ML20128C735

Responds to Encl Ltr from EA Imhoff Commenting That AEC Makes No Tests of Its Own While Inspecting Nuclear Power Plants to Make Sure They Meet Requirements & Summarizes Briefly on AEC Regulatory Programs

ML20128C735
Person / Time
Site:	Monticello
Issue date:	09/17/1970
From:	Price H US ATOMIC ENERGY COMMISSION (AEC)
To:	Quie A HOUSE OF REP.
Shared Package
ML20128C738	List: ML20128C735 ML20128C770
References
NUDOCS 9212040519
Download: ML20128C735 (8)

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SEP 17 M l- Bonorable Albert E. Quio l Mouse of Representatives l

Dear Mr. Quie s l

The enclosed letter from Mrs. Eugene A. -Imhoff that you referred to us

' coussats to the effect that the ABC makes no tests of-its own while inspecting nuclear power plants to make sure they asse requirementa, but '

instead relies hsavily on reports of tests actually conducted by the builders of the plants.

The AgC inspection program, cartied 'out by its Division c2 Compliance was described in detail during the AEC hearing. in the patter of the Northern States power Company, Monticello Nuclest Centrating plant, Unit 1, . Docket No. 50-263. The yrincipal informatica is in Supplement 1 to the AEC Regulatory Steff Safety Evaluation and Wortions of the _testi--

many on August 5, _1970. Copios of this materia 1 are enclosed. This material is also available for-inspection at the Office of- the Clerk, l

Wright Comty Court House, Buffalo, Minnesota, l

Swanarising briefly the Atomic Energy Cawdssion in its regulatory pre-- '

gram holds its licensees responsible far iafety in the design, construction and operation of their nuelaar reactot 'acilities - The ARC inspection program is directed toward assuring that the -licensees are fulfilling these safety responsibilities. Among the requirements imposed upon licensees to accomplish this is one that requires them to establish quality assurance programs that include suitable provisions for independent reviews :of quality of construction. Specifically, part 50.34 'of AEC regulations (copy enclosed) states in part that "A program for inspection _ of activities ' affacting quality shall be established. and executed by or for the organization per-forming the activity- to _ verify conformance with the. documented instructions, i

procedures, _and drawings for accomplishing the activity. Such inspection shall be performed by individuals _other_ than- those who_ performed the ac-tivity being inspected." - Af ter work is -performed by craf tsase under 'respea-sible supervision, it is reviewed by appropriate quality assurance personnel.-

In many cases this imelados quality control personnel fron the workman's organisation, the . construction contractor. - the architect-engineer. and- the licensee. Independent testing laboratories are often employed by these 1-organisations. The licensee' is responsible for auditing the entire program and for assuring that it is functioning properly. , g ')

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a Comerable Albert M. Quis The Division of coup 11anse them inspects the performance of all these groups through a system of opet cheeks, rooerd reviews, interviews, and aboarvation of work in progrees. We believe that this system of independ-est shocks and audito provides adequate aneuranee of the quality of construction.

As to Mrs. Imhoff's questime with raepeat to the authority of the state of Minnesota to establish more restrictive standards regarding releases of radioactivity from anclear power plaats licensed by the AEC, this matter is now is litigation before the U. S. District Court for the District of Minnesota.

Sincerely, I signe3 J Harold L. Price Harold L. Price Director of Regulation Enclosures :

1. Cy ler Mrs. Imhoff to Rep. Quie, dated August 7, 1970

2. Cy Supplement 1

3. Cy Monticalle Testimony

4. Cy Federal Register Distribution:

OCR (2)

H. L. Price, DR H . K. Shapar , GC E . G . Case , DRS P. A. Morris, DRL A . G iamb us s o , CO R. H. Engelken, C0 B. H. Grier, C0:111 G. Ertter, DR-2755 (Note : Retyped on 9/14 per Dr. Beck's consnents)

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'ihe Division of Complianec's inspection progratt has been generally described l in the introductory part of Supplement flo.1, the AEC Regulatory Staff safety -

l cval uat ion. Questiens were raised during the deposition and since the sub -

nittal of Supplcrent 1. An a result of these, I will' provide some further

discussion of the inst ection program.

The inspection role assigned to the Division of Compliance in the AEC tbgulatoryprogramisbanedencertalu-fundamentaldecisionsradobythe 4 Congress and on impicracntlng policios adopted by . the Conraission. The

! Congress bas entablished a systen of licensing privately owned and operated

! nucicar rnet13 tien.

Inherent in the concept of- private activitics, _ subject to licensing and result. tion by a covernment agency is the fact that the liacnsee is held

.esponsible for meeting the objectives of the -licensing.and regulatory

! system, In this case, protection of the health and safety of ;;he public.

This is in contrast to ' the cituation in which operational activitics are 1

carried on by the agency, ,it cif, and in which the agency carries out operational cafety activitics. Let.me reiterate that the Atomic Energy ,

Con:r.ission in its licensing and Regulatory program holds its licensec9 responsible for safety in the design, construction,_ and operation of nucicar

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reactor facilitics.-

-ENCLOSURE 3

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The Division of Compliar.ce's inspection program is designed to assure that a licensee is carrying out his safety responsibilities. The Commission's I '- regulations in Appendix B to Part 50 require a 1kensec to have a quality i

• assurance program which includes provisions for independent safety and i

quality revicus of design, construction, end operation. By independent, l

t it is meant that revicen are conducted by persons who do not have responsibility for perforning the work in question or for related costa in scheduling.

4 I In the case of a construction project, the Division of Compliancc's inspec-tion activitics are directed touard verifying that a 1kensee han inplomcuted J

the required assurance prograr!. Typical ~ Lispection activitics which are carried out in this regard are identified on'Page 3 of Supplenent Mo. 1.

< Specifinn11y, thene include such things chich I tuuld like to ncntion of

! witnessing the perfornance of major construction tents such as hydrostatic 4

tests of piping and pressure tests of containment vessels and review of prograt.i for a functional or preoperational testing of system and equipment including the test program, the test procedures and the test results.

t lie have concluded that these inspection activitico provide an adequate basir-1

- for verifying independent reviews of- construction activitics and provide i  !

i reasonabic assurance that the completed facility vill conform to AEC regulatory requirencnts. - Let tac emphasize one area of our. inspection program I

j which I've just mentioned,' that related to preoperational testing'of the I > facility. The licensee is required to develop and irry out a comprehensive.

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1 preoperational testing program. The procedurco developed under this t

program are reviewed by Compliance inspectors. The comments are directed to the licenccc. The performance of selected preoperational tests are witnessed by Compliance inspectors.

The recults cf the teste and the 11cencce's evaluation thereof are reviewed by the inspectors. Thia testinp, of the plant to the extent possibic prior to the loading of fuel denonstrates whether the plant systens and components .l are capable of performing their intended functions under both normal and abnormal conditions. These testo also serve to demonstrete the adequacy of plant operating procedurcs.

,W Satisfactory completion-of the preoperational testing program is an important part of the basis for our finding of plant conpletion. Division of Compliance a inspection personnel are experienced and knowledgeable in the practical aspects l of construction and operation of nucicar reactors. This is demonstrated by the qualifications of the inspectors which have been entered in the record of this proceeding.

In addition to the inspectors, specialints in appropriate fields of engineering I

and technology who are assigned to the Division of Compliance headquarters staff and to other divisions within the regulatory staf f are utilized to

.nssiat in special inspections.

Further, consultants to the AEC also provide assistance. The experience s

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l and technical competence of the innpcetion personnel arc important factors -

in the success of the innpection program. We scch uniformity and objectivity I

in the conduct of the Division of Compliance inspcetion progran by a system j

of internal checkn and balances. This system. includes prope. ration of inopcc-tien plans prior to an inspection, rev$cu of the results of thnse inspect. ions J

4 by the cupervisor, the preparation and _ distribution of the written inspection i report to headqunrters groups, oncite vinits by suucrvisors with innpactors, accompaniment of inspectors by headqucrters or other Complinnce staff including specialicts nnd consultants, rotation of inspection assignments, and in the case of operating facilitics, assi;nm:nt of back-up inspectors who participate in onsite inspections.

The matter of our reliance on the licensee to maintain accurate and conplete records has been raised. For example, records pertaining to the installation

! i and testing of a particular systen. It has been implied that these records k

could be falsified. It is true that through incent, negligence or oversight,-

incorrect records may be generated. In my opinion, our inspection program cannot be readily frustrated by falsified or incorrect records. As a-basis 4~

for this opinion let me - point out, first, 't order to achieve a coherent i

j coverup of some adverso information, a large nunber Lof licensing and contractor

, personnel would have to be a party to the concealment. . This is almost 4

inconceivable.

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i i Secc..d the licensee does not know ubere our spot checks will take pince.

1 Thene checks nay, indeed, be random and with so nuch interreic.ted data, I

it would be very dif ficult to conceal inconsistencies.

i l  ; Thirdly, the nyntens in question arc t.angible nr.d our inspectors do verify

! information in records or request verifict.t ion uador their observation.

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t. gain, bear in mind as pointed out previously, our inspection personnci are Because of this experience, experienced in reactor construction and operation.

they are fanillar with chat records ought to look like and uhat typical relationships enist amng data through revices of records, observation of vork in progreca, discussion with licensee and contractor per=onnel at all levels they are able to formulate judgaento as to the validity of the records.

Ity com: tents so far have reinted principally to the construction and inspection T

l program. The frequency of inspection after the operation begins depends upon

• the status of the facility. During the period af ter initial fuel loading when low power and power sensing tecting is' in progress, inspections are performed on at least a monthly basis. Inspections may be more frequent

' if tests which we want to vitness are in process or if any operational I difficulties have developed. Inspection frequency will be reduced only af ter f

the plant coupletes full power testing and coterances routine operation. It is at this time, af ter satisfactory performance of. the plant has been

' demonstrated, that the minimum frequency. becomes four times per year. . sTo 1

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I repeat, this is minimun frequency. If the plant maintenance or refueling operations are scheduled, or if operational difficultics develop, our

! inspection frequency will be increased.

The Divisinn of Compliance was initially cetablished in 1960. I have been i

o member of the Division since shortly after its fornation. !!r. Thornburg, the supervioory inspector for Monticello, han nico been a menbcr of the Division since approximately that time. During this ten-year period the fundamental philosophy of inspection has remained the sanc: that is, a system for relectively c.xanininr, the canner in dich the licensee is meeting his responsibilities. The progran has, of course, undergenc period review rnd upanting. The preexam as it hac been deceribed for !;onticello is no different than that which has born and is being followed elsewhere. Based on our exparience during tha perlod since the establinhnent of the Division, t'e conclude the Division of Compliance inspection program as' it applies to the -

facilitica under cont:truction provides na adequate basis for the findings chich must be rxtdo, namely. that a facility has been cornpleted in. accordance with AEC regulctory requirencnts.

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