ML20132B560
| ML20132B560 | |
| Person / Time | |
|---|---|
| Issue date: | 01/19/1983 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20132B439 | List: |
| References | |
| FOIA-84-293 SECY-83-026, SECY-83-26, NUDOCS 8305120590 | |
| Download: ML20132B560 (21) | |
Text
..
e 9
I _
O, gA
..S'..
I
.'.9 1.
- e.e*
POL CY ISSUE 1-(Information)
=.. *....
-*. *." 4s I, S,.
.....,q,
.".,,....e
. ~...
..g.......,
...~ ~
..,..%s..,,...
e w
L',. c.z,..... e.
,q.
.C. *
"g o g,,..
s
.e..re.e..
g
- ~ ~
. e.... n. e.
.C...i e..
g w
IC.
48... C..
,.,e.e..e e.e s
.V.
, r.
y, y, e. n O
r..
...g..
..g e
-..g;.e
.s.
n..
w.
g s.4 e.
..,.g...
,,..,a
~~
- c. e..s.. c.
.r...
.t r.c.. j e.4. p g q c. c. o.
4 4. w... ;, e e...
c..
- e. g e. s 4.. i 7.
- y. *. *t g e. a. e. e..e e =. e a
.s,
,,, : e.....
o..
. q
. :.., e.
.-c r.
....: n
.s e. g i. m,. g. e. a. pe.s...
. c.
e.;
.s. w. 4. y. *. 4. c. e C e.
- e. r
- 3. '< t C**
- e o
C. ". *. b. 0. 7.. * : &,
H l,, g e... c.s e,
=
t 7
.s i. 4....,. '.' ;.........
. egg...
.f..
.r.....g...* g e.
ge.c.geng
..c-
,... d e l. f.. I.
- r. e, $...
4. e.
.. c.. t; :,.. :,
1.
.4 i..
.i w.
w.ww...
[..,
- 4. g *s g y g e.
- h. a.
g...c.
.s r,... c....;.c....
a
- a.:
- e..
s s
w. e s
v.
- e e.. e. E, - e d e...s, C *y *... S *. a **e e......s..
- 6../ y w;
.'
- I }
- r. e t. *. t..
- e. #. e. s. e. d.. s g.
et.re.
,a*--..
.,s. e..
6
. w.....
g.7..r.
. c.
..., r.e.
.c c... e..
- c.
., ew
- i. r.. * *.. n
- e. e.
(' t.. * 'e. *. *
- L.,
- t. ~.
.e t
w-4
=. e cy..ee
.k.g, w -..
....... c, g...
c r.pe.g.
.. g g e.
. c. - *
- e,e s. **'******* ~. ~ ~. ~. ~. ~.
t
...ie.
. -.e....e:
.eg
- s. e i g
e.,e
_. s
- . e e.
i e. ;.
..e.
4
....a.
e,.*. ',. e...
....,.e.
..e
.......e 4
'.., e ;. p.
.L,e..e..
ee
.e
=
k e
...........e..
%3451a@590 M 8%) kl.id
- el*
.e it' e
'- C:nnissi:n In iscussing these nea 01 :r:grart a r.: :: r.:c ;;t, ;; ;c to have a cc,tr n uncerstancing cf ha:
s tant ey
- a.
ante and the resp:nsibilities of the ':.: and N::
ice :.
s.
Quality assurance, as defined in A::er: s E :: '.: : :. 52, comprises all those plannec anc systematic a::i:r:
e:e::a,.
to provide adecuate c nficence tnat a stru::;re, s, e, c pcnent will perform satisfacterily in serv;;e.
Ease: :
- - " :;rg legislation and current NRC practice, '.:C ':cersees ha.e tre responsibility for the design, ccnstractic, anc c: era: en c' the nuclear power plant in a::cr:ince aith c::lica:1e starca and regulations.
The NRC has the res::nsi: 111:y :: ens re :r :
the licensee fulfills its resp:nsibilities te design ar.: ::n-struct a nuclear pcwer plant that can be c;erated in a narrer censistent with public safety.
The decisier whether a :erri:
or license may be issued and/or centinued rests with :ne N::.
e Discussicn:
This paper provides a status report en the staff's eff:-;s ::
study the concepts of an NRC certifica-icn prcgram a.c the role of the designated representative.
The tair. bccy ci tris paper briefly summari:es the s.aff's acticns and plans; the enclosures provide a more detailed discussicn c' tre issues a :
concerns encountered in exp'cring these new and ai e-na: se program ideas.
The third Commission request, to identify the curren: h:.C tcic points, was addressed by the Office of Policy Evaluatien (CFE';
in a memorandum to the Corr.ission dated hovember 15, 1952.
CFE ide'ntified four hold points which are currently erplcyed by the NRC:
(1) issuance lof a limited work authcrization (LWA), (2) issuance of a construction permit (CP), (3) issuance cf a icw-power operating license (CL), and (4) issuance of aLthori:ati:n for full-power operation.
The staff agrees :ht: CFE cer ectly characterized the existing held points.
Certificatien Prograr.
A certification progrem wecid rc:uire, ir ef fe::, w-i:.e cct-firmati:n by the NRC, licensee, er tott, cf the ca:etili:'
readiness and irplenentatice of cualt y assurance progrart at certain points during the censtructicn of a nuclear power : st:
as a prerequisite to proceeding with c:r.structien. Mes h::
programs are presently oriented to prcvide verification :'
licensee perferrance and te identi'y. res:1ved c- ::er :: --
and itens of n ncenpliance.
Assc a :e is ettaire: :. :
- t -
ine Ccnrissicn of significant issues in the area revie-ed.
The ce-::' cati:r program cencept under review
- uld re:uire in assess e.: rf e
existing and prospective capabilities arc readiress cf t:4 licensee to proceed.
The c:n=ept cf esaiuating :ne ca:atilit;.
and readiness of a licensee :: pr::eec cr c:.:ir;e activi:ies represents a significant expar.sicn in curre.: NRC pract ce.
The staff has considered two types cf NRC tertifica:icn ;regra s.
One approach would require a "forr.al" NRC review and certifi-cation at certain r.ajor milestenes in a plar.t's constructien.
All licensee activities would stcc at each r.ilestone.
No cen-struction activities could be continued or initiated until hRC certification to proceed is cbtained. This approach has two major drawbacks:
(1) it would prolong the constructicn :eriod between the issuance of the CP and OL and (2) the recuired hRC certification appears to be a " license" under the A:ministra:ive Proced.re Act which might require the hRC :: seek an arendment to the Atomic Energy'Act.
The seccnd apprca h would recuire reviews and certifications by both the licensee and the NRC.
This approach would consist of a system or hierarchy of centrol points which provide for statements by the licensee of readiness to initiate new activities at major milesteres in a plant's con-struction, for periodic reviews and certifications by the NRC cf licensee performance and readiness to proceed, and for certifi-cations by the licensee, NRC, or both, cf completed activities.
This approach does not have any built-in delays in the con-struction process and does not appear to require any amendments to the Atomic Energy Act.
The staff is in the process cf further st41ng this certification progra: concept.
A brief descripti:n of the three types of control points being considered is provided below:
a.
Evaluation of preparations for beginning a new activity.
This control point would be an evaluatien at cajer milestones in a plant's constructicn.
Eefere :r.e - ti-ation of new activities, the li:t see w:uic te re:;i ed ::
demonstrate that, based on past :erferrarte an: en ;*.e capabilities and readiness cf the licensee's staff anc programs, it is ready to initiate the new activity.
Ongoing activities would normally not be affected by tr.is control point. NRC review and acce:tance of the li:e.ste's report would be required.
This certr:1 :: int is refce e:
to as a
- hold ;cirt."
u
..h n
e ine Cc mssien b.
Evaluation of perfor.ance c,er a se: :erice :f :
control point would establish an ir.:egrate: e.alua- :-
(both retrospective and prospectise evaluatiers'; a : -:2 :
be conducted periodically (for exar:ie, an-aily like SALP).
NRC action may be taken if :ne reu ew ::e-: 'ie:
deficiencies. This control pein; is re#erret to as a
" review po%t."
c.
Evaluation and acceptance c' a ccmpleted activity, structure, system, or component.
This control peint, Of which therc would be many, would be a continual and ongoing evalmien process.
This effort would be basically en extensicn of inspection and observation of work activities, coupled wi:n a certif' cation of acceptance of the completed activity.
This control point is referred to as an "a:ce: ance ;;i,."
Detail on the basis, rationale, and implementation of each cf these points is identified in Enclosure 1 :: this paper.
The implementation of this system of control peints (hold points, review points, and acceptance points) between the issuance cf the CP and OL would reduce the time intervais between NRC evaluation of the adequacy and quality of plant construction and of the licensee's capability to proceed.
The shorter tire intervals for rwview should increase the likelihood of early detection of problems affecting the quality cf the constructior, i
as well as provide a stronger base from which the NRC can ensure j
that the plants are adequately built.
The staff is currently expanding these concepts of helc, review, l
and acceptance points into a more definiti<e program.
The impact on resources, both NRC and licensee, must be evaluated.
Possible allestones and frequencies for each of the control points must be identified and coordinated witn othar NRC Officas, especially ELD, NRR and the Regional Offices.
The program con-cept and ideas will be discussed with industry.
In develcpment of this issue, staff will examine the policy, practicality, and legal problems as well as the time frare required for implementation of these control points, identi-l fying those concepts that can be implemented in the short tern and those that may require an extended period of time (fer example, rule change). The staff plans te carry out the ab:ve activities over the next few months and re;cr: tack :: tr e Cor. nission by July 31, 1983.
Tr e C:.: :st':- Cesiccated Recresentative The concept of the des ignated represe a.3.e (::',, 3 3 that am;,loyed by the Feceral Aviatier A:--
s -a:it- ', r a ;
a quality assurance initiative tha: :ne ::af' r.as.een re<'ec ;
for a number of months.
The designated re: esenta:ne a: esalu-ated in this paper wculd be an indivic ai e ;1cyed cy a li:e see, architect / engineer ( A/E), applicant, :r c;her fir. ec w:uic te assigned by the NR. to perform certain s;ecified ac 'vities er behalf of the NRC.
The designated re;-esentative *:uld e;-M -:
an extension of the NFC inspection progran and would carry cut activities that are clearly delineated and that w uld be evalua:cc against specific criteria.
As described in more detail in Enclosure 2, the e a e sis ifica-:
di.~ferences between the FAA and NRC.
Both agencies re;u'aie a private industry, but the FAA regulates an industr.y t*.at re:.1-cates many 'similar finished products.
The CR evaluates and certifies, for. the FAA, completed activities at certain poi.:s in the production process.
The NRC regulatien of nuclear ec.c-plant construction, while having many internediate r.ilesteres, involves the production of one unique product by each utility.
The NRC certification of this product may be consicered to be the OL, compared to the FAA certification of the airworthiness of each airplane produced.
To make the FAA/NRC analogy nere exact, the NRC would have to expand its certification activities to include, for example, the concept of acceptance points (dis-cussed above) which basically would then create a role for tr.e DR in the NRC program.
In this capacity, the OR would act fer the NRC in evaluating and certifying ccmpleted activities.
The DR would represent an extension of rescurces availatie to tre V:
to carry out inspection activities.
An additional point to consider is the long lead tir.e rectree to implement a DR program. The staff estimates that at lu st three years would be required to rake the recetsary cha ;cs to the Atomic Energy Act and the NRC regulations, ceveic; e : R certification program, and select ano certify the designa:ec representatives. Given the current balance of nuclear plaris under construction and anticipated completien dates, this program implementation may not be a near-tern practical re e:s to prevent deficiencies in the quality cf c nstruction sa M
experienced recently in some facilities.
t e ~ rissi:e Future Plans The staff 'lans to Cor;'ete its er.a'.y5 5.:# :*e :: :e;;
developing a certifica icn pr gra e :i:y: ; ce: : -:ec pcints, review points, a-d a::e: ance :: int:; :: -Prat:
e program with cther NRC Offices; ct:ain 1.:. : y c:- e-: ; : -
report back to the Cenmissicn by July 31, 1:-53.
.e st.:. :'
the role of the designated representau.e ir tre !.:' Or:;ra-is closely linked with the devei:; ent :f ite atte::ar.ce ::'r-concept in the certification program.
Sonry of the ideas anc concepts identified in the stu:ies :ar.
possibly be implemented more in the near term than te inree-year lead tire noted for the DR program.
Hold ::ints c:ule te implemented by adding or revising concitiers cf a ::r.stru::::r e
permit or amending the regulaticns.
Review peints ces'.c be implemented by revising existing NRC programs ar.c revites ','C-example, SALP).
The staff's assessment of the t're ;e-i:d required to implement these concepts will te ir.clude: ir the July 1983 report.
The studies of a certification pregram and a desigr.ated repre-sentative program are initially focused on the ccnstructicn phase of a nuclear power plant.
The staff recognizes that :nese-concepts may also have applicability to the operations pnase :f nuclear power plants and the staff plans to pursue this issue upon completion of its review of the construction phase.
N te that the quality assurance issues discussed in this caper are closely related to the issues identified in the 19E2/15E3 HEC Authorization Act (Ford Amendment).
It is the staff's ir. ten:icn to coordinate this review with the quality assurar:e studies required by Congress.
\\
Willian. Ci-.ks Executive Dire : r for Operations Encicsures:
1.
Certification Fregram 2.
Designated Represer.tative Fregram
9 E :1 CERTIFIC*-*CN FROG m Bacu;round During the Septenber ~29, 1982 briefing cn SECY-E:-352, "*ssurance of Quality."
Cor:nissioner Gilinsky requested that the staff pursue :he idea cf a prograt requiring NRC certification of licensee quality assurance (CA) programs as a prerequisite for going beyond certain hold points.
He also requested at this briefing that the staff determine NRC's current requirements for certifyirg the implementation of a licensee's QA program during certain stages of constructi:n.
Earlier in July)1982, Comissioner Gilinsky requested the Office of Felicy and Evaluation (OPE to identify the steps in power reactor cerstructicn and ir'tial testing where NRC control points cc0ld usefully be established.
In response to Commissioner G'ilinsky's request, OPE prepared a re;crt entitle:,
[
" Regulatory Review and Associated Hold Points During Nuclear Pcwer Plant Ccn-struction and Testing," dated November 15, 1982, wnich the staff has used in examining the concept of establishing a system for certification of a licenses s implementation of the QA program.
There are four formal NRC held f.
peints currently associated with the construction and operation of a nuclear
. power plant which evaleste the licensee's programs, capabilities and comit-(1) the issuance of a meats related to nuclear. safety}, These hold points are:(2) the issuance of a constru g
Ilmited work notherisation (um r
[
(CP). (3) the issuance of an operating license (OL) for fuel loading and low-power testing, and (4) the avtnerization for full-power operation. A prospectise assessment of a licensee's capabilities and readiness to proceed with cen-E struction activities is characteristic of NRC evaluations for issuing of the LHA and CF. A retrospective assessment of the licensee's perferr.ance during construction and testing forms, in part, the basis for issuing of the OL.
Ir this paper the term " licensee" is used in an all inclusive sense to include applicants for an 1.WA, CP holders, and holders of an OL.
Between the CP an_d OL issuances, the JEC reutinely cer. ducts tao types cf eul -
ations - the Systernatic Assessment of Licensee Performance (SALP) and the
- S4300" evaluation (nared after the IE inspection precedure).
These evalu-ations provide input to the licensing decision-r.aking process.
The SALP is a-annual evaluation conducted by the Regicnal Offices for ruclear power clar:
sites, under construction or operating.
The SALP prograr retrospecthely evaluates the licensee's overall performance up to the tire cf t'e evahae r A retrospective focus is also characteristic of the 9*200 euiaat ;n.
Tre
~-
~..
. 2n:l u.
ceci-na' 94300 evaluation results are transmitted in a memoran um frem :.e Adrinistrator to the Director of NRR fellowing prec:eratic al testirg :f ce plant and prior to NRC authorization to load fuel and ccn:uct icw-;
e- :et".
TFe memorandum compiles and sum.arizes the results of the routine ins:ect::-
program and provides a status on the implerentatier cf tre licersee's CA This memorandum identifies each cpen iten, witn status of -etel.:':n pregram.
and significance, status of the inspection program, status cf the liccmee's testing and systems acceptance programs, and the ccnditices to be ir.;csed :n the licensee.
The memorandum is updated monthly until fuel leading.
In examining the certification program, the staff considered that the 9*300 memorandum represents, in effect, a " certification" by the Regicnal Admini-strator of the status of a licensee's QA program implementation and perferr.ance.
A third evaluation, the Near-Term Operating License (NTOL) evaluation, has recently been implemented as an interim measure to assist the licensing review effort in compiling and evaluating licensee performance in preparation for issuance cf the low-power operating license.
The NTOL evaluaticn is c:nducted only ente and that occurs toward the end of construction and preeperaticnal testing.
There is a long interval between the issuance of the CP and the icw-;cwer C.
in some cases as loeg as 10-12 years.
Although many inspections of parti:f 3-technical areas and SALP evaluations occur during this time period and re:.i:
i-sumery reports of specific findings, before 1982 there were no cocumentec
" integrated" evaluations perfomed.
Integrated evaluations include a ret-:-
spective assessment of the licensee's performance to date and a prospective f
assessment of the licensee's capability and readiness to proceed to subsecuent i
l stages of construstlen.and.
ting. Recently, the staff initiated Constructicn AppraisalTeam(C&T)andIn rated Design Assessment Team evaluatiens which includebotharetre$pectiv(andprospectiveassessmentcflicenseeprocrams.
However, these evelsations are just beginning, still being tested, and with tre limited NRC resources available to carry out these reviews, have limited ap;1i-It shculd cability to the total number of sites presently under construction.
be emphasized that it is only at the time of the evalustiens associated witn t issuance that the current NRC programs approximate the performance cf an integrated evaluation.
The choice of appropriate control points or milestones is an im?crtart eieren in considering if and when additional integrated evaluaticns are appre;riate.
Additional evaluations might be considered when, (1) ccnstruction has pr:gre:s :
sufficiently to provide meaningful assessments of elements critical to ccc-struction quality, but when construction is still at a point where necessary corrective action may reasonably be undertaken, and (2) when a signifient transition occurs in the mix of activities, skills, and recuirerents aste: at :
with further construction and testing.
~
. Encicsure '.
During the review cf the current NRC practices with regard te heid/ cent ci points, of certification of a licensee's implemertien of CA pr: grams anc f CPE's analysis, the staff recognized seseral problems which are discussed below.
Current practices - problem Areas The current NRC licensing system includes four formal regulate y hcid peints (LWA, CP issuance, low-power OL, and full-power authori:atien) which provide fcr fornal NRC certification of licensee programs (including CA programs).
The complexity and extent of problems that have been identified in the past few years at units now under construction have raised questions about the quality cf the design and construction of certain nuclear projects and the effectiveness cf NRC's reviews and inspection and enforcement programs.
e A recent analysis of the experience at problem sites resulted in the identifi-cat'on of three primary problem areas:
(1) failure of the project management team to provide adequate management' controls to prevent a significant breakdewn s
la quality from occurring; (Z) failure of the ov:ner's quality assurance progra-to detect the breakdown in a timely manner and to obtain the appropriate cer-rective action; and (3) failure of the NRC's programs to recognize the true extent and nature of the problems in order to take appropriate enforcement action.
~
The first two problem areas have been attributed to a lack cf total owner t
management comnitment to quality at the inception of nuclear projects together with a lack of understanding of the role of quality assarance in project
[
management and what is required by personnel at all levels of the project.
j The l
I
() blems. initiatives proposed in SECY-82-352 are geared toward alleviating these l
i pro The third probles has been attributed to shortcomings cf NRC's programs in not sufficiently examining project management centrols at sites uncer censtructicn and not addressing delign quality as specifically and extensively as cther areas. While NAC performs numerous inspections tec-d establishing adecuacy t;ithin major technical and functional areas (e.g., concrete, electrical, welding), and several evaluations during nuclear power plant cesign, con-stru" tion, and testing, there are no docur.ented evaluations criented toward prospectively assessing that the licensee has the capabilities to continue wit ~.
activities.
It can be argued that the NRC framework of regulatcry centeel ;oints, cen-sidered together with evaluations and the inspecticn program s adec.attiy designed to provice for assessments at a sufficient neer cf stra:egic icca:ic :
that support the primary NRC missien of ensuring that nuclea* ;cwer plants a".
E :'
c-c :- : c re3.-
desig.ed, ccnstructed, and cperated in a manner ccre n e-:::a:;::ry autt- '. :-
Furthernere, NRC has sufficie-:
safety of tha public.
take appropriate action at any time that licersee CA :eri: ~a :e anc :
2:d:
It can aise be arguec :,3: r e ' a ew:r, :e:~
are assessed as inadequate.
nas not been suf ficient to prevent cuality assura :e :-:cle s ' : c:: - - :
~
anc per:isting over icng periods of time befc-e ef fectise ccr e:r,e 2:::c-taken.
The actions initiated by SECY-82-352 have accressec :he ;ercer.ec problems, however, there is no specific acticn to assess orcs;ect vely :.e ce;atilitias i
The ccnce;t cf a :e-ti-of a licensee to proceed with specific activities.
fication program is being evaluated as a means to previde ;rcspective assessments of a licensee's capability and readiness to proceed with scecif :
The concepts and ideas for a certification prcgra are accressec activities.
in the section below.
Certification program Most NRC programs are criented to provide verification cf li:ensee ;e-fc 2 :e T'.e ::r:e::
and to identify unresolved or cpen items and items of ncnccrpliante.
which Co:n.issioner Gilinsky asked the staff to explore and tne programa:ic ideas and concepts addressed in the discussion below recresent a significar.
The idea of prospective evaluations concer.-
change in current NRC practice.
trates on NRC assessment of a licensee's capabilities and requires either an explicit (formal or written) or implicit (lack of objectien) acceptar:e ;y the NRC.
The staff has exp1cred various methods of combining a certificatien ;rc;-am with present NRC practices to increase confidence in the quality of constructicn cf
- er: -
One approach would require a " formal" hRC review a-:
nuclear power plants.
All licensee fication at certain major milestones in a plant's construction.No construction activitie activities would stop at each milestone.
Tr s continued or initiated until NRC certification to proceed is cbtainec.(1) it approach has two nasjer drawbacks:between the issuance of the CP and
)
- c':
appears to be a " license" under the Acministrative 'rececure Tre w::n.:
require the NRC to seek an amendment to the Ate-ic Energy *:t.
a.d approach would require reviews and certificaticr.s ty Octh ine which provide for statements by the licensee of readiress t c.
NRC.
and certifications by the NRC of licensee perfc - arce anc reaciress :
and for certifications by the licensee, NRC, cr t:tn :f :: : sted a
tre :::
- E This appr:ach does not appear to recuire any are c e-:s ::
Act, and its resources and delays impacts ascear tc te 'e5 e : -:e s: e fc -.al certificaticn precess.
The development cf tris c:m e:1 ::
- s v :.-
., O 3-d th
. cely at an early stage; the concept will be purst.ed w'-*
F.e;icral Offices in evaluating its practicality, usefu ess, arc 'e;3:
3-ficatiens.
The staff is presently studying a certification :regra
- c :r:stce ':r the following:
a.
Evaluation of preparations for beginning a nea a:tiv;;y. This c:nt point would establish an evaluation at major milestcnes in a ;iant'e construction.
Before the initiation of new activities, the licensee would be required to demonstrate that, based on past perfer:.ance and on the capabilities and readiness of the licensee's staff and pregra s, it is ready to initiate the new activity.
NRC review arc a::e;:ance e
of the licensee's report would be required.
This centeel ;cint is referred to as a " hold point."
b.
Evaluation of performance over a set period cf time.
Inis centrei and prospective evaluations) grated evaluatien (beth re:res:e:tive point would establish an inte and would be conducted periccically (fer example, annually).
HC action may be taken if the evaluatien identifiec deficiencies.
This control point is referred te as a " review peint.
~
c.
Evaluation and acceptance of a completed activity, struc:cre, sys:e,
or component. This control point, of which there wcuid be many, would provide a continual and ongoing evaluatien precess. This effort would be basically an extension of inspecticn and cbsematicn of work activities, coupled with a certification of a:ce;;ance cf t*e completed activity. This control point is referred :: at e "ac;epta-n point."
The three sections that follow provide a detailed discussien en ea:n cf t*e three control points identified above.
Mc1d Points Current MC regu14tiens provide fer fcur hcid poir.ts during ar':h an evalt.a:ic-is rade cf a licensee's programs, capabilities and cer-itr.cets ri.la:ed to nuclear safety and QA compliance.
The issuance of a pe rit er lir.erse by ve MC can be considered as a fem of certificatien.
Certificati:n *:y the lice en the other hand has only recently been requested ir c:r e:t :
- itt tre '.".
pr: gram, whereby the licensee certifies that the facili:2 tei tes-ec 11.::e:
6-f*:ict.re 1 in a:c:rcance with FSAR ccc:.itments.
As -as discusse: ca- ' e, :~e esis:
and O' held points are ::o far a: art in ti e c ;resice ; --:y at.rance c' c:r.:ir.ueus quality construction of the nuclear p: e :' ant.
Ir.:re: :ing additienal hold peints of the CF cr 0; tj:e a :es se.e-a
- -2::i:a' c.ffic ities with regard to both statu:Ory re:uirerents ae: r:ie e ta;;;r.
The e::ncmic impact of a hold point and the cesis :: tr e ' i ce-t ee are tr.e '.:'
east be c:nsidered in detern:ining if and wren h01d p tr.:s ay be 3;;repriate.
The hcid points sheuld be selected 50 that the r.ea *:Id ;;irts :: n:t cause a unwarranted delays in the plant construction.
S.c ::r:er; c' tre :ertificati--
pregram is being studied and considered as a resu't Of the 'crg tire peried between CP and OL issuance.
Also, as OPE points out i. its report, it may be difficult :: justify i 2: sir; hcid p:ints in every case, in advance of evidence of s:ecific ;1 art irate:n: et, "cr impcsing acditional holds on further plant ccnstructicn aad testia; :: aa:
the cutcore of the reviews.
However, the primary concern in ide tifyia; psssible new hold points would be, of course, to increase the cerfider.:e ir the quality of the ruclear power plant being ccnstructed.
The concept of hold points would apply to both prespectise and rett:s:e: ise evaluation - an assessment of demonstrated performance as well as an assessr.e.:
Gf the capabilities and readiness of the licensee to proceed.
The hold peintt
,betmeen the issuance of the CP and OL, presently being <ensidered, would te Gstablished at certain major milestones in a plant's censt uction. At or before each hold point, the licensee would be required to den:nstrate that, based on past perforinance and the capabilities and readiness of the licensee's staff and programs, it is ready to proceed to the next hold point. The present concept for implementing of the hold points is that engoing cor.struction activities would continue at the held Joint, but that the new c:nstructien I
activities planned for initiation at tiat construction milestene wculd nct te initiated watil the MC has reviewed and accepted the licensee's report.
It is assumed that the licensee's report would be submittee in ecsance cf tre planced date for initiating the activity, so that delays in planne: activi-I ties -culd be trinimized in implementing the hold point.
P :r:an A raj:r scal in developing the c:ncept cf held Scir s ir Pe ::q:
.,c would be to gain prospective assurance cf licensee c:r;iian:e 'n tre ir;le-rectatice of the QA prcgram in the period between the CF ard tre OL.
Hol d peints cculd be established whenever a corstructicn milestene ds identified unich requires the initiation of a new major activity such as irstellatten O' electrical cable, pcuring of concrete, and installation f :r ary picir;.
. E:
Ho',e p:ints c:uld also be establisned when there is a +. c- :ra-ce in nc
- s
,f CA personnel or a major change in QA organizatien a :
3 rage eat.
Tre felic.ing nine hold points, of which fcur are already established, a e presently being censidered and under review:
(1) the Le,- (2) tne CP,*
(3) the start of concrete and steel construction, (4) tre start of instd-lation of electrical cable, (5) the start of the instal'.aticn cf tne prir.ary coolant pressure boundary,)such as pressure ',essels and pi;ing, (6) ::efere
- reeperational testing, (7 before initiation of hot fact nal testin
- ,
(S) before fuel loading at the issuance of the low-pc-er CL,' anc (g) at the issuance of the full-power authorization.*
The new hold points, numbers (3) to (7), have been icentified at this point merely as candidates for hold points. With the develcpment of the concept of hold points, these and/or other hold points may be determined to be appro-priate candidates.
, Implacentatien of the hold point concept will be pursued with IE, hER, the Ragional Offices, and El.0 in evaluating the practicality of the varicus nilestones considered.
It may be a relatively simple procedure to acd hold pcints (2) to (7) to the CP in the fem of conditions of the censtruction
~
permit or a more time-consuming rule change to NRC regulations may be required.
Additionally, major effort will be required to identify the details of what ccnstitutes acceptance and what criteria are to be evaluated at each hold point.
The following are examples of current practices which include a form cf c;rtification and, to sese extent, represent current application of so e Cf the concepts envisioned for hold points. One example cf a current practice which resembles the held point concept is the review of CA implementaticn in the Licensee Centractor and Vendor Inspection program.
Region IV inspects the implementation of SA p/t) grams of nuclear steam supply system designers ro and architect / engineer (A firms which have been submitted to and approved by WRR in the form of Topical Reports or Standardized Programs. Up:n ecmple-tien of inspections confirming satisfactory implementation of 0A pregrams, NRC issues a confirmatory letter to the nuclear steam system supplier er A/E fim which indicates the NRC satisfaction with the implerentatien cf the 3 program.
'Incicates current MC regulatory hold peint.
l
-E-E : '. n. n The 'JC c:nfir at:ry letter also states:
Continuing acceptability cf : cle entatien cf y:ur O*s pec;m-I is contingent upon your maintaining a satisfac cry level o' program implementation, certified through periccic NRC inspection, throughout all corporate crgani:atien units and p
nucletr projects encompassed by your prograr.
Should ycur program implementation at any tire be fcur.d unacce; table ycu will be notified by letter and requested te cor-ect the deficiencies promptly.
In the event ycu fail te c:rrect
... the applicant and licensee... will te ret *fied that the generic implementation of your program is nc 1crger ecceptable to the NRC.
This paragraph in the confirmatory letter addresses, in part, a pres;ective evaluatien of the vendor's QA program.
Another examp1e of current practice is the ASME-administered certification cf manufacturers of pressure boundary components (pressure vessels, pipes, valves, pumps, etc.) via the ASME/NS accreditation (N-stamp) program.
It differs fr:-
the vendor inspection program in that a third party ASME, provides the certi-fication that the vendor's QA program requirements are met.
This process cf accrdditation of vendor capability is accepted worldwide, and allows the h:C.
as well as licensees to devote limited inspection effort to these areas.
The ASE program illustrates the possibility of using a qualified third party fer the evaluations and certifications associated with a new hold point system.
The United Kingdes (UK) practice employs three types of hold points that are controlled by the Nuclear Installation Inspectorate (NII) which regulates construction and commissioning of nuclear power plants.
The construction e
permit includes Ifeenge conditions that provide for three types of direct actions by te Ell.
Inese actions are:
(1) the requirer'ent for a " Consent,"
which essentially prevents the licensee from carrying o.:t a specific operatien on the siM unless the 911 agreest (2) the " Approval" procedure, which requires the licensee to ish its procedure for carrying cut a specific activity to P
h!! for' al plicable to all prospective QA requirements and testing arra s):
- 3) ' Direction" (used rather infrequently), which directs the 1 sensge to carry est an operation the NII considers essential in tre interest er safety.
The implementation of these hold coirts depends en very capable resident inspectors (and their staffs) and on the full cooperation of the licensee.
I
. En: :s.re '.
The examples of hold points, briefly distassed so f ar, c;'f ee in par frr the present practice of NRC's construction inspection program. The ; resent irsce::icn program focuses on review of quality assurance procecures and reccrds, cire:
cbservation of work in progress, and completed werk for the parecse c' assuring ccm;1iance with regulatory requirements.
Assurance is obtairec ey ne absen:e of significant noncompliance in the area inspected.
In centras; to this prcgram, this discussion of hold points focuses on review basec en perfor ance and a prospective review of the capability and readiness of the licensee; in other words, on management's cormitment to the establishment cf an ef fective i
organization rtaffed 'with qualified manpewer, supported by acprocriate equipre-and detailed procedures.
i As a result of the recent difficulties experienced at some construction sites it should be clear to the industry that it would be in their best interest to have a viable, effective, and responsive QA organization at all ticses.
INp0's self-
' evaluation program is moving in this direction.
New NRC ecuirements for 'cid points, as suggested above, could be promulgated by rule change or centained in certain conditions of the Cp and wo0ld provide the incentive to the licensee to catablish a viable, effectivt and responsive QA organizatien.
A deficiency I
finding at any of the newly considered hold points between the Cp and the OL would not necessarily stop the ongoing construction, but would primarily affect the initiation of a new construction phase.
It may be in the best interest of the licensee to ensure that this new phase in the construction program will meet
, the futC requirements for 0A compliance before initiating the activity.
l Review Points Fcr the purpose of this paper, review points refer to the milestones selected for the conduct of an in rated and documented review by the NRC to retro-spectively dssess the trated implementation of the CA progrars since the last review point, and to postively appraise the capability of the licensee and the licensee's sont '
to continue. Review points contrast with hold points in that the review $31st is a periodic review (perhaps annt. ally) while the hold point is an evaluation and decision point that occurs enly at designatec Gilestones in a plant's construction.
The frequency of review points could be on an annual basis, like the annual SALP evaluations, or the review points could be tied to th'e percent ccepletion of construction. A disadvantage of selecting review points on the basis of percent cc pletien is that the elapsed time between review points may vary significantly.
. E r : '. c :. - <.
I ce:encing en the licea.sce's c:nnitrent (cr lack tre-e
.: es:ecita :: 5 In such a :ase, the review points may be too frec.ent :- ::: f ar :: t rt :: :e.c a
eani gful purpose.
- r. ra y respects, the SALP program has sir.ilar etjecti.es i: 19:se
- e-:
'e:
fc-eeview points.
SALP program cbjectives (referente NF.C ar.ai D e::c- :516) are as follows:
Identification of unacceptable licensee pe-f:r am:e; Improvenent of licensee perfernance; Improvement of NRC inspection program; Rationale for NRC's allocation of manpower; Achieving regional consistency frem a natienal perspecti'.e.
5 The SALP assessment is intended to be sufficiently diagncstic te p :vice a rational basis for allocating NRC resources and to prcvide ree. ring'd gecan:e to licensee managenent.
SALP does not apply to QA alone but attempts to assess the overall perferra ;e of the licensee on an annual basis.
The SALP program as presently structured is primarily a retrospective evaluation.
SALP has no prospective c:npenent fer QA.
The staff is pursuing the idea of expanding the scope of the SALP pregram to include a prospective review of the licensee's cacability and readiness su:k l
that an expanded SALP, program could serve as the review peint being considerec in this study.
Acceotance Points For the purpose of this paper the term acceptance point incorporates retre-i spective verification that a certain activity, structure, system, ce ccrpenert has been completed in accordance with applicable QA prcgran recairerents.
In practice, acceptance points would be comparable to present quality contrcl activities.
Acceptance of a product or process by a licensee's inspecte-car te viewed as a form of certification.
For example, typical acceptance peints r>y include a check on rebars and forms before pouring cencrete, the ir.stallat':-
of a piece of equipment that had to be qualified under scecified condit cu, :*
a modification of a pipe-run that required approva; by design review.
It
'.s generally recognized that for any continuing process, like the constructicn cf a nuclear power plant, quality engineering selects many such acceptance pcirti, often running into the thousands, to assure that the finished product reets all the requirements. The focus of evaluation at these peirts is retres;ectise -:
is on quality control activities rather than en cuality assuraece per :(,
- En:'.:s
-o The reason for considering the concept c' acceptance ;cir.ts.s tc : n :e increasec confidence in the quality of ccnstruction.
Many activities, fc-exar;le, the placenent of reinforcing tar, have a very smail winccw for tne ep;crtunity to verify correct placement.
The licensee is ex:ected to have available a sufficient number of qualified Q: persenrei to sign off :n the r,any acceptance points during the progress of construction anc testing.
- t is net possible for the NRC to match this organization at ary cne site, and even less so on every construction site.
As a result, NRC's present practice of con-s%ruction inspection,.can only hcpe to audit a judicicus sar:le cf the many acceptances, ft is because of the magnitude of the inspection task that the cencept of a designated representative, as employed by the Federal Aviation Administratien (FAA), has attracted the staff's attention. Enclosure 2 of this Cc nission paper addresses this concept in greater detail, especially as it applies to verification and certification of acceptance points.
If the staff mere to restrict the study of acceptance points to quality assurance activities, rather than to the much more numerous quality control a:tisities, it would be ncre
. difficult to employ designated representatives.
The reascn is that a DR woulc not be expected to enke subjective determinations as would Le required for CA activities, but merely be expected to verify and certify the acceptatility of activities or products to specific criteria.
9 F
l
- ES
- 2. ATE? ~ i.M i;~ '.T :. E ' : -
E3:n;-cund y
T e ~ederal Aviaticn Adninistratier (FAA) utili:es a :.stc
- f :e. ; :.c:
representatives (DR) to act for the FAA in the exar"a: :. :n::c:
- n r testing necessary for the issuance of aircraft cer:1'i:a:e: ty : e ::-
d.
strator.
Nominees reeting the requirererts for a::: arer: tre n.P :rt:ec :
represent the FAA in determining the ::nsliance f air: a't, ai-: aft c: -
ponents and their repair or alteraticts with the recairererts c' tre FAA's regulations.
The OR serves as a direct agent of the FAA in the :e ferm :c :-
certification duties and is guided by the same quality assurance re:uirt e is, instructions, procedures, and interpretations as FAA enpleyees in tu :e -
f ermance of their certification duties.
During the tire the OR :e ': - s certification duties for the FAA, salary and empicynent berefits c:et'r.e :: :-
provided by the representative's full-tine employer.
The FM does not maintain an engineering staff in sufficient e. :e-s :: re.u-all the details associated with the design of an aircraft.
Hewever, tre agte.:
rest be certain that each design for a new aircraf t reets all tre regulatcry requirements.
To meet this connitrent the FM depends en the rescurces pr:.'ced by aircraft company employees called Designated Engineering Representatives (DERs) who review engineering reports, drawings, anc data to ensure c:r:11ance with all aspects of tt'e regulations on behalf of the FAA.
During the cesign of an aircraft, the DER acting for the FM wil) certify design cen;11ance with the FAA's regulations.
The DERs are usually senior engineers, employed by the t'nufacturer, who possess detailed knowledge of the design, based en a daily involvement that is not practical for FM persennel to achieve.
Once the FAA awards a Production Certificate for an aircraf t, government cser-sight of production is maintained by a system that couples cirect FAA revien ey assigned inspectors with the work delegated to Designated Marufa:turing Int:e:t-Representatives (DMIRs).
The DMIRs certify, en betalf of the FAA, that air:"'-
r And/or components are manufactured consistent with tre a;;reved design a :
specificatiens.
Upon final inspectice, Ain crth % ts Certtficates are issued for each aircraft and can be issued under auth: ity cele;auc :: t*e DMIRs.
DMIRs are individuals who have many years cf er:erierce in raruf a::ar -
spe:ial processes aa.d inspection and have been fourc te te cualified by :Pc FAA.
The certification process e":plcyed by tre FAA utet a seriet c' r *d ::i t!.
The design er.d r.anufacturing pr:: esses pr:teec to S:e: 4f w: *: : :: : rt the revie ard acceptance determinatices are rade :y t e ~11 'r :en' ':"
t
. D; prc:ess to continue.
During the past few ce: aces, as ne.. wen inc;s increased in size and technical Complexity, large Partene* ce vts were
'ne; on the FAA to provide more inspectors to reet the increased irtre:tice :( r ;
P i" :e: cr au '
'e D21ays in the manufacturing process caused by nct ha m ; :
when needed are expensive to the manufacturer.
I ;1e enta:icn :f the CR prcgram provided the FAA with an immediate increase in the curter cf qual fiec I
inspectors.
The aviation industry readily accepted the DR ::regram sin:e it as financially beneficial to the indu< try to have availacle a cualified pers:. h:
could represent the FAA when needed.
The FAA's CR p-cgram cent.nues to be an indispensable technique in assuring that aircraf t are desi;*ec and manufacture:
in accordance with the rules and standard: set forth in f A. regulations.
A recent study by the National Academy of Sciences, entitled "Ir. proving 1.ircra't Safety. FAA Certification of Coninercial Passenger Aircraft" (Washington, D.C.
1980), investigated the DR program employed by the FAA.
The study concluded that, given the thousands of drawings, calculations, reports anc tests that tre FAA must be certain meet applicable requirements, the designated representati e program which augments the capability of the FAA to rev.iew and certify the aircraft design and production, is not only appropriate but indispensatie.
The National Academy of Sciences study also found that the designated re;re-sentative position is a sought-after assignment. The DRs generally hold key technical or supervisory positions in private fires and typically have H-20 l
years experience. The study observed that the individual appointments esident y contributed to a high degree of dedication and motivation in the indivicual's perfonmance. This motivation is apparently based on a number of factors including peer recognition in being selected, special salary s: ale, an.1 tetter promotion potential.
One negative aspect of the DR program is the questien or centern that can t'e raised that the licensee's employees are regulating the licensee - a "fcx guarci ;
the chicken coop" perception. Close scrutiny and audit cf the prcgram a*d OR personnel would be required to ensure that this fern of sel' rt;J aticn *: is.
NRC Proerams In early 1982, IE staff met with representatives cf m m maarters (La'* *rr. -
- :iscuss t*.c ::J D.C.) and FAA New England Regional Office (Burlingte, v.t.;
OR program and to see how a DR progran cencept ceuld te a;;; c : 'R: ac
.1; t -
l Visits were also made to two private fires which are regiate.c ty the FA* a-d empicy Designated Manufacturing Inspection Representatives, I
l l
The general guidelines and qualifications for a DR to be used by the 'J:
- .1 c be similar to those presently used by the FAA.
A p e D - a y listing :f guidelines and qualificatiens is given telow:
i Gi'.[RAL GUIDLL hES TO
'J -
- A 1.
Cualifications, hR; would esta::'. ith taa r. -
/ i for eacn tecnnical area.
The licensee er.c, c-I list of personnel meeting NRC's require en -
.ree.
ould select personnel from tr.at list.
I 2.
- ere of Duty.
NRC would issue a;;atntrert! *:-.- :-..:
.t u M o ts'-
5atisf actory performance and :entinued r+e 1 in NRC renewal of the appointments in o par tr.crem ::.
O tat factory perforraance or personal request by the 3 wes*c re' alt ir temination of the appointment at any time.
3.
Supervision.
The Senior Resident Inspector (!* ',..:01c
- e.'.
DR when the DR is carrying out hRC responsittlitu::.
It ".
'd :
e the DR would spend a fraction of his/her tire carrrte; N In the absence of the $R!, the OR would be supervite
!..- **e
'i.t; Regional Section Chief.
4 Training.
Before performing any work as a DR for tte 'J
, tu :P receive a specified amount of training.
The traintr.g e. q crie r.te: a r;-
each DR would be standardized.
6.
Salary.
For the period of time the OR is performir.g in etsigree en,acit.
My and benefits would be continued by the OR's full time empleye r.
Overtime and holiday my would also be the 5are as t irulated by tN-working agreement witi the full time empicyer.
A spe:ial talary scale (for esemple, an additional 5 percent salary increase) rey :,-
d' appropriate in recognition of the importance cf the OR r:st'.*cn the licenste's staff.
6.
Rosortine ind Decision 4kinc.
Results cf trspectier i ' ': t t a, :t g,ven to tie al for int' ulton in SRI insper t.r re;:'ts, by nen ccrapliance would be reported to the SP! fer r:m ' & > ti;-
not the intent of this program to put tre M tr atitrii.-
(*
c-i.:
1.*,
"e with the full time e*picyer, but rather to eih-t'a cbjective rest,1ts cf the CP's ti;ertise.
)
l
. E ::::a..
- :'e e tatien of a CR pr:;ra w:uld recuire an aren: e t
- ne 4 -i E t re.
- c: revisiens to the NRC regulatices.
The le;al rar.;f *: :i: s of ite ::.
- -:;-r are prese-tly being studied.
The staff cor.serva hely est ates :
1.
recuire a minimum of three years to develop anc wr'te the recessar.
'e; 5:etive changes, submit the changes for congressicna' a;;r val. -rite 3r.c iss.e the new regulations, and select and train eersennel :: cerf er. as de,1;-
2:!d representives.
'a'ithin that tir.e frame, m::: plants currectly uncer
- r: ru:ti:n. al: have received an cperating li:ea.te.
Itts 1:rg tir.e peri:e te de:iement the pr: gram will negate its use fer *ese pla,nts unce-censtrue:m,
tu the pr:gra c:uld be applicable te future plants and pessibly :: ccerating plants.
- ce:ta-ce Feiats and Designated Reoresentative
'E %'esure 1 ciscusses the cencept of establishing certain acce;tance points during the ccr.struction phase of nuclear pc.cr plants as a reans cf ir:reasia;
'.:,C's confidence in the quality of construction, if tre NP: we e :: serify at:
cer:ify ac:eptance poi-ts, a large increase in resources w:ule te e:;uirec Delays in providing an NRC inspector to verify the acceptance ;otnts c:uld ec i
c:stly to the licensee.
Implementation of a program utilizing f RC's cesig. ate:
i re;rtsentatives could provide the required NRC verificaticn of acce:tance peirts withcut a major increase in present NRC staffing levels.
Since t*e :R
, :ald verify and certify acceptance points for both the NRC ar.d :Fe licerste at tr.e specific tire an activity has been ecmpleted, delays in tre licensee's prc:ess should be minimized assuming the specific activity has teen cor-rectly ccepleted.
,.. _ _ _, _ _,, _ _.,. - -. ~ ~. - _.
..,-.-,,v.-__-m