ML20058J510
| ML20058J510 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8208100377 | |
| Download: ML20058J510 (125) | |
Text
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COMMISSION MEETING In the Ma*:':ar cf:
PUBLIC MEETING DISCUSSION OF SECY-82-153 - PP.OPOSED RULEMMING -
ACCREDITATION OF QUALIFICATION TESTING ORGANIZATIONS
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DATE:
July 20, 1982 PAGES:
1 - 99 AT:
Washington, D.
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.HDE3L%Y REPORTLTG L
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DISCLAIMER
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This is an ' unofficial transcript of a meeting of the United States
~ " Nuclear Regulatory Consission held on
. rn l r 9n. 199 9 in the i
.Cocmission's offices at 1717 H Street, N. W., Wasnington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general infomational pureoses.
As provided by 10 CFR 9.103, it is not part of the forinal or informal urecord of _ decision of the matters discussed.
Expressi.on.s._of opinion _ in ithtsmnscript do not necessarily reflect final-detennirrations or ~
~~L2C
' beliefs.
No pleading or other paper may be filed with the Commission in f,'
any proceeding as the result of or addressed to any statement or argument
- -.._.__.. contained herein, except as the Conmission may auth'orize.
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 DISCUSSION OF SECI-82-153 - PROPOSED RULEN AKING-5 ACCREDITATION OF QUALIFICATION TESTING ORGANIZATIONS 6
7 PUBLIC NEETING 8
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9 Nuclear Regulatory Commission Room 1130 10 1717.H Street, N.
W.
Washington, D. C.
11 Tuesday, July 20, 1982 12 rhe Commission met, pursuant to notice, at
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10:05 a.m.
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14 BEFORE:
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15 NUNZIO PALLADINO, Chairman of the Commission 16 JOHN AHEARNE, Commissioner THOMAS ROBERTS, Commissioner 17 JAMES ASSELSTINE, Commissioner 18 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
i 19 R. DeYOUNG J. TAYLOR 20 W. DIRCKS Y. STELLO
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21 W. HORRISON B. KUBICK 22 W. OWEN A. ROBT 23 J. OWENS f
24 AUDIENCE SPEAKERS 25 W.
REINMUTH ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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EE9CEE211EE 2
CHAIHHAN PAliADINO Good morning, ladies and 3
gentlemen.
4 The Commission meets this morning with the 5
Nuclear Regulatory Commission staff and industry 6
representatives on accreditation of qualification 7
testing organizations.
8 Ihe staff is proposing a rule that would 9
require certain qualification testing of equipment 10 important to safety to be performed only by 11 organizations accredited by the Institute of Electrical 12 and Ele'ctronics Engineers, Inco rpo ra ted, commonly 13 referred to as IEEE. 14 In a recent letter from the Atomic Industrial 15 Forum they proposa sn industry alternative program.
16 Today's meeting vill be conducted in four 17 parts.
First, the Commission vill hear from the NRC 18 staff, then the Commission vill hear from AIF 19 representatives and then the IEEE representative.
i 20 Finally, the Commission vill receive the staff's
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21 comments on the industry's presentation.
22 I would like to take the opportunity to 23 introduce the industry representatives for the meeting 24 today.
We have with us Mr. Warren Owen, Executive Vice 25 President, Duke Power Company AIF Policy Committee for ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON D.C. 20024 (202) 554 2345
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1 Nuclear Regulation; Mr. Arnold Roby, Northeast Utilities 2
Chairman of AIF, Equipment Qualification Subcommittee;
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3 and Mr. Bo b Kubick of the Electric Power Research 4
Institute.
You will see these people later as they make 5
their presentations.
We also have Mr. James R. Owens, 6
President-elect, IEEE with us.
7 I understand there are several other industry t
8 representatives on whon Nr. Owen may call for help to 9
answer questions.
10 Now do any of my fellow Commissioners have any 11 opening remarks they would like to make?
j 12 (No response.)
13 CHAIRHAN PALLADIN04 Well, then let me turn l
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14 the meeting over to Mr. Taylor of the NRC who will make 15 the presentation on behalf of the staff.
16 NR. TAYLORs I am Jim Taylor from the Office
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17 of. Inspection and Enforcement.
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18 I wanted to take a few minutes to go through j
i 19 the background of how the staff got to the point of 20 developing the proposed rule which is with the
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21 Commission.
22 (Slide presentation.)
23 MR. TAYLOR:
May I have the first slide, 24 please.
25 First, I would like to touch on the events ALDERSON REPORTING COMPANY,INC.
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that led to the staff and general industry concern about 2
laboratory testing for equipment qualification.
3 Back in mid-1977 during a test chamber 4
check-out at Sandia Laboratory an electrical conne,ctor 5
failed during the testing.
This caused a reaction.
It 6
was reported to the Commission and the Commission with 7
staff action ordered the verification of adequate 8
connectors at all operating reactors.
9 Based on the available data, seven facilities 10 could not promptly provide verification, and there was a 11 long string of actions with the staff until-the-12 Commission was satisfied and the staff was satisfied 13: that this particular issue had been addressed.
14 In November 1977 the Union of Concerned 15 Scientists petitioned the Commission seeking action or 16 relief in the area of environmental qualification of 17 electrical components.
18 Thereafter in April 1978 the Commission issued 19 a memorandum and order addressing this subject raised by 20 the UCS with directives for staff action.
21 In the meantime during the period of 1977 to 22 1979 the staff had been addressing the subject of l
23 problems of electrical equipment in a number of 24 circulars and bulletins.
This included information on 25 specific electrical equipment and failures in service ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345 l
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which should have shown up if a ppropriate and required 2
qualification testing had been performed.
3 In response to the major bulletin in this area 4
which we call 7901B, we asked licensees to submit 5
qualification information on safety related electrical 6
equipment.
When the staff began reviewing these we 7
noted that approximately 70 to 80 percent of the 8
responses to the bulletin were deficient and that there 9
was insufficient data available from the testing that 10 had been performed to the prior or existing standards to 11 demonstrate that qualification had been properly 12 con ducted.
13 That caused a great deal of concern in the 14 staff and I think within the Commission itself.
The 15 information supporting the qualification of equipment in 16 plants was in such a condition tha t you could not be 17 sure and there was not adequate information to be sure 18 about the qualification.
19 The second slide, please.
20 I would like now to touch on the events after 21 the issues had oeen raised concerning equipment 22 qualifiention which led to the idea of accreditation of 23 test laboratories.
24 In July 1980 in response to one of the 25 Commission's 1978 directives in this area, and based on ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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a Sandia study of equipment qualification, the staff 2
recommended several things:
3 One, that the NRC independently test selected 4
equipment in contractor facilities, 5
Two, recommended establishing an NRC 6
inspection program to cover a portion of the laboratory 7
testing; and 8
Three, recommended encouraging standardization 9
in testing based upon what we knew in the response to 10 the bulletins, including a third-party laboratory 11 accreditation program.
12 The reason this was included in the staff 13 recommenditions vss that the staff recognized its
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14 limited resources in this area, and the staff was 15 relating to the programs that had been ongoing in a i
16 third-party sense with ASHE, related to the ASME N-Stamp 17 Program.
These staff recommendations were approved by 18 the Consission in September 1980.
19 In the meantine while the Commission was 20 considering these recommendations, in July of 1980 the i
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21 Commission requested the staff to discuss with IEEE 22 their willingness to develop a suitable standard and 23 implement a laboratory accreditation program.
24 The staff proceeded to hold discussions with 25 IEEE and in December 1980 the IEEE Board of Directors ALDERSON REPORTING CCMPANY,INC, j
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approved the NBC request to participate based upon NRC 2
promulgating a rule to support this accreditation 3
process.
4 By September 1981 a formal agreement had been 5
drawn up between the NRC and the IEEE.
It was published 6
and it included NBC making its best efforts to issue a 7
lab oratory accreditation rule in the first quarter of 8
1982.
9 In February 1982 the IEEE completed its work, 10 with industry representatives and laboratory 11 representatives participating, in developing a~ standard 12 to be used under the NRC rule to accredit both the 13 quality assurance and technical control programs at test'
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14 laboratorics.
15 That is how we got to the point where we are 16 today in recommending to the Commission from the staff 17 the consideration of this rule.
18 The third slide, please.
l 19 I think pertinent to that we should mention 20 that the staff's direct observations in test 21 laboratories have been limited.
Totally we have had j
22 engineers or inspectors visit a total of seven test 23 laboratory organizations.
There have been several 24 visits of rourse is tasting his proceeded, but we have s
1 25 gotten through about seven laboratories and we have l
l ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W, WASHINGTON. O.C. 20024 (202) 554 2345
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considered the problems that were indicative in the 2
responses to the bulletins and the lack of qualification 3
information.
4 What we have seen at the laboratories 5
indicates a need for action to improve laboratory 6
performance. Our of the slide and out of the visits to 7
the laboratories we have seen indications which indicate 8
that some laboratories do not have adequate QA 9
programs.
We have seen, for example, in two of the 10 seven laboratories that there had' never been a customer 11 sudit of the test imboratory QA program.
12 We have seen many problems with test plans.
13 In-seven of the seven laboratories we had major. comments 14 on important IEEE standard requirements related to the 15 test plans for the particular equipment we were 16 witnessing or observing being tested.
17 We saw in four of seven laboratories either a l
18 total lack or inadequate test procedures to conduct the i
19 testing ani qualification of the equipment.
20 He also saw from a QA standpoint in four of 21 the seven inadequate procedures for nonconformance 22 control, that is when the equipment developed problems 23 there weren 't procedures on what to do about it and 24 related corrective actions in the testing.
25 We also, as a take-off on our review of the l
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1 7901B bulletin information, asked Franklin Institute, 2
who has been working with the NRC to review equipment 3
qualifiction reports, to provide us with a synopsis of 4
what they are seeing in the review for the plant 5
specific equipment qualification reports that are being 6
used to develop the SERs under the auspices of NRR.
7 I have typical examples, but there are many 8
indicative of poor controls of the testing, either from 9
the standpoint of the laboratory conducting the test or 10 inade qua te test plans being used in the laboratories.
11 But it continues to show, as they have reviewed this 12 saterial, that 75 percent of the reports of either
~13 missing data, of poor quality or insufficient
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14 information is providad to donermine that the 15 qualification has been achieved.
16 That is an introduction of how and where and 4
17 why the staff is at the point of having recommended to i
18 the Commission their consideration of the proposed rule.
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19 CHAIRMAN PALLADINO.
Thank you, Jim.
'20 I vender if I might ask a series of related 21 questions, and I only have this one series.
22 Does Appendix B to Part 50 apply to the 23 testing laboratories now?
24 MR. TAYLOR:
Yes, I would say it would apply 25 under the suspices of the licansees or indeed whoever is l
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ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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having the testing conducted.
2 MR. MORRISON:
Could I clarify that a minute.
3 Appendix B applies to subtier contractors, but the 4
provision of Appendix B that applies says to the extent 5
necessary the licensee is expected to apply the 8
pertinent provisions of Appendix B.
That doesn't mean 7
that they have to apply all of Appendix B, or in some 8
cases they may apply none and by suit,able tests and 9
inspections upon receipt they can assure quality.
So 10 Appendix B is rather flexible in that regard.
11 CHAIRHAN PALLADINO:
Well, I think it requires 12 records, for example.
It requires a qualify assurance 13 program.
The applicants are now obligated to show you 14 that thosa are met by the testing laboratories, isn't 15 that so?
See, there has been no uniform 17 standard as to what quality assurance provisions should 18 be applied to the organizations performing qualification 19 testing.
That would be one impact of thia P-600 20 standard.
It voc.d establish a uniform standard for 21 application of quality assurance requirements for these l
22 organizations.
We have no such standard today.
23 CHAIRMAN PALLADINO:
I am not clear what your 24 answer says.
You are saying that maybe Appendix B does 25 apply and aaybe it doesn't?
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 1
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MR. HORRISON:
Appendix B is very flexible 2
with regard to the application of quality assurance 3
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requirements for contractors and subcontractors.
4 Criterion 4 of Appendix B on control of procurement 5
states that to the extent necessary you shall apply the 6
pertinent provisions of these quality assurance criteria.
7 CHAIRMAN PALLADIN0s And we had never said 8
which are pertinent?
9 MR. HORRISONs That is right.
10 CHAIRMAN PALLADINO:
So one of the things we 11 could do is say which are pertinent?
12 HR. H0RRISON:
That is right, and that is 13 exactly what the P-600 standard, which we worked-with 14 IEEE on, does.
15 CHAIREAN PALLADIN04 If we follow the 18 accreditation route,.what additional instructions on 17 specific forms of testing would be needed?
a 18 ER. TAYLOR:
The specific technical 19 instructions on what should be done with the component 20 comes from the licensee normally.
That is what we call 21 the test plan.
22 CHAIRMAN PALLADIN0s How will the staff even 23 under accreditation assure consistency among those?
24 NR. TAYLOR:
We would have to do it on a 25 sample basis.
This is where we have several inspectors ALDERSoN REPORTING COMPANY. INC.
400 V!PGINI A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345-
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we are trying to get ready to go to laboratories and go 2
in during testing and look at the test plans.
The 3
standard that we are attempting to apply emphasizes the 4
development and 'the technical capability within the 5
laboratory to review these test plans.
So it will be on 6
a sample basis that we would look at test plans.
7 CHAIRMAN PALLADINO So this will be in 8
addition to accreditation.
9 MR. TAYLOR:
Right.
Now if the IEEE, if there 10 is testing in progress, it is my understanding if the 11 IEEE audit group is in and there is testing in progress, 12 that they will observe that testing.
They will look at 13 the test plan and they will see that it reflects the 14 plant conditions under.which the equipment is expected 15 to operate, but that would be on an as-can basis.
16 CHAIRMAN PALLADIN04 If they don't do that, it 17 is not clear to me how accreditation will help overcome 18 the kinds of problems that you outlined here and also in 19 response to questions raised by Commissioner Ahearne.
20 MR. TAYLOR:
The number that I have hearc goes 21 more than 100 laboratories which are involved in the 22 business.
Our idea is that this effort by the IEEE will 23 astablish with the P-600 document that they have a 24 quality assurance program and that the program meets 25 NQA-1 requirements as appropria te, as Mr. Morrison as ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345 -
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mentioned through Appendix B, and that they have control 2
of the technical process to ensure that they have 3
procedures for testing and to get this leval of 4
capability established.
5 CHAIRHAN PALLADIN0s Procedures for testing 6
what?
Do you mean specific tests?
7 HR. TAYLORa As an example, that they have 8
procedures that are adequate to conduct a testing in the 9
labs, yes.
10 CHAIRMAN PALLADINO:
You see, my impression is 11 that the accreditation is a general qualification.
You 12 still are going t.o need, I believe, either in the form 13 of reg. guides, if you want to get consistency, or 14-instructions on the specifications or whatever you want 15 out of a particular test.
It is not clear to me what 16 the accreditation would do that Appendix B couldn't do 17 if properly applied.
I would like to get a feeling 18 since it is the recommendation of the staff, but it 19 seems to se that we are adding more things.
20 In the end the accreditation will tell you l
21 whether or not, or at least I haven't gottan tha t sense l
22 yet, that the accreditation will tell you whether or not 23 this organization will do the testing on a particular l
24 q u ali. ficatio n.
25 HR. TAYLOH4 Right, that is correct.
ALCERSoN REPORTING COMPANY. INC.
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CHAIRMAN PALLADINO:
So therefore it will not 2
solve the problems that you have lis ted.
3 MR. TAYLOR:
Some of those problems that I 4
havo listed are programmatic QA problems.
5 COMMISSIONER AHEARNE:
Could you look at the 8
problems that you have listed and say how you think your 7
proposal would address those problems?
8 HR. TAYLOR:
I say no customner audit of the 9
test laboratory QA program.
If an accreditation was
.10 done and it is the purpose of the rule and it is 11 recognized that if the IEEE has been in and accredited
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12 the QA program, then it won 't be necessary for each 13 licensee, and there may 15 or 20 using a particular 14 laboratory, to go in and tread through the same process.
15 CHAIRHAN PALLADINO4 Why is that?
I thought 18 it was required for them to do that under Appendix B.
17 HR. TAYLORa No.
18 CHAIRMAN PALLADINO:
So you are absolving them 19 of this responsibility.
Why should you absolve the 20 licensee of this responsibility and give it to somebody
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21 else?
22
-COHNISSIONER ROBERTS:
It is unclear that it 23 is a requirement.
24 MR. MORRISON:
There is a requirement in 25 Appendix L that by suitable measures, such as source ALDERSoN REPORTING COMPANY,INC.
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surveillance, inspection and so forth, that they assure 2
the quality of the service or equipment that is being e
3 ordered, and that is really the extent of the Appendix B 4
requirements.
There are more details in the voluntary 5
consensus standards than we have endorsed by regula tory 6
guide, but I know of none that are specific to l
7 organizations performing qualification testing.
8 CHAIRMAN PALLADIN0a But all we would have to 9
do is require Appendix B.
10 MR. DeYOUNGa I believe that is true.
- Well,
-11 ve were here about two years ago, Mr. Chairman, and.ve 12 said we could do that, that we could, you know the i
13 staff, check against Appendix B, but we needed i
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14 additional resources and we thought a staff of 10 to 15 15 people.
The Commission told us to try to get outside 16 help, an independent third party to cut down the 17 resource req uirements, and this is what we have done.
18 COMMISSION ER AHEARNE:
It is certainly true 19 that in the absense of IEEE auditing and if it is 1
20 unclear that we could pass a new rule, and the new rule 21 would be that we would require licensees to do this.
I 22 sean that is certainly a possibility.
23 HR. TAYLOR:
It could be, yes.
24 CONNISSIONER AHEARNE:
So we could always add 25 a new rule.
l ALDERSoN REPORTING COMPANY. INC.
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CHAIRMAN PALLADINO:
How about the next one?
2 MR. TAYLORa The te st plan problems, the 3
accreditation process may or may not hit a particular 4
test plan.
So that won't necessarily solve some of the 5
deficiencies we have witnessed in test plans.
6 CHAINHAN PALLADINO:
Now how will we solve 7
that then?
8 HR. TAILO'R By our overvie,v of what is 9
happening at test laboratories.
That is the NEC limited to inspection program.
He have two or three inspectors in 11 Region IV and we' intend to sample testing that is going 12 on in laboratories.
13 CHAIRHAN PALLADINO:
But isn't that the crux 14 of the_ prob 1_en?
15 MR. TAYLOR I think that is one of the 16 problems.
As I said, we have only looked at seven 17 2aboratory organizations.
18 CHAIRMAN PALLADIN0s Yes, it shows a need for 19 some attention to the problem.
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20 HR. TAYLORs Yes.
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21 CHAIRMAN PALLADINO:
And I an only wondering 22 what is the best way and that is what I am searching for.
23 MR. TAYLOR:
The third one, inadequate or 24 total lack of detailed test procedures, I think that the 25 IEEE program will address that.
The technical control ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (2C2) 554 2345 =
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process, the portion of the IEEE standard that talks 2
about executing appropriate techincal control of the 3
testing should result, and it requires and discusses e
4 having adequate procedures to discuss the test.
5 CHAIRMAN PALLADINO:
But adequate procedures 8
would be related to the particular test.
They wouldn't 7
be general procedures.
8 HR. TAYLOR:
They would have to be tailored to 9
a particular test, but of course many of the items go 10 through the same kind of testing, spray flow, pressure 11 and temperature.
So I think tha t problem would be 12 ameliorated by the process.
13 - -
CHAIRMAN PALLADINO:
How?
14 ER. TAYLORa Because the IEEE accreditation 15 process is to, first of all, establish that there are 16 procedures.
We have seen some laboratories with no 17
- rocedures.
18 CHAIBMAN PALLADINO:
But so could the 19 licensee.
20 MB. TAYLOB It could be done in another way, 21 sure.
The accreditation process is a method which we 22 came up with because of the limits, frankly, on our own 23 resources.
24 CHAIBHAN PALLADINos Well, but the licensee 25 would be doing this and we would be spot checking the I
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licensee.
2 MR. TAYLOR:
It could be done tha t way.
3 The last one is strictly a QA type, and 4
related to that is where they are running into problems 5
in the testing area.
That is another offshoot of 8
procedures related to quality assurance.
7 CHAIRHAN PALLADIN0s But how would 8
accreditation tell you whether are in conformance or 9
nonconformsnce?
It would j ust say that on a certain 10 date when they visited and looked over the records they 11 found ---
12 MR. TAYLOR:
That the proceduras exist, and 13 what do you do in a test when you reach these kinds of 14 conditions.
15 CHAIRHAN PALLADINO:
But most of the problems 18 you cited with spacificity have to do with particular 17 tests and the fact that they didn't do it right.
18 NR. TAYLORs Right.
19 CHAIRHAN PALLADINO:
So you are going to have 20 to still do all these things.
21 HR. TAYLOR:
The accreditation process will 22 not relieve the individual licensees of getting out 23 there and seeing that the individual tests have been 24 conducted.
25 CHAIRMAN PALLADINO:
So you are going to have A1.DERSON REPORTING COMPANY, INC.
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to impose on them a Part 50 Appendix B kind of operation.
2 MR. TAYLOR:
That still exists.
3 CHAIRMAN PALLADINO:
So they still have that 4
and accreditation on top of it.
5 MR. TAYLOR:
Accreditation establishes the 6
base.
7 CHAIRHAN PALLADINO:
And as long as they are 8
going to be doing that, then why shouldn't ther ---
9 MR. TAYLORa Each licensee then under their 10 real obligati,on would have to go in and make sure that a 11 QA program exists and that it is adequate in each of 12 these labs.
13 CHAIRHAN PALLADINO:
Isn't this what we do on
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14 other things as vall?
15 MR. TAYLOR:
Well, on other things the ASME 16 N-Stamp Program is an example where a third party is 17 used and is recognized by licensees.
18 CHAIRMAN PALLADIN0s But that is a more 19 restricted and rather specialized area.
This covers a 3) wide range.
21 MR. TAYLOR:
That covers many', many people who 22 are performing work to the ASME Code.
On that basis the 23 ASME N-Stamp Program and the ASME auditors go in and 24 establish that the particular organization has a quality 25 control program and that they have appropriate ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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procedures to control what they are doing.
That again 2
is typical where they go in for several days during a 3
month or a week and they don't get back to do that again 4
for some period of time.
So what happens after that, in 5
other words, the implamentation, the d a y-to-da y thing, 8
remains, and that is something of course we try to 7
review using Region IV vendor inspectors where they go 8
out and ASME N-Stamp type operations.
So it is not a 9
cure-all.
10 CHAIRMAN PALLADINO:
Yes, I appreciate that.
11 COMMISSIONER ROBERTS:
But not to lapse into 12 too much minutiae.
Under the N-Stamp scheme you have an 13 authorized inspector who is virtually full time if they
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14 do any volume of work.
15 HR. TAYLOR:
If the plant is large enough to 18 do it right, there may be an authorized inspector, 2
17 right.
If the operation is big enough.
18 CH AIRM AN PALLADIN0s Let me turn it over to 19 other Commissioners for questions.
20 C055ISSIONER AHEARNE:
I just would be 21 interested if Mr. Dircks or Mr. Stello had anything to 22 add.
23
- 58. DIRCKS:
I think you have touched on it 24 and the option you are faced with.is to either do it one 25 vay or the other alternative is to make Appendix B ALDERSoN REPORTING COMPANY. INC.
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applicable and then provide the NRC resources to carry 1
2 out a QA program.
1 3
CHAIRHAN PALLADINO:
You jumped very fast i
4 there, because out of the four things I have three of 5
them that arent going to be covered by accredita tion.
6 (Laughter.)
7 COMMISSIONER AHEARNE:
It is the half full and 8
half empty glass.
9 (Laughter.)
to CHAIRMAN PALLADINO:
Accreditation is not 11 going to assess the individual test, it is not going to 12 prescribe how it is going to be done and it is not going 13 to audit those, except perhaps unless something is -going
(
14 on ---
15 COMMISSIONER AHEARNE But it is going to 16 address whether they do have test procedures built up 17 and whethat they to have a noncomformance system, and 18 whether they are geared up 19 CHAIRMAN PALLADIN0s I agreed.
That is why I 20 said ---
21 HR. TAYLOR Programs as we call them.
22 COMMISSIONER AHEARNE:
No, that is each one of 23 those.
Many of those problems are problems in general 24 and in specific, and the specific isn't there because 25 the general isn't there.
The accreditation will ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
22 1
guarantee the ganacal is thera and than your point is 2
but it still doesn't reach the specific.
Well, that is 3
half and half.
4 CHAIRHAN PALLADINO:
All right, but I am 5
saying that Appendix B exists and we could tell them we 6
vant Appendix B to apply.
7 COMMISSIONER AHEARNEa Right.
8 CHAIRHAN PALLADINO:
And we would say get your 9
procedures.
Somebody is going to have to think through 10 the procedures, and I have a feeling before we are 11 through on each of the individual qualifica tions tha t we 12 will have some sort of a reg. guide.
Then the 13 applicants will have to make sure they comply.
14
- 58. TAYLOR:
One of our problems is we don't 15 have nearly enough inspectors to cover this territory.
16 COMMISSIONER AHEARNE:
The point is, or at 17 least my understanding of what the staff has proposed, 18 the issues are that the labs, we have enough evidence, 19 aren't doing a good job.
So the quality has to be
~
20 impro ed.
21 CHAIRMAN PALLADINO:
I have accapted that.
l 22 CONHISSIONER AHEARNE There has to be some l
23 mechanism by which we can end up having assurance that 24 the quality is improved.
We have had experience through j
25 the ASHE system of a third party accreditation.
This l
ALDERSoN REPORTING CCMPANY. lNC, l
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400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
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would be an approach through IEEE, a third party 2
accreditation.
There is clearly an alternative, and the 3
alternative would be to make sure that our rules are 4
very explicit on the laboratories and then to have 5
someone else provide that assurance.
6 I believe what the industry has come in and 7
said is let us provide you with that assurance, and the 8
staff's response is that at least traditionally the 9
alternative would be for the staff to provide that 10 assurance which, as Dick pointed out, previously when 11 that proposal came up they said the way they could 12 provide th a t assurance is increase staff resources to 13 focus on that.
(
14 HR. TAYLOR I really wish we had the 15 experience from having inspected a hundred laboratories, 16 but we don't have that.
17 HR. DIRCKS:
Well, I think we have come sort 18 of f ull circle.
We were making a proposal along the 19 lines of expanding Appendix B and then provide the 20 resources, and the Commission came back and said find 21 another way to do it.
Now we are arguing the other way 1
22 to do it.
l 23 (Laughter.)
l 24 CHAIRHAN PALLADINO The Commission has 25 changed a little since then.
l l
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24 1
(Laughter.)
2 CHAIRHAN PALLADINO:
So I think it is fair to 3
ask the question again.
4 CONHISSIONER AHEARNE:
The one of us who was 5
there at the time is still arguing the same point.
6 (Laughter.)
7 COHNISSIONER AHEARNE:
I still think the 8
accreditation is the best route.
9 CHAIRHAN PALLADINO:
Well, I have been 10 involved in accreditation and I am not so enamored with 11 it as a process.
But it was in a different area so I 12 can't be sure sometimes.
13 COHNISSIONER AHEARNE:
Yes.
f 14 CHAIRMAN PALLADINO:
Other questions by any of 15 the other Commissioners?
16 COHNISSIONER ASSELSTINE:
I have a few.
17 How many of these labs are there, these 18 testing labs?
19 HR. TAILOR:
The number varies in the area 20 above a hundred.
I don't have a specific count.
I have 21 heard from 100 to 140.
Some of them are labs that do 22 just one thing.
Of course, the rule and the 23 accreditation process would recognize that these fellows 24 who are rather small operations could be controlled by 25 what we call the lead or testing organization; that is, ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
25 1
you know, a lot of it is subcontracted, radiation 2
exposure, and that type of thing.
So the rule 3
recognizes that there are a lot of these substrata 4
laboratories that support.
5 CONNISSIONER ASSELSTINE:
I take it in your 8
visits you made one visit for each of seven labs 7
basically?
8 NR. TAYLOR:
No, that is a,little error.
We 9
ande several visits, but there were a total of seven to laboratory organizations.
We had to run back and forth 11 because of what was going on.
12 COMMISSIONER ASSELSTINE:
Are you comfortable 13 enough that we have a clear enough sense of how 14 widespread the problems are ?
I mean you found a number 15 of problems in the seven that you visited.
18 NR. TAYLOR:
These visits were not only by 17 inspectors but by several engineers.
We recognize that 1
18 is a rather small base, but we were working from the l
19 basis of what we have been seeing in the way of the data l
l 20 submitted.
That was the overwhelming basis.
If the 21 data had come in on the 7109B and we had had 92 percent l
22 or 80 percent good data, I don't think we would be where 23 we are today if it had come in anywhere like that.
But 1
l 24 it didn't.
25 As a matter of fact, as the plants are being l
l l
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reviewed, the record is rather dismal for what is there 2
to show that the equipment is qualified, and there is a 3
great big analysis effort in trying, you know, to settle 4
this question.
5 COMMISSIONER ASSELSTINE:
Does at least the 6
data that was submitted under the bulletin give you 7
confidence that you know the bounds of the problem?
You 8
have given a number of representative examples of 9
problems.
Do you think you have identified all of the 10 range of problems?
11 MR. TAYLOR:
I think in the staff that type of 12 expertise exists.
You know, between NRR and ICE people 13 have been living with how to solve these data gaps.
14 COMNISSIONER ASSELSTINE _ You mentioned that 15 the IEEE accreditation program wouldn't relieve the i
16 licensee of his responsibility under Appendix B to Part 17 50 to assure the adequacy of the lab's OA program.
I 18 guess I am not real clear on why that is not the case l
l 19 and why you can't do most all with the accreditation 1
1 20 program.
21 NR. TAYLOR:
I believe the ruie addresses that 22 he would not have to go in and tramp through the same 23 ground of going through, you know 24 COMMISSIONER ASSELSTINE:
What wo uld th e 25 licensee still have to do on a case-by-case basis?
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1 MR. TAYLORs He will be there looking at 2
specific tests.
That is, if he send out a transmitter 3
to be tested and this goes on in November, then he would 4
have to make enough checks to ensure that the lab was 5
conducting his particular test p ro pe rly.
6 CHAIRMAN PALLADINO:
Who would write the 7
procedure for that test?
8 NR. TAYLOR:
That is normally the i
9 responsibility of the licensee.
10 CHAIRMAN PALLADINO: *He would still write that 11 procedure?
12 NR. TAYLOR:
Hight, or his contractor.
13 CHAIRHAN PALLADINO But who would know that
(
14 it was in place?
15 MR. TAILOR:
He would write what is required 16 in the test s that is, you know, what it has to 17 wit hs ta nd, the tempe ra ture environment, the pressure 18 environment and the spray environment.
19 CHAIRMAN PALLADINoa So how could the 20 accredition team when it goes know whether or not that 21 is (a) needed and (b) whether it is in place?
22 MR. TAYLOR:
Well, they would look to see if 23 the test is in process and tha t there is a test plan.
24 That should have come from the licensee.
Presumably if 25 the licensee is doing an adequate job then the test ALDERSoN REPORTING COMPANY. INO, 400 VIRGtNIA AVE., S.W. WASHINGTON. D.C. 20024 (202) 554-2345-
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pisnt will indicate all the requirements necessary under 2
a LOCA or design basis accident.
3 CHAIRMAN PALLADINO:
That licensee would knov 4
that that procedure is or is not written?
5 MR. TAYLOR:
He should, yes.
6 MR. STELLO:
There is an important point, a 7
distinction between the procedure performing a 8
particular task by setting the task himself.
The 9
licensee has to say this component must withstand 400 10 degrees Fahrenheit or at some pressure for such and such 11 a time.
The procedure then says.we put it in a chamber 12 in a particular vsy and monitor it in a pa rticular way 13 and insert steam in a particular way.
(
14 CHAIRMAN PALLADINO:
Do you expect to have 15 accreditation to tell you that 16 MR. STELLO:
The accreditation will assure 17 that the procedures for temperature, pressure, test i
18 chambers and the competence of the people that are there 19 are adequate.
The actual parameters for the individual 20 tests are set by the licensee or the individual who 21 wishes to have the component certified.'
22 COHNISSIONER ASSELSTINE:
So the licensee only 23 then has to assure that the parameters that he gave the 24 testing laboratory were in fact the parameters that were 25 applied?
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MR. STELLO:
That is his responsibility, to 2
set the parameters, and then it is still his 3
responsibility to assure that he got a test and that he 4
got the results of the test and they are okay.
He can S
sake the assumption that the QA system that was in the 6
laboratory once accredited was adequate.
7 CHAIRMAN PALLADIN04 Is that it?
8 COHEISSIONER ASSELSTINE:
No, I have got a 9
couple more.
10 What are the general similarities and 11 differences between this proposed program and the IEEE 12 program and the ASME N-Stamp program?
Are there 13 differences between the two or similarities?
(
14 BR. TAYLORs I think I will turn to a staff 15 member whose has worked on both programs to answer that, 16 Commissioner.
17 Mr. Reinmuth, would you like to address that?
18 He has been very intimately involved with both 19 of these.
20 5R. REINMUTH:
Well, I think the ASEE program
~
21 has been in place for a good long while.
They have a 22 very shopisticated code against which to measure 23 accreditation and this is probably the primary-24 difference.
25 COMMISSIONER ASSELSTINE:
So in other respects ALDERSoN REPORTING COMPANY,INC, 400 vtAGINIA AVE., S.W., WASHINGTON, O C. 20024 (202) 554-2345
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they are essentially similar programs.
What we would 2
expect out of the IEEE program versus what we would 3
expect out of the ASME?
4 CORMISSIONER ROBERTS:
I am not sure you can 5
sake tha t statement.
6 HR. REINMUTHs The IEEE program was patterned 7
after the ASHE.
In other words, the survey team 8
concept, the review of the survey team report by a 9
separate independent committee, a separate committee 10 vriting the standard, these types of things were built 11 into the IEEE scheme of things and they were patterned 12 after the ASME, ras.
13 COMMISSIONER ASSELSIINE:
Is the continuing 14 responsibility of the licensee for QA under the N-Stamp _____
i 15 program essentially the same as what Victor has l
16 described for the way you foresee that working under 17 this program?
18 HR. REINMUTH:
Well, the agreement we have 19 with the ASHE, we have really not completed that 20 agreement because the OA standards to which the N-Stamp l
21 is granted, we have said the QA requirements have to be l
22 equivalent to ours.
This motivated the writing of the 23 NO A -1 standard and that standard is going to be adopted 24 by the Section 3 Code as the basis for the N-Stamp.
25 When that happens, then we can tell the licensees okay l
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31 1
the N-Stamp is evidence that you meet our standards, and 2
therefore, you do not have to do it.
3 MR. MORRISON:
The NO A-1 standard is a basis 4
for the IEEE lab accreditation.
5 MR. REINMUTH4 What we are getting at is the 6
programmatic requirements will be evaluated by a third 7
party under the ASME system and under the IEEE scheme of 8
things.
The product acceptance, the product in the case 9
of the laboratory is the test.
In the case of the ASME 10 it is a product.
We still hold the licensee responsible 11 for each of those, the prod uct acceptability.
12 HR. MORRISON:
Can I add one thing.
I think 13 Commissioner Roberts has brought up one difference.
In.
(
14 the ASME system the organization gets accredited by a 15 survey team which is comparable to what the IEEE 16 accreditation program would entail.
But in addition for 17 the ASME the organization has to have a con tra ct with an 18 inspection agency where they have an authorized nuclear 19 inspector to inspact various activities under the code 20 covered portion.
That is missing.
There is no
~
21 provision in the IEEE system for that.
22 COMMISSIONER ASSELSTINE:
I guess my last 23 question is if you compare the staf f 's propossi f or the 24 IEEE accreditation program with the alt,erna tive of 25 requiring either if Appendix B is sufficient now or by a l
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new rule and required the utility to adequately verify 2
not only the parameters that Vic mentioned but also the 3
procedures in these other elements of the test 4
laboratory program, what do you see as the principal 5
advantages of the IEEE proposal versus that 6
alternative?
Staffing is one I gather, but is that the 7
only one?
8 HR. STELLO:
Well, each licensee would be 9
required then to certify that aspect in each lab.
So 10 that if a licensea went to six labs to have testing 11 done, different kinds of testing, he would then be 12 required to ascertain by full implementation of Appendix 13 B what equipment and what IEEE vould do or what would be
(
14 expected, and we would then confirm somehow, that is our _. _
15 side of it, that that was done.
16 So if there are 50 licensees going to a 17 hundred laboratories, or whatever combination they use, 18 that is how many more times it would have to be done, 19 and it would seem fairly inefficient to do that, 20 although I think there are some arguments made that l
21 nevertheless it ought to be something that every 1
22 licensee ought to do to fully understand that it is 23 getting the product that he wants to get, and there are 24 certainly advantages to tha t.,I think that is one of 25 the issues you will be hearing that the industry ought i
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to be bringing up in terms of assuring that the 2
licensees actually go out and do that.
3 COMMISSIONER ASSELSTINE:
With the exception 4
of a clearly defined standard for measuring the 5
laboratory testing programs, it is unclear to me why 6
Appendix B doesn't already require that licensees do 7
that on a case-by-case basis.
8 HR. STELLO:
I think I would argue more that 9
they should be doing it.
10 COMMISSIONER ASSELSTINE:
Other than the f act 11 that we don't have a benchmark right now against which 12 to measure the individual laboratory programs.
13 HR. STELLO:
Well, if I were a licensee I
(
14 would be wanting to be sure that I got a high-quality 15 product.
That is one way to be sure of that, and in 16 fact some licensees are doing that.
17 HR. TAYLORa Some of them are, yes.
18 HR. STELLO:
So I would want to make sure that 19 they are persuaded that there is an adequate QA system 20 in the laboratory and that the instruments are 21
=alibrated and qualified and proper instruments and 22 proper ranges are used.
They are doing it, and I think 23 the licensees have recognized that it is important to do 24 and they are doing it, but all of them do not.
25 CHAIRMAN PALLADINO:
Will the accreditation by ALDERSON REPORTING COMPANY,INC, 400 VIAGINIA AVE.. S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
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IEEE be limited to electrical equipment, or do you 2
foresee it doing more than electrical, or are we going 3
to have seversi accreditations?
4 MR. MORRISON:
The accreditation program when 5
it is set up is not limited specifically to electrical 6
equipment, although it is intended to tie in with the 7
rulemaking that is ongoing and would be applied to the 8
equipment that is required to be qualification tested.
9 In the future we have mechanical equipment qualfication 10 test requriements under development.
The intent was 11 tha t tha t accreditation program would apply to those 12 organizations performing qualification testing also.
13 COMMISSIONER AHEARNE:
It is environmental 14 qualification.
15 MR. MORRISON:
Yes.
16 COMMISSIONER AHEARNEa Jim, I wanted to 17 provide one additional answer to a question you asked.
18 You asked what would be the advantages.
Now one of the 19 advantages has little to do with our responsibility, but 20 that would be for those people who a re interested in 21
- catering nuclear power, it would be an~ advantage 22 because I think it you3a help get public su pport for it 23 if they coald see some visibla, independent recognized 24 organization,as being a participant in the 25 certification, that yes, this is done right.
But that ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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is really not an NRC advantage.
2 COMM1SSIONER ROBERTSa Paragraph 5 of your 3
June 7th seno.
4 COMMISSIONER AHEARNE.
Yes.
5 CHAIRMAN PALLADINO:
Any more question's?
6 (No response.)
7 CHAIRMAN PALLADINO:
Well, thank you.
8 Why don't we turn now to the industry 9
representatives.
10 (At this point in the meeting Hessrs. DeYoung, 11 Taylor, Dircks, Stello and Morrison left the 12 Commissioners' table and Messrs. Kubick, Owen and Roby 13 joined the Commissioners at the table.)
14 CHAIRMAN PALLADINO.
I will turn the meeting 15 over to you, Warren.
16 NR. OWENs For the record my name is Warren 17 Owen, and just as quick as I find my notes we will get 18 going.
Excuse me for not being organized.
I was 19 furiously making notes.
20 Mr. Chairman and Commissioners, we appreciate.
21 The group we have assembled f6r the 22 presentation represents the Atomic Industrial Forum, the 23 Nuclear Safety Analsis Center, a part of the Eloctric 24 Power Research Institute and a cross-section of testing 25 laboratorias and annuf acturers.
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Sur objective is twofold.
First, we want to 2
express to you our concerns regarding the NRC staff 3
sponsored third party accreditation program, 4
particularly our concerns regarding both the need for 5
the program and its adverse impacts.
6 Nr. Arnold Roby on my right of Northeast 7
Utilities will share with you the industry's 8
perspectives regarding these concerns.
9 Additionally, we have spokesmen representing to manufacturing organizations with testing facilities and 11 independent testing laboratories available to relate 12 their views as to how this proposed program will affect 13 them.
(
14 Our second ob.jec_tlye_ i.s to describe for you an 15 industry sponsored program tha t we believe addresses and 16 comes to grips with the areas within the total 17 qualification testing process that have already been i
18 identified here earller.
Mr. Bob Kubik of EPHI will 19 present this portion of our presentation.
20 The proposed program advanced by the staff 21 would require that IEEE accredit the general 22 capabilities of a testing facility prior to that 23 facility engaging in any equipment qualification 24 testing.
Significantly, the general capability of 25 tes ting facilities, along with other facets of testing l
l l
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practice, are currently reviewed and evnluited pursuant 2
to quality assurance requirements set forth in Appendix 3
B, as you have already recognized.
Those existing 4
Commission regulations are sufficient to provide 5
assurance of the general capabilities of testing 6
facilities, and that is the bottom line.
7 This position is based on years of 8
industry-wide experience and evaluating and interacting 9
with such facilities.
In this regard we note that if a 10 problem in the area did exist, the staff has failed to 11 document and appraise the industry of its existence.
12 These cases of testing deficiencies that have been 13 discovered by the staff have generally not involved the
(
14 basic capabilities of test facilities.
Further, the 15 deficiencies.have been resolved on an individual basis.
16 In short, we submit that the adequacy of 17 testing facility capability is not a problem which would 18 varrent the imposition of another layer of regulation 19 and an associated accreditation program as proposed by l
l 20 the staff.
We maintain that the program proposed by the 21 staff does not address an existing probien vihin the 22 industry, and therefore vill provide no significant 23 increase in the lavel of public health and safety.
24 If the staff can document the existence of a 25 problem regarding the capabilities of test facilities, ALDERSON REPORTING COMPANY. INC.
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it is our position that the selected corrective action 2
should be commensurate with the magnitude of the problem 3
identified.
Thus, unless the problem is shown to be 4
widespread and flagrant, it would be more appropriate to 5
place greater emphasis, as you have recognized, on 6
current regulation rather than to impose new regulation 7
and an untried accreditation program.
8 To be clear, it is not our position that the 9
qualification testing process cannot be improved.
There to are opportunities for improvement.
In response to this 11 the industry has followed your guidance, Mr. Chairman, 12 and had undertaken a critical review of this area.
The 13 culmination of the review is the industry sponsored
('
14 workshop seminar on the total qualification testing 15 process that will be discussed later by Mr. Kubic.
16 Unlike the staff proposal which addresses only the 17 capability of the test facility, this workshop seminar 18 will address the real problems of the entire 19 qualification process.
20 We are also concerned th a t the implemen ta tion 21 of the proposal will result in some significant adverse 22 impacts.
While Mr. Roby will address these in greater 23 detail, I would like to mention one major concern, and 24 that is the possibility of a decrease in the number of 25 testing f acilities and manufacturers that currently l
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39 1
support the nuclear industry.
2 Discussion with those in the testing business 3
reveal that the market for their products and services s
4 to the nuclear industry may not be significant enough to 5
keep them in business.
Any decrease in the quality 6
testing laboratories available for our use would 7
certainly have an adverse long-time impact on the 8
industry and couli affect completion of short-term 9
qualification programs and schedules.
10
'In conclusion, we maintain that current 11 regulations provide the opportunity for reasonable 12 assurances of the adequacy of testing facilities to 13 conduct equipment testing.
Further, we submit that the
(
14 staff's proposed program does n'ot address any problem 15 currently axisting vthin the industry.
Because of this 16 and in view of the potential adverse consequences of 17 such a program, we strongly recommend that the 18 Commission reject the staff proposal.
19 With your permission rather than using a 20 slide, I would like to make just one other point, and if 21 I could pass this to each of you.
We have listed there 22 the 13 steps that we see in a typical qualification 23 process.
Someone might argue into making it into 12 or 24 further subdividing it into 15, but out of those 13 25 steps, all of which are importan t in the overall ALDERSoN REPORTING COMPANY,INC,
_________.______.___.]
40 1
qualification process, you will note that the laboratory 2
pisys a part in only three of those, and I thin tha t 3
speaks to the point that you were discussing earlier.
4 I would like to now ask Arnold Robi, who is 5
Chairman of the AIF Subcommittee on Equipment 6
Q ualifica tio n, to make some comments.
7 CHAIRMAN PALLADINOs I wonder if I could just 8
ask you one question.
I was trying to find where you 9-said it.
You said the staff has failed to document and 10 apprise the industry of problems.
Yet, industry hasn't 11 found its own problems.
Why did industry not identify, 12 and according to the staff, approximately 70 to 80 13 percent of the resources were deficient, and those 14 related to responses to the_7901B.
Was the industry not 15 aware of deficiencies existing in the testing 18 la bo rato rie s ?
17 NR. OWEN:
I can't speak to their 70 to 80 18 percent.
I would have to look at those.
I suspect ther 19 find 70 to 80 percent of something wrong with everything 20 we submit to them.
We certainly get enough questions.
~
21 (Laughter.)
22 MR. OWEN:
I don't mean that in a disparaging 23 vay.
24 (Laughter.)
25 3R. OWEN:
I think that is a misuse of that ALDERSoN REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O C. 20024 (202) 554-2345
i 41 1
information.
I know of no such widespread deficiencies.
2 I do know that in many instances where they think they 3
have found deficiancies, and I am personally aware of 4
one that cost a hell of a lot of money, they test 5
something that we sold to them and then I have got to 6
spend a lot of money proving the test was no good and we 7
did.
That is a question of we all need to understand 8
the qualification process better, and, to that end that 9
is why we have structured the industry program to try to 10 raise all of our awareness a6d understanding of what is 11 needed, and not another layer of accreditation which I 12 submit does not speak to the real problem at hand.
13 CHAIRMAN PALLADINO:
But I still was
(
14 interested in how industry is coping with the problems 15 that apparently are there, because I don't think the 16 staff invents problems.
We have enough of them so that 17 we don't have to invent them.
l 18 COHHISSIONER AHEARNE:
Perhaps we need to step 19 back one step and ask, Warr en, does the industry think 20 there are any problems?
21 MR. OWEN4 We think there are'certainly 22 opportunities for improvement.
23 COMMISSIONER AHEARNEa But that is always the 24 case.
25 MR. OWENs I would submit, Commissioner, that ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
42 1
I haven't seen any cases of failures of things under 2
transient conditions, even TMI, that indicated a need i
3 for this.
4 CHAIRMAN PALLADINO:
A need for what, for the 5
qualification?
6 MR. OWENs That we have done a bad job of 7
preparing to deal with those transients.
That 8
instrumentation did not fail.
9 CHAIRMAN PALLADIN0s Nov ve are getting into 10 whether or not we need qualification and that is a 11 different subject.
12 NR. OWENs Yes.
If I can just say one other 13 thing., I think it is a little bit improper, and I can't
(
14 think of a better word, to talk about taking a look at a 15 test that was done in the late 1960's and looking at it 16 in today's light without passing an inappropriate 17 judgment that it doesn 't meet today's standards.
That 18 is not the question.
It is does the piece of equipment 19 meet today's standards, and I don't know of any cases 20 where we have found that.
I think we have found cases 21 with connectors.
I happen to know that the connectors 22 that people bought that test that verification were not 23 even bought to the Class I-E standards that we would 24 impose and did impose in those days.
25 So I think there are definitely some ALDERSON REPORTING COMPANY. INC.
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43 1
problems.
The industry proposes to deal with those 2
problems in the vary best way we can and that is by 3
bringing our experts together and making use of the 4
P-600 standard, once it is given a thorough industry 5
review and it is ready, and then we would undertake that 6
task as we have others.
7 COMMISSIONER AHEARNEa Warren, you have in th e 8
chart you handed out, the typical qualification process, 9
you have pointed out that there are only th ree places 10 where the labo'ratory really plays a key part and the 11 utility plays most of the part in the 13 steps.
12 Is it therefore fair te conclude that if there 13 are any problems, the problems are really utility
(
14 problems and not laboratory problems?
15 MR. OWEN:
I would submit that.
We are 16 responsible and we are villing to accept that 17 responsibility and we need to deal with areas where are 18 are not fulfilling it.
19 COMMISSIONER AHEARNE:
I recognize there still 20 is the issue of are there any problems.
But, therefore, 21 if we were to conclude that there really are problems, 22 then we should not conclude it was the fault of the 23 laboratorias, but it is really the fault of the 24 utilities.
25 MR. OWENs ByangtlsjgeIguesstherearebad 3-h Al.DERSON REPCRTING COMPANY,INC, 400 vmGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 -
44 1
laboratories just like there are bad averything else, 2
but most of us do our best to star clear of_those.
3 COMMISSIONE3 AHEARNE:
But, as I guess you 4
pointed out, it is essentially a utility ---
5 MR. OWENs We have a number of th ose 6
laboratory owners and executives here today and I think 7
they are not in that group tha t have those multitudes of 8
problems or else they wouldn't be here I suspect.
9 CHAIRMAN PALLADIN04 Well, why don't we go on 10 to Mr. Roby.
11 MR. ROBY4 My name is Arnold Roby.
I am 12 Chairman of the AIF Subcommittee on Equipment 13 Qualification.
14 I would like to' continue our discussion on the 15 NRC staff proposed testing ' f acilities accreditation 16 program and certain1r to expaad on many of the remarks ~
17 that Mr. Owen's opening statement.
l
~18 To set the record for the credentials of the 19 position paper which we had prepared on this subject, in 20 September 1981, an industry workship was convened to 21 consider the proposals for laboratory accreditation as 22 we then knew them to be.
This workshop did utilize the 23 input from utilitiess testing organizations, 24 consultants, architect / engineers and certainly 25 representation from the BPC.
ALDERSoN REPORTING COMPANY,INC, 400 VIRG.f41A AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345 -
45 1
As an out come of that workship certain basic 2
and very important concerns with the accreditation 3
program were formulated as a trial position paper.
To 4
further the industry belief in its draft position paper 5
the paper was subsequent 1r reviewed by numerous industry 6
organizations, including the EPRI/ Utility Advisory 7
Group, the AIF Subcommittee on Equipment Qualification; 8
the AIF Committee on Power Plant Design, Construction 9
and Operation, and all of the Utility owners Equipment 10 Qualification Groups.
11 That position paper was transmitted to the 12 staff on February 2nd, 1982, and it was also sent to the 13 ACES Subcommittee on Equipment Qualification in February
(
14 of this year.
15 Basically and in substance, that paper 16 expressed a very strong industry disagreement that a 17 nead exists for an accreditation program of the type 18 proposed by the staff.
It was and is the industry view 19 that the existing regulations are adequate and that the 20 accreditation program, if implemented, would not result 21 in any measurable increase in the quality of the testing 22 services or further enhance public health and safety.
23 (Slide presentation.)
24 The paper identified many of the potential l
25 adve'rse impacts of the staff proposed program, and for ALDERSON REPORTING COMPANY. INC.
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rour information slide one illustrates these.
2 The salient points which were included in the 3
AIF position paper and which pointed out the potential 4
disadvantages of the program were that accreditation 5
would only serve to further diffuse the assurance 6
responsibilities between utilities, consultants and now 7
of course the accrediting organization.
8 That aspect has many serious disadvantages, 9
not the least of which may be a false sense of security 10 on the part of licensees or in fact the regulators in 11 the belief that everything up front was cozy and correct 12 and therefore ve need not bother ourselves or interest 13 ourselves indeed in the accuracy or adequacy of that C
14 _p a r_t o f the program.
15 The second thing of course which concerned was 16 tha t the number of quality testing organizations was 17 quite likely to be reduced.
Some organizations, and i
18 certainly some of those people that represent these l
l l
19 organizations are with us today, some of those 20 organizations would either be unwilling to meet the
~
21 accreditation requirements or unable to absorb the costs 22 and remain competitive, which of course is the bottom 23 line for a testing f acility 's organization.
24 We also considered tha t accredita tion 1
25 certification obtained and maintained at a substantial l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0 C. 20024 (202) 554-2345
47 1
cost could also act as a deterrent to advancements in 2
qualification testing technology.
You might like us to 3
enumerate a little further on that aspect in your 4
questions.
5 The fourth point that we had wanted to make 6
was that the industry of course, the manpower and the 7
financial resources of industry are limited, and this 8
program would clearly divert those resources from other 9
higher priority projects which projects themselves would 10 potentially have greater safety benefits.
11 The position paper, in addition to looking at 12 the se potential disadvantages, also looked at the 13 characteristics of the present day industry practices
(
14 and made a judgment that many of these had the potential 15 to be lost is the proposed program were mandated.
16 We considered tha t present industry practices 17 which could be affected by this program includeda l
18 Slide two, please.
19 That the present program virtually assures
(
~
20 that final respnsibility for assuring compliance is in 21 its correct place, i.e.,
the utility for all aspects of 22 those programs that it is charged with the 23 responsibility of assuring;
[
l l
24 That direct involvement of the NRC can occur i
25 a t any stage in the qualification effort entirely as the ALDERSON REPORTING COMPANY,INC, 400 VIRGINfA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54 2345
48 1
staff would see the necessity to do; 2
That there is free competition of the testing 3
organizations for the marketplace that we can offer them; 4
That there is a continued enhancement of the 5
state of the art in qualification testing methods and 6
technology; and 7
that the system that we presently have 8
provides us with the most cost effective system 9
consistent with using high quality testing facility 10 services.
11 He met with the staff on June 9th of this year 12 and we again made clear our concerns with the proposed 13 program.
We stressed that our own industry examination
(
14_ _of _ the purported inadequacies of testing organizations 15 or licensees, that while they we re there, they certainly 16 did not s:1pp or t the' requirement for an improvement 1
17 pro grant of the type proposed by the staff.
18 The overall industry consensus was that 19 accreditation by a third pa rty organization would only 20 impose an additional layer of quality assurance and
~
21 costs on licensees without contributing to improved 22 plant safety or the ability of a testing f acility to 23 even improve its performance.
24 In June of this year the AIF President, Carl i
l 25 Walske sent a letter to Chairman Palladino clearly ALDERSoN REPORTING CCMPANY,INC, 400 VtAGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
49 l
1 identifying that the staff perception of a reduction in 2
the number of audits, as we had heard this morning which 3
was clearly a part of their program, would be 4
unfounded.
Third party certification would not be 5
accepted by the utilities' to reduca their present 6
a udits, tad in that situation all the costs associated 7
with the TFA program must be in addition to the costs 8
already being incurred.
9 The NRC proposal is apparently based on a 10 concern regarding the general capabilities of certain 11 test f acilities employed by the utilities.
The staff 12 has not to date provided specific information 13 identifying such deficiencies.
'Neither, to our
(
14 knowledge, has staff acti~on been taken against any 15 utility regarding the inadequate selection and control 16 of test facilities.
17 Claims that equipment qualification submittals 18 from operating plants, summarizing past qualification 19 tests, that those tests show a high percentage of 20 deficiencies with respect to current qualification 21 requirements, are certainly of no surprise to us, but 22 they are no t relevant to this issue.
These 23 deficiencias, which we haard talked about in terms of 24 percentage deficiencies this morning, they would not 25 have been resolved by the adoption of this accreditation ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W:. WASHINGTCN. O C. 20024 (202) 554-2345
50 1
program, and certainly qualification practices have 2
changed dramatically over recent years.
3 The NRC has also expressed the concern that if 4
accredition rulemaking is not approved that additional 5
NRC staff aanpower will be required to verify the 6
adequacy of the test facilities used by the industry.
7 Again, we don't agree with that conclusion or that such 8
an increase of staff is necessary.
As under current 9
regulations the prime responsibility ~for ensuring the 10 adequacy of test facilities lies with the utilities 11 employing such facilities.
The NRC need only augment 12 their audits of the utilities to verify that this 13 responsibility is being adequately addressed.
I 14 We are of the opinion that existing 15 regulations currently implemented and proper 16 administered will address all of the NRC concerns.
't 17 Supporting that belief we also believe that there is 18 less than adequata justification for the staff 19 proposals, and we submit that 20 The requirements of the proposals neither add 21 to, challenge or modify the applicable requirements of 22 10 CFR 50 Appendix B; 23 The staff has not provided specific 24 information clearly establishing the type and extent of 25 problems which they maintain the TFA program will ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
51 1
correct; 1
2 Industry has not been asked to participate in 3
programs to resolve perceived qualification problems, 4
and certainly not prior to the staff proposal for 5
rulemaking on this issue; 6
The staff has not provided a detailed 7
consideration of any alternatives to their proposal nor 8
have they evaluated those alternatives relative to 9
orrecting the parceived problems with existing to practices.
11 In conclusion, it is the industry position 12 that the staff proposed accreditation program is both 13 unwarranted and inappropriate.
In support of our claims
(
14 concerning the adverse impact of the program, a number 15 of testing. organizations are here today to assist you 16 and are prepared to make brief statements if you would 17 like them.
We have industry experts from Westinghouse, 18 Acton Testing' Laboratories, Southern Transformers, TEC, 19 Combustion Engineering, Corporate Consulting and 20 Commonwealth Edison.
21 Certainly feel free if you wish to have 22 statements delivered f rom any or all of those people.
1 23 MR. OWENs Mr. Chairman, if I might, I would
(
24 very much to withhold any prersing questions on that 25 point and if we could give just a few minutes to Bob ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON. O C. 20024 (202) 554 2345
52 1
Kubick who is hara from Elactric Power Research 2
Institute and has been working hard for the industry in 3
trying to get our program off the ground.
4 CHAIRMAN PALLADINO:
So you propose we go on 5-to Mr. Kubick?
6 MR. OWEN:
Yes, and then come back to 7
questions.
8 MR. ROBY:
What we propose,to do is to 9
introduce you to our alternative which essentially will 10 be covered by myself and Bob Kubick.
After that we can 11 certainly entertain any or all of your questions, or if 12 there is anything th a t you feel a pressing urgency for 13 us to answer at this point in time we could stop.
(
14 CHAIRMAN PALLADIN04 Well, why don't we go on l
15 with Mr. Kubick and then we will come back to questions.
16 HR. ROBY4 Fine.
17 As a positive alternative to the TFA program l
18 ve would proposa an industry program which contains the 1
l 19 f.llowing elements.
20 The third slide illustrates these.
21 The thrae elements that we have within our 22 program ares 23 The preparation of a comprehensive standard, a 24 national standard, which will identify the capabilities l
25 an organization must possess in order to perform i
1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W WASHINGTON, D.C. 20024 (202) 554-2345
53 1
qualification testing.
It will essentially talk to 2
those general requirements which we expect to have in 3
addition to, as we heard this morning, the specific 4
requirements that are placed on an organization through 5
a utility oriented test program.
6 The second element that we have is the 7
provision of a workshop to develop guides and 8
information for assuring the use of high-quality testing 9
facility services.
This workshop, as Bob Kubick will 10 touch on, will be prepared by experts within the 11 industry.
12 Then we would propose to hold industry 13 sponsored seminars throughout the country starting in
(
14 1983 to provide information designed to improve the l
15 process by which the qualification testing was 16 performed.
These seminars would be attended by 17 personnel from utilities, testing organizations, j
18 architect / engineers and other responsible for the l
19 quality and technical aspects of test programs.
The 20 seminars primarily of course would illustra te 21 recommendations developed in the standard and by the 22 vorkshop.
23 We believe that this three-element program 24 elearly established and properly administered will in 25 total provide assurance that licensees are capable of ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
S4 1
a sse ssi ng the competence of the testing organization in 2
both an acceptable and uniform manner which has been a 3
criticism that the staff has levied at the utilities.
4 We also consider that the tasting organization 5
with this program in place will become more aware of 6
their responsibilities in conducting the qualification 7
tests.
8 We believe that our program which is being 9
detailed to you today represents a considerable effort to by the nuclear industry to further enhance safety.
We 11 think it is the kind of industry initiative which the 12 Commission can support and which will lessen the burden 13 imposed by duplicative appraisal and evaluation
(
14 activities.
15 For the second and third elements of our 16 program to be explained in more detail I would like to 17 introduce Bob Kubick from the EPRI.
18 NR. KUBICK:
Thank you.
19 I as Bob Kubick.
20 Could I have my first slide, please.
~
21 (Slide presentation.)
22 I am going to tell you about what in fact we 23 have already accomplished.
This is a program that has 24 already begun, as a matter of fact, and one which we i
l 25 have thrown ourselves behind and will make happen.
I ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
55 1
We have a steering committee consisting of 2
Warren Owen, Byron lee and Dave Rossen who.we will turn 3
to. if we run out of money or motivation in getting the 4
program done.
5 The next slide, please.
6 Our implementation plan consists, as has been 7
mentioned, of a planning workshop followed by a series 8
of seminars.
9 Th e next slide, please.
10 The workshop's objectives, and I will talk 11 mostly about the workshop, is to develop an overall 12 guide to how to effectively administer such a program, 13 and this is aimed at the utilities, and also to develop
(
14 a_ series of specific. test guides that.are aimed at the 15 laboratories.
Then, finally, to outline seminars, a 16 curriculum for seminars, to illuminate those test guides 17 and to illustrate by example good practices.
18 The next slide, please.
19 The workshop will be hosted by EPRI.
It 20 begins next Monday morning and we have hand picked 21 21 people from the utilities and the industry in general 22 who will attend.
These are the 21 people we feel are 23 aost eff ective at defining this problem and its 24 solutions.
25 The next slide, please.
I ALDERSoN REPORTING CCMPANY,INC, 400 VIRGINlA AVE., S.W.. WASHINGTON. 0.C. 20024 (202) 554-2345 l
56 1
CHAIRHAN PALLADINO:
Who is going to attend?
2 ER. KUBICK:
I will show you exactly who is 3
going to sttend.
I have the attendees listed on the 4
next slide.
5 These are utility invitees, and there is 6
another slide of other industry invitees.
Our primary 7
group of utility invitees a re the inner circle of the 8
EPRI Equipment Qualification Advisory Group.
This is a 9
group that has been in existance for about two years 10 guiding EPHI in E0 programs.
It has also become in that 11 period of time an information interchange group on its 12 own.
Now it meets several times a yea r.
One day it 13 talks about RCD and the other couple of days it talks 11 about how to get thingt done.
15 Most of the coastructive, cooperative programs 16 in equipment qualification have been spawned by this 17 group.
So we feel these are the people who most know 18 how to get things done in this area.
We have 19 supplemented that with some other particular people with 20 other particular knowledge.*
~
21 Ihe next slide, please.
22 In addition to those utility representatives, i
23 we also have carefully picked people from test labs, and 24 I include in test labs some of those who are 25 manufacturers who do their own testing or partly their ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W.. WASHINGTON, D.C. 20024 (202) 554 2345
57 1
own testing.
We feel these span the spectrum from large 2
to small vendors and large to small test labs 3
supplementad by consultants who we have picked for 4
particular knowledge that they have.
5 The next slide, please.
6 The various industry organizations are 7
onboard, EEI, INPO and AIF, but primarily EPRI will see 8
that it will happen, and I myself am the Program Manager 9
for this.
I will be responsible for it.
10 The next slide, pleas e.
11 Our schedule, as I mentioned, the workshop is 12 beginning Monday and we have a four-day workshop with I
al these 21 paople to do the planning behind the entire 14 program.
Of course, we have done some preplanning, but 15 to finalize our plans.
We would spend several months 16 preparing the seminar materials, slide shows, video 17 tapes and so on.
18 Now one of the features we intend to provide 19 here is not just to spill this information out, but to 20 present it in a prof essional manner to a large group of 21 people in various cities and present it'over and over l
l 22 again.
So there is a large amount of preparation that 23 will go into this, and I will discuss that a little bit 24 later.
We are offering ourselves at least three months 25 to do that.
We will have a trial run of the seminar in i
l ALDERSON REPORTING COMPANY,INC, 400 VIAGINIA AVE., S.W WASHINGTON D C. 20024 (202) 554-2345
58 1
November and then go back for a couple of months and 2
redo.
3 The next slide, please.
4 Then we will take our road show around the 5
country and we would offer on the schedule of once a 6
month in' differing cities at least five seminars and as 7
many more as are necessary to cover our entire audience.
8 The next slide, please.
9 Our estimated attendance of the seminar, 10 originally we thought the primary audience was the 11 utilities.' We still feel that, althou-h tf**r 17 discussior.s with the staff and in recognition of their i
13 c onc e rn s., we see as another primary rulience the test
('
14 la'.i s_a n d_v_e n do rs t h e ms elv es.
I think we can guarantee l
15 that every nuclear utility will be represented in these 16 seminars.
We can't quite guarantee that every test lab i
17 and vendor will be there.
I think all the major ones 18 and those that we can identify that need it will be 19 there.
20 CHAIRMAN PALLADINO:
This is at the seminar 21 and not at the road show?
l 22 MR. KUBICK:
At the seminars, yes.
That is 23 the road show, and each offering vill be, you know, 24 several days.
We are not sure whether that is going to 25 be a three-day or four-day seminar.
ALDERSON REPORTING COMPANY. INC.
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59 1
Certainly others in the industry, 2
architect / engineers, consultants, NRC representatives 3
and national lab people will be welcome.
~
4 The next slide, please.
5 CHAIRMAN PALlADINO:
I thought those seminars 6
were aimed eventually for the test labs.
7 MR. KUBICK:
Well, there e;a two aims really.
8 The primary aim are the utilities who have the 9
responsibility for the planning.
An important secondary to audience though is the test labs.
We have got to hit 11 them both.
12 HR. OWEN:
Certainly they are an important 13 part of that, P. r. Chairman.
But the reason that we
(
I 14 prepared that little chart of steps to go through is the 15 utility, the licansee has the bulk of that 16 responsibility.
I don't care how good the lab does its 17 job, they can't define the job nor can they completely 18 interpret the results of the test.
19 MR. KUBICK:
Now our outline f or the seminar, 20 this is what we will be going over next week and adding 21 flesh to, but this is the way we think about it at the 22 present time.
We will start of f with sort of the 23 front-end work.
This is the sort of thing that is not 24 addressed by the test lab accreditation, questions of 25 how is the equipment used, what environment will it see, ALDERSON REPORTING COMPANY. INC, 400 VI AG'NIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554-2345
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how do you plan qualification, what should be done and 2
how do you draw up a specification for the test lab, all 3
the front-end work that must be done before you ever cet 4
to a test lab.
5 In each case and for each saction here we will 6
have a paid lecturer.
We have lined up a faculty here 7
of people that we think are particularly well equipped 8
to deal with that and they will be at the workshop and 9
help in the planning es well as the industry 10 representatives.
11 The next slide, please.
12 The next section is concerned with those 13 things that actually occur in the test lab, the detailed l
(
14 test plan develop, the doing of the test and very-15 importantly the interpretation of the results, which 16 again is something that is not addressed by test lab 17 accreditation.
18 Our lecturer is Sal Carfagno, a person who is 19 well recognized and has been used by the NRC extensively 20 in this araa.
21 This section will also bring up the detailed 22 test guides th a t we intend to develop which would 23 address what is the best current practice in doing a 24 bulk head test, in doing a humidity test and in doing a 25 seismic test.
There is a need for getting out to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON. O C. 20024 (202) 554,2345
61 1
everybody how do you do these, not in the sense of a 2
standard, but in the sense of best current practice.
3 The next slide, please.
4 Another and certainly important section would 5
be to identify and discuss all quality assurance 6
documentation, standards and codes associated in this 7
field.
8 The next slide, please.
9 Perhaps most importantly, though, and larded 10 through this presentation will be case studies.
We* feel 11 there has been a great deal learned by the mistakes, as 12 we perceive of the past or inadequacies, and we would 13 intend to put together a series of case studies.
Most 14 of these will be presented by utility people, and in 15 order to make it practical we will have high-quality 16 video tape productions made of these.
Each of these 17 vill probaby be a 20 to 30-minute professional video 18 tape production.
19 For instance, spawned from EPRI's EQ Advisory 20 Group was an industry effort in qualif ying 21 transmitters.
Now Hary Hanneman of Wisconsin Electric 22 led that eff ort and they have had their f ailures and 23 their successes in doing that qualification.
We feel 24 that Harv in person on camera well rehersed discussing 25 what they learned from that would be an excellent way to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W-, WASHINGTON. D.C. 20024 (202) 554-2345
62 1
present this kind of material, in addition to lectures 2
and slides shows.
3 Also, the BWR Owners Group has had a 4
committee, a nd I have attended some of their meetings, 5
with a very narrow focus on how to qualify the Comsec 6
Bellfi Hydrogen Analyzer, and they have had their 7
difficulties.
There is a great deal for others to learn 8
from that.
Westinghouse has had an Owners Group which 9
took a much broader look at many pieces of equipment.
10 We want at least one case study from an 11 individual utility that has some fine successes to talk 12 about, Len Casselo of Florida Power and Light.
13 We would see, altnou,gh we haven't identified 14 specifically, at least one case study from an 15 architect / engineer's point of view and another from a 16 manufacturer's point of view and another from a test i
17 lab's point of view.
I t
18 We feel that this bringing actual experience, 19 wha t worked and what didn't work is one of the principal 20 f ea tures of this program.
21 May I have the next slide, please.
22 To give you some idea of what we think is 23 behind this, here are estimated costs for the workshop, 24 f or the seminar preparation and the seminar 1
25 prese n ta tio ns.
You will notice that the preparations of 1
i l
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63 1
the seminar cost substantially more than the 2
presentations themselves.
As I mentioned, we have spent 3
a number of months preparing material.
If any of you 4
have ever taught, you know that preparation for the 5
teaching is the big part of it.
6 Overall we feel that it will be about $150,000 7
of out-of-pocket zoney.
That is for producing 8
audio-visuals and our paid faculty preparation time and 9
giving time, and even more importantly though, about 305 10' donated person days.
When you stop to think that these 11 people who are donating their time are the individuals 12 who are best qualified to address these issues in the 13 United States, we feel that is a very substantial 14 commitment on our part.
15 Ihank you.
16 CHAIRHAN PALLADINO:
I have only one question 17 for you, Mr. Kubick.
I gather that the workshops and 18 seminars, that attendance will be voluntary.
How can 19 the program meet its objectives if many utilities, 20 testing organizations and manufacturers do not attend 21 the workshops or the seminars?
22 3R. KUBICKs Well, first of all, I think we 23 have developed, pa rticularly at NSAC, some pretty 24 sophisticated ways of finding out who should know what 25 or who the problem is.
So I think we know who our ALDERSON REPORTING CCMPANY,INC, 400 VIRGIN! A AVE, S.W WASHINGTON. O.C. 20024 (202) 554 2345.--
64 1
audienca is largely and we can find out who should be 2
there.
3 CHAIRMAN PALLADINO:
But if they don't come ---
4 HR. KUBICK:
Well, I think we have some ways
~
5 to make them come that is desirable on their part.
6 (Laughter.)
7 CHAIRMAN PALLADINO:
You will explain it in 8
the right way.
9 HR. KUBICK:
Yes.
10
( Laughter. )
11 HR. OWEN:
We have discussed that, and I think 12 the most telling thing that we could say is that we have 13 had support of'our programs at INPO and across the
[
14 industry.
Every utility, be it publicly or privately 15 owned involved in the nuclear business has been 16 supporting INPO and continue to do so, and we don't see t
17 any reason why we can't be just as successful at this.
l 18 We were able to do this kind of thing with emergency 1
19 planning facilitias several years ago.
We got 100 l
20 percent attendance there of everybody involved and ready
~
21 to do anything at that time, and I believe we could 22 assure you that we will have the attendance that we need.
23 COMMISSIONER AHEARNE.
As was popular a few 24 yea rs ago, they have an offer that can't be refused.
l 25 What they will say is that if they don't come, then ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN. D.C. 20024 (202) 554-2345
65 i
1 Warren will come back and support the NRC rules.
2 (Laughter.)
3 MR. OWENs I don't recall saying that, 4
Commissioner Aheane.
5 (Laughter.)
6 MR. OWENs I do recall saying though that we 7
have some very prestigious chief executives around the 8
country who are 100 percent behind our efforts, and I 9
think a gall from them to the chairmen of those 10 companies would ensure the attendance that we need.
11 MR. KUBICKs And I would add that already the 12 acceptance of our workshop has been all positive.
We 13 have not been disappointed in one respect.
(
14 CHAIRMAN PALLADINO:
Well, I am going to let 15 my colleagues have the first crack on other questions.
16 COMMISSIONER AHEARNE:
Just a couple of 17 questions.
18 First, Mr. Kubick, in your discussion about 19 this meeting that is shortly going to be held you had a 20 phrase in there or something that they will clarify the 21 problem.
What is the problem that you see from your 22 point of view?
i 23 MR. KUBICK:
Well, I think in any human 24 activity that mistakes and blunders even are made.
I 25 know the staff holds up certain blunders where someone l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554 2345
66 1
tested to 300 degrees Fahrenheit instead of 300 degrees 2
Centigrade, or something like that.
There are human 3
blunders that occur.
4 There are also though, as has been alluded to, 5
a changing set of requirements over the last 15 years.
6 This is something that has been evolving and it is very 7
easy then to compare things against previous 8
understandings.
There is a need to get.everybody up to 9
the same level of understanding at this point in time 10 and say this is what we know about these things and this 11 is the way we have to address them and bring the entire 12 industry to the same level of understanding.
I think 13 tha t is the primary difficulty.
14 COMMISSIONER _AHEABNEa I don't want to try to l
15 put words in your mouth and give you a statement, but I 16 am really trying to explore.
Do you see that the 17 staff's version is close to being correct or quite far 18 from the mark?
The staff obviously has concluded that 19 there are a number of problems with the testing 20 laboratories.
I know from previous conversations that 21 in many cases the industry's view is that we have 22 modified the requirements sufficiently that it is 23 difficult to keep up with the number of requirements we 24 have made.
25 Now your description sounded more like that, ALDERSON REPORTING COMPANY,INC, 400 VIRGIN!A AVE.. S.W.cWASHINGTON. O C. 20024 (202) 654 2345 '
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67 1
that what was necessary was to try to make everybody in l
2 the industry understand where the requirements now are 3
and how they are to be interpreted and then how they are 4
to be met.
Would that be a more accurate picture?
5 HR. KUBICK:
I think that is a big part of 6
it.
I think certsinly, too, that in past years, and the 7
staff I think is looking back, as they can only do, over 8
history in the last 10 to 12 years.
There have been 9
many people who have paid too little attention to this, 10 but I think we are getting people's attention and this 11 is one way of doing it.
12 ER. OWEN:
Hight I comment on that 13 Commissioner?
14 COMMISSIONER AHEARNE:
(Nodding affirmatively.)
15 MR. OWEN:
I interpret tha t to mean I might.
16 (Laughter.)
17 MR. OWENs More so than changing requirements, 18 it is changing technology.
I do believe that we have 19 sany more tests f acilitias available to test things 20 today than we had many years ago.
I remember how
~
21 difficult it was for us to find anybody to do the kind 22 of testing that we wanted dona.
23 COMMISSIONER ROBERTS:
I participated with you 24 when you had some difficulty in that.
25 (Laughter.)
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3R. OWENs We saw the need for it and we did 2
the best we could, but we really did have to entice 3
people to do the kinds of things that wanted them to do 4
and we worked with them.
We were sort of crude
~5 sometimes but most of the time very conservative and 6
those things when we tested held up.
7 The other is that we do much more rigorous 8
testing, somewhat the same kind of thing, but because we 9
have ready access to some exc211ent testing facilities l
10 ve test many more things that back then we looked at and 11 said, you know, we can analyze and our judgment is that 12 it has survived in similar kinds of environments and so 13 ve will use it.
.14 As Bob said, we have only got so many 15 resources and as a manager you have to pick and choose 16 where you put them, and sometimes we didn't test 17 everything that we should have back in those days.
18 COMMISSIdNER AHEARNE:
But, Warren, are you 19 then saying that the perception that one gets from 20 looking at the reports doesn't give a good picture of 21 what the current status of testing labs are?
It sounds 22 like what you are saying is that when we look at the 23 reports coming in we are seeing this historical pattern, 24 but currently right now labs are essentially doing it 25 well.
Is that what you are saying ?
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MB. OWEN:
I think the laboratories that we 2
are familar with, that our folks go into, by and large 3
we are very pleased with what we find there.
If we are 4
not, we holler about it.
Now I cannot say that there 5
might not be some contracter out there who is not doing 6
everything that he ought to do.
There certainly is a 7
spectrum of understanding and awareness.
When we 8
discussed it, when we got together a number of months 9
ago we said, this-is one of the problems and we have got 10 to do something about it.
11 We decided that the basic problem was that we 12 didn't fully understand all the things that were out 13 there and rather than spending a lot of our time trying,
('-
14 to reconstruct history, let's get everybody up as 15 quickly as we can to the highest level of performance to 16 which we can bootstap ourselves, and we think that takes 17 the kind of program that we have here and tha t is why we 18 are fully 100 percent behind it.
19 COMMISSIONER AHEARNE.
Mr. Roby, do you have i
20 anything to add in your perception of what kind of a 21 problem might exist?
22 MR. ROBY:
The problem that exists today I 23 think is because of a lack of proper definition of what 24 the utilities should be doing in assessing the 25 capabilities of the testing organization or an ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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organization that conducts qualification tests so that 2
we can demonstrate to the regulators that it is being 3
done in a consistent, reliable fashion, a uniform 4
fashion.
5 I would have to agree that documents today 6
don 't exist which enable us to demonstrate that with a 7
great degree of sufficiency.
A lot of it of course is 8
traceable to the fact that as an industry we have 9
prepared qualification standards, things like 323, 324 10 or 383 which were really what those people who happened 11 to be sitting on those representative bodies thought we 12 should be doing.
They weren't really articulated to, 13 vell, what are the requirements of the regulators.
~
14 What is the true meaning of qualification 15 testing?
We only test one of any device.
Certainly you 16 can't gain a lot of confidence from. testing one of any 17 device that the thousand devices see going to work 18 adequately.
It is all verification testing, 19 verification testing of design adequacy.
That is where l
20 the real crux of this thing is, design adequacy.
21 Now to the extent th a t those definitions don't 22 exist today, I am quite sure that we as an industry can l
23 do the very best we can to prepare them.
We can prepare l
l 24 a standard which essentially looks at these basic 25 requirements of the testing organization, whether they l
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are testing concrete, whether they are testing an 2
electric motor or whether they are testing the strength 3
of a structure.
4 They are all ba51c requirements that an 5
organization aust possess.
That is the kind of thing I 6
think that a national standard can address correctly and 7
can provide the dafinition.
8 Now on top of that, the programs of the 9
seminars and workshop, they can develop that into a 10 meaningful way that you can apply those requirements.
11 COMMISSIONER AHEARNE:
Wha t organization would 12 you see developing this comprehensive standard which you 13 ref er to?
(
14 3R. ROBY:
I would see it across the board.
15 Either it is the IEEE assisted by the mechanical 16 engineers and civil engineers or a task group from all 17 three.
It necessarily has to have input from all the 18 disciplines.
19 You know, a testing organization that is 20 testing electrical equipment, many of their attributes l
21 are not electrical in nature.
They are mechanical, 22 hydraulic, something like that.
So basically we should 23 be talking across the board at this basic level, on top 24 of whien by specific requirements, as you identified, we 25 then expect the test program to be successfully carried l
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out.
2 COMMISSIONER AHEARNE:
Now why though wouldn 't 3
the description that you just gave be met by the 4
accreditation program of the IEEE7 5
MR. ROBY The IEEE accreditation program, as 6
we perceive it to be, wouldn't provide us with the 7
degree of confidence that we would want because this is 8
a matter of safety, there is no doubt about that, it is 9
foremost a safety problem here, it wouldn't provide us to with the assurance that we would require to have in 11 order to delegate that responsibility to that 12 o rg aniza tio n.
13 MR. OWENs It doesn 't deal 'dith the front end 14 to the back end.
15 COMMISSIONER AHEARNE:
I know, Warren.
I was 16 really trying to get Mr. Roby's view.
17 HR. OWENs I am sorry.
18 (Laughter.)
19 MR. ROBY What I was really saying is that if 20 we are required to go with the accredita tion program, 21 then we would want to carry out our audits as they 22 presently are.
Now you say is that because you can ' t l
23 have the confidence in the IEEE to do that kind of work?
l 24 Is that be'cause you don't believe that their l
25 capabilities are of the requisite type to do that?
But l
i i
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I' don't think that they are talking just to the real 2
problem.
3 When we audit a manufacturing organization who 4
has 1 capability f or tests, we do it for all of his 5
attributes, his capability to design, his espability to 6
engineer and his capability to test.
All we would be 7
relegating this accreditation program to would be to 8
take that little bit of disconcern with the test and now 9
put that up front with somebody else.
10 COMMISSIONER 1.HEARNEa The last one I would 11 like to make is more a comment.
The presentations we 12 just received stressed a criticism of the staff 13 approach.
I think to be accurate and probably for some f
14 people who don't have the historical background on it, 15 although two years is not much history, the staff 16 followed what the Commission directed.
The Commission 17 had reached the conclusion, as Mr. DeYoung had said, 18 they came in and proposed doing certain things and the 19 Commission said no, that rather than going the route the 20 staff was talking about, whnt the Commission wanted was 21 for them to explore third party accreditatf*n for this 22 kin d of a program.
As I recall, twice in ou calicy 23 guidance we reiterated tha t.
So the staff really is 24 here with a proposal under the guidance of the last 25 Commission guidance.
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Now, as I think the Chairman pointed out, and 2
it is obvious, the Commission may be rethinking that, 3
but nevertheless, it should be really viewed as the 4
staff was responding to the Commiscion direction.
5 CHAIRMAN PALLADINO:
Yes, I think that is 6
important to say.
Thank you.
7 Well, I see our time is rushing on.
8 Did you have some questions?
9 COMMISSIONER ASSELSTINE:
Just a couple.
10 First is a follow-up to one of John's 11 questions to you, Warren.
I as a little troubled by I 12 guess the absoluteness of your statement where you say 13 "Thus, we maintain that the program proposed by the NRC 14 staff does not address an existing problem within the 15 industry."
16 I can see your point as to the reports 17 pursuant to the bulletin, and I can understand your 18 argument that that is a historical view of pa s t 19 practice.
I am a little more troubled by your statement 20 when I look at the four bulleted items that the staff 21 had on the vievgraph based upon their visits to the 22 laboratories because some of those, particularly the 23 first point, no customer audit of test laboratory QA 24 program, th a t, it seems to me focuses more on a 25 continuing probTen or a present problem, and tha t is ALDERSCN REPORTING COMPANY. INC.
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75 1
where you have some utilities apparently that aren't 1
involved at all in going in and auditing the QA programs 3
of the testing lab.
4 I wonder if you could just repond to that.
It 5
seems to me that there may.be a t least somewhat more of 6
a problem than, even if you set aside the historical or 7
the past practice kind of concern.
8 MR. OWEN:
Certainly if there is some testing 9
being done where neither t'e utility nor its agent has 10 visited the facility, I would agree that there is a 11 problem.
I would also submit though, Commissioner, tha t 12 we ought to speak to that problem and tha t we are not 13 going to solve that problem with an accreditation 14 program when you have that lack of understanding.
15 COMMISSIONER ASSELSTINE:
That may well be, 16 but it is a little different than saying well, we really 17 don't think there is a probles at all.
18 MR. OWEN:
I apologize.
If we in our short 19 time here didn't overstate things just a little bit we 20 might not make our point.
21 (Laugh te r. )
i 22 CO MMISSION ER ASSELSTINE:
The next question I l
23 had also was for you, Warren.
I got the impression from 1
24 your presentation that you basically think that the 25 utilities under Appendix B to Part 50 now do have the ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
76 1
responsibility for assuring tho adequacy of these 2
programs and for going in a verifying that these QA 3
programs at the labs are satisf setory so that you get a 4
quality product.
Is that basically right?
5 MR. OWENs Absolutely.
I think we have always 6
had it.
I think we have it today.
I think our 7
understanding of that is probably across the industry 8
and it is probably br'oader today than it ever has been, 9
and our intent is to make it much broader and it will to grow.
11 COMMISSIONER ASSELSTINE:
I was pleased to see 12 in the AIF's letter and also in your presentations today 13 the acknowledgement that we do probably need a much 14 clearer standard, a definitive standard for assessing 15 the adequacy of the test lab's QA programs.
Once we 16 have that, would you agree that the utilities then 17 really ought to ba held secountable if we go with your 18 approach for the adequacy of these programs and for 19 failures then that ought to be the subject of fairly 20 strong action by us?
21 MR. OWEN Absolutely.
I personally feel that 22 way, and I don 't know that I have run into anybody in 23 the industry, any senior executive in the industry that 24 feels otherwise.
25 COMMISSIONER ASSELSTINE:
Mr. Roby, I just had l
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a couple of questions for you as well.
Could you give 2
se your response to the same question that I asked the 3
NRC staff, that is just a general comparison of the ASME 4
N-Stamp program with the staff's proposal here, what you 5
see as the similarities or differences so I can get a 6
sense of how much we can rely on the ASME N-Stamp 7
program.
8 HR. ROBYa Well the equivalent to the ASME 9
N-Stamp would be achieved if you were to put an E-Stamp 10 essentially in effect on all the manufacturers of 11 electrical equipment who manufacture and design.
Now 12 that is not the purpose of the accreditation program.
13 It is to look at that whole complex'of manufacture,
(
14 design, engineering and test, and then to accredit just 15 that little group that is responsible for the test.
16 The equivalent E-Stamp to the N-S tamp would 17 essentially be saying that now we are going to apply 18 that manufacture and design, and that anybody who causes 19 to be constructed electrical equipment for use in a 20 nuclear power station has to have an E-Stam p.
That is 21 not what this program does or even purports to want it 22 to do.
Many people, let me be clear, see it perhaps as 23 a start of such an endeavor, but it is not that.
24 COMMISSIONER AHEARNE:
Would be you be for or 25 against that?
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MR. BOBYs Undec the present day state of the 2
nuclear industry, I would be very much against it; very 3
such against it.
I think that if we had a blossoming 4
program with an avid acceptance of nuclear as a means of 5
electrical generation, you may come out with a good case 6
for it which wouldn't serious affect all of the people 7
that wanted to produce elec trical equipment.
But today 8
certainly you wouldn ' t do that.
In fact, you would 9
probably' f oreci.ose on almost every option we have got 10 for the supplies of electrical equipment.
11 COMMISSIONER AHEARNE:
Because of the 12 additional financial b,urden.
13 MB. ROBY:
Yes.
14 MR. OWEN I am a mechanical engineer and not 15 an electrical engineer, and I guess feel differently 16 about sore things, but I think there is one thread that 17 runs through tha boiler code that does not exist for 18 electrical equipment which would deal with pressure 19 boundary.
Everything is built around pressure boundary, 20 not so much about function.
Electrical equipment is 21 control equipment really.
It is function that you are 22 after and you have many, many options as to how you 23 achieve tha t function.
The boiler code was built up 24 over many, many years of concarn about pressure 25 boundary, and it is a fundamental difference and has to ALDERSoN REPORTING CCMPANY. INC.
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be recognized if we ever try to come up with any sort of 2
E-Stamp program.
3 COMMISSIONER ROBERTS:
Let me make an 4
observation.
5 CHAIRMAN PALLADINO:
Go ahead.
6 COMMISSIONER ROBERTS:
Your containment liners 7
at Oconee I, II and III did not have a Section 3 ASME 8
code stamp.
I am not persuaded they are any less safe 9
than containment liners that do have a Section 3 stamp, 10 and I guarantee you there is a quantum leap in the 11 cost.
What we fail to relate to is the ratepayer pays 12 that.
13 CHAIRMAN PALLADINO:
You hav'e one other
?
14 q ue stio n.
I do want to make sure that we give Mr. Owens 15 of IEEE a chance to make his presentation and have the 16 staff comment.
17 COMMISSIONER ASSELSTINE:
Okay.
Let's go 18 ahead.
19 MR. OWEN:
Let me ta k e ten seconds in 20 closing.
I would just submit that the industry's track 21 record on trying to wash its own linen on the last 22 couple of years has been pretty good, and we would like 23 for you to give us a chance on this one.
24 CHAIRMAN PALLADINO:
Thank you.
25 Tom, did you have more?
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COMMISSIONER ROBERTSs No.
2 (At this point in the meeting Messrs. Kubick, 3
Owen and Roby left the Commissioner's table and Mr.
4 James R. Ownes joined the Commissioners at the table.)
5 CHAIRMAN PALLADINO:
Mr. Owens, we have you at 6
the table all alone.
7 MR. OWENS:
I am scared to death.
8 (Laughter.)
9 CHAIRMAN PALLADINO:
We appreciate your being 10 here and look forward to your comments.
11 COMMISSIONER AHEARNE:
I gather you have left 12 the executive committee meeting in San Francisco to be 13 here?
14 MR. OWENS:
Yes, I have, a Board of Directors 15 meeting of the IEEE.
It is going on today in San 16 Francisco.
17 (Copies of Mr. Owens prepared statement was 18 distributed to the Commissioners.)
19 CHAIRMAN PALLADINO.
Do you have one for 20 Commissioner Gilinsky?
21 MR. OWENS:
Yes, I do.
22 CHAIRMAN PALLADINO:
Thank you.
23 MR. OWENSs Gentlemen, I am James B. Owens, 24 the President-Elect of the IEEE.
I will assume the 25 position of President of the IEEE in January of 1983.
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I have left a meeting of the Board of Directors of the 2
IEEE that is being chaired by P resident Dr. Robert 3
Larson.
I was asked by him to come and represent them 4
and address the Commissiors and answer any questions that 5
the Commission may have for the officers of the IEEE. 6 I have prepared a formal statement that I 7
Would like to have as part of the record of this 8
meeting, and you have that on the right-hand side of the 9
folder I have passed to you.
10 With your permission I will not read that 11 statement but I will tell you what it contains.
Some 12 substantial part of what it contains, especially the 13 history of the IEEE's involvement in this aff air, has.
l 14 been quite accurately and completely recited to you by 15 Jim Taylor in his earlier statements to the Commission 16 today.
[
j 17 I guess I would like to say very briefly what l
18 I think the main elements of the IEEE position are.
19 First, that the IEEE wants to be known that,it 20 is not in opposition to the AIF or to the NRC or to any 21 other body.
It takes no position on the need for third 22 pa r ty accreditation of laboratories testing safety 23 system equipment for nuclear power stations, but it 24 stands ready to provide the service if indeed the 25 service is needed.
That clearly is the simplist ALDERSON REPORTING COMPANY. INC.
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statement of the IEEE position.
2 The IEEE wants to say to the Commission that 3
it considers itself a very strong advocate for the 4
nuclear power option in the United States.
It feels it 5
is very important to our country, to its economic and 6
social well-being and to its defense to have a strong 7
nuclear power industry.
8 We believe indeed tha t we have conducted our 9
affairs in a way that demonstrates that conviction.
We 10 have prepared many position papers advocating 11 development of the nuclear power option, and I put 12 several samples on the left-hand side of your folder 13 just as evidence of the IEEE's commitment to the nuclear 14 power option.
I hope you find all of them attractive.
15 I am sure some of them are controversial.
They are even 16 controversial within the IEEE, but they do represent a 17 consensus opinion of the IEEE.
l 18 In addition to preparing position papers and l
l 19 going around making speeches in favor of nuclear power, 20 and I personally have made many speeches in favor of l
21 nuclear power, the IEEE has created a large number of 22 standards that are endorsed by the Commission and have 23 become part of the reg. guides on which the safety 24 system equipment in particular of nuclear power stations 25 is regulated.
The requirements are stated in our ALDERSON REPORTING COMPANY,INC, l
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standards and our endorsed in the reg. guides as one way 2
to meet the requirements f or adequate safety in nuclear 3
power systems.
4 So that we have this considerable commitment 5
and involvement in the activity of nuclear power 6
engineering and the building and safe operation of 7
nuclear power stations and we want to continue to work 8
with you.
9 It was against that background that when Mr.
10 Stello and Mr. DeYoung and other representatives of the 11 Commission came to us and asked us if we would be 12 willing to conduct a third party accreditation service 13 as a needed public service that we said yes.
14 The Board debated and recognized that there 15 were legal and financial risks to the IEEE, but said by 16 gosh we are committed to helping the na tion develop its 17 nuclear power resource, and if this is a needed service 18 the IEEE will indeed step forward and. he counted and 19 provide that service.
We did indeed sign an agreement 20 late in 1981 with the NRC, a formal contract.
21 We committed the IEEE to make its best efforts 22 on a very expedited basis from our point of view to 23 develop a program plan, the necessary standards, the 24 necessary facilities and staff and all that it took to 25 implement a plan to do accreditation of laboratories ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 that tested in our view safety system equipment for 2
nuclear electrical power stations.
3 We did develop P-600, a standard which has 4
been talked about in this room today in record time.
I 5
never saw a standard go through IEEE and the proper 6
consensus established any more quickly than P-600 did.
7 And it was just in the last few weeks authorized by the 8
Standards Board as a trial use standard for the IEEE.
I 9
believe it is a good standard.
I read it and I commend 10 the large number of professional volunteer engineers who 11 contributed to its developed.
It indeed will be an 12 important basis on which our program plan provides for 13 the accreditation of labora tories.
14 I would be remiss in not saying to you that we 15 have difficulties in these days because the agreement we 16 signed with the Commission provided us an obligation to 17 use our very best ef forts to get a plan ready so that we 18 could indeed audit laboratories during 1982 so that in 19 January of 1983 the industry would find a number of 20 accredited laboratories tha t could provide the needed 21 service.
22 This was a very tough timetable for us and we 23 believe th a t we have risen to the occasion and have been 24 very responsive in preparing ourselves with a program 25 plan and a standard and qualifications for auditors and ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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a training program for auditors and detailed 2
instructions on how laboratories should fill out test 3
reports and how auditors should fill out reports to our 4
committees that would consider their worthiness and the 5
need and the propriety of issuing certification to them.
6 We have a pile, you know, it is four inches of 7
paper, and I didn't bring it here, I didn't want to 8
confound you with that, of material that we have 9
prepared in order to do this job adequately.
10 I guess I would like to summarize, and then I 11 would be prepared to answer your questions, by saying 12 that the IEEE has kept its part of the bargain, we 13 believe.
14 (Laughter.)
15 HR. OWENS:
We are uncomfortable because we do 16 need the Commission.
We have put the program on hold 17, now because it is apparent that we can't have 18 laboratories audited and accredited by the end of this 19 year because of the absence of the issuance of a rule l
20 and general industry support for the program.
21 We are having increasing difficulty in getting 22 people to work enthusiastically on the program because 23 of the concern that it is not coming down.
So I say 24 that to you in a spirit of forth rightness that I really l
25 come not advocating a decision for or against third ALDERSON REPORTING COMPANY,INC.
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party accreditation, but 1 do come advocating a 2
decision.
I do believe it is important.
The IEEE has 3
spent quite a lot of money.
For the IEEE I don ' t have 4
an exact accounting, but we have spent $300,000 in round 5
numbers to get ready, and that is a big part of an IEEE 6
budget.
A volunteer organization doesn't run on a big 7
budget.
So we ara anxious for a decision in one form or 8
another.
9 I would like to close by saying that we did 10 believe that we were responding to a legitimate need 11 expressed by the Commission, and we do believe that if 12 that need is established and the rule comes down that we 13 can provide the service in a very professionally
?
14 competent manner, that we have got people who have the 15 right kind of qualifications and we have the dedication 18 and we have the motivation to do it and do it well.
17 If it needs to be done, I believe that the 18 IEEE is tha best organization to do it.
I think that is 19 clearly true.
We are talking in particular about 20 qualifying safety system equipment at nuclear power 21 plants for which at least 85 percent of the standards 22 are IEEE standards.
23 We are talking about electrical equipment in 24 the main and the IEEE is the group of professional 25 electrical engineers that has the qualifications to ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W,. WASHINGTON. D.C. 20024 (202) 554-2345
87 1
examine the laboratories and to be sure that they have, 2
not only their instruments calibrated on the right 3
intervals and to the right standards traceable back to 4
the Bureau of Standards and all of those normal good 5
practices for laboratories, but that t;ter have the right 6
complement of equipment and people to test safety system 7
equipment for nuclear power stations to ensure adequacy, 8
to ensure safety, to ensure reliability and to ensure 9
the public interest.
10 So if it needs to be done, the IEEE will do it 11 and it will do it well.
We do advocate an early 12 decision and hope that the Commission can come to that.
13 If we can help with developing that decision, we will be 14 glad to do so.
15 Thank you for listening to me.
16 CHAIRMAN PALLADINO:
Thank you very much.
We 17 appreciate your taking the time from Board of Directors 18 meetings to come here.
19 I have one question, if I may, and then I will 20 turn it over to others.
21 Will the IEEE provide accreditation for 22 programs that test other than electrical equipment?
23 MR. OWENS:
We have a continuing dialogue with 24 the NRC staff about the scope of the IEEE program.
The 25 IEEE's view is that safety system equipment for nuclear ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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power stations is kind of a defined scope and that these 2
safety systems are in very large measure electrical 3
systems.
But indeed we must observe that laboratories
\\
4 conduct mechanical tests and environmental tests and a 5
variety of other tests in order to demonstrate the 6
adequacy of this safety system equipment.
Therefore, 7
the IEEE must be prepared and must draw in the right 8
experts to judge the adequacy in the laboratories on 9
mechanical testing and environmental testing.
10 A substantial part of the testing that we have 11 encountered in our plan preparation has been radiation 12 of materials and s,amples, radiation testing, and we do 13 have in the IEEE the Nuclear P1asma Sciences Society, in 14 addition to the Power Engineering Society, that has 15 competence in this field and they have been helping us 16 to prepare the right kind of quality assurance plans for 17 these laboratories.
18 I hope tha t is responsive.
I think the answer 19 to your question, if I gave a single one, it would be 20 yes.
It has some constraints and we seek some i
21 constraints from the staff in limiting it to a range of 22 equipment that we call safety system equipment for 23 nuclear power stations, at least in the beginning.
So 24 that we can indesi go farther than just doing very 25 general kinds of qualification of laboratories, and we ALDERSON REPORTING COMPANY. INC, 400 VIRGINI A AVE., S.W. WASHINGTCN. D.C. 20024 (202) 554-2345
89 1
can survey the laboratories to see that they have the 2
necessary equipment to demonstrate compliance with 3
standards and all of the requirements for the safety 4
system equipment.
5 CHAIRMAN PALLADINO:
I was trying to look 6
ahead.
If we go down the accreditation route and there 7
are more mechanical tests or perhaps even seismic tests, 8
where would we go on.the accreditation route, and ther 9
begin to get outside'the principal purview of the IEEE 10 and to get into other people turfs and are we then f aced 11 with the accreditation by several organizations if we go 12 down that road.
I am not saying that we will go down 13 that road, but I am looking ahead to see what you 14 thought about the capabilities in those areas as well.
15 HR. OWENS Mr. Commissioner, I think that the 16 seismic example that you chose is an outstanding and 17 alear one and helps illustrate the point that I would 18 like to make, and that is that now in our requirements, 19 motor control centers and switch gear and a variety of 20 control equipment for nuclear power stations, including 21 safety system equipment must be subjected to seismic 22 qualification testing.
23 The electrical engineers and the mechanical 24 engineers in the IEEE who design these systems are very 25 deeply involved in designing the equipment to meet ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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seismic criterion to be sure that the equipment works 2
correctly during seismic events.
And, indeed, the 3
laboratories that we will qualify in the IEEE program 4
include laboratories like the laboratories with big 5
shake tables that do seismic testing.
We intend to and 6
we do have expertise in our organization to qualify 7
seismic testing facilities.
8 CHAIRMAN PALLADINoa I wasn't takin g oxception 9
to the fact that some of the things have to be designed 10 for seismir adequacy,. but they are not generally done by 11 the electrical engineer.
They are done by people who l
12 have become expert in that area, and I am not sure if 13 those people find as their society the IEEE.
That was 14 the point of my question.'
15 MR. OWENSs Our agreement with the Commission 16 has obligated us to ga ther together the expertise, and 17 we will recruit auditors who have special expertise as 18 well as general expertise in laboratory evaluations.
19 Indeed, we had intended and we do have within our 20 membership and our competence people who can judge on 21 the adequacy of testing 'ilke seismic testing and other 22 forms of mechancial and envionmental testing.
It is 23 intended to be included in our program.
24 CHAIRMAN PALLADINO:
Well, I must express a 25 little bit of doubt.
Some of my best friends are ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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electrical engineers.
2 (Laughter.)
3 CHAIBMAN PALLADINO:
So I do have some 4
reservations in that regard.
5 MR. OWENS:
I understand, sir.
6 CHAIRMAN PALLADINO:
Well, I will turn 7
questions over to others.
8 COMMISSIONER AHEARNE:
I have no questions.
9 It is really more a comment.
I find myself in agreement 10 with Mr. Owens, as I have mentioned many times in other 11 memos within the NRC.
I guess the way I would phrase it 12 is the same way you phrase it.
If there is a problem, 13 then I think the I'EEE is the organization that ought to
(
14 assist in this.
15 CHAIRMAN PALLADINO:
I do want to express my 16 appreciation for the participation of the IEEE in coming 17 this far, even though some of my biases on accreditation 18 may show.
But I do think you have been very responsive l
19 to help the staff in pursuing a direction that was given i
20 to them by the Commission.
21 COMMISSIONER ASSELSTINE4 I have just a couple 22 of points.
l 23 Mr. Roby in his statement identified four 24 potential disadvantages of the accredita. tion program, 25 and I wonder if you could comment on two of those.
The l
l l
ALDERSON REPORTING COMPANY. INC.
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first one was the disadvantage that the number of 2
quality testing organizations would be reduced with some 3
organizations unwilling to meet the accreditation 4
requirements or unable to absort the costs and remain 5
competitive.
6 Do you see that as a potential problem based 7
upon where you see the requirements that you would see 8
being imposed under the IEEE program ?
9 NR. OWENS:
I am not in opposition to Mr.
10 Roby, but I do believe that the IEEE would have an 11 obligation to ensure that all organizations providing 12 testing provide a minimum level of quality, a level of 13 quality that'is adequate to ensure safety and 14 reliability in nuclear power stations, and that ther 15 should seek that level of quality and seek a quality 16 assurance program and be willing to stand audits on that 17 program.
If they are not, then the Commission has a 18 concern about their adequacy.
19 The cost of these audits are going to be borne 20 by somebody and they are going to be borne by the 21 laboratory through fees that they pay or by the 22 utilities who voluntarily provide the audit service or 23 by someone else, or by the Commission perha ps through 24 the taxpayers providing for the proper audits and 25 quality assurance procedures.
So that I think.indeed it ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE S.W WASHINGTON. D.C. 20024 (202) 554-2345
93 1
is unlikely that the industry would find laboratories 2
that found this excessively burdensome, but that is a 3
private opinion and not an IEEE opinion.
4 COEHISSIONER ASSELSTINE:
I understand.
5 The second one that I wanted to solicit your 6
comment on as well was the disadvantage that 7
accreditation certification obtained and maintained at a 8
substantial cost would deter advancements in 9
qualification, testing technology.
10 MR. OWENS:
I have no opinion on tha t.
I 11 guess the operational word is a substantial cost.
If 12 indeed this program costs the laboratory so much that 13 they have less money to invest in their own kind of RED, 14 then that would have to be true.
The real question is 15 is this a very costly program to the laboratories, or a 16 very burdensome program, or can it be made an economic 17 program, one that would be welcomed because it helps 18 them with their own quality assurance.
If, indeed, the 19 costs are reasonable, then it need not be a burden to 20 advancing the techr. ology.
21 COMMISSIONER AHEARNE:
What kind of costs 22 would you expect?
I guess there is such a wide range of 23 laboratory sizes that it would be a little difficult to 24 make an estimate, but do you have any feel for the 25 typical laboratory, what it might cost.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
94 1
MR. OWENS:
I guess I don't, sir.
I guess I 2
choose not to answer, sir.
I hesitate to make guesses 3
because we are really inexperienced in what we are going 4
to find when we send the auditors into these 5
laboratories.
We have done a trial audit of Sandia and, 6
incidentally, found some number of. things that we think 7
need to be improved.
But we have not really gained 8
experience, and how many man-hours of audit time it will 9
take per laboratory it a very uncertain thing at this 10 point.
11 COMMISSIONER ASSELSTINEa That is all I have.
12 Thank you.
13 CHAIRMAN PALLADIN0s Tom?
14 COMMISSIONER ROBERTS:
No.
15 CHAIRMAN PALLADINO John?
16 COMMISSIONER AHEARNE:
No.
17 CHAIRMAN PALLADINO:
Well thank you very much, 18 Mr. Owens.
We do appreciate your participa tion today.
19 CHAIRMAN PALLADINO:
We had indicated that we 20 would provide some time to the staff for comments af ter 21 the presentations.
22 Do you have succinct words of wisdom or a 23 comment that you would like to make?
24 (At this point in the meeting Mr. Owens left 25 the Commissioners' table and Messrs. DeYoung, Taylor,
[
l ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 vr
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Dircks and Stello rejoined the Commissioners at the 2
table.)
3 MR. DIRCKS:
I think we are coming back to 4
where the Commission was a couple of years ago.
5 (Laughter.)
6 MR. DIRCKSs Again, the requirement for 7
aquipment qualification testing, and how does the 8
Commission achieve a certain level of confidence in the 9
adequacy of that testing program.
Then we are back to 10 those options that we started off with.
We could impose 11 Appendix B requirements and clarify how they might apply 12 and then instruct the staff to assure that those 13 requirements are complied with.
Or you can try the 14 third party approach which you have heard a lot about 15 today.
I am not sure I can add very much more to the 16 discussion, and I think you are faced with essentially 17 two options.
18 COMMISSIONER ASSELSTINE:
If we went the NRC 19 staff route, the first option, does your estimate of 10 20 to 15 additional staff years, does that still stand or 21 is that 22 MR. DIRCKS:
That was done a couple of years 23 ago and in our period of austerity now we would have to 24 go back and take another look at the resource 25 requirements.
I haven't looked at it lately.
ALDERSON REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON O.C. 20024 (202) 5_54-2345
96 1
COMMISS7.ONER ASSELSTINEs Okay.
2 CHAIRMAN PALLADINO:
Any other comments?
3 MR. DeYOUNG:
I would 216 4 to add a point.
I 4
have heard a lot today and I would hate to see the 5
proposal by the industry group put aside.
I don't think 6
there are alternatives.
I think they complement one 7
another.
I think it is an excellent program that they 8
have proposed and I think it should be established and 9
followed through.
But I also think that the 10 accreditation program should move forward hand in glove 11 with it.
I think accreditation will be much easier to 12 obtain with the industry program.
I think they are two 13 programs that could be very effective.
14 QA has been a problem and this is part of the 15 quality problem.
I think we should invest the resources 18 that we have both been talking about today.
17 MR. TAYLOR:
The question was asked about cost 18 and these are just informal numbers, but I think the 19 IEEE cost, and informally the staff has talked about 20 this type of thing, you know, what will it cost to go 21 out to the laboratoties, and of course it is dependent 22 upon the size of the laboratory and the size of the 23 operation and the number of tests that ar.e done and the 24 number of customers for nuclear equipment, but the cost 25 at a big lab, and there are some meet that that do an ALDERSON REPORitNG COMFANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
97 1
awf ul lot of testing, the numbers we have heard are in 2
the range of audit costs of around $25 to $35 thousand 3
the first year.
4 I would anticipate personally, that after a 5
laboratory is accredited tha t th e re turn visits by IEEE 6
auditors would be less costly because I think ---
7 CHAIRMAN PALLADINO:
That is not the 8
experience in accreditation in engineering colleges.
9 The costs have gone up, up, up.
As a matter of fact, 10 in the one accreditation period they have more than 11 doubled.
The doubling may have been in part due to 12 infla tion, but the cost doesn't go down.
The same 13 things have to be examined.
(
14 MR. TAYLOR:
But having tramped through the 15 territory in establishing that the QA manuals and QA 16 programs exist, I could foresee some economy in scale in 17 return visits.
18 COMMISSIONER ROBERTS:
What was the initial 19 cost, you mentioned $25 to $30 thousand?
20 HR. TAYLOR:
Yes.
21 COMMISSIONER ROBERTS:
Should I have the same 22 degree of confidence in that number tha t I have in the 23 staff number that said it cost $5,000 to get an N-Stamp?
24 (Laughter.)
25 MR. TAYLOR:
I think it is a ball park.
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1 MR. DIROKS:
We remember the question.
2 COMMISSIONER ROBERTS:
And I remember the 3
answer.
4 (Laughter.)
5 MR. TAYLOR:
The smaller labs would be less..
6 CHAIRMAN PALLADIN0s Any other comments?
7 COMMISSIONER AHEARNE:
Yes, I would like to 8
make a comment.
I frankly had a similar reaction as 9
Dick DeYoung did, that it appeared to me that the 10 industry was really speaking to a different type of 11 problem.
Th ey were taking about, as was very clea'rly 12 outlined, they were primarily focusing on the utilities 13 and the utility industry side.
That I think is 14 extremely valuable and, like Dick,':I reached the 15 conclusion it was complemen tary.
16 Now whether what the staff proposed in 17 response to the Commission, et cetera, the program, is 1
i 18 necessary depends on whether there is a' second type of 19 problem.
20 I would entirely agree with what I at least 21 concluded was the position of Warren Owen and Mr. Roby 22 and Mr. Kubick, t h,a t if there was no problem on that l
l 23 side, then obviously there is no need for the 24 accreditation program.
t 25 If there is that kind of a problem, then I I
l ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 654-2346
99 1
don't think that the prograra th a t the industry has 2
proposed is really going to reach to it.
I think that 3
the accreditation through IEEE is the best choice.
4 As I wrote to the Commissioners some time ago, 5
I ctill am amazed at'what I see, at least from my point 6
of view, of what appears to me as a reluctance on the 7
part of the industry to take;those steps which can do i
i 8
nothing but help improve their public support.
But I am 9
just a neutral bystander.
10 (Laughter.)
11 CHAIRMAN PA LADIN04 I can 't subscribe to 12 everything you say in that regard though.
/
13 Any othar comments?
j 14 (No respo;4se.)
I 15 CHAIRMAN'PALLADINO:
Well, I gather after this 16 meeting the Commisslorers will re-examine their f
17 conscience ---
18 (Laughter.)
19 CHAIRMAN PALLADINO:
--- and thereby give 20 direction to the staff.
21 Well, thank you very much for your
't 22 participation..
i 23 The meeting will stand adjourned.
24 (Whereupon, at 12:15 p'.m.,
the meeting 25 ad jo urn ed. )
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r ALDERSON REPORTING COMPANY. INC, l
400 VIRGINfN AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
Kr**G, RE:,.,ui*C5CC CCW*S~C1 This 11 OO c a. M i f*/ O h a,0 tae. 4:Oachec prOcted.ing: 0ef::re the s
I tU COMMISSION MEETING ~ PUBLIC MEETING 10 the :: attar cf:,
Discussion of SECY-82-153 - PROPOSED RULEMAKING -
ACCREDITATION OF QUALIFICATION TESTING ORGANIZATIONS Caca cf Frecesc1:g:
July 20, 1982 Ocek2C litcher:
Flace cf ?recteding:
Washington, D.
C.
were held as '---
d-appears, anc : hat this is the cri.;;inal., :: scscr$
thersef fer the-fila cf the Cc=::1:sicc, Mary C. Simons Official Eepertar (!7:ed) f
, --rc M
--w Officisi Eepce ar (51.i; acare)
O n
v
STEERING COMMITTEE WARREN OWEN DUKE BYRON LEE COMMONWEALTH EDISON DAVE R0ssEN EPRI l
(uBIX V r ewcM 9H5 1
I
0 e
IMPLEMENTATION PLAN A PLANNING WORKSHOP A SERIES OF SEMINARS l
t l
2
THE WORKSHOP'S OBJECTIVES 1.
DEVELOP A " GUIDE" TO EFFECTIVE ADMINISTRATION OF QUALIFICATION TEST PROGRAMS BASED ON INDUSTRY EXPERIENCE.
2.
OUTLINE " SEMINARS" TO ILLUMINATE THE " GUIDE" AND TO ILLUSTRATE, BY EXAMPLE, GOOD PRACTICES.
l 3
i
WORKSHOP LOGISTICS HOST - EPRI/NSAC SPONSORS - AIF, EPRl/NSAC, INPO, EEI ATTENDEES - ABOUT 15, HAND PICKED, MOSTLY UTILITY PEOPLE, BUT ALSO SOME FROM VENDORS, TEST TABS AND CONSULTANTS TIME & PLACE - JULY 26 - 29 IN PALo ALTO l
4 L
INVITEES EPRI EQUIPMENT QUALIFICATION ADVISORY GROUP
- DON LAMKEN (CHRMN) - COMMONWEALTH EDISON
- BILL BOYER - PHILADELPHIA ELECTRIC
- JOHN O'CONNOR - YANKEE ATOMIC
- HARv HANNEMAN - WISCONSIN ELECTRIC
- TOM HARRALL - DUKE
- ALEX MARION - BALTIMORE GAS & ELECTRIC
- JIM WAGNER - TVA
- DON WOODLAN - TEXAS UTILITIES AIF SUBCOMMITTEE ON Ecu1PMEn Q ALI FI C ATION l
- ARNOLD ROBY (CHRMN)
AST UTILITIES OTHERS
- WILL RAUTIO
- CON AA
- R. RUPERT WYLE
- BOB COWDREY
- ACTON
- SONNY KASTURI
- EDS NUCLEAR
- SAL CARFAGNO
- FRANKLIN INSTITUTE I
- PHIL HOLZMAN
- ENGINEERING PLANNING AND MANAGEMENT, INC.
- GEORGE BUTTERWORTH
- WESTINGHOUSE 1
- REPRESENTATIVE
- IIRC 5
SPONSOR'S REPRESENTATIVES EPRI/NSAC Bos KusIK AIF ART BIVENS INP0 DAN WILKINSON EEI LORING MILLS t
I i
l t
6 l
f l
,,n n.en -,,,-
,.,__,.,----n
-._.__,n___-
m SCHEDULE JULY 26 - 29 WORKSHOP TO DEVELOP GulDE a SEMINAR Aus - OCT PP,EPARE SEMINAR MATERIAL, SLIDE SHOWS, VIDEO TAPES AND PRESENTATIONS.
i N0vEMBER TRIAL RuN SEMINAR FOR REVIEW AND COMMENT IN PALO ALTO DEC - JAN REDO BASE;
-'ACK l
7 i
i SCHEDULE 1983 FEB LOS ANGELES MARCH ATLANTA APRIL WASHINGTON, D.C.
MAY CHICAGO JUNE BOSTON JULY 1;
~"rDULED IF DEMAND WARRANTS i
l i
f 8
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1 1
ESTIMATED ATTENDANCE AT SEMINAR UTILITIES
- 50 - 80 VENDORS 8 - 15 TEST LAEs 10 - 15 A/Es & CC TANTs 12 - 30 80 -Il40
- ENGINEERING 8 QA 9
SEMINAR OUTLINE I.
QUALIFICATION OBJECTIVES A.
EQUIPMENT APPLICATION B.
FUNCTIONAL REQUIREMENTS C.
ENVIRONMENTAL CONDITIONS II.
QUALIFICATION PLANNING A.
EXISTING DATA B.
QUALIFICATION METHOD (S) 111.
QUALIFICATION SPECIFICATION DEVELOPMENT A.
DOCUMENTATION OF OBJECTIVES, METHODS, STANDARDS, ASSUMPTIONS B.
ESTABLISH TEST FAC:_
MDEMENTS AND QA REQUIREMENTS C.
ESTABLISH ACCEPTANCE CRITERIA LECTURER: PHIL HOLZMAN - ENGINEERING, PLANNING AND MANAGEMENT, INC.
10
e IV.
QUALIFICATION TEST PLAN DEVELOPMENT (A STEP BY STEP APPROACH TO IMPLEMENTING THE QUALIFICATION SPECIFICATION)
V.
QUALIFICATION IEST PLAN EXECUTION A.
TEST SPECIMEN HANDLING B.
TEST SET-UP C.
TESTING VI.
QUALIFICATION IEST RESULTS EVALUATION (ACCEPTABILITY BASED ON RESULTS)
LECTURER:
SAL CARFAGI..
INSTITUTE 11
O Vll.
QUALITY ASSURANCE AND DOCUMENTATION A.
ESTABLISHING REQUIREMENTS B.
LEVELS OF DOCUMENTATION Vill.
QUALIFICATION STANDARDS AND CODES LECTURER: ' SONNY KASTURI - EDS NUCLEAR I
12
s IX.
QUALIFICATION CASE STUDIES A.
TRANSMITTER QUALIFICATION GROUP HARv HANNEMAN - WISCONSIN ELECTRIC B.
BWR OWNERS GROUP HYDROGEN ANALYZER COMMITTEE DAN THOMrSON - PHILADELPHI A ELECTRIC C.
WESTINGHOUSE OWNERS GROUP E.Q. COMMITTEE DON WOODLAN
- IEXAS UTILITIES D.
AN INDIVIDUAL UTILITY'S APPROACH LEN CASSELLA - FLORIDA POWER AND LIGHT E.
CASE STUDY FROM AN A/E'S POINT OF VIEW F.
CASE STUDY FROM A MANUFA idRERS POINT OF VIEW G.
CASE STUDY FROM A TEST LAB'S POINT OF V:EW (VIDEOTAPE PRESENTA~ 0NS) l l
13 l
t
ESTIMATED COSTS
" WORKSHOP"
$ 6,000
+ 165 PERSON DAYS DONATED BY UTILITIES, EPRI, OTHERS
" SEMINAR" PREPARATION
$53,000 AUDIO / VISUALS 40,000 TECHNICAL CONTRACTORS 10,000 HANDOUT MATERI ALS
+ 90 PERSON DAYS DONATED BY UTILITIES, EPRI, OTHERS
" SEMINAR" PRESENTATION
$41,000
+ 50 PERSON DAYS DONATED BY UTILITIES, EPRI, OTHERS TOTAL
$150,000
+ 305 PERSON DAYS DONATED 14
DISTRIBUTION LIST Sonny Kasturi R.K. Hanneman EDS NUCLEAR WISCONSIN ELECTRIC POWER C0.
Will Rautio Tom Harrall CONAX DUKE POWER COMPANY R. Rupert Don Lamken WYLE COMMONWEALTH EDIS0N COMPANY Bob Cowdrey Alexander Marion ACTON BALTIMORE GAS & ELECTRIC C0.
Sal Carfagno J.F. Rhoads FRANKLIN INSTITUTE WASHINGTON PUBLIC POWER SUPPLY SYSTEM Phil Holzman Don Woodlan ENGINEERING PLANNING &
TEXAS UTILITIES COMPANY MANAGEMENT, INC.
J.F. Wagner George Butterworth TVA WESTINGHOUSE Arnold Roby W.J. Boyer NORTHEAST UTILITIES PHILADELPHIA ELECTRIC C0.
John O'Connor YANKEE ATOMIC ELECTRIC C0.
BACKGROUND ON PROPOSED RULE ON ACCREDITATION OF EQUIPMENT QUALIFICATION TESTING ORGANIZATIONS JULY 20,1982 STA F F vi sw q RMri s
I.
EVENTS WHICH LED TO CONCERNS ABOUT LABORATORY TESTING FOR EQUIPMENT OUALIFICATION A.
MID-1977 - FAILURE OF AN ELECTRICAL CONNECTOR DURIN5 TEST CHAMBER CHECK 0UT AT SANDIA LAB.
COMMISSION ORDERED VERIFICATION OF ADEQUATE CONNECTORS AT ALL OPERATING REACTORS.
BASED ON AVAILABLE TEST DATA SEVEN FACILITIES COULD NOT PROMPTLY PROVIDE VERIFICATION.
B.
NOVEMBER 4, 1977 - UNION OF CONCERNED SCIENTISTS (UCS)
PETITIONED COMMISSION SEEKING ACTION IN AREA 0F ENVIRONMENTAL QUALIFICATION OF ELECTRICAL COMP 0NENTS.
C.
APRIL 13,1978 - COMMISSION ISSUED A MEMORANDUM AND-ORDER ADDRESSING ISSUE RAISED BY THE UCS WITH DIRECTIVES FOR STAFF ACTION.
D.
1977-1979 - STAFF ISSUED SEVERAL BULLETINS RELATING TO EQUIPMENT QUALIFICATION.
MOST COMPREHENSIVE WAS BULLETIN 79-01B WHICH REQUESTED LICENSEES TO' SUBMIT QUALIFICATION DATA ON SAFETY-RELATED ELECTRICAL EQUIPMENT.
APPROXIMATELY 70 to 80 PERCENT OF RESPONSES TO 79-01B WERE DEFICIENT IN THAT THERE WAS INSUFFICIENT DATA AVAILABLE FROM LABORATORY TESTING TO DEMONSTRATE QUALIFICATION PER EXISTING STANDARDS.
~ ~
II.
EVENTS WHICH LED TO CONCEPT OF ACCREDITATION OF TEST LABORATORIES A.
JULY 1,1980 - IN RESPONSE TO ONE OF COMMISSION'S 1978 DIRECTIVES AND BASED ON A SANDIA STUDY, THE STAFF RECOMMENDED:
(1) INDEPENDENTLY TESTING SELECTED EQUIPMENT IN NRC CONTRACTOR FACILITIES; (2) ESTABLISHING AN NRC INSPECTION PROGRAM TO COVER A PORTION OF LABORATORY TESTING; AND (3) ENCOURAGING STANDARDIZATION IN TESTING, INCLUDING A THIRD PARTY LABORATORY ACCREDITATION PROGRAM.
THESE STAFF RECOMMENDATIONS WERE APPROVED BY COMMISSION ON SEPTEMBER 16, 1980.
B.
JULY 18,1980 - COMMISSION REQUESTED STAFF TO DISCUSS WITH IEEE THEIR WILLINGNESS TO DEVELOP A SUITABLE STANDARD AND IMPLEMENT A LABORATORY ACCREDITATION PROGRAM.
C.
DECEMBER 1980 - IEEE BOARD OF DIRECTORS APPROVED NRC REQUEST TO PARTICIPATE BASED ON NRC PROMULGATING A RULE TO SUPPORT ACCREDITATION.
D.
SEPTEMBER 1981 - FORMAL NRC/IEEE AGREEMENT SIGNED AND PUBLISHED WITH NRC TO MAKE BEST EFFORTS TO ISSUE A LABORATORY ACCREDITATION RULE IN FIRST QUARTER OF 1982.
E.
FEBRUARY 1982 - IEEE COMPLETES STANDARD TO BE USED UNDER NRC RULE TO ACCREDIT QUALITY ASSURANCE AND TECHNICAL CONTROL PROGRAMS AT TEST LABORATORIES.
l t
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-S e
v.
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Ill.' INFORMATION ON PROBLEMS FROM NRC'S LIMITED LOOK AT TEST LABORATORY FUNCTIONS A.
SELECTED PROBLEMS NOTED IN SEVEN LABORATORY VISITS BY NRC PERSONNEL p NO CUSTOMER AUDIT OF TEST LABORATORY QA PROGRAM (2 0F 7) e TEST PLANS NOT COMPLETELY ADDRESSING IMPORTANT IEEE 323-1974 REQUIREMENTS (7 0F 7) e INADEQUATE OR TOTAL LACK OF DETAILED TEST PROCEDURES (4 0F 7) e NO PROGRAMMATIC PROCEDURES FOR NONCONFORMANCE CONTROL OR CORRECTIVE ACTIONS (4 0F 7)
B.
PROBLEMS REPORTED FROM NRC/ FRANKLIN INSTITUTE REVIEW 0F QUALIFICATION REPORTS SUBMITTED BY LICENSEES e AS WITH REVIEW 0F RESPONSES TO NRC BULLETINS, REVIEW 0F QUALIFICATION REPORTS SUBMITTED FOR PLANT SPECIFIC SER's-SHOWS 75 PERCENT OF REPORTS ARE OF POOR OR UNACCEPTABLE QUALITY
PROBLEM SOURCES INDUSTRY QA PROGRAMS CONTAIN APPROPRIATE ELEMENTS PROBLEMS ASSOCIATED WITH IMPLEMENTATION LACK OF TOP MANAGEMENT COMMITTMENT T0 QUALLTY a
INADEQUATE DETECTION OF PROBLEMS INADEQUATE CORRECTIVE ACTION NRC DETECT /C[0RRECTSYMPTOMS LATE UNDERSTANDING OF SCOPE AND MAGNITUDE INSUFFICIENT EFFORT ON DESIGN REVIEW SALP BENEFICIAL l
l ALLEGATIONS l
ARE A VALUABLE AND EFFECTIVE PART OF ROUTINE INSPECTION PROGRAM l
COME FROM EMPLOYEES /PUBLIC/ MEDIA NRC LOOKS INTO ALL ALLEGATIONS Slide M i
re.
SUMMARY
OF RECENT PROBLEMS SPECIFIC EXAMPLES:
NONCONFORMING STRUCTURAL STEEL WELDS AT ZIMMER SEISMIC DESIGN ERRORS AT DIABLO CANYON INADEQUATE 50Il COMPACTION AT MIDLAND VOIDS IN CONCRETE STRUCTURES AT MARBLE HILL DESIGN DEF,ICIENCIES AT SOUTH TEXAS CONTRIBUTING FACTORS TO THESE PROBLEMS INCLUDE:
UNQUALIFIED WORKERS AND INSPECTORS l
FALSIFICATION OF RECORDS INTIMIDATION OF QUALITY CONTROL INSPECTORS INADEQUATE STAFFING OF QUALITY ASSURANCE FUNCTIONS l
INADEQUATE CORRECTIVE ACTION SYSTEMS AND POOR PROCEDURES Slide N
l
_Sc e uh d ling Notes for Discussion of SECY-82-153 -
PRM - Accreditation of Qualification Testing Organizations Scheduled:
10:00 a.m.,
Tuesday, July 20, 1982 Duration:
1-1/2 hours
Purpose:
The meeting is being held to hear presentations from staff and from industry on a pending proposed rule.
Participants:
Presentations will be in three parts:
- 1. Jim Taylor, IE
- 2. Warren Owen, Executive VP Duke Power Company AIF Policy Committee for Nuclear Regulation Arnold Roby, Northeast Utilities Chairman, AIF, Equipment Qualification Subcommittee Bob Kubick, EPRI/NSAC Backup speakers:
)
George Butterworth, Westinghouse Woody Stroupe, Technology for Energy Corporati6n Bob Cowdrey, Acton Labs Don Kline, Southern Transformer 3.
James R.
Owens, President-elect,IEEE Time will be provided for reply comments by the staff after the industry presentation.
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