ML20094P683
| ML20094P683 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/13/1984 |
| From: | Bleuel W AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20094P677 | List: |
| References | |
| OL, NUDOCS 8408170321 | |
| Download: ML20094P683 (47) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFGRE THE ATOMIC SAFETY AND LICENSING BOARD
- hhh In The Matter of )
COMMONWEALTH EDISON Docket Nos. 50-454 0 00 16 P/2.3 COMPANY ) 50-455 0L
) JECRgi-(Byron Nuclear Power Station, Units 1 & 2)
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SUMMARY
OF DIRECT TESTIMONY OF DR. WILLIAM H.
BLEUEL ON CONTENTION 1 (THE REINSPECTION PROGRAM)
I. Dr. William H. Bleuel, Ph.D., has twenty-five years of business experience in design assurance (which includes both reliability engineering and maintainability engineering) and quality assurance. His ex tries including aerospace,perience defense,has been in control computers, a rangesystems of indus-and business equipment. He holds academic degrees in reliability en-gineering, statistics and electrical engineering, and has taught production management, including quality assurance and quality control, at the university level.
II. The purpose of his testimony is to suggest that the Byron Reinspection Program does not provide reasonable assurance that the plant will be operated safely, for three principal reasons:
- 1. Edison's failure to perform a failure modes and effects analysis.
- 2. Edison's failure to define clearly at the outset the criteria for evaluation of safety significance of discrepancies found during the program, or, failing that, to retain an independent firm to conduct an after-the-fact evaluation.
- 3. Edison's assumption that inspectors would perform least well during their initial three months is inconsistent with his business experience.
III. A failure modes and effects analysis is a tool of reliability engineering. By identifying potential hardware failures with the greatest likelihood of causing serious safety problems, such an analysis enables one to focus resources (inspectors, en-gineering analysis, managerial attention) on the most safety )
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significant components and subsystems' . It also both permits and demands the application of stricter standards (such as reliability requirements) to the most safety'significant failure modes. Finally, it focuses on. the system, rather' than on individual components in-isolation, and requires calculation of statistical reliabilities
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for the' system rather than by individual attribute.
IV. ~In Dr. Bleuel's opinion, without performing a failure modes and effects analysis, one cannot have reasonable assurance that ~ adequate reliability. of Byron and its associated safety re-qutrements can be achieved.
V. In Dr. Bleuel's opinion, the of ten highly judgmental criteria'and methods used.by Sargent & Lundy to evaluate discrepan-cies should not be considered as a reliable basis for adjudging safety significance, because they'were not clearly defined at the outset. In his experience, if not so defined, applicable criteria can generally be defined during the course of evaluation to guaran-tee success, especially :Un a highly judgmental. context. This basic tenet of quality assurance requires no inference of bad faith.
1 VI. Ilhen the criteria are not clearly defined at.the out-set, an acceptable alternative is to have the evaluation conducted by an independent entity with no economic or institutional stake in the outcome. Sargent & Lundy is not such an entity with respect to the Byron Reinspection Program.
VII. Edison's assumption that inspectors would perform least well during their-initial three months is inconsistent with his business experience, especially for attributes which~the in-spector did not inspect during the first three months.
VIII. Dr. Bleuel also has concerns relating to the use of PTL for overinspections and to the exclusion of certain in-adequately documented welds from the Reinspection Program.
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UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of )
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COMMONWEALTH EDISON ~) Docket Nos. 50-454 OL
. COMPANY ) 50-455 OL
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(Byron Nuclear Power )
Station, Units 1 & 2) )'
DIRECT TESTIMONY OF DR. WILLIAM H. BLEUEL ON CONTENTION.1 (THE REINSPECTION' PROGRAM)
Q.l. Please state your name, business address and your current position.
A.l. I am Dr. William H. Bleuel, Ph.D. I am a partner in Zarkov & Gordon, 5400 Newport Drive No. 2, Rolling Meadows, Illinois. Our firm provides a range of services to the computer industry, including assistance in developing hardware service plans and strategies as well as direct provision of hardware service.
Q.2. Please describe your professional background and expertise.
A.2. My doctoral thesis was in the field of reliability en-gineering for repairable complex systems. I also' hold a
' Master's degree in statistics.and a Bachelor's degree in elec-trical engineering. I'have twenty-five years of business experience in design assurance and quality assurance in the fields of aerospace, defense, computers, control systems and
business equipment. From 1959-1961, as a design instrument engineer for Aerojet General, I designed instrumentation systems for low thrust engines for deep space' applications. From 1961-1964, I. worked in quality control for the Endevco Corporation, which manufactured vibration measurement systems for the Surveyorf satellite tha t made the first sof t landing on the moon. From 1964 through 1970, as an engineer for General Dynamics working under contract with the U.S. Department of Defense, . I worked on design assurance, including reliability engineering, for military communications systems. Since 1970.
my experience has been in the fields of computers, control systems and business equipment. I am co-author of the book Service Management, the first definitive work on -the subj ect, and author of_the American Management Association monograph,
" Service Planning." I have won various awards'.for applications of management science in the fields of reliability engineering and maintainability engineering. My resume is attached to this testimony.
Q.3. Do you have any experience with nuclear power plants?
A.3. No.
Q.4. Does your expertise have any bearing on questions of quality assurance and quality control at a nuclear power plant?
A.4..Yes. My extensive practical experience in design assurance (which includes both reliability engineering and y
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. maintainability engineering) an'd quality assurance has been -
in a variety of business contexts. It.has included experience
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in matters of critical safety significance, .such as work for.
the1 Defense Department on military communications. My work has also called for practical business application of such statistical tools as Military _ Standard 105D. As Assistant Quality Control Manager for Endevco, among other activities, I wrote standards for welding. My business experience, as well'as'my academic training, has given me an understanding of the tools
.and principles of design assurance and quality assurance, which can be applied to any particular business or industry, including the nuclear power industry.
Q.5. What is the purpose of your testimony?
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A.5. The purpose of my testimony is to suggest that the Byron Reinspection Program, as structured and implemented, does not provide adequate assurance that the plant will .be '
operated safely.
- Q.6. Why do you hold that opinion?
1 A.6. There are three principal reasons, discussed below in my testimony. First, Edison failed to employ a failure modes and effects analysis,which is a tool of reliability engineering, in formulating and implementing the program.
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Second, in ;its engineering evaluation of discrepancies, Edison ,
failed to ~ define exactly at the outset what would be the criteria for determining failure, or, in the alternative, to retain an independent firm with no direct economic or
-institutional stake in the outcome to perform an after-the-fact reliability assessment. Sargent-and Lundy, an engineering firm directly.and extensively involved in Byron, was asked, after the program was already underway, to analyze the safety significance of the discrepancies detected in the program.
That analysis was highly judgmental, and was not' conducted according to predetermined, clearly stated criteria for success or failure. Third, the program's assuraption that inspectors would perform least well during their initial ~ three months is inconsistent with my experience.
Q.7. What is the basis for your opinion?
A.7. My opinion is based on the application of my training and practical business experience in the tools and principles of design assurance and quality assurance' to the i
- particular case of the Byron Reinspection Program. To familiarize myself with that program, I have read the Reinspection Program Report of February,.1984; the June, 1984 Supplemental ~ Report; the direct testimony of Edison witnesses Laney, Hansel and Singh; and some related materials.
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.Q.8. What is failure modes anil effects -
- analys is ?
A.8. Failure modestand effects' analysis is a tool-of reliabilityLengineering. Essentially i t entails three steps:
E first,; identifying each of the possible ways (modes) in which ausystem could' fail;,second, analysing the effects of each such failure mode; and' third, categorizing the failure' modes according to.their. effects. For example, they may be critical-(e.g. ,' pose a threat of death due to excessive radiation); major (e.g., pose a threat of temporary plant shutdown with attendant economic costs); or minor (e.g., cosmetic).
For purposes of conceptual illustration, one common device is to depict a " fault tree" for the system in question. By graphically representing each of the identified failure modes, the fault tree assists one to analyze ~the ultimate effect of any one failure mode (fault) on the
. entire system.
The importance of failure modes and effects analysis is'that it enables the analyst to focus , not on individual items viewed in isolation, but on the item in the context-of the. system as a whole, based on thorough understanding of its systemic interactions and their relative importance.
The practical value of failure modes and effects
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(- 1 1 e analysis is, first, that it enables one to focus resources .
(inspectors, engineering analysis, managerial attention) on the critical failure modes (taking into account both their criticality and their likelihood). Second, it both permits and demands the application of stricter standards (such as statistical reliability standards) to the critical modes then are applied to less important modes.
Q.9. Was failure modes and effects analysis utilized in the Byron Reinspection Program?
A.9. No, the documents which I have reviewed contain no evidence of this analysis having been done.
Q.10. In what respect did the Reinspection Program fail to use failure modes and effects analysis?
A.10. In many respects. Most fundamentally, the Reinspection Program, as designed and implemented, neither concentrated re-sources and effort, nor utilized stricter criteria, for the components of the most critical failure modes at Byron. Indeed, there appears to have been no effort in the original program even to identify, analyze or categorize critical failure modes, let alone to act on such analysis.
Q.11. What is the significance of this failure?
A.ll. This failure may be understandable in light of the program's primary purpose as stated by Edison, namely, to deter-mine whether inspectors, who may not have been properly qualified, nevertheless performed capably.
f However Jwi th recpect. to t he ' Program's second (and 1 apparently~no_t initial) purpose -- namely,_.to demonstrate that
~ the quality. of work at -Byron is adequate to provide reasonable assurance that; the plant-ean he operated safely -- the absence
.oftany failure modes and. effects, analysis is a serious flaw. In my opinion, without performing a failure mod.es and effects-analysis',. one cannot have reano.intile assurance that adequate reliability'of the plant and:its associated safety. requirements can'be achieved.
^ Q,12. .How night a failure modes and effects analysis have been incorporated into the
. Byron reinspection program?
'A.12. To' accomplish this purpose credibly, a wholly different approach would have been required. Rather than spread-reinspection resources randomly among inspectors, without regard ;
'to the relative' safety significance or systemic impact of the
. work they inspected, the program would have begun by identifying the most safety significant failure modes, and.the components involved in each.
This task is achievable. For example, Byron's Startup Coordinator, Mr. Richard Tuecken, at his deposition and upon request of intervenors' counsel, categorized all the
- Hatfield procedures and PTL and Hunter attributes according to their safety significance, in categories 1, 2, 2, and " Leas t,"
. ranging, respectively,-from the first rank of safety significance, i to the second and third ranks, to least important. (A copy of' Mr. Tuetken's categorizations, which has previously been f
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. n engineering.evalunti.on (e.g.. reinspection of other weldc -
subject co load redistribution effect Cue to the failure of the weld ~ originally reinspected); and stricter engineering evaluation criteria (c.g. . more conservative ra tios of actual to allowable stress)
Moreover, Mr. Toetten':. categories might have been refined, with even-greater scrutiny given-toLthe-most critical sub-categories. For example, his category of visual weld in-spections might have been divided into highly stressed welds J
on critical safety components, less highly stressed welds on critical safety components, highly stressed welds on less
. critical components and lightly stressed welds on less critical components.
Q.13. Would such a failure modes and effects analysis also have affected the statistical reliability assessment of the program?
A.13. Yes. For the most critical procedures, in addition to ensuring larger sample sizes than for less important pro-cedures, one would use stricter statistical standards. If Military Standard 105D were to be used, for example, then one would use Inspection Level III rather than Inspection Level II, a' higher than usual confidence level, and a higher than usual reliability standard. In fact, the statistical requirements demanded by NASA during my quality control work for Endevco i.
went beyond the minimum requirements of Military Standard 105D.
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. .The reliability required for the overall vibration measurement system for the Surveyor satellite was 99.9, and for the transducer, cable and pieces of the amplifier the reliability' requirements were at-least 99.999.
Of equal importance is the fact that in a fatture modes and effects analysis, reliabili ties would not be calculated for individual' procedures or att ributes in isolation f rom others (as Edison's Reinspection Program Report does in Chapter VII)
Rather, the question would be the reliability of the particular system. To obtain the reliability for the system, one would multiply the reliabilities of the individual components. Since these reliabilities are less than 1.0, the system reliability would be-lower than the reliabilities for the individual components.
liowever, since failure modes in actuality occur by systems, the system reliability would, more accurately than any individual component's reliability, predict the likelihood of a safety-sigificant failure. In my opinion, Edi. con erred seriously by failing to calculate reliabili-ties for systems.
Q.14. Does the Supplemental Report of June 1984 remedy the failure o f the February, 1984 Reinspection Program Report to employ fail-ure modes and effects analysis?
A.14. No. The Supplemental Report moves in the right direc tio n . Fo r example , it includes analysis of additional welds selected on the basis of being highly stressed. However, rather curing the deficiencies , these partial steps merely illustrate what is ..rong with the entire Reinspection Program.
For instance, in the case of the highly stressed welds, it is not clear that an ef fort was made to s; elect welds that were highly
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, , stressed on the most safety significant components, let alone the most highly stressed welds throughout an entire system identified as critical through a failure modes and effects analysis.
Thus, while the Supplemental Report properly recognizes that the original Report 's engineering evaluation of the most visually discrepant welds missed the point, the Supplemental Report, too, misses the point to the extent it selected welds for evaluation based on their degree of stress rather than on their safety significance.
Mo reo ve r , the degree of inspection ano engineertng scrutiny of all reinspected procedures and attributes should have been based, not merely on which inspector happened to inspect them, or on their visual appearance, or on their degree of stress, but on their relative safety significance, i.e., the extent to which any discrepancy in the particular procedure or attribute would contribute to failure of a critical system, as determined by a failure modes and effects analysis.
Q.15. Do you have an opinion on the criteria and methods utilized to assess the safe ty signi-ficance o f discrepancies found in the Rein-spection Program?
Q.15. Yes. My opinion is that the of ten highly j udg-mental criteria and methods used by Sargent & Lundy to assess the design significance of discrepancies should not be considered as a reliable basis for adjudging safety significance, because they were not clearly stated at the outset.
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A basic tenet of quality assurance is that the criteria .
for determining failure should be clearly defined before any evaluations of success or failure are actually conducted. Other-wise the criteria, especially in a highly judgmental context, can generally be defined duri.ng the courne of the evaluation to guarantee success, regardler.s of the actual reliability of the system being evaluated. No charge of bad faith need be made to support this practical lesson from my years of experience in the field.
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'Q.16.-.1How did the failure.=to specify evaluation criteria
. at'-the outset affect. .the ! reliability of' the engineering evaluations
'-for . the rein'spection program?
A.16. I have not analyzed the specific engineering criteria and methods utilized by Sargent &~Lundy to evaluate the Byron Reinspection Program; nor would I' bc competent to-do so. Rather,
. I am_ making a universal. point, based on extensive buriness experience in design assurance 'and quality assurance, that criteria for evaluations of success or failure -- no matter who
-conducts the evaluations -- should be clearly defined at the
. outset, if the. evaluations are to be deemed reliable.
The point. has particular force where, as here, the choice of criteria.and methods for the evaluation is highly judgmental.
A reading of the Reinspection Program Report shows plainly that such was the case here.
Appendices C and D to the Report concern tlu3 engineering
. evaluations of discrepancies. Of three types of evaluations (Categories X, Y and Z defined in Appendices C and d of the Report, excerpts from which are appended as Attachment C'to my testimony), Category 4 is expressly described as evaluation based on engineering j udgment. In the case of subjective .,
discrepancies, of 4,132 total discrepancy evaluations, 3,074 '
fell in this category; of:2117 Hatfield subjective discrepancy evaluations, 2064 were in this category of evaluation by
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. judgment. (Table C-2, p. C-4, in Attachment C to my testimony.)
Judgment was likewise involved in the evaluations in
- categories X'and Z, least significantly in subjective category 4
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'X where L the' principal; judgment wasf simply that .certain types.of weld
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discrepancies did not reduce weld strength, and most significantly
'inLcategory Z, which involved evaluation by:engineerin'g calculations. .
Such calculations, of. course, require the exercise of considerable judgment as to both the criteria' and the methods - for the evaluation.
- Recent testimony in this case by Sargent & Lundy engineers McLaughlin and Kostal, which has been brought.to my attention by intervenors' co'unsel, illustrates the use of judgment in such calcu-lations. In the case of the Reinspection Program, I am advised that-the testimony suggests that individual welds on a component were evaluated by calculations which did not necessarily entail reinspec-tion of other welds subject to load redistribution effects (unless, by coincidence, those other welds happened to have been captured in.
the Reinspection Program sample). (McLaughlin testimony, Tran-script at 9154-56; Kostal testimony, Transcript at 10,238-10,240.)
In contrast, for purposes of preparing his testimony on the engineer-ing evaluations of Systems Control Corporation weld discrepancies, Mr. Kostal selected certain cases in which load redistribution ef-
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fects were calculated, and any welds thereby affected were visually reinspected. (Transcript at 10,238-10,240.)
Now, in the testimony just cited, both engineers expressed their judgment that these additional calculations and rein-spections were not necessary, but that is precisely my point.
They so. determined by an exercise of judgment -- one of many such ' judgments which permeate engineering calculations. If this 1 judgment were to govern the evaluations, it (along with many 14 -
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. - 1 othars) should have- been clearly ' stated at the outset. The veryffact that Mr. Kostal felt 'it. desirable to perform: these additional . calculations and reinspections for his testimony.
suggests that'it is not irresponsible to raise legitimate
. questions about the validity of the particular judgment.
, In short, the criteria and metho'ds for evaluation should
- have been clearly -specified before any reinspection results
.were received, especially because the engineering evaluations were- highlyL j udgmental .
Q.17. Is there any accept'able. alternative to clearly defined criteria for success or failure at the outset?
A.17. Yes. In cases where the criteria for success or failure are not: clearly defined at the outset, an acceptable alternative is to have the evaluation conducted by an 'indep-endent entity with no economic or institutional stake in' the o ut come . This avoids the situation of the " rabbit guarding the cabbage patch."
Intervenors' counsel has asked me to review NRC Chairman Nunzio Palladino's February 1, 1982 letter _ to Congressman John Dingell, concerning criteria for an independent design review of the Diablo Canyon nuclear power plant. I have reviewed the letter (Attachment D to my testimony). In my opinion, the criteria set forth therein appear adequately to describe an acceptable degree of independence for review in-a case, like this one, in which the criteria for success or failure are not clearly defined at the outset and are highly judgmental . I re fer particularly to the following f
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'i languagefin: Chairman LPalladino's response ~ to the portion of ~
' Congressman ) D'inge11's ques tion 1 wh'ich ' asked for .a definition-lof ' the : term, "independen't ":
Independence menas; that -the' individuals or .
companies-selected:must be able to provide-
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an obj ective, dispassionate technical -j udg-c ment, -provided' solely on the basis o f tech-
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_ni cal : me ri t . Independence also means that
. the ijesign .ve rification p rogram must be con-
- ducted by' companies ' or . individuals ' not pre-viously involved with 'the activities at -
Diablo Canyon'that they will now be revi~ ewing.;
Sargent - 6 Lundy , of course, has been extensively involved in' the design, prior partial evaluatiuns of, and~ advice concern '
ing_the activities-at Byron which it was. asked-to evaluate-in the. Reinspection 1 Program. It has a direct economic and institutional stake in the outcome, both of the Reinspection
~ Program and of this licensing proceeding.- I f. engineering evaluation were to show serious safety problems at Byron, and -Byron were not to be licensed,'the firm, which according to press reports has recently laid off engineers due to loss of business resulting :in part from cancellations of other nuclear power plants , might lose business at Byron. Its business at Edison's Braidwood plant, also designed by Sargent & Lundy and quite similar to Byron, would likewise be in question, and its reputation might be jeopardized, threatening further: loss o f -business .
None of this is to impugn in any way the integrity of Sargent 6 Lundy. I am merely pointing out that"Sargent &-
Lundy is-not-in any real sense, or in the sense of Chairman 1
- Palladino 's de finition, " independent" for purposes of engineer ling . evaluations of the1 work at Byron.
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JIn' sum, based on my extensive business experience'in
. des'ign assurance and quality assurance , when - the criteria for
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s uccess or failure ~are not clearly defined _ at' the outset,- the 2
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2svaluation must beidone by a firm which is independent, if the
-evaluation'is to be deemed-reliable. Here the evaluation was
- done by a1 firm which is plainly not independent , . and the
. evaluation otherefore should not be deemed reliable.
Q.18. Does the NRC Staff review of Sargent .& Lundy's engineering evaluations supply the necessary degree .of independent review?
A.18. No '. The evaluation itself, not =merely a limited,.
partial review of the evaluation, must be independent, if it
'is to be' relied upon.
Q.19. Do you_ have an opinion on whether the use of each selected inspectors' - first three months as a sample introduced a conservative bias'into the Reinspection Program?
A.19. Yes. Based on-my years of business ~ experience in servicing of hardware, I believe that use of the first three months had the opposite effect. My experience on this point is mainly in supervision of technicians performing repairs on business equipment. However, from my experience in Quality Control for Endevco, I believe that for this purpose the two types o f activities -- hardware repairs- and hardware inspections --
and the behavior patterns of the human- beings who perform 'them, are. comparable.
My experience has been that the technicians are most
. enthusiastic, most informed on technical points , and try the hardest 7when they first start. Once they-get settled into the 17 -
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,. job, : their enthusiasm tends to drop and they tend to get sloppy unless they are continually challenged.
An important factor is how often their training is re-in forced . If they are trained for several different kinds of
- activities, b ut during their first months on the job their activities are confined mainly. to one of them, they tend to forget what they have learned on the others.
As applied to this case, an inspector might do quite well in his or her first three months on one or two attributes , but if not retrained, may later do poorly on other attributes which he or she did not inspect much until after the first three months. Thus the use of the first three months is likely to mask subsequent deterioration in inspector performance, espec-ially as to inspections of attributes for which few inspections were done during the inspector's first three months.
Here again, as in my answer to question 11 concerning the absence of failure modes and effects analysis, the problem arises in part from Edison's effort to stretch the Reinspection Program to cover a purpose for which it was not originally intended, and for which it clearly was not designed. In other wo rds , had the only purpose of the Program remained to resolve questions about the adequacy of inspectors ' initial certifications and qualifications, then use of the first three months for sampling would have made good sense. But once the purpose shifts away from initial qualifications to the question of how the inspector in fact performed throughout his tenure, then use of the first three months is no longer a conservative sample. On the contrary, based on my exper-R
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-ience, such a sample' period is'likely.toJoverstate the'inspec-
- tor's actual performance over time;
, ;.Q.20. Do you have-other concerns relatf.ng.to Edison's Byron-Reinspection Program? -
A'.20. .Yes. The selection of PTL.for overinspectors was
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inappropriate because.PTL inspectors were not certified to higher standards than-the reinspectors;'in fact, PTL-inspectors overall scored.significantly lower than inspectors for other companies. . In addition, the Reinspection Program Report at p IV-5 indicates that.
-certain welds for which complete documentation was not available were not reviewed, yet'it would seem likely that inadequately-documented welds are among those most in need'in reinspection.
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-ATTACHMENT A RESUME OF-WILLIAM H. BLEUEL, Ph.'D.
Education: '
. ' Ph.D. , Tex a s A & M Univ e rr i ly,19 70. Doctoral dinnertation'in the field of reliability engineering for repairable complex systems.
. M.S. In' Statistics, University of Rochester, 1967.
.- B.S. in Electrical . Engineering, Texas A &M University, 1959
-Experience:
. Aerojet. General-Corporation, Design Instrument Engineer, 1959-61. Designed instrumentation' systems for low thrust engines for deep space applications.
. -Endevco Corporation, 1961-64. Served for all but a brief portion of this period as Assistant Quality
- Control Manager for Endevco, which manufactured vibration measurement systems for the Surveyor
' satellite that made the first soft landing on the moon.
. General Dynamics, 1964-70. Under contract with the U.S. Department of Defense, responsibilities concerned design assurance, including reliability engineering for military communications systems.
. SSR Corporation (Stochastic Systems Research),
President, 1970-72. SSR provided consulting in systems analysis.
. Xerox Corporation, 1972-75. Served as manager in charge of all field services reporting systems, equipment field reliability analysis and development of mathematical models for service.
. Taylor Instrument Company, National Service Manager, 1975-79 Renponsible-for field service, factory repair and related activities of 250 persons, for Taylor's business which involved provision of control systems to a variety of industries.
.- AM International Service Division, Director of Planning and Control, 11979-80. AM was a conglomerate; my Division's annual sales exceeded
$100 million.
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' RESUME OF WILLI AM 11. BLEUEL, - Ph . D . .
Experience:'(cont.)
. Barber Colman, Director of Marketing for the Envir-
-onmental Controls Division,'- 1980-83 Division marketed iiVAC systems'to industry.
. Zarkov.& Gordon, Principal, 1o83_ to present. Our firm ~providen services to the computer' industry, including both hardware servicing and assistance in developing hardware service. plana and-strategies.
Publications:
. Co-author of the book, Service Management: Principles and Practices.
.- Numerous articles and professional presentations in the fields of reliability engineering, operations research and service management.
Awards (partial list):
. Operations Research Society of America, 1958 award for a paper on the reliability of radio hardware for
' military communications systems.
. Institute of Management Science, First Prize in 1975 national competition on the Practice of Management Science.
. Armitage Medal from the Society of Logistics Engineers, 1978, for my book on service management, which is used for logistical support for defense systems.
. Association of Field Service Managers, S.B. Ross Award, 1980, for contributions to the literature of service.
Teaching Experience:
. From 1970 through 1975, I. taught production management, including quality assurance and quality control, in the graduate business schools at the University of. Rochester and Rochester Institute of Technology.
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RESUME-OF WILLIAM H.'BLEUEL,'Ph.D. --3 -
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-Current'ProfessionaliActivities: -
. .. Board of Directors, Association of Field-Service-
-- Managers.
. -. Chairman, Cocimittee on: Publications, Association of Field -- Serv i ce ' Managers .
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. Cert.ified Service Executive, - National ~ Association of.
Service. Managers.
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C-2
- C.
CATEGOltl2A flON OF SUBJECTI.VE D.
- - ISCitEPAN..CIES pm 9.
An engineering evaiuanon- har been per!vrn.ed for ' eacii observed subjective (weld) discrermcy. The evahi.it:en methods u.cd can be. 'divided 'nito three categories. These :bree categories are related to the acceptarice criteria fer -
visual weld inspectien. The accept ince criteria c onsists et inspecting v. elds for arc sicike, spat ter, convexity. cr ater, incomplete 'usmo, oserlap, perosity, undercut, underrun. and racks. The-preser.cc of diese weld inspection items
.are considered as + veld discrepancies. These weld discrepac.c es vary in degree as to their effect en weld capacity.
L Category X ~-
Evaluation by comparison with current design parameters and J tolerances.
Category X contains weld discrepancies that do not reduce the weld' capacity. Arc strikes and spatter are cosmetic indi-cations that relate only to appearance. Convexity relates to weld meta! en the tace of a weld m excess of the weld metal necessary for the required weld size. Convexity has no effcct on weld capacity (see Exhibit C-2 Section C.1).
Category Y -
l Evaluation based on engmeeting judgment by comparison of the discrepancy witn design inargins.
l Ca teg. r y Y contams some of the following weld dis-crepancies:
crater, incomplete fusion, overlap, porosity, undercut, or underrun.
- Portions of the wc!d with these discrepanco
- s are considered inef fective, and weld capacity is ca ed en a reduced weld length. Engineering judgment is used to evaluate the weld discrepancies based on the available '
design enardi n in the weld and the reduced weld length, which accounts fer the assumed ineffective portions. Typically, this results io less than a 10% reduction in weld strength l
prop +:r ies to accoont ior the weld discrepancies.
) 3 C-3 Ca ter:r ', 2 -
...ua:a b, enga:e r.ng en:u!a tions..
Cate. tog : evat. urn; are ba_ec cn red.;cing the v e!d length toxcx a for tne pre ence of weid di'.crepar.t ies as gisen tor Caege . Y. Tuo re'ds " ith traces w ere evaluated in .
Ca tegur . Z. Tre nietheo 'er es .in :'r;', tne occrepancies it.
'.s "1 04 1' f, M ie t 'T . ? C t. .s'. 't u ld t 10I
- 12 t?'J a' be Ul* ? nldgilllude dild
- ; .- o r a n..r-:uncie , t a,,not be p.dy:d .n adequa te .vitr.out a Je t:n~. > 1 caicula t.on, i
D. RESULTS OF SUBJECTIVE DISCREPANCY I!VALUAT!ON The results c,f me sh;. eti.e enc . panc, eva:uation for each contractor are sumniarced in Tante C-2.
A mere detaileo b eakd , s n o! discrepancy evaluatien is >nown for each h contractor in i snib:t C-!. s.n:ch contain.; Tubles CE-i Coh % n Centrols), CE-2 (Hunter), CE- 3 n iat f r 9, et. .:, (Pew ers-A/ro-Pope) CE 'i (Pit t burgh Testing),
and C E-6 (PeabM,).
A more detat.'ed aewr puu.i at tne e..gineermg evaluations that were performed is presented in l~ &: rats C t Au 5 a c! ding) tnd C-3 ( ASME and ANSI B31.1 Welding).
~
1 s
C-3 Categerv Z - E.aluation t,y ent,ineeruig calculations. ,
Category Z e.aluations are bmsed on reducing the we!d length te acco"nt for the pro..:::ce of weld dncrepancies as given for C.i t e g er , Y. Two reids w ith crc.u s were evaluated in Ca te>,ar i Z. Inc m.etned fer er.iltatir,g the clicrepancies is a.ued s; e,.pneo. .:,g t. ;ce!at: ens beca .ue th.- u agnitude and
- t. pes at discrepancies cannot t e p.dg. J a:, adequate without a detailed alcula non.
D. RESULTS OF SUfMECTIVE DISCREPANCY EVALUATION The results of the sub!cct.ve discrepancy eva;uation for each contractor are sumrnarized in Table C-2.
A more detailed breakda so of discrepancy evaluation is 3hown for each h contracter in Exhib:: C-1. Mch contains Tables CE-l (Johnsen Controls), CE-2 (Hunter), CE 3 (Hatf:e! !), G-4 (Posers-Azni-Pope), CE 5 (Pattsburgh Testing),
and CE-6 (Peabody).
A more detai:ed descrtption of the ear,ineering e.aluations that were performed is presented in Exhibits C ; (Au S 4elding) and C-3 (ASME and ANSI B31.1 Welding).
Y 1
1
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. '.-2 C-4 Table C-2 ' ~
Summary of Subjective DiscrepancLjvaluation I Results No. of Catecorv X Catecer. Y Category Z Discrepancy No. with No. Wtthin No. Acceptable No. Acceptable Design Contractor Evaluations Parameters by Ji,dgmerg by Calculation Significance Blount Brothers' N/A N/A N/A L
N/A 0 Johnson Controls 65 iS I2 33 0
!!unter 109 2) '23 6l 0 NISCo 0 0 0 0 0 Hatfield Electric 2,117 Ii 2,064 42 0 Power s-Azco-Pope 914 201 77 636 0 i
Pittsburgh Testing 905 337 1
l7 0 Peabody Testing 22 0 1I II O l
! TOTAL 4,132 253 3,074 l 805 0 l
- Inspection of Blount Brothers was performed by Pittsburgh Testing.
results are reported under P.ttsburgh Testmg. Inspection h
Table C-2 sho.'s that 6% of the discrepancies identified in the Reinspection Program as Category X are em "vahn" discrepancies and represent work that is within current cesign parameters. The Category X discrepancies result primarily from design parameters that have been expanded since the time of the original inspection and therefore are withm current design limits.
l The Category Y evaluation m Table C-2 indicates that 74% of the observed weld discreparctes, wherein weld capacity was reduced by approximately 10%
af ter accounting for the weld discrepancy, are acceptable. In all cases, the design margin remained within design limits.
l The Category 2 evaluation in Table C-2 indicates that 19% of the observed weld discrepancies are acceptable. The reduction in v. eld capacity varied af ter accounting for the weld discrepan y. However, in all cases, the design margin
' remained within the specified design limits.
7 . .s 9 ..**-*
D-2
, i
- C. -. CATEGORIZAT!ON OF OBJECTIVE DISCREPANCIES .
An engineering evaluation has been performed for each observed cbjective discrepancy. The evaluation methods used.are divided into three categories.
The categories and typical types of evaluation methods used in each category are shown below:
Category X - Evait. ition by compa isen with current design parameters and tMer mew..
Perform a comparison of actual component locations to the corresponoing design location Lwith applicable installation tolerances to show that the actual lacations are 'within-tolerance.
Perform a comparison of the actual installation to the designed installation for discrepancies with minor documentation errors to show that error was limited to the documentation and did not af fect the actual installation.-
h'
(-
Perform a comparison of actual component dimensions to the corresponding design dimensions with applicable tolerances applied to show that the actual dimensions are within tolerance.
Category Y - Evaluation based on engineering judgtnent by comparison of the discrepancy with design margins.
Perform a comparison of discrepancy to current design analysis or calculations to determine that the discrepancy was not signilicant.
- g. ..w
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. 03
- n .
Review the cornpanent cesign function to determine that the function of the component was not affected by the
- discrepancy.
- Category Z - Evaluation by engineering calculations.
Revise uv existing desiga 'ocuments. to incorporate the design change reflected in .'. unscrepancy.
Prepare a specific calcufation to address the impact of the discrepancy on the design.-
D.
RESULTS OF OBJECTIVE DISCREPANCY EVALUATION The results of the objective ' discrepancy evaluation for each contractor is summarized in Table D-2.
ib Table D-2 Summary of Objective Discr'eWncy livaluation Re:,ults Categorv Y Category Z No. No. No.
No.of Category X Acceptable Discrepancy No. Witn:n~ Acceptable with by by Design Contractor Evaluations Parameters Judginent Calculation Significance Blount Brothers 23 10 3 10 0 Johnson Controls 47 15 19 L3 0 Hunter 634 614 52- 18 0 NISCo 12 0 12 0 0
' Hatfield Electric 1,673 1,243 74 s
353 0
< Powers-Azco-Pope -295 232 5 53 0 Pittsburgh Testing 66 I 9 56 0 Peabody Testing
- N/A N/A , N/A N/A N/A
> TOTAL 2,307*' 2,115 179 313 0
- Reinspection of Peabody Testing im o!ved only subjective inspections.
' * 'In some cases, more than one discrepancy was associated with a component. This results in the number of discrepancy evaluations (2,307) shown in Table D-2 being different than the number of discrepancies (3,247) shown in Table D-1.
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February 1, 1982 MIR AAAN The Honorable John D. Dingell, Chainun Corisittee on Energy and Com.3rce United States Heuse of Representatives Wastiington 0.C. 20515 ,
Dear Mr. Chhir an:
k'e share the ccncerns c;q.rcssed ir. 2 cur Neverar n.1301 htier
' regarding tha ir. plication of the tc:uat scis'",1c design err::r detorted at the Diablo C3nycn nuclear ;:..er plant. Tne ir.clication of these errors has been and will be th;ughtfully considered by the Ccccissicn.
. The timing of the cetection of these errors, to scon efter outhorization "
for low-power operation, was inoced unfortuncte end it is quite understandsble that the Ccnc,ress' and the public's perception of our licensing process has been advarsely cffected. Had t.his infor:2 tion teen kncwn to us on er prior to Septe.v.ber 22, 1931, I am sure that the f acility license would not have been issued until the questions reised by these disclosures had been resolved. .
Eecsuse of'these. design errors, on Ncvccber 19, 1981 ve suspended '
Pacific Gas and Electric Ccm;any's (PC3E) license pending satisfactory completion of the fcilowing: .
- 1. The conduct of an independent design review program of all safety-related activities perforr.ed prior to June 1,1978 under all seismic-related service contracts used in the design of
. saf ety-related 5;ructures , system , and co.mponents.
- 2. A technical report that fully essesses the basic cause of all design trrors identified by this progren, the significance of the errors found ard their h oact on f acility design.
- 3. FC5E's conclusions of the effectivence of the desigp verificaticn program in assuring the adequ,acy of faciitty design.'
4 A schedule for capletin;; any modifications to the fccility that are required as a "etult of the de',ign verification prograc:.
1r. addition, the Comission ordered P31E to provide for NRC review and approval: ,.
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- 1. A description and discussion of the corporate qualifications of the
- i cc:npny, or co:rpenies that PGl>E would propose to carry out the
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s independent design verificaticn prograrn, including information that
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demonstrates its independence of these companies.
- 2. A detailed program plan for conducting the design verification ~
program.
In recognitien of the need to assure the credibility 'of the design -
' verification program, NRC will decice on the accapt:bility of the companies' proposed by PGLE to conduct this progrtm af ter providing the Governor of California and Joint Intervenors in the pending operating licensing proceeding _15 days -for concent, Also, the NRC will decido on the acceptability of the plan proposed by P35E to conduct the progrs=,
atter providing the Governor of Califtrnia and the Joint Intervenors in the pending opurating license proceeding 15 days for comment.
Prior to authorization to proceed with fuel loading, the NRC must be satisfied with the results of the seismic design verification program and with any plant modification resulting fecm that progrcm that esy bc .
necessary prior to fuel loeding. The NP,C nay ingc;e additional requirements prior to fuel loading necessary to protect health and safety based upon its review of the program or any of the information .
provided by PG&E. This may include soc.o or all of the requirements specified in the letter to P35E dated November 19, 1981.
Responses to each of the four questions in your letter era unclosed.
A decision to permit PG1E to pro.: ecd with fuel loading will not be made until allare Order thefully actions contained in the Comnissien's Nove:ter 19. 1981 satisfied.
Since rely.
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Hunz10 J. Pallaoino -
cc: Rep. Ca rlos Moorhead
Enclosures:
- 1. Commission Orcer, dated 11/19/81
- 2. Ltr f rom Of fice of Nuclear P,esctor Regulation, NRC to PG?d dated 11/19/81
- 3. Respor.ses to Questions e
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- RESPONSES TO QUEST 10..
. . .. . - . CHAI RMN P AL ADI N IN NOVEMSER 13. 1981 LETTER FROM CONGRESSMEN DINGELL AND OTTINGER FJ2
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k Question 1: ,
Please provide, prier to the issuance of the 50.54(f) letter, the definition of the terms (i) "indapendent *
(ii)" competent,"(iii)" integrity,"and(iv)=ccepl$te, g. -.
Resp:nse:
Although one of the opticas under.consideraticn by the '
Comnissien was a 50.54(f) letter, the Cctraissica decided t.o .
- 5 percent pcner by Macrandum and Order dated Nc 1981, pending satisfactory completion cf certain acticas,
- including the conduct of a design verification progrca.
Also, a staf f letter of the sema .date required PGLE to carry on other design verification prograr.s prict to issuance of any license authorizing operation above 5 percent power. -
The most important f actor in NRC's evaluation of the indi-
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viduals or companies proposed by Paci~fic. Gas and Electric *
. to complete their ccm;etence. the required design verification program 1s and experience in tha matters under review.This competence or ccmpanies should also be independent. Independence These individuals means that the individuals or companies selected must be .
able to provide an objective, dispassionata technical judgment.
provided sclely on the btsis of technical ocrit.
also means that the design verification program must beIndependence cenducted by corrpanies or inoividuals not previously involved with the activities at Diablo Canyon that they will now be reviewing.
. .Their in'egrity must be such that they are
, regarded as reputable companics or individuals. The werd .
"ccmplete" applies to the NRC requirement (cr review of all quality assurance procedures and controls used by each p~rT ,
June 1978 seismic and non-seismi,c service related contractcr and by PGLE with reprd to that contrcct. A comparison of . ~
these precedures end controls with the related criteria of Appendix B to 10 CFR 50 is also required. Any deficiencies or weaknesses in the quality assurance procedures and controls of the contractor and PGLE will b2 investigated in more detail. In eccitien, calculations will be checked in an audit progr am.
Nux.erical calculations for which the original besis ca'nnot be determined will be recalculated to verify the initial design- input.
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.v-guestion 2: Please provide.the criteria to 'be used in assuring that the proposed audit will be
" independent." .
Response: The competence of the individucis or .
companies is the most important factor in the -
selection of an auditor. Also, the companies or individual's may not have had any ' direct - *
. ..' previous involvement with the activities' at." -
Diablo Canyon that they will be rev,iewing.. ,
In addition, the following factors will b'e considered in evalusting the question of independence: ,
- 1) Whether th'e individuals or companies.
involved had been previously hired by PG&E to do siroilar seismic design work. *
- 2) Whether any individual involved had been
, previously employed.by PG&E (and the
, nature of the employment).
- 3) Whether.the individual owns or controls significant amounts of PG&E s,tock. -
- 4) Whether members of.the present household of individuals involved are employed by PG&E. .
- 5) Whether any relatives are employed by PG&E in a management capacity.' ,.
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' In addition to the above considerations..the following procedural guidelines will be used to assure independence:
- 1) An auditable record will be provided of' ell comments on draft or final reports, any changes made as a result of such comments, and the reasons for such changes; or the consultant will issue only a final report (without prior licansee comment).
, 2) NRC will assume and exercise the respon- ,
sibility for serving the report on all l 8
parties.
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.50ueltion 3_: IN. view of the licensee's past performance, and'that of its subcontractors, what . -
procedures will be utilized to ensure that there are not ecnflicts of interests in the -
performance of any required. audits?- :
Response: We are requiring that PG&E provide the NRC * '
. with a-description and a discussion'of the ~
corporate qualifications of the companies .. J proposed to carry out the varicus design verification programs, including information that demonstrates the ir.depe'ndence of these -
companies. This information will be provided to th2 Governor of California.and the Joint Intervenors for comments. Based upon review.
of the ir. formation provided'by PG&E and the '
comments of the Governor and Joint Inter.
. venor, the NRC will decide on the accept-ability of the companies with respect to ,
thei r i nd e pe nd e nce" and " competence." .In addition, approval will not be given by NRC if we determine that a potential conflict of interest exists in the performance of any required audits that cannot be adequately -
addressed by procedural safeguards. , ,
Ouestion 4: What plans does the NRC have to ensure that a similar situatien will not arise at other plants now under const'ruction? What, if any, additional quality control procedures does the NRC propose to institute in its inspec- .
. tion program?
Response: The Commission is developing an action plan that will result i n improved HRC review of
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- quality assurance programs at operating nuclear power pl a nts a nd nu cl e a r powe r plants'"
under cor.struction. The details of the ,
action plan wil,1 be available in the near future.
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