ML20134A530
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SLIDES FOR COMMISSI0t; BRIEFIfiG
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Ot; QUALITY ASSURAfiCE ItGTIATIVES SEPTEMSER 29, 1982 8508150335 850703 E GH 08 -293 PDR FotA 293 E--- --
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ANALYSIS OF THE EXPERIE!!CE AT PROBLEM SITES HAS FESULTED Ili THE CLASSIFICATION 7
0F THREE PRIMARY PROBLEM AREAS:
FAILURE OF THE OWNER'S PROJECT ltANAGEMENT TEAM TO PROVICE ADEQUATE MANAGEME!;T CONTROLS TO PREVENT A SIGNIFICM 7 EREAKDOW:: It. QUALITY FROM OCCURRING; l
FAILURE OF THE OWNER'S QUALITY ASStsANCE PROGRAM TO DETECT THE EREAKDOWN IN A TIMELY MANf;ER AND TO OSTAIN APPROFF.IATE CORRECTIVE ACTION; FAILURE OF THE NRC'S PROGRAMS TO RECOGNIZE THE EXTENT AND NATURE f
GF THE BREAKDOWNS.
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TFE FIRST TWO PROBLEM AREAS ARE FUNDAMENTALLY DERIVED FROM A LACK OF TOTAL l
MANAGEMENT COMMITMENT TO QUALITY AT THE NUCLEAR PROJECT'S INCEPTION.
LACK OF COMMITMENT HAS EEEN EXACEREATED BY:
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LACK OF TOTAL UNDERSTAfiDING OF THE ROLE OF QUALITY ASSURANCE IN PROJECT I
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LACK OF TOTAL UNDERSTANDING OF WHAT IS F.ECU* RED EY FEES 0'iNEL AT ALL l
LEVELS OF THE PROCESS.
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l THE THIRD FF.CBLEM AREA IS TK0-FOLD IN DERIVATION:
FIRST, THE NRC'S LICENSING AND INSFECTION PROGRAMS HAVE NOT SUFFICIEiliLY EXAMINED THE PROJECT MhNAGEMENT CONTROLS AT SITES UNDER CONSTRUCTION ORIENTED TOWARDS ESTABLISHING ADEQUACY KITFIN MAJOR TECHNICAL AND FUNCTIONAL AREAS, E.G., CONCRETE, ELECTRICAL, ETC.
SYSTEMATIC ASSESSMENT OF MANAGEMENT FERFORMANCE AND EVALUATION OF ALL OTHER AVAILABLE INFORMATION HAVE NOT RECEIVED THE SAME LEVEL OF EFFORT AS OPERATING SITES.
SECOND, PREVIOUS NRC PROGRAMS HAVE NOT ADDRESSED DESIGN QUALITY AS SPECIFICALLY AND EXTENSIVELY AS OTHER AREAS.
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It: SU!:, THE FUNDAMENTAL ISSUES CAN EEST BE CHARACTERIZED AS:
LACK OF TOTAL MANAGEMENT COMMITMENT'TO QUALITY THE UNCERTAINTY IN INDUSTRY'S AND t;RC'S AEILITY TO DETECT AND CORRECT THE RESULTING DEFICIEt:CIES.
STAFF HAS DEVELOPED INITIATIVES THAT SHOULD LEAD TO EFFECTIVE IMPROVE!'ENTS IN QUALITY AND QUALITY ASSURANCE PROGRAMS.
UNDERLYIIG PRINCIPLE IN THEIR DEVELOFMENT HAS BEEN THAT THE ULTIMATE RESPONSIBILITY FOR OUALITY AND SAFETY REMAltS WITH THF NUCLEAR INDUSTRY, AND NONE OF THE It!ITIATIVES ARE INTENDED TO TRANSFER THIS RESPONSIBILITY TO THE i:PC.
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If.ITIAilVES ARE DESIGNED TO:
ESTABLISH ADDITI0fiAL C0t;FIDEriCE It' THE QUALITY C'F DESIGN, FROCUREME!T, CONSTRUCTION, AfiD TESTIfiG ACTIVITIES IMPROVE THE ltAf'AGEMENT CONTROL OF QUALITY IMFROVE THE f;RC CAPABILITY TO EVALUATE THE IMPLEMENTATIO!' 0F LICENSEE PROGRAMS.
SATISFY THE DIRECTION PROVIDED THE NRC lli Af; At1EP'DMENT ACCEPTED BY THE HOUSE AND SEf' ATE C0tiFEREES Ili THEIF 'OlhT C0fiSIDEP.AT10N OF THE liRC'S FY E2-83 AUTHORIZATION EILL.
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e SOME OF THE ACTIONS C0ilSIDERED AND ENDORSED EY THE STAFF ARE ASSOCIATED WITH EXISTING AGENCY FROGRAMS.
FOLLOWUP OF ALLEGATIONS IS AN ESSENTIAL PART OF THE NRC's INSPECTION PROGRAM, AND IS AN EFFECTIVE EXTENSION OF INSPECTION RESOURCES.
fiRC HAS SUFFICIEt!T AUTHORITY TO TAKE APPROPRIATE ENFORCEMENT ACTION FOR INADEQUATE QUALITY ASSURANCE.
RULEMAKING ACTION IS CURRENTLY IN FROGRESS WHICH WILL CLARIFY THE NRC STAFF POSITION REGARDING THE TYPES OF CHANGES THAT CAN SE MADE TO QUALITY ASSURANCE PROGRAM DESCRIPTIONS WITHOUT INFORMING THE NRC AND CLARIFY, IN THE REGULATICNS, THE REQUIREMENT TO IMPLEMENT THE ACCEPTED QUALITY ASSURANCE PROGRAM DESCRIPTION.
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INITIATIVES IN THIS PAFER (WITH EXCEPTION OF LONG-TERI.' REVIEW) ARE DIRECTED FF.II.CIPALLY TOWARD REACTOR FACILITIES NOT YET LICENSED FOR GrERATION.
EASIS FOR NOT BACKFITTING THESE INITIATIVES TO OPERATIliG REACTORS:
PREVIOUS REVIEWS OF THE FACILITIES
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FACILITY OPERATING HISTORY EXTENSIVE STARTUP TEST PROGRAMS REVIEWS AND UPGRADES IN RESPONSE TO TMI AND BULLETIN ACTIONS.
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0A INITIATIVES i
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MEASURES AT NEAR-TERM OPERATING LICENSE FACILITIES 1.
SELF-EVALVATI0f:S APPLICANT REVIEWS QA PROGRAM FDR DESIGN AND CONSTRUCTION NRC STAFF REVIEWS LICENSEE'S SELF-EVALUATION ADDITIONAL ACTI0ti MAY SE REQUIRED l
CEO OR DESIGt:EE CERTIFIES PLANT DESIGri, CONSTRUCTION AND l
TESTIllG MEETS FSAR At40 OTHER LICEt; sit!G COMMITMENTS I
IMPLEMENTATION 1
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l' ELEVEN PLA!!TS COMPLETED 9/82 l
l COMPLETE !!TOL EVALUATIONS 11/82 DECISION ON C0!iTIt:UAT10ti 1/E2
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REGIONALEdALUATIONS NRC STAFF C0t:SIDERS HEED FDP ADDITIONAL INSPECTICNS FROJECT INSPECTION AND ENFORCEMENT HISTORY IS EVALUATED SALP REPCRTS ARE REVIEWED IMPLEF.ENTATION STARTED 12/81 EIGHT PLANTS COMPLETED 9/82 DEVELOP FROCEDURE TO FORMALIZE EVALUATIONS 12/82 ISSUE Afl0 IMPLEMENT PROCEDURE FOR QA SL'MMARY REPORTS 2/83 S '. 4 c' e ' 0. 10
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INDEPENDENT DESIGN REVIEWS AFPLICANT FOR OL MAY BE REQUESTED TO CONDUCT
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FROVIDES AN INDEPENCEt:T EVALUlTIC!; 0F THE (LALITY OF DESIGN ADDRESSES PROGRAMMATIC AREAS (i.e., INTERFACE CONTROL, VERIFICATION RECORDS, CLASSIFICATION OF SYSTEMS, AUDIT FINDING AND CORRECTIVE ACTIONS)
CHECKS SPECIFIC DESIGN FEATURES EY INDEPENDENT CALCULATIONS 1
COMPARES IllSTALLATION AGAlfiST AS-EUILT DRAWINGS l
NRC STAFF REVIEWS THE PLAN, !!!PLEMENTATION AND AUDITS WORK l
Ill PROGRESS IMPLEMENTATION l
l TWO REVIEWS COMPLETED 9/82 l
flINE REVIEWS IN PROGRESS COMPLETE REVIEWS 1/83 DECISION ON CONTIliUATION 1/83 Slidt to. 11
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INDUSTRY INITIATIVE (INPO)
EVALUATE QUALITY IN DESIGN CONTROL AND CONSTRUCTION INFO CRITERIA SASED ON "EEST PRACTICE" LICENSEES WILL USE CRITERIA FOR SELF-INITIATED EVALUATIONS IMPLEMENTATION EVALUATION CRITERIA DEVELOPED 4/82 THREE TRIAL INSPECTIONS COMPLETED 7/82 V0GTLE HARRIS FOPE CREEK INSPECTION CRITERIA REVISED 8/82 KORKSHOPS CONDUCTED ON EVALUATION CRITERIA 9/82 UTILITIES PERFORii SELF-INITIATED EVALUATIONS 9/82-12/82 ASSESS OVERALL PROGRAM AND FORMULA E PLANS FOR UTILITY IMPLEMENTATION 1/83 Slida Nt. 1E
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CONSTRUCTION INSPECTION PROGRAM DEVELOPMENTS
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PROCEDURAL CHANGES PROGRAM HAS CHANGED OVER YEARS (fiOSTLY ADDITIONS)
CONSTRUCTION ENHANCEMENT PROGRAM 1979-1980 CONSTRUCT 10t: ASSESSMENT TEAM INSPECTIONS (TRI AL) 1981 MAJOR REVISION IN PROGRESS TO MATCH PROGRAv.TO AVAILASLE RESOURCES FY 83-84 NRC BUDGET ALLO:ATES AN ADDITIONAL 0.3 (FY 83)
AND 0.2 (FY 84) STAFF YEARS INSPECTION EFFORT PER CONSTRUCTION UNIT INCREASE EMPHASIS O!; OBSERVATION OF KORK DECREASE RECORDS REYlEW INCREASE EMPHASIS ON INS?ECT10t' 0F DESIGN AND DESIGN CHAf.:ES RESIDEllT INSPECTOR NOW AT ALL SITES 15% COMPLETE IMPLEMENTATION STARTED INSPECTION PROCEDURE REVIEK L REVISIONS 10/81 MECHANICAL INSPECTION PROCEDURES ISSUED 8/82 t
It[SPECTIONPROCEDUREREVISIONSAPFROXIMATELY l
45% COMPLETE COMF'.ETE PROCEDURE REVIEW & FEY:S:'.h5 10/83 4
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C0liSTRUCTION ASSESSMEET TEAM INSPECTION PAT TYPE litSPECTICMS AT SELE'CTED CONSTRUCTION SITES COMPREHEtSIVE LOOK AT LICENSEE MANAGEMENT INDEPENDENT REVIEW OF REGIONS INDEPEhCENT REVIEk' 0F INP0 I!!PLEMENTATION
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STARTED CAT PROGRAM 7/82 i
INSPECT 10t: CRITERIA DEVELOPED 8/82 I
i TEAM SELECTED 8/62 i
FIRST CAT INSPECTION AT BELLEFONTE 9/82 l
CONDUCT FOUR CAT IllSPECTIONS DURING 1983 CQNCUCT FOUR CAT INSPECTIONS DURING 1954 DECISION TO CONTINUE CAT lllSFECT10'45 1/85 Slide Nc. 14
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INTEGRATED DESIGN IliSFECTIGrj REVIEW SELECTED SYSTEtt AND/0R STRUCTURE REVIEW DESIGN INTERFACES SA!'PLE CALCULATION CHECKS I
AS-BUILT VERIFICATION INTEROFFICE AND CONTRACTOR PARTICIPATION l
IMPLEMENTATION TRIAL PROCEDURE DEVELOPED 7/82 SELECT TEAP. & CONTRACTOR 9/82 CONDUCT FIRST INSPECTION 11/82 CONDUCT SECOND INSPECTION 2/83 FINALIZE DESIGN INSPECTION PROCEDURE 4/83
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4 EVALUATION OF REPORTED INFORMATION IMPROVED SYSTEMATIC REVIEW 0F 50.55(E) AND PART 21 REPORTS l
IMPROVED REV]EW OF ALLEGATIONS i
l; IMPLEMENTATIOR CURRENTLY DATA REVIEW OF 50.55(E) AND PART 21 REPORTS DONE MANUALLY L
l-DEVELOP COMPUTERIZED TRACKING OF REPORTED d
EVENTS 2/83 INPUT AND EVALUATE EVENTS 6/E3 i
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DESIGNATED REFRESENTATIVES ALLOWS FOR INCREASED INSPECTION EFFORT OF KEY AREAS AT SPECIFIC TIMES WITHOUT A CORRESPONDING INCPEASE IN NRC STAFFING LEVELS WOULD SIGNIFICA!!TLY RAISE NRC'S CONFIDENCE LEVEL OF QA IN NUCLEAR FGlER PLANTS PROVIDES AN INCREASEL AVAILADILITY OF INSPECTORS FOR SPECIALIZED INSPECTION AREAS.
WILL REQUIRE STATUATORY CHANGES TO IMPLEMENT IMPLEMENTATION PRELIMINARY STUDY OF FAA SYSTEM 3/82 IDENTIFY ELD AND OGC REPRESENTATIVE FOR PROPOSED RULEMAKING 10/82 II;ITIATE PILOT PROGRAM AT CONSTRUCTION AND OPERATING SITES 3/83 FREPARE RULE AND LEGISLATION 8/83 FINALIZE FROPOSED RULE 11/83 RECOMMENDATION TO COMMISSION
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MA','AGEP.ENT OF OUALITY 1.
MAllAGEl;El:T WORKSHOPS AND LICEllSEE OUALITY It'PROVEMElli PROGRAMS COMMUNICATE COSTS OF BREAKDOWNS IMPF.0VE ATTITUDE AND PERFORMANCE PERSONAL COMMITMENT OF SENIOR MANAGERS CONTINUING SERIES OF WORKSHOPS PROVIDE FEEDBACK ON ACHIEVEMENTS UPGRADE QUALITY AND CERTIFICATION OF QA/QC FERSON!iEL l
IMPLEMENTATION COORDINATE DEVELOPMENT OF QUALITY MANAGEMENT WORKSHOPS WITH INDUSTRY 1/83 COORDINATE DEVELOPMENT OF QUALITY IMPROVEMENT PROGRAMS WITH INDUSTRY 3/83 4
COORDINATE QUALITY MANAGEMENT WORKSPOPS 5/83 INITIATE QUALITY IMPROVEMENT PROGRAMS 6/83 1
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CUALIFICATION & CERTIFICATION OF CA/0: F E R S C ' ',E L EftFORCE EXISTING STAliDARDS F0,R QUALIFICATIO;, OF QA/QC PEFSONf!EL STUDY ESTA LISHMENT OF QUALIFICATION AND CEF.TIFICATI0t! SYSTEM AS PART OF LONG-TERM REVIEW DEVELOP QL'ALIFICATI0tl SYSTEl' FOR liDE PER50t,NEL IMPLEl1EtiTATION
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MEETINGS HELD WITH INDUSTRY ON NDE PERSONNEL QUALIFICATION 5/82 EPRI NDE COMMITTEE PROPOSED PLAN FOR NDE PERSONNEL 7/82 TEMPORARY INSFECTION INSTRUCTION ISSUED TO ENFORCE EXISTING QA/QC QUALIFICATION STANDARDS 1/83 EPRI NDE COMMITTEE TO DEVELOP DRAFT CERTIFICATION PROGRAM 1/83 FINAL CERTIFICATION PROGRAM TO NRC 1/83 NRC STAFF TO REVIEW AND ADOPT PROGRAM 6/83 NRC TO DEVELOP RULE FOR NDE CERTIFICATION 8/83 START QUALIFICATION & CERTIFICATION PROCESS FOR NDE PERSONNEL 10/83 MAlhTAI!: REGISTRY OF LEVEL III I;DE PERSONNEL 10/E3
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CRAFTSMAf! SHIP 4
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DISCUSS OA IMPROVEMENTS WITH MAJOR TRADE UNIONS QA/QC ACTIVITIES MUST REACH THE CPAFTSMAN ASSURE GOOD CRAFTSMANSHIP IMPLEMENTATION 1
MEETING HELD WITH TRADE Ut4 IONS 7/82 MEETING HELD WITH NUCLEAP. STABILIZATION COMMITTEE 9/82 CONTINUE DISCUSSION WITH LABOR &
MANAGEMENT AS PART OF LONG-TERM REVIEU 11/82
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LONG-TERM REVIEW C0!'.FREHEtiSIVE NRC STAFF STUDY TO DETERMINE ROOT CAUSES OF QUALITY EREAKDOWf:S AT FLANTS WITH IDEf;TIFIED DEFICIENCIES DETERMINE UNDERLYING CHARACTERISTICS CF SUCCESSFUL OA FROGRA!'S DEVELOP RECOMMENDATIONS FOR CHANGES / IMPROVEMENTS IN NRC AND
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INDUSTRY QA PROGRAMS EXAMINATION OF EXISTING PROGRAMS AND PAST PROSLEMS WILL INCLUDE REVIEW OF EXISTING DOCUMENTATION VISITS / DISCUSSIONS WITH REGIONS AND RESIDEhTS VISITS TO PLA!iT SITES AND CORPCRATE OFFICES BOTH OPERATING AND CONSTRUCTION SITES EXAMINE NRC QA PROGRAM AND POLICIES AS WELL AS LICENSEES / VENDORS / CONTRACTO OUTSIDE QA PROGRAMS (NON-NUCLEAR AND FOREIGN NUCLEAR)
EMPHASIS ON GENERIC IMPLICATIONS COST / BENEFIT OF VARIOUS ALTERNATIVES RESPONSIVE TO FORD AMENDMENT PLAN TO ESTABLISH ADVISORY PANEL S l i c.s ?:c. 2 *.
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LONG-TERM REVIEW (Cont'd)
!!'PLEMENTATION SELECT CONTRACTORS FOR SITE VISITS 9/82 INITIATE SITE VISITS 10/82 INITIATE STUDY OF NRC PROGRAMS, ANALYSIS OF FORD AMENDMENT ALTERNATIVES, PILOT PROGRAMS AND OUTSIDE PROGRAMS 11/.82 INITIATE STUDY OF CERTIFICATION AND QUALIFICATION OF OA/QC PERSONNEL 12/82 C0liTINUE STUDIES, ANALYZE FINDINGS, PROPOSE SOLUTI0l'S AND COST / BENEFIT AllALYSIS 1/83-9/83 FILIAL REPORT TO COMMISSION AND CONGRESS 12/83 Sl i G O !!C. 21 (Cer.:inuec)
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