ML20052B060
| ML20052B060 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8204290630 | |
| Download: ML20052B060 (95) | |
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PUBLIC MEETING BRIEFING ON VENDOR INSPECTION PROGRAM k
DATE:
April 21, 1982 paggg 1 - 71 AT:
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UNITED ST ATES OF AMERICA
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2 NUCLEAR REGULATORY COMMISSION 3
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BRIEFING ON VENDOR INSPECTION PROGRAM S
6 PUBLIC NEETING T
8 Nuclasr Regulatory Commission Room 1130 9
1717 H Street, N.
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Washington, D. C.
10 Wednesday, April 21, 1992 11 The Commission met, pursuant to notice, at 12 9 :3 5 a.m.
13 14 BEFORE&
15 NUNZIO PALLADINO, Chairman of the Commission VICTOR GILINSKY, Commissioner 16 JOHN AHEARNE, Commissioner THOMAS ROBERTS, Commissioner 17, l
STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
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l 19 S. CHILK N. NALSCH 20 F. REHICK J. NURRAY 21 J. COLLINJ
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22 M. PERANICH 23 l
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k DISCLADIER This is arr unofficial transcript af a meeting' of the United States Nuclear Regulatory Consission held on am 41 fi. 1982 in the Cocmissi'an's. offices at U17 H Street, N. W., Wasnington, D. C.
The meeting was open te public attendance and observation.
Tnis transcript has not been reviewed,. corrected, or edited,. and it may contain inaccuracies _
The transcript is intended. solely for general infomational puroeses.
As provident by 10 CFR 9.TGI,. it is nat part of the forinal or informal
- recordcaf decision of the matters discussed. Express. ions of opinion in
.this. transcript do not necessarily reflect final detennina.tions or
.- beliefs.
No pleading.or other paper may be filed with the Commission in any proceeding as the result of or addressed ts any* statement or argument conta.ined: hereirr,. except as the Conimission may authorize..
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1 P E Q C E E D I,1 2 S 2
CHAIRMAN PALLADINO:
The meeting vill please 3 come to order.
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The Commission meets at the request of 5 Commissioner Roberts to receive a briefing from the 6 staff on the vendor inspection program.
7 About half the work associated ~with 8 constructing a nuclear f acility is accomplish,ed off 9 site, inclu. ding overall design and the fabrication of 10 components to safety related systems.
11 Inspections of nuclear steam systems 12 suppliers, architect / engineers and vendors of safety 13 related components are performed by NRC's Vendor Program 14 B ranch located in the Region IV office.
15 We have with us today representatives of the 16 Region IV office to speak to us on the functions and
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17 activities of the vendor inspection progras.
18 Unless any of'my fellow Commissioners have 19 opening remarks they would like to make, I am going to 20 turn the meeting over to Mr. Collins, Administrator for l
21 Region IT.
22 COMMISSIONER ROBERTSt I just want to make a 23 comment.
On my visit to the region I had a presentation 24 tha t I thought was quite in teresting and I would like to 25 share that with the other Commissioners.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2346
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CHAIRMAf PALLADINO:
Okay, thank you.
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2 ER. C3LLINS:
Thank you very much, Mr.
3 Chairman.
We are pleased to be here to make this
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4 presentation to you.
5 As Commissioner Roberts indicated, when he 6 visited Region IV several months ago, we took the 7 opportunity to discuss with him the vendor inspection 8 program and, as he indicated to you, he felt it would be 9 advantageous for you people to hear the same discussion.
10 So at this time I am going to turn it over to 11 Oldis Potapovs who is the Chief of the Vendor Inspection 12 Program out of Region IV and he will discuss with us 13 this morning the principal ingredients of that program.
14 Uldis. -
15 MR. POTAPOVS:
Thank you, John.
16 The vendor inspection program was established 17 as a separate inspection f unction within the Office of 18 Inspection and Enforcement in 1974.
Ihe primary purpose tg of that function was to verify that off-site 20 organizations supplying equipment and services to 2t licensed facilities had quality assurance programs which 22 were consistent with the NRC requirements which are 23 applicable to the f acilities being built.
24 Over the last few years the vendor inspection 25 program has undergone several significant changes.
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1 These changes have affected the inspection philosophy, 2 inspection priorities, enforcement, mechanics of 3 reporting inspection results the organization and e
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4 staffing within the program and also interfaces with the 5 other NBC functions.
6 Whereas the program was originally established 7 as a completely independent and isolated inspection 8 function, some of the recent changes in the program have 9 necessitated much more frequent interfacing between the 10 vendor inspection program and the other NRC activities.
11 What I would like to do in the next half an 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or so is to give an overview of the current 13 program,about tha current workload that we are 14-tackling,about the effort that we applying to this 15.setivity and describe some of the program interface and 16 functions and show actually some examples of the program l
17 activities.
18 So with that I can go to the first slide.
Is (Slide presentation.)
2g In the basic program the objective is still to 11-increase reactor safetr br providing reasonable 22 assurance that products and services supplied by 22 non-licensee organizations for licensed activities meet 24 NBC requirements.
25 COHRISSIONER AHEARNE&
Can I ask a question?
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1 MR. POTAPOVS:
Yes.
2 COMMISSIONER AHEARNE:
Are you going to get 3 into what requirements you measure against?
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4 MR. POTAPOVSs Yes.
5 COHHISSIONER AHEARNE:
You are inspecting 6 non-licensees and you are saying that you want to make 7 sure that their products and services meet NBC 8 requirements.
So one of the questions at least that I 9 would be interested in at some point you discussing is 10 what kinds of requirements are you holding th e 11 non-licensee against?
12 CHAIRMAN PALLADINO:
The way I would propose 13 to answer that is that only directly applicable 14 requirements to non-licensees would be contained in Part 15 21 of the ragulations, and those would be the reporting 16 of known deficiencies to NRC.
17 The other criteria that we use for our 18 non-licensed inspection are primarily NRC requirements which are passed on br'the utilities, by the licensees 19 20- through their procurement documents, or in some cases, 21 like in a-case of the-nuclear steanr system suppliers and 22 architect / engineering organizations, made directly to 23 the Commission in topical reports These basically 24 address and define the quality assurance program of 25 those organizations.
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1 COMMISSIONER AHEARNE:
Let me see if I can 2 understand.
You are saying that a steam supplier's 3'
topical report is treated as a requirement?
4 CHAIRMAN PALLADINO No, it is an inspection 5 basis.
It is a commitment.
6 COMMISSIONER AHEARNE4 But what is the 7 requirement?
8 MR. POTAPOVSt The requirement would be only 9 to the licensee and not to the non-licensee organization 10 as f ar NRC requirements are defined.
11 COMMISSIONER AHEARNE:
That is what I was 12 trying to get clear.
I will probably return to it'.
13 MR. POTAPOVSt I will get into this a little 14 bit when we talk about enforcement policy that we use in 15 the program.
16 COMMISSIONER AHEARNE4 All right.
17 CHAIRMAN PALLADIN0s Going over to the next 18 slide, the primary program function is to conduct 19 routine programmatic inspections of nuclear steam system 20 suppliers, architect / engineering organizations, 2t component suppliers and service organizations to verify 1
l conformance with Commission rules and regulations 22 23 imposed directly or indirectly.
24 COMMISSIONER AHEARNEr I was taking exception 25 when I read this with the topical report imposing a l
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2 3R. POTAPOVS4 The topical report is not a 3 requirement.
Let me clarify that.
It is a commitment.
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4 COMMISSIONER AHEARNE:
What kind of legally 5 binding commitment is made in the topical report?
8 HR. POTAPOVS:
As far as I know, there are no 7 legally binding commitments made.
The enforcement 8 against the commitments in a topical, report are handled 9 through enforcement correspondence such as notices of 10 non-conformance.
We request the organization to respond 11 to our concerns without invoking a legal requirement.
12 MR. COLLINSs To'get back to your question or 13 try to answer it, I think what Uldis is trying to sa y is 14 that a licensee may use that topical report reference in 15 his SAR as his commitment to Appendix B requirements, 16 quality assurance requirements.
The staff is reviewing 17 that topical report on a generic basis so that you would l
18 not have to go back and review it on an individual 19 application.
So.it is the licensee's commitment based 2g on his acceptance of that topical report.
21 COMNISSIONER AHEARNE:
But-then anr legal 22 commitment which would lead to any kind of an action on 23 our part that would be an enforcible action has to be on 24 the licensee.
25 NR. POTAPOVS:
Ultimately the enforcement, if ALDERSoN REPORTING COMPANY,INC,
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1 it was escalated to that point, would be with the 2 licensee.
In fact, if we would find fault with the 3 product, we would ask the licensee to provide remedies.
4 COMMISSIONER AHEARNE So that these notices 5 of non-conf ormance and so forth, the discussion back and 6 forth, is it not really a terminofogy that is used but 7 there is not really ant legal binding relationship 8 associated with it.
9 MR. POTAPOVS:
That is correct.
We treat it 10 as a request for corrective action.
11 CONNISSIONER AHEARNE:
It is really a subtle 12 pressure that is being implied.
13 NR. POTAPOVSt Yes.
14 CONNISSIONER ROBERTS:
If I may make an 15 observation.
If you are some poor devil out there 16 naking widgets and your name apppear.s one one of those 17 things you can forget about making widgets for nuclear 18 power plants.
It is an incredible lever.
19 CONNISSIONER AHEABNEs.
Well, yes.
What I was 2a going. to work. my war towards is that it is a very 2t powerful level, and I wasn't sure what the converse 22 System was in our formal legal system.
If we take 23 action against someone and they don' t like it, they go 24 to a hearing and object to what we are doing.
25 CONNISSIONER ROBEETS I am not sure that ALDERSoN REPORTING COMPANY. INC,
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1 process exists.
2 COMMISSIONER AHEARNE:
That is what I am
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3 vondering.
4 CONNISSIONER ROBERTS:
I don't think it does.
5 Once your name appears on one of those lists you are mud.
6 (Laughter.)
7 COMMISSIONER ROBERTS 4 I am saying that is 8 right or wrong.
I as just stating the facts.
9 COMMISSIONER AHEARNE:
I understand.
10 MR. POTAPOVS:
Historically we have not had 11 too many problems achieving proper correction of 12 identified non-conformances.
13 CHAIRMAN PALLADIN0s But suppose you go to a 14 vendor and you see something that appears not to be in 15 compliance with our requirements and then you go back 16 and find out that the licensee had failed to put the th appropriate requirement in the procurement document.
18 What steps do you take?
1g HR. POTAPOVSt That has happened.
We do not 2n take any action against the vendor under those 21 circumstances.
We would contact the region of NRC who 22 has responsibility for that particular licensee and ask 23 them to look into the manner in which the licensing 24 requirements are passed down, and they would take action 25 with the licensee that is affected.
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE S.W WASHINGTON. D.C. 20024 (202) 554-2345
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1 Now when you have a number of supplierc 2 involved, starting f rom the utility to the nuclear steam 3 system supplier to the A/E to the component 4 manufacturer, it happens that somewhere along the line 5 somebody drops the ball and we stop at that point and 6 see why the requirement or the commitment was not passed 7 on and take action against whoever failed to pass on the 8 commitment.
9 CHAIRMAN PALLADIN04 You try to get the 10 licensee to make sure that your requirements are passed 11 on.
12 MR. POTAPOVSs That is right.
13 CHAIBMAN PALLADINO:
Suppose you find that the 14 requirements had been passed on but they weren't being 15 met.
Then what steps do you take there?
16 MR. POTAPOVS:
Well, in that case the vendor 17 who failed to meet th e requirements would get a notice 18 of non-conformance and be requested to take appropriate 19 correctiva action and also establish preventative 2a seasures to assure that it would not happen again.
21 So basically that slide defines the base 22 pro g ram which is oriented to assuring that the 23 commitments are kept by the various organizations in the 24 procurement chain.
25 CONFISSIONER AHEARNEt In the middle one, two l
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or three years ago the Commission revised the coverage
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2 of Part 21 with respect to 3
MR. P3TAPOVSs Commercial items?
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4 CONNISSIONER AHEARNEs Right.
To what extent i
5 has that affected your review with respect to that, Part 6 217 Did,that cause much of a changa in the approach you 7 took?~
8 HR. POTAPOVS Not very much.
9 COMMISSIONER AHEARNE:
It did not to significantly affect the reach of your particular 11 reviews ?
12 HR. POTAPOVS:
N o.-
There are still some 13 problems with the Part 21 regulation, but I am not sure 14 that this is the time to go into that.
15 0055ISSIONER AHEARNE:
Could you 'give a quick 16 thumbnail sketch of it?
17 (Laughter.)
18 MR. POTAPOVSt Well, there are a number of 19 things that are not very precisely defined.
Basically 20 the regulation requires that an organization supplying 21 basic components establish procedures for evaluating and 22 reporting defects.
As f ar as things like how long the 23 evaluation can take, there are many loose ends.
24 Somebody can be evaluating defects for some period of 25 time without ever being in a position to report.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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Also, there is currently some concern as to 2 what specific enforcement actions can be taken against 3 the various parts of the rule.
It is fairly clear-cut 4 if an organization does not report a condition known to 5 exist that enforcement action can be clearly taken, but 6 there are various lower-level actions such as improper 7 evaluation of items which are safetr significant, 8 improper procedures or lack of procedures.
But again, 9 these are not of the magnitude where it would really 10 prevent use of the rule in our activities.
11 COMMISSIONER AHEARNE:
Thank you.
12 COMNISSIONEH GILINSKY To what extent have we 13 used the rule?
14 NH. POTAP0YSt Well, we do routinely verify 15 that the Part 21 requirements in fact are applied to all 16 levels in the procurement chain.
We also verify that 17 the major companies supplying safety related basic 18 components do have procedures for evaluating safety 19 related concerns and that these procedures are being 20 used.
2r There has been considerable-improvement in the 22 last three years or so in this area by the major 23 suppliers of equipment.
When the rule first came out 24 there was a reluctance by Lany companies to report items 25 under Part 11.
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1 advising the utility of the problem and suggestinv that 2 the utility report the problem under 50-55-E if it was a 3 construction related deficiency.
Thereby the company
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4 would not go on record as having reported a deficiency.
5 Now this has changed and I think most of the 8 major companies now have effective systems for 7 evaluatin7 and reporting defects and these defects are 8 in fact being reported in increasing numbers.
9 COMMISSIONER GILINSKY:
Could you give me some 10 sense for the extent of reporting.
11 NR. POTAPOVS:
Like numbers of Part 21 12 COMMISSIONER GILINSKY:
Well, just something 13 that you think would characterize the situa tion.
14 HR. POTAPOVSt Iypes of items reported 7 15 COMMISSIONER GILINSKY:
Anything, j us t some 16 sense for it.
s 17 NR. COLLINS: Yes, just some feel for the 18 number of Part 21's say in the last year.
19 NR. POTAPOVS:
I rea117 have not made a 20 statistical study and what I would be doing would be 21 guessing.
22 CONNISSIONER GILINSKY:
That is all right.
I 23 ar not going to look up the answer.
24 (Laughter.)
25 NR. PERANICHs I am Mark Peranich from the ALDERSoN REPORTING COMPANY,INC, Mi>VIMINIQ ANL fiWe WmMT@A D.& R774)(tK.7a 9204EtTa
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Office of Special Enforcement and I am in the Division 2 of Program Development and the Chief of the Vendor 3 Special Programs Branch.
We did a computer run on the
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4 Part 21 reports a while back, this was about eight 5 months ago, and the number was like 300 Part 21 reports 6 were submitted since the effective date of the T regulation.
8 Initially I belle.ve the first year was in the 9 neighborhood of 90, the second year was about 150 and 10 we had a drop off in that next year.
We couldn't make a 11 com pa rable tabulation against 50/55E reports because we 12 did not summarize at one location.
Each region kept 13 their tabulations.
We were aware that a number of the
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. 14 reports that were coming in to satisfr Part-21 were 15 indeed coming in via 50/55E or the LEE route.
1e There seems to be, as Uldis said, a definite 17 increase now of the vendors reporting on their own, but 18 there still is a certain amount of reports that do come 1g in through the licensee.
20 CORNISSIONER GILINSKY:
Have we brought any 2t enforcement actions in connection with Part 21 other 22 than TMI related?
23 HH. POTAPOVSs No.
24 MR. PERANICHs We had the enforcement action 25 against BCW with a $100,000 fine.
ALDERSON REPORTING COMPANY,INC,
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The following correction to a statement by Mark Peranich on pp.13-14 was submitted by Mr. Peranich on Wednesday, April 21, 1982.
Number of Part 21 Reports received:
1977 27 reports 1978 64 reports 1979 98 reports 146 reports 1980 1981 159 reports TOTAL of 497 reports.
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1 MR. POTAPOVS:
That was TMI related.
2 MR..PERANICH:
Oh, TMI, I am sorry.
3 COMMISSIONER GILINSKY:
I said other than that 4 one.
5 MR. PERANICH:
No.
6' MR. POTAPOVSa We routinely issue violations 7 in this program against Part 21, but they a re primarily 8 procedural rather than failure to report.
They would be 9 items such as not imposing the Part 21 requirements in to procurement documents, not having the procedures in 11 place, not posting the notices on the bulletin boards 12 and these types of items.
But we have not processed any 13 civil penalty action against Part 21.
14 COMMISSIONER GILINSKYs Or even short of civil 15 penalties, notice of violation?
18 MB. POTAPOVS:
Other than procedural, we have 17 not really processed any Part 21 violations.
18 COMMISSIONER GILINSKY:
Thank you.
19 COMMISSIONER AHEARNEL One other question on l
20 tha t.
ron had just mentioned some of the problems you 21 saw with current Part 21.
Does that conclusion stem 22 from the inability to take action when you thought i
23 action should have been taken but in the absence of that 24 clarity you couldn't?
25 MR. POTAPOVS:
I don't know that I would ALDERSON REPORTING COMPANY,INC,
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1 really go that far.
There have been some questionable 2 e valua tions, or timeliness of evaluations which we have 3 come across in our reviews of Part 21 items, but whether
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4 those were of the severity where we would actually take 5 sction if we could, I am not really prepared to say.
6 If you will go to the next viewgraph.
A 7 growing part of our inspection program which recently 8 has become much mo.re significant is the conduct of 9 reactor inspections in response to NBC headquarters or 10 regional requests for follow-up of licensee event 11 reports, construction deficiency reports, Part 21 12 reports, allegations which are related to suppliers and 13 items which we identify during our own inspections of 14 different levels of suppliers.
15 Basically these inspections are wha t they call l
16 reactor inspections.
We attempt to verify the accuracy 17 of the completeness of information.
We look at th e 18 generic implications of problems that are reported to 19 us.
We verify that the cause of the deficiencies have 20 been properly established and identified.
We look at 27 corrective and preventative measures and then we also 22 try to analyze the program itself that may have l
23 contributed to this deficiency and the organization that 24 reported it and of course we evaluate the need for 25 taking enforcement action.
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1 May I have the next slide.
2 Another part of our program which has been 3 recently put in place is the equipment qualification 4 program.
That has three basic parts.
5 One is to review and evaluate equipment 6 qualification test plans and witness selected 7 qualification tests performed by licensee contractors.
8 Another one is to recommend and witness 9 independent verification tests by NRC contractors.
10 COMMISSIONER AHEARNE:
What contractors are 11 you speaking of here?
12 MR. POTAPOVS:
These would be laboratories tha$ we would select for doing replicate testing of 13
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14 qualified equipment.
15 COHNISSIONER AHEARNE:
Is that a program you 16 already are doing?
i 17 NR. POTAPOVSs It is a program that is 18 currently evolving.
Right now we are not involved in 19 the independent qualification testing phase of it and we 20 are also no.t.currentir actively involved in the 21 third-partr laboratorr accreditation program.
22 COHHISSIONER AHEARNE:
But focusing on the 23 second one, are there any specific NRC contractors at 1
24 the moment who are doing this?
25 MR. POTAPOYS:
Not in the sense that would be 1
ALDERSON REPORTING COMPANY. INC.
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done in this program.
There is a sizeable contract of 2 the NRC Office of Research with Sandia Labs to do some 3 testing of equipment primarily for research purposer.
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COMMISSIONER AHEARNE,t Hight.
5 ER. POTAPOVS:
The way this would 6 differentiate from that would be that tnese would be 7 replicate tests very closely duplicating the actual test 8 conditions of qualified equipment.
9 COMMISSIONER AHEARNE:
Do you expect that 10 Sandia would also then be the contractor that would be 11 used in this program?
12 MR. POTAPOVSs That is a possibility but it is 13 not definitely established that Sandia would be the 14 con tracto r.
15 CHAIRMAN PALLADINO:
Uldis, could I go back to 16 the previcas slida for a moment where you verify a
17 accuracy / completeness of information, cause of defects, 18 appropriate corrective and preventive measures.
If you 19 find EDything that might have a criminal aspect, what do 20 You do with regard to that?
2t MR. POTAPOVS.
Well, in that case we turn it 22 over to our investigation staff ---
23-CHAIRMAN PALLADIN01 Who pick it up.
24 MR. POTAPOVS
--- and they pick it up.
Or 25 vice versa, we interface with our investigation staff in ALDERSoN REPORTING COMPANY,INC,
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the course of following up allegations from the start, 2 or if va come across during our inspection of an item 3 that appears to be falsification or potential
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4 criminality, they would contact and notify our 5 investigative staff to pick up on that item and provide 8 them whatever technical assistance is necessary to 7 com plete that activity.
8 MR. COLLINSs All the allegations now that 9 come in on vendors or from licensees go first to our to Director of Investigations and Enforcement and then he 11 would make a decision on how what program would be put 12 in place to follow that up.
13 If the a11egation were more technical in 14 nature, then Uldis and his people would participate in 15 the follow-up on the allegation.
But, as Uldis said, he 18 may be out on an inspection and come upon something that l
17 should be followed up by an investigator and then of 18 course he would come back to our director and speak with Ig. him and make the sporopriate investigation.
CHAIRHAN PALLADIN0i Thank you.
20 2r MR. POTAPOVS: 'Can we go on to the next slide.
22 COMNISSIONER AHEARNE:
Let me just ask a 22 question.
I think you already answered the question but 24 let me just make sure.
Your last point on the equipment 2g qualification program-was auditing a third-party s
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I laboratory accredita tion program.
That has not yet 2 started yet, has it?
3 MR. POTAPOVS That is correct.
It has not
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4 started.
There is activit7 underway in that area with 5 IEEE. 6 COMMISSIONER AHEARNE:
I knew tha t 'we had done 7 a lot of work developing a proposed program but my 8 understanding was that that program was now in front of 9 the Commission for approval.
10 MR. POTAPOVS:
That is correct.
The 11 rulemaking is not complete in that the laboratories at 12 thic point are not required to be accredited.
But in 13 absence of that, what we would do is to do a 14 programmatic type of review-of the same laboratories 15 rather than auditing the third party activity.
16 MB. C3LLINS: But there is the ongoing program 17 working with the IEEE people to develop the 18 accreditation program 19 COHNISSIONER AHEARNEa Hight.
20 HR POTAPOVSt Another function which has been 21 broken out separate 1T to differentiate it from the base 22 program is the conduct of technical inspections of NSSS 23 and AE organizations to perform in-depth review of 24 selected pisnt systems or design activities.
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25 would be for the purpose of verifying conformance with i
ALDERSoN REPORTING COMPANY,INC,
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specific SAR/SRP or topical report commitments and to 2 assess the effectiveness of the design quality assurance 3 through direct inspection and measurement.
4 The only way this differs from the baseline 5 program is that we approach it rather than from a 6 programmatic standpoint we look at a fairly focused or T narrow scope of activities such as a specific system and 8 we do an.in-depth review of the effectiveness of the 9 quality assurance of the vendor in applying it to this 10 system, and of course if you find any problems during 11 this type inspection they are related to basic quality 12 assurance system weaknesses.
13 CHAIEHAN PALLADINO I don't quite understand 14 what you are telling us here.
Do you perform an 15 in-depth review of their design?
16 NR. POTAPOVS:
We don't do a complete 17 full-blown design verification per~se of, let's say, a 18 selected system but we do pick specific parts of that 1
19 process for a much more comprehensive review than we 20 would in a quality assurance program review.
21 CHAIRMAN PALLADINO:
Are you talking about 22 looking at the process of design?
23-NR. POTAPOVSt That is correct.
l 24 COMMISSIONER AHEARNE Could you give an 25 example.
That might help.
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MR. POTAPOVS:
There is one slide that will be t
2 coming up I think and we can spend more time on it where 3 I talk about some vertical design inspections.
4 COMMISSIONER AHEARNE:
It would fit under this 5 category?
6 MR. POTAPOVS Right.
So if we can just go on 7 to that.
8 COMMISSIONER AHEARNE:
Could you, before you o leave this, explain what kinds of measurements, direct 10 measurements you do?
11 MR POTAPOVS:
Well, direct measurement may 12 not be a very appropriate word for a design review.
We 13 have made some actual calculations and verifications on 14 selected activities that are part of a system design.
I 15 guess that is what I would call direct measurement.
16 COMMISSIONER AHEARNE:
But y.ou don't do any 17 actual testing equipment measurement?
18 MR. POTAPOVS:
No.
19 COMMISSIONER ROBERTS:
But you might likely 20 witness it.
21 MR. POTAPOVS We might likely witness it.
We 22 might also, if it appears necessary, get a consultant to 23 perform a test or a design verification of a particular 24 suspected problem.
25 CHAIRMAN PALLADIN0t With regard to design, ALDERSoN REPORTING COMPANY,INC,
23
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1 you take the standard review plan and you go pick a 2 system and you go see whether or not the design has 3 conformed to the standard review plan?
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.g Ms. POTAPOVS:
That is essentially correct.
5 Actually the way this would interf ace with the NRR e function would be that basically the NRR function would 7 be to review that the proper design commitments have 8 been made and not necessarily to examine the design 9 process by which these comnitments are met.
So we would 10 focus in the design process on the details of it.
11 CHAIRNAN PALLADINO:
I wasn't aware that you 12 did th a t.
13 NB. POTAPOVS:
This is a relatively new 14 activity and we have. just been doing this type of 15 inspection on a limited basis for the past year, but I 16 anticipate that we will get more involved in it.
~
17 CHAIRMAN PALLADINot How big a system would 18 you take.
I presume you do this on a selected basis.
19 HR. POTAPOYS&
The way we would approach it is 20 we would write essentially an inspection procedure 21 around an activity like, for instance, the last one we 22 did was in the area of a high-energy line break.
We 23 would select specific parts from the SAR and the 24 standard review plan of this type of design process 25 activity and we would develop first an inspection ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON D.C. 20024 (202) 554 2345
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module, an inspection procedure giving specific guidance i
2 to the inspectors and then we would apply this 3 inspection module against the major equipment design
(.
4 organizations.
5 There are several under development now in e this area.
We have not done very much in it, but it has 7 shown to be a rather productive way of measuring the 8 effectiveness of the design control.
9 CHAIRMAN PALLADINO:
How big a staff do you to have to ' perform all these f unctions?
11 MR. POTAPOVS:
Total onboard we have aboat 20 12 inspectors at this point.
13 MR. COLLINS:
We are budgeted for 27 i
14 professionals for FT-82 and a total, counting the 15 clerical and supervisory, of 31 people.
My budgeted 16 ceiling for '83 would be one more than that.
It would 17 be for 32 people.
18 CHAIRMAN PALLADINO:
It seems rather ambitious 19 but maybe I don't have a good feel for it.
I say the 2a functions seem rather ambitious for the size of the l
11 organization.
22 MR. POTA20VS:
They are.
CHAIRMAN PALLADINO:
Narbe I shouldn't have 23 24 said that.
25
( Laugh ta r. )
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l ALDERSON REPORTING COMPANY,INC,
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COMMISSIONER AREARNE:
I am still not clear on 2 this measurement aspect.
I understand the 3 recalculation, but you mentioned that they may witness a
(
4 measurement or you may ask a consultant to do 5 something.
What kind of consultant have you employed to 8 do what?
7 HR. POTAPOYSt We have any employed any 8 consultants at this time.
We are making some inquiries 9 in this area recognizing that when we get more involved 10 in this activity there will be a need for more than what 11 we have in the way of talent.
12 May I have the next viewgraph, please.
13 Another program function is the audit of all 14 NRC approved third-party inspection a-tivities.
This is 15 primarily the ASME activity which includes the National 16 Board of Boiler and Pressure Vessel Inspectors, 17 authorized inspection agencies and authorized 18 inspectors.
There is also the Coordinating Agency for 19 Supplier Evaluation, CASE, and there is another one 20 which is American Institute of Steel Construction, which 21 -we have not done verr much with at this point.
22 COHNISSIONER AHEARNE:
I am familiar with the 23 Boiler and Pressure Vessel Inspectors.
Could you say a 24 few words about the authorized inspection agencies and 25-the authorized inspectors?'
ALDERSON REPORTING COMPANY,INC,
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HR. POTAPOVS:
They are all part of the ASME
(
2 system in that the whole program is cremised on the 3 manufacturers being surveyed by the 7.?HE survey team and
(
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4 then the maintenance activities of the code compliance 5 being policed through use of a contractor which would be 6 the authorized inspection agencies, state agencies, 7 which in turn employ the authorized inspectors.
8 COHNISSIONER ROBERTS:
But in practice these 9 are primarily insurance companies.
10 HR. POTAPOVS:
That is correct.
11 COMMISSIONER ROBERTS:
Now you can use the 12 state.
13 HR. POTAPOVS:
That is correct.
14 COHNISSIONER ROBERTS:
I mean the manufacturer 15 may choose to employ the state, but in practice 95 16 percent of the time it is insurance companies.
17 HR. POTAPOYS:
Right.
18 CONNISSIONER AHEARNE:
And the authorized 19 inspectors are employed by ---
20 HR. POTAPOVS:
Employed by the insurance 21 companies.
22 Can I have the ne xt viewgraph, please.
23 This gives some idea of the workload.
There 24 are primarily four sajor nuclear steam systems 25 suppliers, about 15 architect engineering organizations.
ALDER $oN REPORTING COMPANY,INC, ass vmcm AR MMWN@T@N D.@. SUB4 (878 DMXG
27
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t o counting the different locations of some of these 2 organizations which work essentially inde pe nde n tly.
3 CONMISSIONEB BCBEBTSs Well, f or instance, if 4 Bechtel has six offices in the U. S. would you audit all 5 sir?
6 MR. POTAPOYSt We would audit all six of them.
7 COMNISSIONER B0BERTS:
I understand.
8 MR. COLLINS They all operate differently.
9 COMMISSIONER ROBERTS:
Yes, and that applies 10 to manufacturing locations also, correct?
11 MB. POTAPOVSs That is correct.
12 MR. COLLINS That is correct.
13 CHAIRMAN PALlADINO:
When you say architect 14 engineer organizations, and say 15,. you don't include 15 six for Bechtel or do you?
16 MR. POTAPOVS:
W e ll., I am not sure that there s
a 17 are six of Bechtel.
18 CHAIRMAN PALLADIN0s Well, whatever the numbed.
19 MR POTAPOVSt They are included in there.
20 CONNISSIONER AHEARNEL As different ones.
21-MH'. POTAPOVSs As dif ferent ones.
There are 22 at least three.
There is Gaithersburg and the San 23 Francisco and the ---
24 MR. COLLINS: There are actually four, 25 including the Houston effort.
ALDERSoN REPORTING COMPANY,INC,
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MR. POTAPOV5s That is right.
We have a 2 temporary resident down in the Houston area on the South 3 Texas transition team activity.
(
4 We also audit a number of service 5 organizations which are consulting agencies, computer 6 service organizations and any agency that contracts 7 either directly with the utility or indirectly th ro ugh 8 an A/E to perform safety related work.
There is a 9 larger number of these type of companies coming into 10 being.
We are not auditing them all, but we do audit a 11 few of the:.
12 We also look at fuel suppliers.
There are 13 five major ones.
14 We reasonabir routinely inspect about 200 15 component aanufacturers and an assorted number of 18 third-party organizations.
17 The statistics that am showing th ere, ther 18 are for calendar year 1980 but they should not have 19 - changed very much.
We do about 250 inspections a year 20 of 160 to 180 different vendors.
The site hours are as 21 shown,and typically we come up with a number of 22 non-conforsances. in these inspections.
23 CHAIRMAN PALLADIN0s What do you mean by 24 " direct on-site hours"?
25 MR. POTAPOVS:
Those would be actually ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W WASHINGTON. D.C. 20024 (202) 554-2345
29 l
1 inspector hours spent at the vendor's facility.
2 Typically one of our inspectors makes anywhere from i
3 about 16 to 20 inspections in a calendar fear.
Some of
('
4 these are team inspections, especially at the 5 architect / engineer organizations.
At larger vendors we 6 send more than one, but some of the coaponent 7 fabricators are inspected by a single individual.
8 COMMISSIONER AHEARNE:
When you have 9 non-conformances identified, did any of these lead to 10 enforcement actions?
11 MR. POTAPOVSa Well, we call non-conformance 12 enforcement.
.So basically all of those are 13 COMMISSIONER AHEARNE Well, let me put it in 14 different terminology.
We have just recently finished 15 an enforcement policy paper and that has some fairly 16 explicit descriptions of what enforcement actions are.
17 In that co n t ex t.
18 MB. POTAPOVS:
Well, it is my understanding 1g that enforcement policy is not directly applicable to 20 the non-licensees.
21 COREISSIONER AREARNE That is probably 22 correct, but that doesn't answer whether these led to 23 any enforcement actions.
Obviously you could get there 24 in either of two ways.
One could have been Part 21 and 25 rou have already answered that.
The other could be tha t ALDERSCN REPORTING COMPANY.INC.
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you have identified a non-conformance and it led a trail 2 back to a licensee.
3 NE. POTAPOVS:
That has happened and an
-(
4 enforcement action has been taken against the licensee 5 as a result of some of these.
6 COMNISSIONER AREARNEs That has happened?
7 NR. POTAP0YS It has. happened.
Typically 8 though the problem is resolved with the vendor and we 9 request corrective action responses and they are 10 received and verified.
11 MR. COLLINS: I would like to add that number
'nclude any i
12 for the direct on-site hours, that does not 13 investigative or any effort required on a technical part 14 on alle~gations because that would come under a different 15 category.
This is direct inspection hours of a program 16 and that number of hours is substantial, too.
17 CHAIRMAN PALLADIN0s If you find a 18 non-comformance that results from a lack of a licensee's 19 placing appropriate requirements on a vendor, is that 20 the trail that you indicate would lead to an enforcement 21 action on the-licensee?
22 MR. POTAPOVS:
That is correct.
That could be 23 one.
Another one would be, and I think we have had a 24 case where we found a problem in a vendor's shop which 25 the licensee was aware of but did not report under the ALDERSON REPORTING COMPANY,INC, RJFMtl(K+FiLTD -MYR
39 1
reportinc system that he is committed to.
t 2
ER. COLLINS:
The normal process, Mr.
3 Chairman, is once the inspection report for a particular
\\
4 vendor is completed, if in the course of that inspection 5 it pertained to a particular licensee, his docket number 6 is so noted in the inspection report.
A copy of that 1
7 inspection report is forwarded to the appropriate region 8 for appropriate action on that licensee.
So that there 9 is a double check.
The vendor would receive his 10 inspection report and be asked to comply to the items of 11 non-comforance, the licensee would become aware of it 12 from the appropriate regional office and NRR would be 13 aware of it because a copy would go to NRR for the i
14 docket file in NRR.
15 3R. POTAPOVS:
May I have the next slide, 16 please.
17 This is sort of a summary of the evolution of 18 the program functions as they now exist.
As I mentioned l
l 19 before, when the program was first established it was 20 primarily for verification that these organizat' ions l
21 supplying equipment did in f act have a quality assurance 22 program in place.
23 At the present time most of our effort is 24 spent in the reactive area which is what I described 25 before, tracking and following and verifying corrective ALDERSoN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 2002_4 (9 8 5_54 2345
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actions on identified problems.
1 2
It is not that well separa ted from the C A 3 programmatic part'in that if we identify problems in the
(
4 program as a result of a product deficiency we still 5 take enforcement action to get the QA systematic problem 6 corrected.
So there is an inter' face there.
7 When I say 33 percent QA program, these are 8 primarily inspections started from the programmatic 9 approach.
Then we do have some equipment qualification 10 activity ongoing now, and the technical inspections 11 which I mentioned about the specific in-depth design 12 type of inspection comprise about 10 percent of our 13 activity.
14 COMMISSIONER AHEARNEs Uldis, could you say a 15 few words about the reasons for this change?
I could 16 imagine at least th ree.
One would be that you have a s
4 17 different staffing level and that has led to this big 18 shif t of percentage, or that there was an increasing 19 number of 111egations which lead 'to reactive, or that
~
20 yon found the CA programs so good that you were 2t increasing the----
22 MR. POTAPOVS:
Well, those are all valid
~
23 reasons and were in f act the basis for this evo1ution, 24 the fact that five years ago, or six years ago many of 25 the companies that we inspected did not have a very well ALDERSoN REPORTING COMPANY,INC,
33 1
defined quality assurance program in place.
At this 2
time most of the major companies do in fact have a very a adquequate quality assurance program.
N.
When was the revision 4
COHNISSIONER ROBERTSs 5 of Section 3 of the ASME Code which took in a great e number of venders which were previously not covered.
7 MR. POTAPOVSa That is right.
If a vendor 8 does have the ASEE certification in an area that we are 9 inspecting, we would concentrate primarily on the 10 quality assurance program that he has which covers 11 non-ASME activities, which would be other than the 12 pressure boundaries, like in a valve manufacturer it 13 would be the functional parts of the va-1ve or the pump 14 or whatever.
That is one of the reasons.
15 The other reason of course is that there is a 16 large in the complexion of the industry.
Many of the 17 manufacturers which had a very level of activity five or 18 six years ago have really either gone out of business or 19 had. such a lot level that we do not put a lot of 20 inspection effort into that.
21 Also, there has been an increase in the 22 reports of problems identified with either operating 23 sites or construction sites or allegations from the 24 public.
So all of these are reasons.-
25 Can I have the ne xt slide, please.
At.DERSoN REPORTING COMPANY,INC,
_ ED VIRGINlA AV1 @.W., WASHINGTON. D.C. 20024 (202) 554-2345
34
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1 This is sort of a summary of the reactive 2 inspection activity.
3 No. 1 is basically the sources of reactive 4 items and the people that we interface with.
They would 5 be the Regional Offices, the Office of Inspection and 6 Enforcement headquarters, the Office of Nuclear Reactor 7 ~ Regulation, other government agencies, such as the FBI 8 and the public, which would be in the form of 9 allegations.
10 COMMISSIONER AHEARNE:
Is there any one of 11 those sources that dominates the rest?
12 MR. POTAPOVS:
Well, I would say that the NRC 13 Regional Offices by far are the largest inputters to the 14 system, and they could be either as a result of 15 information provided to-the regional office by the 16 licensee or by an inspection finding that the site 17 inspector has made, the resident inspectors, whatever.
18 Of course we classify the reactive items as 19 shown in item 2 there.
20 A little bit about the reactive item 21 processing and close-out.
When we do get these requests 22 to do a certain follow-up we will assign priorities to these items and these are based on safety significance 23 24 considerations.
25 Also on the performance history of that ALDERSoN REPORTING COMPANY,INC,
35 1
particular vendor that is involved, we do maintain what 2 I call a reactor file on most suppliers which has in it 3 the reports concerning product deficiencies by that
('
4 manufacturer and also our own inspection results and se 5 typically review that before assigning pricrities.
6 Also, we have to identify and define 7 inspection responsibilities because many of these items 8 it is not clear who to inspect because it could be an 9 interface between a manufacturer or the to architect / engineer or their consultants or other 11 organizations.
12 Of course, a big job is planning and
~
13 scheduling inspections.
We try to consolidate as many
\\
14 items as we can in one inspection.
Then th e inspections 15 are performed and the results are evaluated.
Then 16 typically we put'out inspection reports which are then, 17 and I will go into this a little bit later, also 18 duplicated in NUREG 0400 which is a white book which is 19 a quarterly publication supplied to the public on a 20 subscription basis.
21 Enforcement action we talked a little bit 22 about.
23 Then we also have feedback to the requestor of 24 these items.
When we close out an item we write a meno i
25 and transmit it to the requestor with the inspection ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554-2346
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1 report and our recommendations of any follow-up.
Some 2 of these casult in some general actions such as possibly 3 bulletins or information notices.
4 Our typical workload, we are currently doing 5 about 300-plus reactive items a year.
8 May I have the next slide, please.
7 This we pretty much discussed and that is the 3 enforcement.
9 COMMISSIONER AHEARNE4 The seactive items, 10 when you had previous charts you had inspection effort 11 applied and inspections performed yearly.
That would 12 not count reactive items?
13 NR. POTAPOV5t Yes, it would.
k 14 COMMISSIONER AHEARNEL It would?
15 MB. POTAPOVS:
Yes.
18 COMMISSIONES AHEARNEs My puzzlement is you 17 have "300 separata items (requests) per yea r," but the 18 inspection effort is 250 a year.
19 NR POTAPOYSt Okay We consolidate a number l
20 of these.
Like we mar close out five or six items in 21 one inspection because we have vendors that may have as 22 many as 20 or 30 reactive items on fila.
We do have a 23 backlog and we obviously cannot accommodate all of these l
24 requests fully.
So they are handled on the order of 25 priority.
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COMMISSIONER AHEABNE:
That is where that 2 first " assigned priorities" comes in?
3 MR. POT 3POVS4 That is correct.
Some of them 4 are given a fairly low priority and if no additional 5 information is developed by the time we get to it then 6 some of these are closed out nimply by a memo to the 7 originatoc.
8 The next slide, please.
9 This again, we pretty much discussed the 10 enforcement philosophy.
So we can go to the next one.
11 This is a typical page.
Well, actually it is 12 a composite of our reactive item tracking system to 13 provide some sort of i summary as to how we track these 14 items.
We do have identification of the inputting 15 organization, a description of the subject and the 16 assigned inspector.
We put a due date on it for i
J 17 priority.
After the inspection is done, there is the I
18 reference inspection report.
If there was a memo i
1g unitten,as in most cases, then we also reference that.
We are currently trying to put this 20 2t information into a computer because it is getting too 22 unw ield y to be handled mechanically.
23 Can I hive the next slide, please.
24 This is a typical type of an item which we 25 would track and follow up on as a reactive item.
In ALDERSoN REPORTING COMPANY,INC, M
38 1
this case it was a Part 21 report by the NSSS agency 2 concerning a possible misorientation of some integral 3 heads opposite tha inlet flow line on lubricant oil
(
4 coolers.
We followed this up with the vendor.
5 The main thing that I wanted to demonstrate 6 out of this is that we did identify in this case that 7 the problem did have generic implications which had not 8 been assessed.
9 If you will go to the next slide, please.
10 If you look at item B on the Notice of 11 Nonconformance it states:
" Contrary to the above, a 12 determination was not made, in regard to identified 13 misorientationof lube oil cooler heads on high pressure 14 make-up injection pumps at WPPSS-WMP 1/4, of whether 15 similar deficiencies existed in equipment s up plied to 16 other locations."
i 17 Then if you will go to the next slide.
18 COMMISSIONER AHEARNE:
Wait.
Let me ask you a 19 question on the terminology you use here.
This is nov 20 being sent to the Bingham-Willamette Company?
21 5R. POTAP0Y5t That is correct.
That is 22 enforcement correspondence.
COHNISSIONER AHEARNE:
Hight.
It says 23 24 "Noncomformances with these requirements."
Is the 25 implication that they are requirements on the l
I ALDERSoN REPORTING COMPANY,INC,
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1 Bingham-Willamette Company?
2 MR. POTAPOVS Basically the implication is 3 that the esquirements that ara committed by that company 4 in their procurement documents include Appendix B to 10 5 CFR 50.
We are treating th ese as commitmen ts.
I guess 6 requirements may not be the exact terminology that
(
7 should have been used and I guess you are picking it up.
8 COMMISSIONER AHEARNE:
I as trying to track 9 the terminology tha t we used in th e ---
It is a committed requirement 11 is what I am saying.
Appendix B is an NRC requirement 12 to licensees but it has been committed to by the company 13 in their procurement documents.
14 COMMISSIONER ROBERTSa When BEW issued a 15 purchase order to Bingham-Willamette they agreed to 16 sccept those requirements.
That is a contractual 17 obligation.
18 MR. POTAPOVS4 That is one thing that we 19 always verify that that is in fact a valid commitment.
20 So basically the enforcement action is taken 2t against the requirements of Appendix B.
22 If you go to the next slide you can see that 23 the corrective action was an extensive review of 24 Bingham-Willamette contracts.
"As a result of this 25 review we have determined that there is a possibility ALDERSoN REPORTING COMPANY,INC, JEG-l
40 t.
1 that similar defects do in fact exist.
for those 2 customers, an addendum to the inssruction manual will be 3 issued stating.the problem and identifying the correct 4 head orientation."
5 So basically that is just an example of a e generic corrective action which otherwise would not have 7 taken place.
8 COMMISSIONER AHEARNEa You say here in several 9 places that actions will be taken in this particular
- 10 case.
Is this something you are saying will be taken 11 because you and Willamette have agreed that this will 12 happen, or is this an order to Willamette that they must 13 do this?
14 HR. POTAPOVSs That is their commitment to us.
15 COMNISSIONER AHEARNE:
You mean they have 16 agreed they will do this?
17 MR. P3TAPOVS:
No, that is their letter to us.
18 COMMISSIONER AHEARNE:
Oh, I am sorry.
I see.
19 ER. POTAPOVSi Of course, the next time we are 20 out there we will verify the fact that this in fact has 21 been done.
COMMISSIONER AHEARNE4 Okay.
Sorry.
22 23 MR. POTAPOVS:
Can I have the next slide, 24 please.
This is a little bit more about the inspection 25 ALDERSoN REPoR ANG COMPANY,INC,
41 1
philosophy that we are using in these design inspections 2 that we discussed hera previously.
This is a listing of f,
3 typical activities at an NSSS or a design office.
Then 4 all we are saying is that we take a verical slice 5 through these activities using as an example either a e system or a design process or it could be even a 7 component.
In this case it is the containment spray 8 system.
9 We would develop an inspection module around 10 the containment spray system again drawing on the SAR 11 commitments for a specific project and looking at the 12 standard review plan requirements for that particular 13 project and we would develop an' inspection plan.
Then 14 we would go into detailed inspection in as many of the 15 numerical activities there as we can.
16 COHNISSIONER AHEARNE:
By going into 17 inspection in the numerical activities, do you mean that l
18 you would redo some of the calculations?
19 MH. POTAPOVS:
We have done this in some cases l
20 but not extensively.
This is a rather involved and 21 comple'r uniettaking and we would do what we can with the l
22 resources that we have and an inspection plan would take 23 that into consideration.
24 COMMISSIONER ROBERTS:
It is a random sample 25 audit type thing, is that not correct?
AL.DERSoN REPORTING COMPANY,INC,
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.5R. POTAPOVS Ihat is exactly right.
We find r
2 this to be more productive than simply looking at the 3 programmatic implementation of the Q A requirements 4 because when you start looking into the detailed design 5 activities then you find problems with it.
We back into 8 the Q A requirements which were either not effective or 7 vere not adhered to during the controlled design process.
8 CHAIRMAN PALLADINO:
You do go into the design 9 basis and what inputs they have?
10 MB. POTAPOVS That is correct.
Like computer 11 programs, va would verify that the inputs that are 12 listed are proper and consistent.
13 CHAIRNAN PALLADINO&
Now you have a tremendous 14 population out there counting all the A/E's and the 15 nuclear steam suppliers and the many vendors.
16 MR. POTAPOVS Yes.
17 CHAIRMAN PALLADIN0s This is an important 18 activity.
What fraction of all the activities going on 19 are you really sampling here?
20 MR. POTAPOVSt Very,very small.
2t CHAIRMAN PALLADIN0s The question I. guess I 22 have in my own mind is have we assessed whether or not 23 we are doing an adequate sampling?
What I am getting at 24 is if it is worth doing then we ought to do it right, 25 and if it is not worth doing, then mayhe we oughtn 't to ALDER 5oN REPORTING COMP /.NY. INC,
43 1
do it at all.
I am not saying that I have a decision to 2 give.
3 MR. POTAPOVSs If I can say, I think we are in
(
4 the assessment process.
I think so far we are doing 5 what I would call pilot programs in this trea.
6 ER. COLLINS:
We have not gained enough 7 experience yet to answer your question of should it be 8 enlarged in scope.
9 CHAIRMAN PALLADIN0s Okay.
As a pilot program 10 I could see it being 11 COMMISSIONER ROBERTSa Let me make an 12 observation.
I can't comment on whether the effort is 13 ad aquata, but the f act that an organization is subject 14 to this type of audit and review is a powerful tool.
CHAIRMAN PALLADINO4 Oh, absolutely.
That is 15 16 what I was getting at.
If it is such a powerful tool, 17 it seems we are attacking such a small sample that maybe je we are not being as effective.
l Ig COHNISSIONER ROBERTSa That very well could be.
20 CHAIRHAN PAL 1ADINO But as a pilot program I 21 could see where he could bring about ---
22 COMNISSIONER ROBERTSa I am not saying that l
23 everybody involved is 100 percent ideal, but it is a j
f 24 powerful level.
I 25 CONNISSIONER AHEARNE4 It is the IRS system.
ALDERSoN REPORTING COMPANY,INC,
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1 COMMISSIONER ROBERTS:
Yes, exactly.
2 (laughter.)
3 MR. POTAPOVSs It is an area that I feel is 4 definitely worth axploring, expecially in the last few 5 numbers like the field changes and analysis of installed 6 systems.
This is another area where we are interfacing 7 more with our site people in that we have found that 8 many of the interf ace problems in the architect / engineer 3 activities especially can be traceable to the disiogue 10 that they have between their own field operations and 11 the hope office operations.
So we are trying to 12 concentrate more activity in that interface.
13 We are doing what we call periodic assessment 14 of our own inspection history of the 15 architect / engineering organizations that we inspect and 16 then we intend to select a specific active project which 17 is currently under construction and so a thorough 18 inspection of the interfaces between the as-built and 19 the home office design activities.
We a re developing i
20 some procedures right now for this activity.
l l
21 COMMISSIONER AHEARNE How do you choose the 22 people that you audit?
23 HR. POTAPOVSs Well, we audit all of the l
active A/E organizations.
For these select activities I 24 25 quess we look at the ---
l i
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1 COMMISSIONER AHEARNE:
You mean you audit 2 every one every year?
3 MR. POTAPOVS Architect /angineers, we audit
(
4 them more than once a year.
Typically the active 5 organizations such as the larger A/E's we audit on a 6 three-times-a-year. basis, two or three times a year.
7 C05HISSIONER AHEARNE:
How do you choose in 8 which area you are going to.make this vertical slicc?
9 MR. POTAPOVS:
Well, we are somewhat limited 10 in th a t va have to, first of all, develop a procedure 11 for doing it.
Right now we have a couple of procedures 12 in the works.
One has been applied.
What we would do 13 once we develop a procedure is to apply that procedure 14 to all of the A/E organiza tions.
Then if the procedure 15 is productive we may repeat it later.
If not, we may 16 discard it and develop a new procedure using a new 17 system or activity.
18 COMMISSIONER AHEARNE:
Currently then the 19 containment spray system is the one that you have 20 developed?
21 MR. POTAPOVSt No, this is a sample.
The one 22 that we have used I believe was around a high-energy i
23 line break and we have a draf t procedure developed in 24 that area.
We also have done a series of inspections in i
25 computer code usage and development and this has been ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
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1 applied to all of the major organirations.
2 May I hsve the next slide, please.
3 This is just a take-off on one of these 4 horizontal lines on the previous chart.
It represents 5 what they would do-in detail, for instance, in the 6 controlled procurement process at an architect / engineer 7 or NSSS office.
These are the type of things that we 8 would select for sample and the type of things we would 9 look at in the procedure.
to The next slide, please.
11 This is a cover page of the Licensee 12 Contractor snd Vendor Inspection Status Report.
This 13 was recently completely overhauled in a different 14 format.
At this point we call this our integrated 15 reporting system in that basically it duplicates the 16 inspection report.
17
'Je developed a standard format that we use to 18 document our findings and the standard format consists 1g of about a two-page report.
If it is a more complicated 20 problem it may be ss sant as five pages of written text 21 and then handwritten document listings.
But basically 22 the report is sent to the licensee and it is also 23 published in this quarterly.
24 May I have the next slide, please.
25 This is the typical f ron t page or the first ALDERSoN REPORTING COMPANY,INC,
47 1
page of our inspection repcrt which also is the white 2 book input., So basically it is a duplicate and it 3 contains more information than it did before.
It
(
4 identifies the vendor thoroughly and it defines his 5 involvement in the nuclear activity.
Also it provides 6 the basis and the scope for an inspection and then if 7 you would lift that slide a little bit it also indicates 8 the plant site applicability.
9 COEMISSIONER AHEARNE:
When you say "before,"
10 what vis the switch-over time?
11 3R. COLLINS: April 1st of this year.
12 MR. POTAPOVS:
This is the first issue.
Since 13 then there should be two more issues out.
14 COMMISSIONER AHEARNE:
But this would include 15 your new format.
16 MR. POTAPOVSs Except that it does not have 1
4 17 the plant site applicability in that one.
We added that 18 since.
19 COMMISSIONER AHEARNEt Here is my point.
I 20 noticed that Volume V, No. 4, which is the one you 21 referenced here, covers October to December, is that 22 right?
23 MR. POTAPOVS:
It should be quarterly, yes.
24 COMMISSIONER AHEARNE But I think that.
25 previous slide showed October to December.
Volume 5, ALDERSoN REPORTING COMPANY,INC,
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No. 2 covered April to September.
2 (Laughter.)
t 3
5R. COLLINS: During the transition period it
(
4 was decided that rather than put out a quarterly report 5 for that transition period, I made the decision to hold 6 that quartar and put two quarters together and that is 7 why that one shows from April ts September.
8 COMNISSIONER-AHEARNEa What happened to No. 3 ?
9 3R. COLLINSs There was no No. 3.
10 (Laughter.)
11 MR. COLLINS:
But I think what is of 12 signifirance on here that has been added to this form is 13 what we talked about earlier, and that is the plant site 14 applicability, in that the dockets are identified and 15 then the region gets a copy of this report to take to appropriate action against those docket numbers.
Of 17 course, it will go in the PDR that way, too.
18 ER. POTAPOVS:
If we can have the next slide, 19 that shows the second page, and the subsequent pages of 2g the report are similar.
It simply lists a section on l
21 violations and non-conformances.
Then we also have 22 unresolved items and we always track previous inspection 23 findings until such time as they are closed out and i
24 satisfactory action has been taken.
So those may be l
25 carried until we have verified corrective action.
ALDERSoN REPORTING COMPANY,INC,
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1 COMMISSIONER AHEARNE:
This is probably 4
2 obvious but I am missing it for the moment.
You have 3 Plant Site Applicability and you have reference to plant
(
4 dockets.
Are all the plants that you inspect linked 5 then to a docketed application?
6 MR. POTAPOVS:
All the vendors that we 7 inspect?
Yes, but we may not always do this.
In some a cases we do generic inspections and would not 9 necessarily identif y plants.
We would have just simply 10 said "Not Identified" under tha t Plant Site 11 Applicability if we do it basically on the generic level 12 and there is no real significance of why you would 13 identify a plant.
14 Can I have*the next slide, please.
15 This is simply a regional organization chart 16 which shows where we are located.
Basically the Vendor 17 Inspection Branch is part of the Division of Vendor and 18 Technical Programs and fits in the chart as shown.
19 We have three sections in the branch.
One is 20 the Reactive and Component Program Section.
Basically 21 that is the organization that is responsible for all of 22 the reactive inspections..
23 CHAIRMAN P ALLADINot Which block is this?
I 24 as having trouble following it.
25 MR. COLLINS: In the middle of the page at the ALDERSON REPORTING COMPANY,INC,
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1 bottom.
t 2
CHAIRMAN PALLADINO:
Thank you.
3 MR. POTAPOVS:
We currently have three l
(
4 sections in the branch.
5 The next slide shows the branch organization 6 and the types of individuals that we have in these 7 sections.
8 The Reactor Systems Section is currently eight
~
9 authorized positions.
We have six onboard.
Basically 10 those are the inspectors that are involved with the 11 architect / engineer, nuclear steam systems, supply 12 operations and the design inspections.
13 The Equipment Qualification Section is fully 14 staffed at this point and the activities there we are 15 starting to get into laboratories and look at the test to p erfo rm ance.
17 The biggest section is the Reactive and 18 Components Pregram Section which is responsible for all 19 of the reactive inspections plus also inspections of a 20 prgramma tic nature of major component suppliers such as l
21 reactor vessels, pumps, valves, et cetera.
22 By disciplines there we have four mechanical 23 engineers, two electrical engineers, one metallurgical 1
24 engineer and five positions for reactor engineering 25 qualfications.
Those are basically specialist personnel i
t i
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in either Q A or NDE or some other disciplines.
(
2 Ihat pretty much completes my presentation and 3
I would be glad to answer any more questions that you
(~
4 may have.
5 CHAIRMAN PALLADINO:
Well, you are certainly 6 doing some interesting and important work tha t I wa sn ' t 7 aware was going on.
8 COMMISSIONER ROBERTS I think we ought to be 9 aware of how important what they do is.
10 CHAIRMAN PALLADINO:
Yes.
I am most grateful 11 to you and Commissioner Roberts for bringing it to our 12 attention.
This a uditing of the design fun ction was 13 something I didn't appreciate was part of your activity 14 and could have an important impact.
15 Do you have any questions?
~
16 COMMISSIONER ROBERTS:
No.
17 COMMISSIONER AHEARNE:
I have a few.
18 CHAIRMAN PALLADINO:
All right.
19 COMMISSIONER AHEARNE:
First, I would like to 20 refer to the Volume 5,No. 2, the April to September, 21 and in particular the Brown and Root, Incorporated, 22 section.
There are a couple of things I am puzzled by 23 and perhaps you can explain.
This is more in the 24 general nature of the approach taken.
25 Under "Noncomformance" it lists:
"This is the ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2346
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1 fourth inspection in which corrective actions or 2 preventive measures were not completed as conmitted."
3 I wonder why that would be the case?
I 4 wouldn't expect to see, for example, in a review of an 5 operating plant in an ICE report s ayin g this is the 6 fourth time we have been there and the corrective 7 sctions weren't completed.
8 MR. POTAPOVSs It may not be, and I don't 9 think it was, the same action tha*, was dragging on for 10 fou r consecutive inspections.
If I recall, and it has 11 been a while, there were a number of cases where ther 12 were not completely timely with their. commitments.
In 13 other words, when they would make a commitment to either 14 change a ococedura or rado something by a certain time, 15 they failed to do so and failed to advise us beforehand.
16 If I recall, we had several meetings with i
4 17 Brown and Root about that subject and we did eventually 18 reach some accommodation.
But it was what I guess you 19 could term somewhat escalated enforcement.
20 Normally if a vendor does not meet a 21 commitment in time, the next time we will write him a 22 letter requesting that he discuss with us why he failed 23 to meet the commitment and typically this letter would 24 be signed by the Regional Administrator.
That is the 25 first level of escalated enforcement ". hat we use.
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1 COMMISSIONER AHEARNE Are you saying tha t it 2 is unusual for four times to come around?
3 MR. POTAPOVSs Yes, it is.
('-
4 COMMISSIONER AHEARMEs Another point that is 5 mentioned in here, they say :
"The only current nuclear 6 design activity, for example the South Texas Project, is 7 not committed to the QA program."
8 MR. POTAPOVSa Well, I assume tha t that is the 9 QA program described in their topical report.
10 COMMISSIONER AHEARNE:
Right.
11 MR. POTAPOVS:
They may have their own program 12 which is somewhat different.
No t all utili ties accept 13 the topical report of a vendor.
14 COMMISSIONER AHEABNE:
I see.
That would be 15 the interpretation.
16 MR. POTAPOVS:
So in those cases we would do 17 the inspection against the utility 's 'Chapte r 17 in their 18 PSAR or wha tever.
19 COMMISSIONER AHEARNE:
In the section "Other 20 Findings or Comments" you went on to says "It was not 21 apparent that the present program" -- this is the 22 quality assurance program -
" adequately addresses 23 recurring design errors, errors for needed corrective 24 action.
Ihis area will be assigned further during a 25 future inspection."
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Hindsight is magnificently clear usually.
2 Would it be normal that if you find something, as you 3 say, that doesn't adequately address recurring design
(~
4 errors, would it be normal then to put that on file for I
5 a future follow-up or would it be more normal to 6 immediately follow up on that?
7 MR. POTAPOVS4 The way we use that particular 8 phrase is if we get into an area and we either do not 9 have sufficient time to finish it or if we have some 10 findings in the area which we are not comfortable with 11 but we cannot specifically develop a nonconformance in 12 that they are close enough to tne program commitments 13 where a nonconformance doesn't exist.
14 Wu use that as a tool to both put the vendor 15 on notice that we are going to be looking at it more 16 next time and in fact to also give us an outstanding 17 item list, and our inspectors track th e se, that next 18 time he should look at that area again.
19 COMMISSIONER AHEARNE:
So you are saying this 20 does not immediately indicate a very high magnitude o'f 21 con cern ?
~
22 MR. POTAPOVS:
That is correct.
It indicates 23 that en inspector had some doubts in that area but not a 24 sufficient basis to write a nonconformance.
COMMISSIONER AHEARNE:
The second question 25 ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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sort of relates to this.
I went through a list here and 2 I wasn't clear on when you would drop or when you would 3 pick up a company.
You say you handle all the A/E firms.
.~-
4 MB. POTAPOVS That is correct.
5 COMMISSIONER AHEARNE:
Do you handle companies 6 like PGCE that did their own A/E work?
7 MR. POTAPOVS:
No, we don't.
That is regional 8 inspection function.
PGCE, TVA, Duke, those are handled 9 by the ---
10 MR. COLLINS: What we are doing in Region IV 11 right now, Commissioner, is that we had a licensee who 12 just changed over to do his own design work.
13 COMMISSIONER AHEARNE:
Who was that?
14 NR. COLLINS:
That was Arkansas.
They used to j
15 have Bechtel doing their design work for them and ther 16 undertook now to implement their own engineering l
17 department.
18 My people are working with Uldis to try to 19 develop a module inspection program specific for the 20 utility's design but taking the benefit of his 21 experience on the architect / engineers and folding that l
22 into our program.
l l
CHAIRMAN PALLADINO Do the other regions take 23 24 advantage of the experience gained in your region on 25 this?
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F.R.
POTAPOVS:
They have.
2 CHAIRMAN PALLADINO:
I mean where the utility 3 acts as his own.A/E.
( '
4 MR. POTAPOVS Not particularly, but we have 5 actually provided on a number of occasions our design 6 inspection people to regional inspection teams looking 7 at site design activities.
8 MR. COLLINS:
What I would hope would fall out 9 of our effort, together with the special inspection 10 program that I have going on at South Texas, is that we 11 would make recommendations to the Program Division and 12 to ICE headquarters to fold that type of program into a 13 future inspection effort.
14 COMNISSIONER AHEARNE What kind of an overlap 15 or interaction did you have with Region V with respect 16 to'PGCE and their a rchitect/ engineer program?
17 3R. POTAPOVSs We didn't, not on that one.
We 18 are making some interface inspections with Region V on 19 the Washington Nuclear Power Sy' stem.
20 COMNISSIONER AHEARNEs Now that PGCE is 21 transferring over to having I guess Bechtel and Ebasco, 22 and I am not sure what their relationship is, are you 23 people then going to get involved?
24 MR. POTAPOVS:
Well, we are inspecting Ebasco 25 on an ongoing basis and we would inspect any activity ALDERSoN REPORTING COMPANY. INC.
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relating to the A/E office or design office activities.
2 As I said before, we are developing in the new program 3 this period assessment and site review where we would
(
4 pick a project and track the interf ace down to the 5 construction site on selected architect / engineers.
e MR. COLLINS: But I don 't want you to leave the 7 Commissioner with something that isn 't true.
8 You would do your normal inspection program of 9 that A/E but Region V has not requasted any special 10 effort on our part.
11 COMMISSIONER AHEARNE:
You had just mentioned, 12 John, that has far as Arkansas that here is a company 13 that previously used to be inspected by ven do r 14 inspection and is now shifting to doing its own A/E and 15 as a result you are shifting th e responsibility.
l 16 In the PGCE case for Diablo Canyon it is going 17 the other way and I was wondering whether there was a 18 converse transfer of any kind of responsibility taking 19 place?
2a NR. COLLINS &
To my knowledge we have not 21 received any request from Region Y for that.
22 COHNISSIONER AHEARNE:
The last set of 23 questions really relates to this document which is NUREG 24 CR-0217 which is a Report of the Study of the Licensee, 25 Contractor and Vendor Inspection Program.
This was done ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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1 for the NRC in 1978.
Are you familiar with this?
2 MR. POTAPOVS:
I was familiar with it when it 3 was done.
I think I just joined the program at that k
4 time.
5 COMMISSIONEB AHEARNE:
It has in it a set of 6 conclusions and reccamendations, and if you were very 7 familiar with it I would just ask you to go through a them, but failing that let me ask you about a couple of 9 specific issues that they raise and see if you would 10 care to respond.
11 They criticize the mechanism f or compiling the 12 active list of vendors and then for selecting the 13 vendors, the ones that you actually end up looking at.
\\
14 Their argument was that it was not a formalized 15 procedure.
They were saying that you should have a 16 formalized procedure.
Do you?
17 3R. POTAPOVS:
Well, that problem has changed 18 complexion in the_three years or so after that report is was written.
At the time when the audit was made, which 20 was probably before that time, most of the inspections l
l 21 that were made out of that branch were what I would call 22 programmatic inspections and they used kind of a shotgun 23 approach at component manuf acturers based on whatever 24 available data existed on the product volume and safety 25 significance of those components without any real ALDERSoN REPORTING COMPANY,INC, CG MCDINIA AS @@ WSIC@T@Q @.@. FETES 3 GSTED E$fB3]
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1 formalized method.
2 As I mentioned before in the presentation, 3 right now we do not make too many routine repetitive
(
4 inspections of component manufacturers at all because 5 there is not that much activity in that area.
6 COMMISSIONER AHEARNE:
Well, there is a 7 difference between saying that there aren't many vendors 8 who sell the components versus that there is a set of 9 vendors but you don't inspect them very often.
Which 10 would be the case?
11 MR. POTAPOVS:
There is probably a different 12 set of vendors that we inspect.
I guess what I was 13 going to get to is that the mode of selection of the 14 vendors and the priorities is based or controlled pretty 15 much by the reactive inputs.
So in essence we do have a 16 system and the system is maybe problem oriented.
~
17 COMMISSIONER AHEARNEs That would say that if l
18 no problem is seen or alleged then the vendor doesn' t 19 have a high chance of getting inspecte'd.
20 ER. POTAPOVSt That is correct, unless it is 21 one of the major known suppliers of the primary pressure 22 boundary components that we still keep in touch with.
23 CONNISSIONER ROBERTSt But to follow up on 24 that, I mean do your resources allow you to inspect a 25 vendor where there is no problem ALDER $oN REPORTING COMPANY,INC.
400 VIRGINIA AML @.W. WTHe@U$3, @.@. E4 GS) @~UfE!D
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1 MR. POTAPOYS:
No, very definitely not.
Our s
2 resources don't even allow us to inspect the vendors 3 that we do have problems with.
\\.
4 COMMISSIONER ROBERTS:
Okay.
5 COMMISSIONER AHEARNE:
I don't want to lose 6 thdt last point.
What you said is that your resources 7 don't allow you to inspect all the vendors that you do 8 have problems with.
9 MR. POTAPOVS Even all the vendors that we do 10 have problems with because we do have a very limited 11 amount of resources and there are many problems.
So it 12 is a matter of prioritizing.
13 COMMISSIONER AHEARNE:
I found interesting in 14 here the point, and in fact they felt sufficiedtly 15 strongly that ther underlined it as part of this 16 conclusion recommendation, the point that Commissioner 17 Roberts made earlier, that the procedures should ensure 18 that no active vendor of safety related nuclear 10 equipment can feel immune to inspection by this program.
20 MR. POTAPOVS:
I believe that has been 21 accomplished.
22 CHAIRMAN PALLADINO:
Except under design we 23 are probably not there yet.
24 COMMISSIONER AHEARNE:
Except, also, I think 25 they can't feel immune if a problem is uncovered.
From ALDERSoN REPORTING COMPANY,INC, 03 A66% ON @S M M DM
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what you just sali I think they could feel immune if no 2 problem were uncovered.
3 In coverage of the inspections they
(
4 recommended that the coverage include the quality of the 5 products resulting f rom the application of of such 6 Grocedures.
Now is that an area into which you would 7 like to go?
For example, when you talked about the 8 third-party inspection, laboratories and also this 9 vertical slice that you are doing, is that in your 10 view 11 ER. POTAPOVS:
It is designed to accomplish 12 that goal anyway.
13 COMMISSIONER AHEARNE:
You mentioned that you 14 were starting down that.
It is too early then to tell 15 whether that is going to be a useful approach?
16 MR. POTAPOVS:
You are talking.about the 17 design type?
18 COMMISSIONER AHEARNE:
Right.
19 HR. POTAPOVS:
I think the early indications 20 that we have are very positive.-
l 2t COMMISSIONER AHEARNE:
And you would expect to 22 try to accomplish that?
23 MR. POTAPOVS:
I think there will be more 24 effort put in that area.
25 COMMISSIONER AHEARNE:
You mentioned it being ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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sort of a pilot program.
What is the time period that 2 you feel is appropriate to then take a look at it to see 3 whether it is ---
('
4 MR. COLLINS 4 I don't think I have ever 5 established a time f rame.
I think it is more based on 6 the experience as we get it to continue to evaluate that 7 information, but I have never really sat with Uldis and 8 said, well now, by June we will cut this off and I will 9 take a look at it.
10 I think, as I mentioned, that one of the areas
~11 that will be helpf ul to us in formulating f uture 12 programs will be an effort that we have ongoing at the 13 South Texas project where we are interf acing with Uldis' 14 vendor program and our own inspection effort and we are 15 getting more into this design review on the individual 18 systems during that transition phase.
l 17 I think some of the information in the 18 samplings that we are taking is going to be very helpful 19 in future inspection programs in telling you what kinds 20 of things you should be looking for.
21 COHNISSIONER AHEARNE4 They recommended tha t 22 NRC document the program in a topical report, a quality
~
23 1ssurance topical report explaining objectives, 24 rationale for the program and the standards that will be 25 used.
Have you ever done such a report?
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MR. POTAPOVS:
No.
That really has not been 2 done other than we have rewritten the manual chapter 3 which in a sense describes the program objectives and k~
4 the policies.
That has been recently revised to reflect 5 some of the se things that we are talking about.
6 MR. COLLINS:
I am not sure whether at this 7 time it is a ppropria te.
8 MR. POTAPOVSs I think the program has never 9 res11y been completely finished to where you could sit 10 down.
It has been evolving continually.
11 COMMISSIONER AHEARNE:
For several years it 12 almost was completely finished.
13 (Laughter.)
14 MR. POTAPOVS Well, I guess that is probably 15 true.
18 CHAIRMAN PALLADINO:
You mean in a different 17 sense?
18 COMMISSIONER AHEARNE:
Yes, a different 19 sense.
There was for years substantial pressure from 20 OMB to kill the program.
21 COHNISSIONER ROBERTSs. To do what?
22 COMNISSIONER AHEARNE:
To kill the program.
23 There was a very simple basis.
They concluded this was 24 something that was industry self-interest and that the 25 industry ought to be interested in doing this.
The i
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government hai no direct interests, their view wa s, in 2 the vendors because the NRC didn't license them and it 3 should have been up to the utility to be in terested in
('
4 doing this.
5 CHAIRMAN PALLADINO:
That would be consistent 6 with our claiming that they ought to have good quality 7 assurance on the plant?
8 COMMISSIONER AHEABNE:
Yes.
Their argument 9 was we ought to be inspecting the licensee's QA program 10 and then it was up to the licensee to handle the rest of 11 it.
12 I guess their final conclusion is that ther 13 seem to strongly feel that there should be larger 14 samples with greater randomness.
I think their basic 15 flavor was esptured in the previous point that I 16 mentioned, that they felt that everybody ought to feel 17 that they sight be open to this kind of inspection and 18 consequently probably the industry standard they felt l
19 could be higher.
l 20 MR. POTAPOVSs Well, actuallr -I think we are 21 inspecting more organizations than we did before at this l
22 time even with the same resources because we do not do 1
23 as many repetitive inspections and we also get into 24 organizations that we did not inspect previously based 1
25 on this reactive mode.
I l
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COMMISSIONER AHEARNE:
If you were asked to
(
2 defend the pecoram, and it has now been in existence 3 since
'74, what do you view as the most significant i
4 benefits that have come from the program?
5 MR. POTAPOVS I think from a standpoint of 6 cost effectiveness and with relatively limited resources 7 I think the program has identified and resolved a number 8 of significant problems which otherwise could have 9 created undesirable situations.
10 It is more of a preventative program in that 11 we try to correct a situation before it becomes written 12 up in newspapers.
13 Also, it does have a very valuable function of 14 taking ---
15 COMMISSIONER AHEARNE:
I have got to stop in.
16 I would hope that the purpose is to correct a problem so 17 that it doesn't lead to the lack of safety in a plant.
18 MR. POTAPOVS4 Well, that is what I really had 19 in mind.
20 MR COLLINS &
Tha t is righ t..
I think 21 sometimes the actue.1 benefits of the program can never 22 really be waived on a one-to-one basis because the 23 findings that you make in the vendor program, you take 24 care of that problem bef ore that problem is put into a 25 plant where then you have a potential safety problem.
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.tR. PDTAPOVS
'4 ell, if you take that simple 2 example as I showed on this safety injection pump cooler 3 misorientation, that is just one of many, many similar
(.
4 items that I could sit down and list where we have 5 defined a potentially generic problem and achieved 6 correction before the problem actually got built into a 7 system.
8 00HNISSIONER AHEARNE:
Given that, and as the 9 Chairman had previously pointed out and you agree with to that there is a very large universe and you are looking 11 at a very small sample of that universe, is your sense 12 that the existence of the program is keeping the rest of 13 the universe whole or is your sense that the rest of the 14 universe that you don't actually get to is probably in 15 bad shape?
16 (Laughter.)
17 CHAIRMAN PALLADINO I presume that the 18 fraction of the universe that you are sampling is 19 different for each of these applications.
20 (Laughter.)
21 MH. COLLINSs Let me take Uldis of f the hook.
22 (Laughter.)
23 COMMISSIONER AHEARNES I don't want to take 24 him off the hook.
I want an answer.
25 (Laughter.)
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CHAIRMAN PALLADINO:
I know you do.
2 MR. POTAPOVS4 That is a rather dif ficult 3 question to address I think.
('
4 MR. COLLINS &
I think that I would answer it 5 tha t my opinion is that our sampling may be very small 6 com pa re d to the total that is out th ere.
I think that 7 because of some of the findings that we have 8 particularly seen over the last year or two years now 9 with tha increase of reactive inspection, that there is 10 concern on my part that perhaps our sampling is not 11 large enough and tha t we snould be doing more'to look at 12 the total or increase our sampling.
Yes, I have a 13 concern.
14 MR. POTAPOVS:
There is also the fall-out from 15 this because we do what we can with wh a t resources we do 16 have, but also the information is disseminated.
4 17 Organizations realize that we do exist and tha t we do 18 some of these things.
Expecially in the organizations 19 where we go in that really are neophytes in this and 20 there are some that have never been inspected, I think 11 the effect is verr great.
I think we do get the 22 organizations that we inspect to get their own house in 23 order indirectly.
24 COMMISSIONER AHEARNEs Say that again.
You 25 believe that ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON D.C. 2Co24 (202) 554 2345
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MR. POIAPOVS:
I believe that the fall-cut 2 from the program, not just the direct nonconformance to 3 simply correct, is greater than what we can measure by
(
4 our own actions.
5 COMMISSIONER AHEARNE:
The effect on whom?
6 MR. POTAPOVSs The effect on the organizations 7 that we inspect.
8 COMMISSIONER AHEDINE:
That you inspect which 9 is another way of ---
10 MR. POTAPOVS:
Or the organizations that they 11 are buying equipment from, that they become suspicious 12 of.
13 COMMISSIONER AHEARNE:
Yes, but of course 14 clearly my question relates to the ones that you don't 15 inspect.
16 MR. POTAPOVS Well, there again, even though 17 we don't inspect them, it is very probable that'we m'icht 18 if we became aware of a problem that existed either by 19 our inspection of another organization or through any of 20 the reporting syst'ess.
21 CHAIRMAN PALLADINO:
If this one of the 22 services for which we charge the licensee?
23 MR. POTAPOYS:
I don't believe so.
24 MR. COLLINSs No, we are not charging a fee.
25 CHAIRMAN PALLADIN04 It sounds like a very ALDGSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 2Ci 44 (202) 554-2345
69 1
interesting place to consider chargina a fee because in 2 effect we sCe doing some of the things that they could 3 probably do themselves.
t 4
COMMISSIONER AHEARNE:
When if they came back 5 to you, Joe, and said we don't want to pay for it.
We 6 can inspect that ourselves.
7 (Laughter.)
8 CHAIRMAN PALLADINO:
Well, they either ought 9 to do it and pay for it themselves or ---
10 COMMISSIONER AHEAREE:
What if they say we do 11 tt?
12 CHAIB3AN PALLADINO4 Well, they would have to 15 prove it.
14 (Laughter.)
15 MR. POTAPOVSs One thing that I would like to 16 point out is this type of inspection is unique in that 17 any indiviiual licensee can do the job for their own 18 contract within their scope of activity.
Whereas, we can'do in there and we can take a generic slice through 19 20 the whole problem and look at all of the vendor's 21 suppliers and look at all of the systems, and look at l
22 many l
l 23 MR. COLLINSs Maybe we ought to charge the 1
24 - utilit y then for the inspection.
25 CHAIRMAN PALLADINO:
That is what I meant, the i
l l
l
,N ALDERSoN REPORTING COMPANY,INC, l
c13 VIRGINlA AR @,W., WZDINGToNo O.C. M (98) 564-519
70 1
licensee.
2 MR. COLLINSs Oh, I thought you meant the 3 vendor.
4 CHAIRMAN PALLADINO:
No, no, the licensee is 5 the one I was thinking of because I could see to gain 6 the kind of benefit that you provide they might have to 7 have an organization such as INPO do it for them and 8 they certainly would pay there.
9 I am just asking whether or not we charge.
10 COMMISSIONER AHEARNE:
I think I know the 11 answer to this question, but do any vendors say no that 12 you can't come in, tha t you don ' t have any legal right?
13 MR. POTAPOVS
'Je have not been kept out of a 14 vendor's shop yet.
15 MR. MURRAY:
From time to time we do get 16 questions about our legal rights and we explain to them 17 that unless they let our inspectors in there we are 18 going to have to tell our licensee not to buy their I
l 19 products and tha t gets th eir atten tion very rapidly.
20 (Laughtger.)
2t COMMISSIONER ROBERTS:
It certainly does.
22 COMMISSIONER AHEARNE:
Since you raised that, 23 what is the legal right we have to tell the licensee not 24 to buy their product?
25 MR. MURRAY:
Our concern that the product
(
ALDERSoN REPORTING COMPANY. INC, l
l
71 1
don't function safely in the plant in the absence of an j
2 assurance that it is made properly.
3 MR. POTAPOVSa I guess the terms that we have k~
4 used is that we require that each of the individual 5 licensees using a product demonstrate to the Commission 6 tha t the product will fulfill the function for which it 7 is intended.
8 COMMISSIONER AHEARNEs Thank you.
9 CHAIRMAN PALLADINO:
All right.
10 Well, thank you very much.
As I indicated 11 earlier, you provided information that I wasn't aware of 12 and I do appreciate both you and Commissioner Roberts 13 bringing it to our attention.
14 HR. COLLINSs Thank.you very much, Mr. Chairman.
15 MR. POTAPOYS Thank you.
16 CHAIBMAN PALLADINO:
We will stand adjourned.
17 (Whereupon, at 11:10 a.m.,
the meeting 18 adjourned.)
39 20 21 22 23 24 25 t
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, W ASHINGToN. D.C. 20024 (202) 554-2345
m W'AR.muA%M CDt'l! CSS C5 This is Oc setif7 that the atcached pecceedings bef:re the COMMISSION MEETING 13 the 2att e ef*
PUBLIC MEETING - BRIEFING ON VENDOR INSPECTION PROGRAM CEU4 of Frcceeding:
April 21, 1982 Oce!csc tlunker:
? lace of Proceedisg:
Washington, D. C.
were held as harti appears, anc cha't. this is the c:-i.iiinal :: scsc:-tE therecf fe:
the fiia of the Cc==1ssicc.
Mary C.
Simons Off*.cial Reperta.- ( T ;ee.)
/
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,r rc M Officizi Espercar (Si.; = care) e
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COMNISSION BRIEFING ON VENDOR INSPECTION PROGRAM l
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PROGRAM OBJECTIVE TO INCREASE REACTOR SAFETY BY PROVIDING REASONABLE ASSURANCE THAT PRODUCTS AND SERVICES SUPPLIED BY NON-LICENSEE ORGANIZATIONS (VENDORS) FOR LICENSED ACTIVITIES MEET flRC REQUIREMENTS.
l t
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- 4 PROGRAM FUNCTIONS II.
CONDUCT R.EACTIVE INSPECTIONS IN RESPONSE TO NRC/HQ OR REGIONAL REQUESTS FOR' FOLLOW-UP ON LICENSEE EVENT REPORTS, CONSTRUCTION DEFICIENCY REPORTS, PART 21 REPORTS, ALLEGATIONS OR VENDOR-RELATED PROBLE'MS IDENTIFIED DURING PROGRAM INSPECTIONS.
- VERIFY ACCURACY / COMPLETENESS OF INFORMATION AND ASSESS GENERIC IMPACT OF IDENTIFIED PROBLEMS, DEVIATIONS OR DEFECTS.
- VERIFY PROPER IDENTIFICATION OF CAUSE OF DEFECTS /
ESTABLISH BASIS OF ALLEGATIONS.
- VERIFY APPROPRIATE CORRECTIVE AND PREVENTIVE MEASURES.
- LOOK FOR POTENTIAL PROGRAMMATIC WEAKNESS WHICH MAY HAVE CONTRIBUTED TO THE PROBLEM.
- EVALUATE THE NEED FOR ENFORCEMENT ACTION.
l l
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I
PROGRAM FUNCTIONS I.
CONDUCT ROUTINE PROGRAMMATIC INSPECTICNS OF NSSS AND AE ORGANIZATIONS, SERVICE ORGANIZATIONS / CONSULTANTS AND MAJOR COMPONENT VENDORS TO VERIFY:
- CONFORMANCE WITH COMMISSION RULES AND REGULATIONS IMPOSED DIRECTLY OR INDIRECTLY (10 CRR 50, APPENDIX 3, TOPICAL REPORT, SAR COMMITMENTS).
- CONFORMANCE WITH REGULATIONS REGUIRING SIGNIFICANT SAFETY HAZARDS TO BE IDENTIFIED, EVALUATED AND REPORTED (10 CFR PART 21).
- CONFORMANCE WITH SPECIFIC PURCHASE ORDER REQUIREMENTS WHEN SUPPLYING SAFETY RELATED COMPONENTS, DESIGNS OR SER, VICES FOR LICENSED FACILITIES..
f.
s PROGRAMS FUNCTIONS III.
IMPLEMENT EQUIPMENT QUALIFICATION PROGRAM CONSISTING OF:
.- REVIEW AND EVALUATION OF EQUIPMENT QUALIFICATION TEST PLANS AND WITNESSING SELECTED OUALIFICATION TESTS PERFORMED BY LICENSEE CONTRACTORS.
- RECOMMENDING AND WITNESSING INDEPENDENT VERIFICATION TESTS (BY NRC CONTRACTOR) 0F SELECTED EQUIPMENT.
- AUDITING THIRD PARTY LABORATORY ACCREDITATION PROGRAM.'
6.
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PROGRAM FUNCTIONS IV.
TECHNICAL INSPECTIONS OF NSSS AND AE ORGANIZATIONS TO PERFORM IN' DEPTH REVIEW OF SELECTED PLANT SYSTEMS OR DESIGN ACTIVITIES
- VERIFY CONFORMANCE WITH SPECIFIC SAR/SRP OR IOPICAL REPORT COMMITMENTS
- ASSESS THE EFFECTIVENESS OF THE DESIGN QUALITY ASSURANCE THROUGH DIRECT INSPECTION / MEASUREMENT.
9 PROGRAMS FUNCTIONS V.
AUDIT NRC APPROVED THIRD PARTY PROGRAMS ASSOCIATED WITH NRC-LICENSED ACTIVITIES.
- ASME, INCLUDING NATIONAL BOARD OF BOILER & PRESSURE VESSEL INSPECTORS AUTHORIZED INSPECTION AGENCIES AUTHORIZED INSPECTORS
- COORDINATING AGENCY FOR SUPPLIER EVALUATION (CASE)
- AMERICAN INSTITUTE OF STEEL CONSTRUCTION (AISC)
ORGANIZATIONS COVERED NUCLEAR STEAM SYSTEMS SUPPLIERS 4
ARCHITECT ENGINEER ORGANIZATIONS 15 SERVICE ORGANIZATIONS (DESIGN CONSULTANTS) 10+
FUEL SUPPLIERS 5
COMPONENTS VENDORS (PRIORITY) 200+
THIRD PARTY ORGANIZATIONS 10+
INSPECTION EFFORT APPLIED INSPECTION S PERFORMED (YEARLY) 250 VENDORS INSPECTED 165 DIRECT ON' SITE HOURS 8850 NONCONFORMANCES IDENTIFIED 515 -
EVOLUTION OF PROGRAM FUNCTIONS 1974-1978 PRESENT
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ACTI 10% TEC I.
14%
- EQUIP, OlAl' 43%
EACT VE
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90% OA PROGRAM 33% 0A PROGRAM e
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1.
PRINCIPAL SOURCES ( EOUESTORS)
- NRC REGIONAL 0FFICES
- 0FFICE OF INSPECTION AND ENFORCEMENT
~
- 0FFICE OF NUCLEAR REACTOR REGULATION
- OTHER AGENCIES
- PUBLIC (ALLEGATIONS) -
2.
REACTIVE ITEM CLASSIFICATIONS
- LICENSEE / VENDOR REPORTS (CDR/LER/PART 21)
- NRC INSPECTION RESULTS
- SPECI AL CONCERNS FROM LICENSING REVIEW PROCESS
- ALLEGATIONS 3.
REACTIVE ITEs PROCESSING /CLOSE-0UT
- ASSIGN PRIORITIES SAFETY SIGNIFICANCE PRODUCTION VOLUME / PERFORMANCE HISTORY (REACTIVE FILE)
- IDENTIFY RESPONSIBILITIES / INTERFACES DESIGN / PROCUREMENT - AE/NSSS MANdFACTURING - COMPONENT VENDORS
- PLAN / SCHEDULE INSPECTIONS CONSOLIDATE ITEMS DEVELOP PLAN / INSPECT
- EVALUATE RESULTS INSPECTION REPORT." NOREG 0400 ENFORCEMENT ACTION - VIOLATIONS /NONCONFORMANCES FEEDBACK TO REQUESTOR (CLOSE-Our f1EMO)
GENERIC NOTIFICATIONS (3ULLETINS/ INFO. NOTICES)
VENDOR FOLLOW-UP (CORRECTIVE ACTION) 4, REACTIVE INSPECTION YORKLOAD
- Ovea 300 SEPARATE ITEMS (REcuESTS) PER YEAR
_g_
ENFORCEMENT VIOLATIONS FAILURE TO COMPLY WITH 10 CFR PARf 21.
BASIS:
SECTION 206 0F THE ENERGY REORGANIZATION ACT OF 1974.
NONCONFORMANCES 1.
FAILURE TO COMPLY WITH COMMITMENTS TO NRC (TOPICAL REPORTS) - NSSS/AE 2.
FAILURE TO COMPLY WITH APPLICABLE NRC REQUIREMENTS IMPOSED BY PROCUREMENT DOCUMENTS 10 CFR, FART 50, APPENDIX B
~
ASME CODE OTHER INDUSTRI AL STANDARDS
l
_ REACTIVE ITEM TRACKING SYSTEM Level Assigned Dal.e Oue bate Closiout insp.,
Thne !
Rdceived Date Hethod -
Class To:
SVHJECT/0RIGillATOR I
Spe6 g. M @ M/ZhDd Westinohouse.
Request from HQS for Inspection N/A Potapovs 6/10/81 i m pj3pg,
Subject:
_Barnes.
of lof tran Harvel Computer Programs, used by W to isuppr.rt reactor licensing.
g Hale hd,
! MMA}IllN fly Mb'iMM-ALLEGATION OF FORMER llES QA EN6lilEER. Identifie i Jotapous 8/5/81
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concerns pertaining to Nuclear Energy services in regaWI >: trvlL 3 1y,6 d
rp (TTQTcBryEiirrEt1MEl firardcorto rdenTiffdef1cienc1es.
g-g geqatrinrcorrective scrtonT-(2)-desirfrtantrot;Tand-gt\\
8' (3)-irr-Tervice-inspection activities of7utentated equ,igmgr.
I lubject: Resident Inspector (River _ Bend). Requested inspec-Pntanns 10! !81 5
_Bunes yM D
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sion of Bergen-Paterson in regard to procurement control Dractices use'd foi X3fff A500 s tructural tubing. %-\\/\\iy 1
gelley q
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$ubject: RV Investigation Referral-Alterat' ion hf_WPPSS 3__ 1.evel varnes II
^
eadiographs b(Associated Piping and Engin'eering, Compton Rotmrds7Drisk 11
)
j So enfiance visib1Tity of penetrameter hole.
m I
REPORT NO.: 99900031/81-02 INSPECTION RESUI.TS:
PAGE 4 nf 4 5.
Follow-uo Insoection of Misorient on of the Heads on Lubricant Oil Coolers Babcock & Wilcox (B&W) notifed the NRC of a 10 CFR Part 21 report on January 9,1981, relative to the possible misorientation of the integral heads opposite the inlet flow line on lubricant oil coolers, thus causing reduction of flow through the coolers and an attendant reduction of heat transfer. These lubricant oil coolers are an integral part of the high pressure make.-up injection pumps at WPPSS-WNP 1 and 4.
The subject pumps were fabricated by BWC; the. lubricant oil coolers were manufactured by NiETEX, Inc.; and purchased 6y BWC.
BWC informed of this safety-related deficiency,in a letter from B&W on January 20, 1981, and was asked to review and make a recommendation for positive alteration to the cooler head to prevent misorientation of the head during assembly.
BWC Purchasing responded on May 18, 1981 (MSG No. 1952) stating that B&W had taken adequate corrective action and that hardware modifications were n6t necessary.
In BWC inter-office correspo,ndence of February 27, 1981, Field Engineering Service was requested by QA to determine if other units were affected in the field and take actions to correct and mark heads to avoid mislocation during re-assembly.
No actions had been taken by Field Engineering Service as of the date of this inspection. (See nonconformance, item B.2).
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APPENDIX A NOTICE OF NONCONFORMANCE Bingham-Willamette Company Docket No. 99900031/81-02 Based on the resu'lts of an NRC fospection conducted on November 16-19,1981, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
Criterion V of Appendix B of 10 CFR Part 50 states: " Activities affecting quality shall be prescribed by documented instructions, procedures, or draw-ings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satis-factorily accomplished."
Nonconformances with these requirements are as follows:
A.
Paragraph 3.1.3, in Section 3 of the QA Manual states in part, " Drawings, procedures, instructions, and material lists with supplemental appendices as needed shall be prepared from the Design Specification and the Code Contrary to the above, the material list for Sales Order No. 14210471 (South Carolina Electric and Gas Company - Virgil C. Summer, Unit 1) was not prepared from the Design Specification and Code, in regard to im-position of required ASME Section III, Class 3 Code for the Emergency Feedwater Pump turbine lube oil cooler.
B.
Paragraph 5.2.3 in Bingham-Willamette Company (BWC) Procedure A 14.0, Revision 1, states, "The Quality Assurance Manager shall, together with personnel cognizant in the area of concern, perform an evaluation of the condition relative to safety and at the same time make a determination of similar conditions past or present."
Contrary to the above, a determination was not made, in regard to identi-fied misorientation of lube oil cooler heads on high pressure make up injection pumps at WPPSS-WNP 1/4, of whether similar deficiencies existed in equipment supplied to other locations. -
_m_.
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-] Bingham-Willamctto Company
~
NONCONFORMANCE. ITEM B.2 Description of Finding In regard to the misorientation of lube oil cooler heads on high pressure make-up injection pumps at WPPSS-1/4, a determination was not made whether similar deficiencies existed in equipment supplied to other locations.
Corrective Action An extensive review of BWC contracts has been completed for the purpose of determining whether similar deficiencies exist in other locations.
As a result of this review we have determined that there is a possibility that similar deficiencies do in fact exist.
For those customers, an addendum to the instruction manual will be issued stating the problem and identifying the correct head orientation.
BWC Field Service will follow-up with end users to verify proper orientation of heat exchanger cooler heads in the field.
~
Steps to be Taken to Prevent Recurrence A training session will be conducted within Pump Engineering for the purpose of addressing design of heat exchangers.
In addition, a letter will-be issued to all heat exchanger manufactures that we procure like products from identifying the problem and recommending that they revise their design and take corrective action to eliminate any potential head misorientation.
Date Corrective Action & Preventive Measures Will Be Comoleted Issuance of instruction manual addendums for contracts with like heat ex-exchangers is targeted for completion by April 15, 1982.
Follow-up by Field Service is anticipated to be complete by July 30, 1982:
Training sessions for responsible engineers regarding heat exchanger design was conducted on February 26, 1982.
Correspondence to heat exchanger manufactures will be completed and mailed by March 31, 1982.
w-
"VERIlCAL" DESIGN INSPECTIONS 1.
CONCEPTUAL DESIGN 2.
PRELIMINARY DESIGN 5-3.
DESIGN CRITERIA II.
DESIGN BASES g;
5.
DESIGN INPUTS
!SO 6.
DESIGN' INTERFACES a_
5 7.
DESIGN VERIFICATION v>
N 8.
DESIGN CHANGES 9.
PROCUREMENT PROCESS 10.
FIELD CHANGES 11.
ANALYSIS OF INSTALLED SYSTEM i
l l
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CCWS RilR C0tlT.
ANALYSES, SYSTElis, STRUCTURES, COMP 0flENTS l
l -
PROCUREMENT PROCESS (FOR EACH SYSTEM COMPONENT SELECTED)
SELECTEn COMPONENTS FROM CS SYSTEM SPRAY SYSTEM PuMeS 12" GATE VALVE (IAG No. XYZ)
MOTOR OPERATOR FOR As0vE VALVE SPRAY ADDITIVE TANK DESIGN INSPECTION OF EACH COMPONENT SDECIFICATION DESIGN CR.ITERIA
- DESIGN DASES DESIGN INPUT QUALIFICATION, IESTING, & ENVIRONMENTAL DESIGN REv!3W/ VERIFICATION PROCUREMENT
- SUPPLIER QUALIFICATION SUPPLIER SELECTION SUPPLIER SURVEILLANCE i
VERIFICATION ACTtvrTIES WITNESS / HOLD POINTS WELDING /NDE PROCEDURES & QUALIFICATION DRAWING / PRINT REVIEWS CONTRACT / DESIGN CHANGE REcuESTS
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NUREG-0040 Vol. 5, No. 4
\\
LICENSEE CONTRA.CTOR AND VENDOR INSPECTION STATUS REPORT QUARTERLY REPORT OCTOBER ISql - DECEMBER 1981 UNITED STATES NUCl. EAR REGULATORY COMMISSION iYhi i.t,7esy S
__._._______.q
. i. 1..
ORGANIZATION:
IJNITED ENGINEERS AND CONSTRUCTORS, INC.
PNILADELPHIA, PENNSYLVANIA I
REPORT INSPECTION INSPECTION l
NO.:
99900510/82-01 DATE(S) 1/4-8/82 & 2/2-5/82 ON-SITE HOURS: 56 CORRESPONDENCE ADDRESS:
United Engineers and Constructors, Inc.
ATTN:
Mr. R. A. Curnane, Vice President i
Project Support Operations 30 South 17th Street e
Philadelphi.a, PA 19101 ORGANIZATIONALCONTACT:
Mr. J. B. Silverwood, QA Manager TELEPHONE NUMBER:
(215) 422-4744 PRINCIPAL PRODUCT: Architect Engineering Services NUCLEAR INDUSTRY ACTIVITY: United Engineers and Constructors (UE&C) is the Architect Engineer on the following major projects:
Seabrook, Units 1 and 2, and Washington Public Power Supply System, Units 1 and 4 (WNP - 1&4).
- Also, UE&C has active engineering service contracts on two nuclear plants for two utility clients.
ASSIGNED INSPECTOR:
3 $2-D. 0.vChamberlain, Reactor Systems Section (RSS)
Date OTHER INSPECTOR (S):
APPROVED BY:
~O I-- % _b.,e C.I Sl2 3 // 0 / TZ.
C. J. Hale, Chief, 45 Date INSPECTION BASES AND SCOPE:
A.
BASES:
The PSARs, for the Seabrook and Washington Public Power Supply System projects and 10 CFR Part 50, Appendix 8.
8.
SCOPE:
Status of previous inspection findings, design verification (UE&C home office design activities and UE&C WNP-1 field design activities) and a special inspection conducted as the result of a Region II request for follow up on the generic aspects at the Architect Engineer relative to the potential loss (cont. on next page)
PLANT SITE APPLICABILITY:
This inspection relates to the following plant dockets: 50-324, 50-325, 50-443,.
50-444, and 50-460. _
. _i. c.E
.2ATION:
UNITED ENGINEERS AND CONSTRUCTORS, INC.
?
PHILADELPHIA PENNSYLVANIA i
?
E.
i INSPECTION J
99900510/82-01 RESULTS:
PAGE 2 of 9 i
i, ;
i :' 5
.e COPE: Cont.
if id E
.f scram redundancy upon closure of two reactor instrument penetration i' j.:-
alvas as reported by Carolina Power & Light at the Brunswick 1 and 2
',3 r3 ject.
Q
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5 IOLATIONS:
en]
ONCONFORMANCES:
5 i
Contrary to Criterion V of 10 CFR Part 50, Appendix B, and procedure 7
GEDP-0034, the Reliability and Quality Assurance Department did not assure that the committed completion date was met for corrective action J
in response to a previous NRC inspection finding (Item B.1, Report E
81-03).
i Contrary to Criterion V of 10 CFR Part 50, Appendix B, and procedure
[,
PG-02, the transferring organization for three pipe stress analysis
-f packages examined did not verify that the latest revision of the Com-
{ 53 posite/ System Piping Drawing and Fabrication and Erection Drawing was
=
referenced on the Analysis Orawing and, consequently, no evidence cxisted to indicate that the analysis drawing had been verified against i
E the latest drawings.
9 NRESOLVED ITEMS:
.t was :1ot apparent that program requirements were adequately defined and/or leing followed in the preparation of nuclear pipe support design packages C
'or transfer of responsibility to the WNP-1 site design group.
=
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'2 lTATUS OF PREVIOUS INSPECTION FINDINGS:
.5 5
i O
(0 pen) Nonconformance (81-03):
QA records for the Seabrook Project are i
5 not being stored and/or adequately protected from damage or deteriora-g tion and audits of record storage areas are not being performed on a pariodic basis.
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Procedure QA-17 was revised to designate the Record Retention Room as g,
tha Remote Correspondence File and to require duplicate storage of b
r cords of design reviews.
A letter was issued to the NRC Quality E
Assurance Branch (QAB) on December 14, 1981, which describes the
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proposed duplicate storage facilities.
The audits of the revised R
procedures and the record storage areas were not performed by
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BRANCH CHIEF TECHNICAL ASSISTANT SECRETARY REACTOR SYSTEMS SECTION SECTION CHIEF REACTOR ENGINEER (SYSTEMS) 8 POSITIONS EQUIPMENT GUALIFICATION SECTION SECTION CHIEF ECUIP. CUAL. & IEST ENGINEER l! POSITIONS REACTIVE & COMPONENTS PROGRAM SECTION SECTION CHIEF MECHANICAL ENGINEER l! POSITIONS ELECTRICAL ENGINEER 2 POSITIONS 4'
METALLURGICAL ENGINEER 1 POSITION REACTOR ENGINEER (COMPONENTS) 5 POSITIONS D.