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UNITED STATES 7
y y e.g,g NUCLEAR REGULATORY COMMISSION g Ygy'. j WASHINGTON, D. C. 20555
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OCT 8 1332 Mr. W r,1d Harty,
Seni r Staff Engireer Er.T
?.:ters :erar: ment Er d,'.e :acific i"s Labs Ea teile Eculevard Richland, Washington 99352
Dear Mr. Harty:
Enclosed for your review are several cocuments that should be useful to you in your work for I;RC on the Long-Term Review (LTR) of cuality assurance.
The first document is a draft description cf a format for the team reports for the site visits ccnducted as part of the LTR.
I woulc like ycu to use this as an input into your thinking regarding the deveio; ment of an assessment methodology for the site visit activities of the LTR.
Money for the contracts for PNL and EG&G suppcrt to NRC fcr the site visits was officially obligated by September 30, 1982, and ccntractually you are new.in the planr.ing mode of the site visit task.
Given :nat you have twenty cays to develop an assessment plan, I propose a meeting of the involvec PNL and EG5G staff members with me the week of October 25 or N:vember 1.
The meeting wcuic be for approximately two days and would be held either at Battelle PNL or at EG&G Idaho.
I will inform you more precisely of the arrangements as the details are firmed up.
At this meeting, I.would like for ycu to be prepared to discuss ideas you gave for the other tasks identified for the LTR.
I wculd like to start work on them as scon as is feasible.
As I have discussed with you en the phone, we are examining the possibility of using " mixed" teams for the site visits - that is, the teams would contain representatives frcm both EG&G and Battelle, and possibly some private con-sultants.
Such an arrangement would permit me to tailor a team tc each specific site and optimize the various talents and specialties available for this effort.
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s H. Harty OCT 819M l
I am working on identifying and scheduling apprcpriate plants for our visits.
I hope to make the first site visit in November.
Sincerely, is/
Willard D. Altrran NRC Project Manager Long-Term Review of QA
Enclosures:
1.
Draft Report Format 2.
Memo, W. Dircks to Commission, 9/23/82 3.
Memo, J. Zerbe to Ccamission, 9/28/82 4
Slides for Commission Briefing, 9/24/82 5.
Transcript of Commission Briefing, 9/29/82 6.
Memo, J. Ahearne to Secretary, 9/30/82 cc w/o enclosures:
R. Sorenson Battelle Pacific NW Labs Battelle Boulevard Richland, Washington 99352 C. F. Obenchain, Manager NRC Support Branch -
EG&G Idaho, Inc.
P.O. Box 1625 Idaho Falls, Idaho 83415 H. Kirschenmann Manager, Ouality Department c/o EG&G Idaho, Inc.
Willow Creek Building P.O. Box 1625 Idaho Falls, Idaho 83415 14/
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QUAS:DEQA:IE WD Altman 10/7l82 kie
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W, Il ENCLOSURE 1 Format of 0ACS* Report
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H Jhafw First Page 1.
f:ame of reacter, utility II.
Dates of field work, and places visited III. t!ames and Organizations of SSA team members IV.
Persens contacted, their organizations and positoins V.
Literature reviewed in conjunction with this visit VI.
Description of plant in terms of the follcwing:
SWR or PWR, No. Mwe, no. of units, utility name and ccrocrate HQ, name of AE, names of major contractors, NSSS, etc., also date of CP, date of bl (expected if plant in construction), % complete if in construction.
Second Page I.
Summary of Findings - This section should include saliert points regarding 0A program or organization characteristics, significant prcbiens that have occurred, why they occurred, what was done to correct them and how success-ful remedial action has been.
If no significant problems have occurred, a description of those features of programs that seem to contribute to its apparent success.
'OACS = Cuality Assurance Case Study
Format of 0ACS Report 2
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This writeup should be about one page long and ccntain the bottom line regarding what can be said about their plant and its OA program.
In the summary we should highlight those site specific findings that we think r.ay have generic applications.
Third Page and Successive Pages II.
General Topics A.
Description of the licensee's Q/. progran, its organization, and its interfaces within and outside the licensee organization.
Include key
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dates (brief history)~,. size of the organization, how it is structured, its responsibilities, its authorities, reporting chain cf command internally and externally.
Include aspects that contribute to the strengths and/or weaknesses that will be highlighted in sub-sequent sections.
This section should include quantitative as well as qualitative information:
how many QA inspectors in what specialties, how many construction workers, how many welders, etc.
B.
Description of QA problems that have developed at the plant, and how and by whom they were identified.
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Format of QACS Report 3
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1 C.
Analysis cf why the above problems developed, i.e., what were the root causes.
We are in'terested in identifying the programr.atic deficiencies that led to the identified QA problems.
In this section, each postulated rcot cause shculd be justified in terms of supporting evidence:
i.e., inspection reports, investigation reports, interviews with inspectors, discussions with licensee, discussions with A/E, craftsmen, etc.
If scmething is opinion, label it as such.
We need to document the logic train that brought us to our conclusions.
D.
Description of remedial action taken to address the identified QA problem, whether it solved (or failed to solve) the problen, and how it was decided upon (describe involvement of NRC and licensee in' arriving at and implementing remedial action).
This section should detail the costs associated with the remedial action - costs to the licensee in terms of lost time - construction delays, unplanned shutdowns, etc.
It should also describe ccsts in terms of people and dollars.
Costs to the NRC (investigations, extra inspection and licensing actions, etc.) in terms of people and impact on the routine NRC program.
E.
Description of the positive aspects of the QA program, both historically i
and presently.
If the plant has undergene remedial actions, what can 1
l we learn from the success or failure of the reredial ortgran, especially l
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Format of 0ACS Report 4
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in a generic sense.
If the QA program has not had major problems, why not? Are there some key aspects that seem to make the program successful, or is it just another major breakdown waiting to be discovered? What we want to arrive at in this section are the basic underlying characteristics of a successful QA program.
II,I. Specific lessons Learned A.
Implications of this case study for improvement of QA programs for design.
This section should include lessons learned frcm this QA study th'at suggest possible approaches or solutions to improve licensee's QA programs for design.
Suggested approaches should be evaluated critically in terms of whether they would really solve problems and their costs and benefits should be discussed and weighed.
B.
Implications of this case study for improvement of QA programs for I-Construction.
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Similar content as for design section, etc.
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Format of 0ACS Report 5
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C.
Implications of this case study for improvement of 0A programs for startup.
Etc.
D.
Implications of this case study for improvement of QA programs for testing.
.Etc.
E.
Implications of this case study for improvement of QA programs for naintenance Etc.
.F.
Implications of this case study for inprovement of QA programs for operations.
Etc.
G.
Implications of this case study for improvement of QA programs for contracting and procurement.
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Format of 0ACS Report 6
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H.
Implications of this case study for improvement of 0A programs with regard to management.
I.
Implications of this case study for improvement cf QA programs with regard to training.
J.
Implications of this case study for improverent of QA programs with regard to organizational structure and flow of information.
K.
Implications of this case study for improvement of QA prograns with regard to project management.
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Implications of this case study with respect to suggested accroaches for imorovement of 0A, A.
Implications with respect to Ford Alternative 1:
Providing a basis for quality assurance and. quality control, inspection, and enforcement actions through the adoption of e-mere FFeSeF4pt4Ve-appFeaeh-te-an approach which is mere prescriptive than that currently in practice for defining principal architectural and engineering criteria for the construction of commerical nuclear power l
plants; 9
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B.
Implications with respect to Ford Alternative 2:
Conditioning the issuance of constructicn termits for commercial nuclear power plants on a demonstration by the licensee that the licensee is capable of independently managing the effective per-formance of all quality assurance and. quality control responsibilities for the power plant; C.
Implications wih respect to Ford Alternative 3:
More effective evaluaticns, inspections, or audits of commercial nuclear powr plant construction by representatives of independent associations of professionals having expertise in appropriate fields (including-the-esset4at ens-referred-te-4n-the-preceed4fs-senteece)-
d which evaluations, inspections, or audits are more effective than those under current practice; D.
Implications with respect to Ford Alternative 4:
Improvement of the Commission's organization, mettods, and programs for quality assurance development, review, and inspection;
Format of 0ACS Report 8
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E.
Implications with respect to Fcrd Alternative 5:
Conditioning the issuance of construction permits for commercial nuclear power plants on the permittee entering into contracts or other arrangements with an independent inspector to audit the quality assurance program to verify quality assurance performance.
F.
Implications with respect to establishir.g a program analogous to the FAA system, including designated NRC reoresentatives, QA holdpoints.
G.
Implications with respect to the effectives of present (not neces'-
sarily NRC) nuclear quality assurance standards, especially from the
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viewpoint of simplifying and updating existing QA standards.
H.
What lessons learned from this case study should be fed back into the national standards process?
I.
Implications with respect to TMI Action Plan (NUREG-0660) initiatives (1) Task I.F (2) Task II.J.
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Format of QACS Report 9
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Implications with respect to NRC's cualifying and/or certifying licensee / contractor 0A programs including the establishment of holdooints based on achieving certain levels of QA progran.certifi-cation.
V.
Implications of this Case Study with Rescect to NRC Policies and Programs A.
Implications with respect to adequacy of existing NRC regulatory base in QA.
B.
Implications with respect to NRC licensing practices.
C.
Implications with respect to NRC standards and guidance.
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D.
Implications with respect to NRC research programs.
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E.
Implications with respect to the NRC enforcement programs.
l F.
Implications with respect to NRC inspection program assumptions, definition, and guidance.
G.
Implications with respect to NRC inspection progran implementation.
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H.
Implications with respect to NRC staff expertise, cualificrtion and training.
l 1.
Implications with respect to MFC organizational structure.
j VI.
Implications of this Case Study with Resrect to Other SECY-82-352 Initiatives
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A.
Implications with respect to NT0L licensee self evaluations.
B.
Implications with respect to requiring licensee CEO certification
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that plant design, construction, and testing meets FSAR and other licensing commitments ~.
C.
Implications with respect to NT0L Regional evaluations.
d D.
Implications with respect to NT0L independent design review.
E.
Implications with respect to INF0 evaluations.
F.
Implications with respect to NRC inspection initiatives:
(1)
PAT inspections i
(2)
CAT inspections 1
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(3)
Revision of inspection program (4)
Integrated design inspection (5)
Change emphasis frca recoras audit to cbservation of work G.
Implications with respect to improved systematic review of 50.55(e) and Part 21 reports by NRC.
H.
Implications with respect to improved NRC soliciting of and review of allegations.
I.
Implications with respect to management workshops.
J.
Implications with respect to stronaer enforcement of existing standards for QA/QC personnel.
K.
Implications with respect to establishment of a more forvel cualification and certification system for QA/QC personnel.
L.
Implications with respect to upgrading cuality oj[ craftsmanship.
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