.
Is the problem 12 that some of the utilities had that they didn't 13 understand what it is we wanted or was our guidance not 14 sufficient 1r specific, as you suggested, or are items 15 lacking, or whatever else?
16 ADMIRAL WILKINSON:
If I can talk to that.
17 There are many different utilities and one way they are l
18 the same is how much they are different.
19 COMMISSIONER GILINSKI:
I recognize that.
20 MB. W. S.
(Bill) LEE:
Different utilities 21 interpret and implement and keep reccrds in different 22 vays.
There isn't as auch uniformity as I believe you
~
23 vould like tc see.
24 COMMISSIONER BOBERTS Well that also applies 25 to the architect / engineers and the equipment l
ALDERSoN REPORTING COMPANY,8NC,
30 1 manufacturers.
Ihat is not true just of the utilities.
2 COMMISSIONER GILINSKY:
It sounds like we 3 haven't overseen the process as carefully or as 4 consistently as we might have.
5 CHAIRNAN PALLADIN04 I don't feel that we have 6-tried to define every aspect of the QA problem.
We set 7 the general characterists and there are a lot of ways to 8 implement those and a lot of ways to carry them out or 9 expand or modify them.
10 I do think there is room f or additional 11 specificitT,. quite a bit of room, and there is a lot of 12 difference in the way people carry them out.
13 To me I was thinking as you were talking it is 14 like to trying to get an instruction book on how to fly 15 and then without ever having anybody show you how to fly 16 you go up and try to do it and you may do it well or you 17 may do it not so well the first time.
But after people 18 have learned how to fly then it is appropriate to take 19 advantage of what additional inf ormation they have.
20 ADMIRAL WILKINSON:
Mr. Chairman, I couldn't 21 agree with you more, and you can't do it just with a 22 cookbook check-off list.
You have got to be able to 23 check and see if the functional requirements are 24 performed.
25 CHAIRMAN PALLADIN0s I thought that maybe i
ALDERSoN REPORTING COMPANY,INC.
31 1 Commissioner Gilinsky was looking for examples of how it 2 could be applied in one area where you would get in.
3 Maybe you want to come back to that.
4 COMNISSIONER GILINSKY:
Just on the point you 5 were making, it does seen as if INPO is trying to 6 ',ntroduce the unformity which ve, for whatever reason, 7 didn't manage to introduce.
8 ADMIRAL WILKINSON:
As I said earlier, I 9 believe that these criteria will be of value to all 10 utilities to look at themselves.
To some it will be of 11 more value to them than others.
I believe it will also 12 be of value to the Commission in analyzing that look.
13 COHHISSIONER AHEARNE:
I would like to ask the i
14 other Hr. Lee a question since you have been identified 15 as being the chairman of the two subcommittes that were 18 identified ---
17 NR. BYRON LEE:
One of the committees and I am 18 on the other one.
19 COMMISSIONER AHEARNE:
--- as an initiator of 20 this.
Let me follow up on a question that Commissioner I
21 Gilinsky just asked.
1 1
22 I am getting increasingly curious as to what 23 was or vera the questions to which this is the answer?
24 Here you concerned that the NRC was going to come down 25 harder in QC and with more regulations, or were you i
ALDERSoN REPORTING COMPANY,INC,
8 a
32 l
1 concerned that there problems in the construction in the 2 industry and that as responsible to industry groups you 3.were turning to those problems?
4 NH. BYRON LEE:
Well I think that we 5 recognized again, as I said, that these programs have 8 developed into some very detailed programs which I don't 7 think requires the.NRC to have that kind of detailed 8 regulations or requirements.
In fact, I think it would 9 restrict people's activities.
But I don't think ther 10 were being uniformly applied.
11 I think that obviously there was some concern 12 on the part of people within the industry that there was 13 going to be a response that wouldn't be as good as we 14 think we can establish ourselves because of our 15 experience and all the efforts that we have developed 16 over the years.
i 17 We have learned there wasn't any Solomon ten 18 years ago or six years ago that knew all the ansvers I 19 don't think in this area and we talked to the N ASA 1
l 20 people and all varieties of people over the years.
21 Everything we were doing seemed to be in conformance 22 with their kinds of programs.
There obviously were some 23 details that could have been done better than they have 24 been done.
We feel that by getting these people 25 together we can develop some criteria that will look ALDERSON REPORTING COMPANY,INC,
33 1 into the general program.
2 The first concern that everybody has is are we 3 just going to have another audit.
That seemed to be the 4 key that we vill have another audit.
I think 5 everybody's immediate reaction is that we have got more 6 audits than we can handle already and that is not the 7 secret to the problem.
The real concern is are the 8 prograss that are being used, that are being audited 9 against complete in a sense, can they be better and can 10 we fill in a few holes.
11 We learned something f our years ago that we 12 are now doing that maybe somebody else hadn 't learned 13 four years and we can transfer that, or somebody else 14 has learned something and we pick up.
I think that is 15 what we are saying.
We think that through this 16 mechanism we can transfer those good ideas much faster 17 than it can be done any other way.
18 CHAIRMAN PAL 1ADIN0s Perhaps we ought to go on 19 and I am sure we will have a lot more questions.
20 ADMIBAL WIIKINSON4 If I can talk to the life i
21 cycle aspect, we have started with periodic operational 22 evaluations, first.
We have started this year on 23 assistance visits to near-term operating plants prior to 24 f uel load.
We have started assistance visits and 25 emergency preparedness.
We will do special evaluations ALDERSON REPORTING COMPANY,INC,
34 1 if there is some triggering event at some specific 2 utility that indicates the need.
3 Then if we add to all that an evaluation 4 system to look at quality of construction you really are 5 looking at plants through the whole life cycle.
8 Mar I see the next slide, plaase.
7 There were several questions as we went along 8 that related to coordination with the NBC.
In the 9 criteria development we already have some information on 10 the criteria the NBC is using.
We would expect to have 11 NRC review our strawman inputs.
I would hope to get NRC 12 to brief us on their experience in construction review 13 and any lessons that would be applicable to these 14 criteria.
15 I think that the INPO program and the NRC 16 program should be meshed together.
Really together we 17 will learn the right things to check and the best way to 18 do it.
NBC has regulatory responsibility, but what ther 19 and the industry to should mesh and compliment each 20 other and should not be d uplica tive.
So I would hope 2tthat as we went along NRC would review the entire 22 process.
23 We would like to periodically brief the NBC.
24 I am not talking to you, gentlemen, but I mean at the 25 working level.
ALDERSoN REPORTING CCMPANY,INC,
35 1
COMMISSIONER GILINSKY We work, too.
2
( la ugh ta r. )
3 ADMIRAL WILKINSONt Excuse me, I meant the 4 staff levels.
I would like to volunteer for NRC staff 5 members to accompany us on some of these evaluations.
6 When we get to the decision on Phase II, again I would 7 like to have NBC staff people to help us to develop that 8 so it will be meshed together with their program.
9 At that Phase II point then I would suggest 10 tha t we come back and brief you gentlemen again at that 11 time as to where we stand.
12 MR. W. S.
(Bill) 1EEs In summary, gentlemen, 13 ve are planning to initiate a program that meets our 14 understanding of the full meaning of independent.
We 15 propose to do this and would urge that it not be a 16 redundant program o'r it will collapse.
17 Finally, we are committed to develop a strong l
18 and meaningful program to improve the quality of design,
19 quality assurance, construction and start-up testing.
20 thus adding to INPO's very good track record and its 21 contribution to operating plants and thus add even 22 greater margin to the public health and safety.
23 CHAIRMAN PALLADINO:
I wonder if I can take 24 advantage of your thinking on how we can dovetail our 25 activities because it is very easy for these to become ALDERSON REPCRTING COMPANY,INC,
36 1 duplicative processes and actually perhaps even 2 competing processes.
3 The NBC still hr.s a responsibility for 4 assuring that its role is fulfilled.
Yet if we possibly 5 can maybe we would like to take advantage of some of the 6 activities that you are doing.
I am sure you must have 7 thought a little more on how we could dovetail these 8 activities or take advantage of each other's work.
I 9 don 't yet have a feel for how that might be done.
10 For example, you might find things out.
- Well, 11 rour purpose may be better served by not letting anybody 12 know and our purposes might be better served by 13 knowing.
So there are going to be little questions that 14 come up even on the dovetailing.
Or you nar be 15 concerned that if we knew that we going to do something 16 horrible as a result of it.
i 17 How do you envision those things working?
l 18 ADMIRAL WI1KINSON:
In that meshing together 19 or dovetailing relating to this problem I am not aware l
20 of all the things that the staff is planning.
11 I can only go back to our experience over two 22 years in other areas.
Really by constant interactions
- 23. with the NBC staff we are a ttaining a meshing together 24 of some of our other programs, as for example, event 25 analyses are operational evaluations themselves.
l t
ALDERSoN REPORTING COMPANY,INC.
37 1
I think that you can't say in advance that you 2 will dovetail this way because we must mesh to your 3 staff requirements, but I really believe that it ought 4 to be worked out so that we are not duplicative and so 5 that the government, if you will,. has the benefit of 6 industrT's effort to improve themself.
After all, we 7 all have a common purpose.
8 CHAIBHAN PALLADIN0s Tom.
9 CONHISSIONER ROBERTS:
Based on your 10 experience to date where you emphasis has been on the 11 operating plant do you feel that INPO's efforts have 12 been redundant or have INPO's efforts and NRC's efforts 13 been complementary?
14 ADMIRAL WILKINSON:
I would have to answer l
15 that by looking at the calendar.
In the beginning ther 16 were more duplicative and redundant.
I think over the 17 last two years they have evolved into being more l
l 18 complementary.
l 19 I at the staff level get great cooperation in 20 us both not going to a utility at the same time and 1
21 scheduling and what-not.
I believe that we are in the 22 process of NRC saking more use of our efforts to l
23 complement theirs.
24 MR. W.
S.
(Bill) LEES Mr. Commissioner, 25 almost two years INPO was a new kid on the block and it
/
ALDERSON REPORTING COMPANY,INC,
38 1 han to prove itself.
Of course, initially the programs 2 were redundant and duplicative.
I believe now they are 3 better meshed in the operating area and I believe that 4 progress in that shift of six is the proper one.
5 CONHISSIONER ROBERTS:
Then are you saying 6 that having been in existence and demonstrated one area 7 of operation you think it might be likely that there 8 could be not this redundant effort?
9 I think I understood very well your second 10 point, that if these things were redundant your program 11 was going to collapse.
I think that was in pretty clear 12 English.
13 ER. W. S.
(Bill) 1EEs Yes, sir.
14 ADHIRAL WI1XINSON:
I could give you many 15 examples.
16 COBEISSIONER AHEARNE4 I thought it was very 17 clear but let me just make sure I understood it.
My 18 interpretation of that is is that you were saying that l
19 if we on the NRC side were to initiate some kind of 20 broad review of all plants' QC programs that you 21 conclude that this effort you are undertaking could i
22 collapse?
,?3 HR. W. S.
(Bill) LEE:
Yes.
i 24 MR. BYRON LEE:
Yes, because some of the 25 people that will be u.ying to respond to your program it t
ALDERSoN REPORTING CCMPANY,INC, t
39 1 will also be necessary for them to respond to this 2 program.
3 CHAIBMAN PALLADIN0s Well I can see some areas a where we would not necessarily have to do something or 5 cooporate, for example.
You spoke about workshops with 6 the chief executive officers.
That was something that 7 our staff has talked about and considered.
That kind of 8 thing maybe we don't have to do or 'we might cooperate 9 with you so we don 't have to duplica te.
10 There are other areas though where there may 11 be an aura of duplication unless we learn how to take 12 advantage of your work.
For example, from time to time 13 people refer to the aviation industry and they say, 14 well, they deputized one of the air frame personnel to 15 represent the FA A.
Is that a concept where in certain 18 areas if INPO was doing a good job that we might say, 17 vell, that is an activity that INPO is doing well with 18 our observers looking over their shoulder and maybe we 19 don 't have to do that.
Is that part of your thinking.
2C I am not trying to suggest what your thinking 21 out to'be but I as trying to draw it out.
22 ADMIRAL WIlKINSON4 If we had time to discuss 23 in more detail there are many areas that have evolved 24 over the last two years where there is close 25 coordination between our people and the NBC staff, in ALDERSoN REPORTING COMPANY,INC,
_ --~--__-_--_
40 1 such areas as event analysis, control room review, 2 emergency operating procedure review, our actual 3 evaluations and so forth.
I believe that that is a very 4 desirable process.
5 We are providing considerable information to 6 the NRC on our activities at the present time and what 7 those activities sre disclosing.
8
- 58. W. S. (B:il) LEES Let me say, Mr.
9 Chairman, that frankly I am co'nvinced INPO can improve 10 quality where needed in these plants that are under 11 construction f aster than can che Commission.
12 I believe the combination of evaluation and 13 assistance and the sharing of the good practices rather 14 than you are wrong here and you are fined.
That sort of 15 program can result in a faster uplifting where uplifting 18 is necessary, but both are not needed.
l 17 COMMISSIONER BRADFORD:
Both are not needed?
18 CHAIRHAN PALLADINO:
What sort of teeth or 19 what stick and carrot can you use?
20 HR. W. S.
(Bill) 1EE4 Well, a fully redundant 21 system is not aceded, Commissioner Bradford, is what I 22 am saying.
We invite the NBC to come, as they have in 23 the operating area, to accompany us on evaluations.
24 They went through the system with us and satisfied 25 themselves whether or not it has teeth in it and whether ALDERSON REPORTING COMPANY,INC,
41 1 or not it is good.
2 As part of the meshing and only one element of 3 meshing we would invite the staff to do same thing in 4 this area.
He would invite the staff participation as 5 ve develop the criteria and as we revise the criteria.
6 I am sure there vill be many other elements of the 7 program that will unfold as we go through Phase I that 8 are needed in Phase II and we would have a close 9 coordination with the staff as we develop those.
10 We did that in the operating area and came up 11 with Notepad, we came up with the SEEIN and the fast 12 exchange of significant events evaluations.
You 13 remember TMI, we didn't have that exchange inf ormation.
14 Now it is computerized and every plant is hooked up and 15 INPO has got it in service.
16 CHAIRMAN PALLADINO:
Incidentally, I don't 17 expect you to have all the ansvers.
I as throwing out 18 some of these questions mainly as points that might be 19 considered.
20 I used the word " teeth," but I would ra ther 21 use carrot and stick to get compliance with your 22 suggested or mandated improvements, and I don 't know if 23 you mandate them.
24 Suppose you go into a plant and you find 25 places where they really ought to be something to fix it ALDEASoN REPORTING COMPANY,INC,
42
^
1 up.
2 HR. W. S.
(Bill) LEES Well, I think the 3 carrot is Mr. CEO, this is costing you big bucks and 4 that is going to delay your plant.
Over on the 5 operating side I would of course have carrots and 8 sticks.
We haven't thought about the stick on this side.
7 CONNISSIONER GILINSKY But doesn't he know 8 that already?
9 NR. W. S.
(Bill) LEE:
Yes, sir.
I think, as 10 Dennis said earlier, the utility industry is a 11 heterogeneous group.
We don't speak with one voice and 12 no two of us are slike.
Some of us are stronger in some 13 areas and not so strong in some areas.
INP0 has been 14 very contributory in helping share those strengths and 15 applying where there were weaknesses and we think the 16 same thing can happen here.
17 Yes, they knov that already, but somewhere l
l 18 down the line it isn't happenine right.
t l
19 MR. BIEON LEE:
None of us, you know, have l
i 20 really come up with all the best ideas.
A lot of the 21 ideas come out of the NRC, out of the inspectors and out i
22 in the regions and in the field.
23
'COHNISSIONER GILINSKY Have you had a chance 24 to look at the initiatives that were proposed by the 25 staff I guess a week or so ago in this area?
f l
i l
ALDERSoN REPORTING COMPANY. INC.
L
43 1
NR. W. S.
(Bill) LEE:
I have seen the slides 2 the staff used last Friday.
3 COMMISSIONER GIIINSKY:
I guess that is when 4 it was, yes.
5 3R. W. S.
(Bill) LEE:
The 29th I believe.
6 CONHISSIONER GILINSKY:
I don' t have a date on 7 here,but that is probably what it was.
I just wondered 8 if you had any comments, other than we ought to avoid 9 duplicating activities.
Some, as the Chairman pointed 10 out, wouldn't fall in that category.
11 NR. W. S.
(Bill) 1EE Ccamissioner, we have 12 not analyzed those slides in detail.
We would be glad 13 to be responsive to that question later and tell you 14 what areas we think might be in the meshing category.
15 CORMISSIONER GILINSKT4 One of them in fact 16 would have chief executive officers or comparable rank 17 officers in effect signing off on the conformance of the 18 plant to the requirements.
19 HR.W.S. (Bill) LEE.
We knew you had 20 discussed that and we have discussed it among ourselves, 2t yes, sir.
22 CHAIRMAN PALLADINO:
You say you haven't or 23 you have ?
24 HR. W. S.
(Bill) LEE:
We have, that is just 25 the group here.
ALDERSoN REPORTING COMPANY. INC, i
44 1
CHAIBMAN PALLADINO:
Yes.
2 COMMISSIONER ROBERTS:
Well, get a transcript 3 and you will get a variety of views.
4 HR. W. S.
(Bill) LEE:
We saw you had a 5 variety of views.
I think Commissioner Roberts is quite e right that any officer of the company can fulfill a 7 legal requirement that is binding on the corporation.
8 Er. Sillin, Mr. Parris and I happen to feel 9 that if the CEO personally signs off that he is going to 10 tend to ask some questions before he signs it.
11 I think we are required to do that sometimes 12 on a bond indenture and some other things where bond' 13 holders will only take the signature of somebody.
14 Whereas it may be cosmetic, it does tend to suggest to 15 the CEO that before you sign this satisfy yourself that 16 your people are doing what they ought to do.
He is not 17 going to be familiar with the details of what he is 18 signing but he is going to ask questions.
To me that is 19 not unreasonable to ask.
20 COMMISSIONER AHEARNE:
Would you take the 21 other next step then, since you have signed it, that you 22 would be personally responsible for it and not the 23 corporation?
24 MR. W. S.
(Bill) LEE:
Well, we a re anyway.
25 With civil and criminal penalties you can throw us in ALDERSON REPORTING COMPANY,INC,
45 1 jail tomorrow.
My neck is out every day.
2 (Laughter.)
3 COMMISSIONER AHEARNE:
So you would not take 4 the position that you are only signing on behalf of the 5 corporation?
CORMISSIONER ROBERTS:
Nov valt a minute, that 7 is a legal question.
That is why we have corporations.
8 Nr. Lee, I don't understand your response.
I 9 sean if you say your neck is out there every day in the 10 sense of your job, yes.
Well, that is a legal question.
11 HR. W. S.
(Bill) LEE:
Well, your regulations 12 do prcvide for some criminal penalties of individuals.
13 I don't know that that has been tested legally and I 14 haven't talked to the lawyers about it.
15 (Laughter.)
16 HR. W. S.
(Bill) LEE:
I was responding in 17 that sense.
l 18 COMMISSIONER ROBERTS:
I understand.
19 MR. W.
S.
(Bill) LEE:
I don't much want to go 20 to jail.
l 21 COMMISSIONER ROBERTS I don't want to send 22 you either.
23 (Laughter.)
1 24 MR. BYRON LEE:
I think to believe that any 25 one individual though, no matter who he is in the ALDERSoN REPORTING COMPANY,INC,
46 1 operation, can sign something with complete assurance 2 that everything has been done right all the time ---
3 CONHISSIONER ROBERTS:
Well, you would never 4 find an intelligent person who would sign it.
5 COMMISSIONER GILINSKY:
A Commissioner has to 6 take responsibilty for decisions all the time on the 7 basis of staff recommendations after they have been 8 reviewed and signed.
9 It seems to me that the chief executive 10 officer or a comparable officer would be taking 11 responsibility for the company.
It focuses the mind 12 wonderfully to have to do that and he would be making 13 sure that the company was really complying in a way that 14 he might not otherwise.
15 CHAIRMAN PALLADINO:
Well, certainly that 16 would be his intent.
Having been involved in many large 17 organizations, well, not that many, less than five l
18 any how ---
(
19 (Laughter.)
20 CONNISSIONEB BRADFORD:
A few.
l 21 CHAIRMAN PALLADIN0s You ask your questions 22 and you make the best effort to make sure that you know 23 Wha t is going on and then you put your neck on the 24 lin e.
If you knowingly or intentionally try to mislead, 25 then I would say your neck is personally out.
If you ALDERSoN REPORTING-COMPANY,INC,
47 1 did it by not being diligent, I guess the individual's 2 neck would be out or if one were negligent in the 3 process.
4 NR. W. S.
(Bill) LEE:
Those are legal terms.
5 (Laughter.)
6 NR. W. S.
(Bill) LEE; Let me say in response 7 to this general subject that I think we can have better 8 plants if we approach it through a nonpunitive 9 activation.
If we keep adding punitive measures and 10 punitive measures I as af raid it gets into the role of 11 trying to comply with the letter of the regulations 12 because that is the legal exposure.
13 We are after good plants, all of us.
14 CHAIRMAN PALLADINO:
Yes, we are.
15 CONNISSIONER ROBERTS:
I think your point is 16 well taken.
17 MR. W.
S.
(Bill) LEE:
We learned at TMI that 18 attempts to comply with the letter of the regulations do 19 not always result in success.
20 CHAIRHAN PALLADINot May I ask a question in a 21 different area.
Getting back to the examples would you 22 f oresee, and let me talk at least about the Phase I, 23 would you f oresee that your rule would be to see that 24 things were built as the design drawings call for, or 25 would you envision this to see whether or not the design ALDERSON REPORTING COMPANY,INC,
48 1 itself is adequate.
2 MR. W. S.
(Bill) LEE:
The former, to ses that 3 they are built as the design called for, that is, wha t 4 ve would call design control and quality of 5 construction.
But we would not be competent really to 6 go back in and go over the review of the design itself.
7 CHAIRMAN PALLADINO:
So you are sticking 8 strictly to quality.
You wouldn't go into control rooms 9 and say, my God, why do you have those instruments over 10 here where your response levers are over here?
11 COMNISSIONER AREARNE:
Not in this 12 presentation.
13 (Laughter.)
14 ADMIRAL WIIKINSON:
That is one of the 15 examples of a great amount of coordination between our 16 people and ycur people in that control room review at 17 the present time.
18 CHAIRMAN PALLADINO:
Having established that, 19 if you were pouring concrete would you go so far as to 20 make sure that they are following the right methods such
(
2t as vibration, or whatever they do in pouring concrete, i
1 1
22 to make sure that you are getting no voids?
23 ADMIRAL WILKINSON:
We would really be looking
(
24 more that the utility had the management practices to 25 check up to see that they were following on such things, l
l 1
(
ALDERSoN REPORTING COMPANY. INC,
@ VIURYCS AMh @.W WGHINGToNo D.C. 20024 (202) 554-2345 y
49 1 that they had the management systems, action tracking 2 systems and that those systems were working.
An 3 individual item would be a detail that would indicate a 4 problem in a system of management.
of course, you have 5 to dig into some details, but obviously you wouldn't 6 look at every detail.
7 CHAIRHAN PALLADINO:
But you would spot 8 check.
If there were a procedure and you picked tha t 9 procedure'you would go and observe and see that it was 10 being carried out as sanagement had indicated it should l
11 be?
12 ADMIRAL WILKINSON:
Yes, sir, and if you see a 13 problem in an area you would dig in and pull the thread
{
14 in more and more details not to correct those individual l
15 items but to correct the system that let them happen.
16 HR. BYRON LEES I think you would redirect the 17 utility if there appeared to be a shortcoming in their 18 system to go back and take a look in more specific 19 areas. Do you have a specification that follows the code 20 requirements or follows the standard good practices in 21 the industry for placing concrete as such? ' "Is that 22 specified?
23 I would then have a system in my quality 24 control area that went out and checked that as such, and 25 in today's atmosphere can I document all of that.
If I ALDERSoN REPORTING COMPANY. INC,
50 1 go back too far I am not so sure that we have all of the 2 papers that we can verif y that thing.
3 It is a question cf do you have the right 4 procedures and the program in place to verify it and 5 then has your progran been actually working.
6 Now if there are some shortcomings in an area 7 I would think that it would redirect the utility or, 8 depending on the magnitude of it, you might take a look 9 in some areas and see if those apparent program to deficiencies have ended in actual deficiencies in the 11 field.
They may not have.
12 COMMISSIONER GILINSKYa I wonder if you could
~
13 take a specific example and just suggest what you might l
14 do and how that differs from what we now do.
l l
15 MR. BIRON LEE:
Well, as I said, I guess it is 18 a question of taking a look, and I did read the 17 transcript this morning.
There was discussion obviously t
18 about design control and what-have-you.
How much 19 auditing was done on designs and design control areas?
20 Quality control, quality assurance programs or 21 contractors or subcontractors interf ace.
I think that 22 this would say let 's look at all of those areas and see 23 was there some kind of a program or is there an area 24 here that you didn't have a program that covered that 25 interface or that part of the design or the construction ALDERSON REPORTING CClaPANY,INC,
.~~~--_---nn
~
51 1 or the interface between the two adequately enough, you 2 know.
Was it done' informally}
3 COMMISSIONER GILINSKIa But that is something 4 I would expect that we would be doing or should be 5 doing.
When you were talking about duplica tion were you 6 talking about the possibility of us laying on additional T third-party audits, or were you talking about things 8 that we are doing right now?
9 HR.W.S. (Bill) LEES I as talking about the 10 possibility of adding additional third-party audits.
11 Now there may be some things you are doing now that 12 af ter INPO demonstrates a track record in this area that 13 you may not elect to do if it is duplicative.
14 COMMISSIONER GILINSKY But doesn't that sound 15 like the kind of thing that we are now doing or should 16 be doing?
17 MR. W. S.
(Bill) LEE:
The third-party audits?
18 COMMISSIONER GILINSKY:
No, no, the kind of l
19 thing of checking to see if their QA practices and 20 design, that adequate engineering checks have been made 21 and so on.
22 HR. W. S.
(Bill) LEE:
let me see if I can 23 give you an example.
The Chairman mentioned voids in 24 concrete a moment ago.
If INPO vere to go on a l
25 construction job and what assurances do you have, Mr.
l l
ALDERSON REPORTING COMPANY,INC,
52 1 Utility, that you don't have voids in concrete?
The 2 utility would demonstrate the procedures and arcw how 3 they checked the mix and show how they vibrate and show 4 how ther inspect and what-not.
5 Then as the INPO team was on the job for a 6 period of time they found not in the nuclear side but 7 over on the turbine side somewhere a lot of voids in 8 concrete.
That is symptomatic of something.
Some 9 management system has broken down,. althought they may be 10 complying with the letter of your recommendations on the 11 nuclear side.
If that is all they intend to do, 12 something is wrong there.
They are not excellent.
13 Ferreting into that what is wrong, what 14 management system is wrong, may uncover some other 15 things, or it may indicative of where the utility can be 16 helped by good practice from another company.
17 CONHISSIONER GIIINSKY:
My impression is we 18 have gotten into non-nuclear concrete on occasion, but I 19 am be wrong.
20 MR. W. S.
(Bill) LEE:
I haven't been involved 21 in that in several years so I was not aware of it, sir.
22 CHAIRMAN PA1LADIN04 I guess I am not sure 23 that we go into as much depth or as ertensive an 24 evaluation of all procedures.
25 COMMISSIONER GIIINSKYs Oh, no, I am not ALDERSON REPORTING COMPANY,INC,
53 1 suggesting that it is not valuable to do these things.
2 I am just trying to understand what we were talking 3 about of how the activities mesh and also talking about 4 trying to avoid unnecessary duplication.
So I was 5 trying to understand just what it is we are talking 6 about here.
7 CHAIRMAN PALLADINO:
You said you were going 8 only as far as plants being 80 percent complete or maybe 9 I misunderstood you.
There is an important area that is 10 perhaps treated a little bit late in some utilities and 11 that is planning the manpower for these plants.
Is that 12 going to be something that INPO would be looking at and 13 advising management about?
14 ADMIRAL WILKINSON:
If you will remember Mr.
15 Lee 's presentation of some of the things that IMPO has 16 done in the last two years, one of them was manpower 17 planning.
As I believe you know, we have come out with t
i 18 an inventory of assets in the industry, a determination 19 first cut of requirements and advice to utilities 20 involved of more eff ort on their part to put the 21 requisite number of people in the training pipeline.
22 CHAIRMAN PALLADIN0s Are you going to evaluate 23 these as part of the pre-operational situation, because 24 certainly the criteria may exist but the implementation 25 is not apparent in all cases.
l l
ALDERSON REPORTING COMPANY. INC,
54 1
ADMIRAL WI1KINSON:
Yes, sir, and in our 2 second round of evaluation each one of our evaluation 3 teams is now looking more closely at what each utility 4 is actually using so that we can refine the requirements 5 which of course differ from different kinds of plants, 6 single units, double units, size, output, et cetera.
7 CHAIHHAN PAL 113INos Any other qu'stions?
e 8
COMMISSIONER AHEARNE I guess I would like to 9 make a comment.
As you mentioned several years ago when 10 rou first came in and talked about your other approach I 11 had some skepticism on how you would be doing.
I have 12 been pleasantly surprised in a lot of the work that has 13 been going along.
I second both Lee's laudits of 14 Admiral Wilkinson.
My skepticism is still there to some 15 extent and I still have to see more to overcome that.
16 Maybe I as just a perpectual skeptic.
17 In this area once again I think you are laying 18 out a program that looks as thought it really could be a 19 major improvement as f ar as the industry is concerned.
20 That doesn 't in my mind yet make me feel well then I on 21 on the NRC side can close up my book and walk away 22 because it is now in good hands.
23 It may eventually be a point that we could 24 back off of substantially, but right at the moment I 25 have still got to think a little bit more about where I l
ALDERSON REPORTING COMPANY,INC,
--m...-
55 1 would come out on our side of the table.
2 MR. W. S.
(Bill) LEE:
I am glad, Mr.
3 Commissioner.
There are a number of areas in which I am 4 uneasy and we can both get better and we hope to mesh 5 closely with your organization.
We have learned a great 6 deal from it.
They have been contributory to INPO and 7 ve would like to compliment the staff in that regard.
8 We were a little skeptical at first as to 9 whether there would be broad-scale interference.
- But, 10 no, sir, there has not been.
There has been 11 encouragement, there has been constructive help, there 1; has been communication and coordination and we have 13 demonstrated we can aesh and work together to make it 14 happen.
We think this complements your role and I hope 15 rou will never rest fully assure.
16 (Laughter.)
17 CHAIRMAN PALLADIN0s Well I think there is 18 potential here for a major contribution.
It still l
19 remains to be developed.
I do think we have important 20 questions to answer with regard to our interfaces 21 between the NRC and the industry eff ort.
But, as has 22 been characteristic in the past, we are prepared to 23 cooperate and encourage the staff to work to take 24 advantage of your initiatives as much as we possibly can.
25 Anything more?
I ALDEPSON REPORTING COMPANY. INC.
56 1
MR. SILLIN:
Mr.' Chairman, may I just inquire 2 on that latter comment because I do think it will be 3 quite important in terms that the marshalling of this
& effort is going to be a major one and it is going to 5 require quite an effort on the part of'the industry.
6 May I interpret that comment that you would 7 encourage the industry to proceed with this program?
I 8 think that will be very critical in terat of our effort 9 to really carry this forward to know that this is 10 something that this Commission is encouraging us to do.
11 CHAIRMAN PALLADIN04 05 course, we haven't 12 voted on that question so I can't tell you the sense of 13 the Commission.
But having worked with then I would 14 guess there is support to see you get started on this 15 and help evaluate the opportunities that are arising 16 from your work from time to time.
17 Does anyone want to add anything?
18 COMMISSIONER AHEARNE:
I guess my comment 19 would be that I would certainly encourage them to do it, 20 but that doesn 't mean that I have yet reached a 21 cenclusion on where I will come out on what I will 22 recommend we do.
That is not a complete answer to your 23 question, I realize that.
24 COMMISSIONER ROBERTS It is a reasonable 25 question however.
ALDERSON REPORTING COMPANY,INC, f61 ^ JrMMSFRP! hfErR
l 57 1
CHAIRMAN PALLADIN0s I do recognize that it is 2 going to take the expenditure of significant resources.
3 Hy intent would be to try to take as much advantage as l
4 possible of the work that you are doing and try to 5 dovetail the activities as best as we can.
6 Any other comments?
7 COMMISSIONER GILINSKYa I will certainly be 8 interested to see how you proceed.
It could certainly 9 be a very important effort and anything you do in these to directions is certainly very much to the good.
11 NH. W. S. (Bill) LEE:
Thank you, Mr. Chairman.
12 CHAIRMAN PALLADIN0s Thank you.
We appreciate 13 rour coming by and briefing us on this and we will be 14 vatching your initiatives with great interest.
15 We will stand adjourned.
16 (Whereupon, at 3s30 p.m.,
the meeting 17 adjourned.)
l 18 19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC.
m UUC"J.AR RZwA"*CIE CCF*SICN Tais is 00 certif7 that the attachec ;: eceecings *:efere :he COMMISSION MEETING is the sattar Of:.
Public Meeting - Briefing by Industry on Plans for Quality Assurance Improvement CaC4 cf ?rccetcing:
February 4, 1982 OCC!LSC lli.U Lber:
Flace Cf ?:"Ocetciag: Washington, D.
C.
scre held as hereis appears, anc cha~t. this is the origi:21 :: scsc:-1;-
thersef for the file of the C =:=issisc.
Mary C.
Simons Cfft:ial ?.eportar (! ;ec)
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f Of ficisi ?.a pcrtar ( 5.ifnac. :* e )
l l
SCHEDULING NOTES FOR COMMISSION MEETING ON IllDUSTRY PLANS FOR OA/QC IMPROVEMENT Scheduled:
2:00 p.m.,
Thursday, February 4, 1982 Duration:
1-1/2 hours INP0 presentation will last approx. 30 minutes --
remainder will be for questions from the Commission
Purpose:
To brief the. Commission on the industry-INP0 plans for. a QA/4C audit program l
Participants:
1.
William S. Lee, Chairman, INP0; President, Duke Power Company 2.
Admiral Eugene P.
(Dennis) Wilkinson, President, INP0 i
Also attending:
Lelan F.
Sillin, Jr., Chairman and Chief Executive Ofticer, Northeast Utilities Hugh G. Parris, Manager of Power, TVA Byron Lee, Jr., Executive Vice President, Commonwealth Edison Company e
l.
l NUCLEAR PLANT CONSTRUCTION QUALITY EVALUATION PROGRAM
Background
NRC established broad and general criteria (18 criteria in 10CFR50).
Industry took various approaches to implementation.
NRC requirements have changed extensively over the past decade.
Industry and standards groups developed expanding requirements, stan-dards, and daughter standards.
Control of quality in construction and design was complicated by the changing requirements.
Now need to ensure programs in effect nation-wide meet the performance goals intended.
Several recent events in nuclear plant con-struction stimulated industry action.
An industry group met on December 17, 1981, under joint AIF/EEI auspices to formulate plans.
A second meeting was held on January 5, 1982, with representatives of AIF, EEI, APPA, and INPO to develop a proposed industry approach.
Follow-on industry meetings were held with the INPO Board of Directors, UNPOC, EEI CEO i
l Conference, etc.
Strong industry support has been marshalled.
l l
l 1
l l
INPO History Nuclear utility industry established INPO in late 1979.
INPO's mission is to promote safety in nuclear power plant operations.
INPO is a non-profit, independent organization.
Membership includes every U.S. utility with an operating license, construction permit, or limited work authorization for a nuclear power plant.
Two CEO workshops -
" Managing for Safety" and
" Initiatives for Safety" -- and three plant managers workshops have had excellent participation.
INPO Response to Industry's Needs o
developed criteria for plant evaluations o
completed 1st evaluation of every U.S.
operating nuclear station in late 1981 o
initiated in 1982 assistance visits to plants approching initial fuel loading and startup o
developed criteria for corporate evaluations o
identified, analyzed and communicated information on significant events through the SEE-IN program o
initiated Review and Assistance visits to aid utilities in emergency planning efforts o
coordinated transportation and fixed facility agreements to provide for assistance in the event of an emergency 2
Program Description Formation of a Nuclear Plant Construction Quality Evaluation Program under the direction of INPO.
Evaluations will assess individual utility programs based on best practices and will assist utilities in achieving a consistent level of excellence in building quality into nuclear plants.
The INPO Board of Directors will provide pol-icy direction and support for the program.
Evaluation criteria will be developed under the auspices of INPO.
An Ad Hoc Review Group, composed of senior utility managers, will provide oversight.
After criteria completion, utilities will initiate evaluations, using the criteria as a basis, and will report the results to INPO.
Following completion of the utility initial evaluations, industry and INPO will assess the effort and formulate detailed plans for an ongoing evaluation program.
3
~
Implementation Plan PHASE I Criteria Development and Pilot Evaluations TARGET DATE Form criteria development group.
3/1/82 Industry Ad Hoc Review 4/15/82 Group complete review of first draft of criteria.
Complete three pilot evaluations.
7/30/82 Revise and refine criteria based 8/15/82 on Ad Hoc Review Group, member utility review, and pilot evaluation experience.
Publish criteria.
9/1/82 Conduct workshops to train utility 9/82 personnel in the use of the criteria for evaluation purposes.
Utilities initiate an evaluation 9/82 -
I using the criteria as a basis.
12/82 1
Obtain a report from each utility on 12/31/82 the results of their evaluation.
Industry and INPO assess overall 1/83 program and formulate plans for Phase II.
l 4
l
PHASE II Alternatives Independent INPO-managed evaluations for plants under construction Continued conduct of utility-initiated evaluations, using INPO-developed criteria A modification of the above approaches PHASE II:
When integrated with INPO's regular evaluation program, which includes:
o utility corrective action commitment o
INPO follow-up will be designed to provide full life cycle evaluations.
Coordination with NRC Invite comments on criteria as they are l
developed and on final draft.
I Periodically, brief NRC on the status of program.
1 Provide a detailed briefing when plans for PHASE II are formulated.
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