ML20134A857

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Elaborates on Re Need for Formal QA Policy & Confusion About NRC Function in Area of QA & Reliability Assessment.Clear Commission Directive on Reliability & QA Needed
ML20134A857
Person / Time
Site: 05000000
Issue date: 05/12/1983
From: Forscher F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Palladino
NRC COMMISSION (OCM)
Shared Package
ML17198A269 List: ... further results
References
FOIA-84-293 NUDOCS 8508150443
Download: ML20134A857 (3)
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MAYj3999 MAY 1213

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t l'EMORANDUM FOR:

Chaiman Palladino A

FROM:

Frederick Forscher Quality Assurance Branch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement

SUBJECT:

QA POLICY: RELIABILITY AND PUBLIC CONFIDENCE In my letter to you of June 18, 1982, I tried to call your attention to the need for a formal Quality Assurance (QA) Policy.

This need still exists.

Furthermore, the confusion about NRC's function in the area of QA and reli-ability assessment has been increasing.

Quality assurance is the multi-disciplinary system of manacement controls that comprise all those planned and systematic actions necessary to provide adequate confidence that acreed upon requirements are met.

" Agreed upon requirements" include pre-and post-accident performance requirements.

Hence, we are dealing herewithreliabilityissues(suchasequipmentqualification).

The reliability of performance is not only a function of the design, construction, and testing, but also of the surveillance and maintenance that is applied.

The staff has no It fim guidance on what NRC's function is in regard to reliability assurance.

is noteworthy that:

(1) a reliability breakdown nay or may not affect public health and safety, (2) Appendix B to Part 50, Quality Assurance, does not deal with reliability at all, and (3) equipment qualification requirements are still unresolved, although the finalized Part 50.49, " Environmental Qualification of Electric Equipment" is a step in the right direction.

NRC is sponsoring various Reliability Assessment Programs (RAP) without any coordination between the various programs, and with no attention being given to the question of QA in the implementation of RAP results, or in the application of the Safety Goals Policy.

The difficulty with the phrase " agreed upon requiments" is by itself not enough

However, reason to call your attention to the need for a formal QA Policy.

another phrase, " provide adequate confidence," appears to be a better way to show this need.

The question is:

Whose_ confidence?

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I Chairman Palladino MAY l21933 l

l Congress ought to have confidence that we know what we are doing.

How can it gain such confidence?

If we had a QA Policy, the GA0 could audit its imple-mentation in similar fashion as we audit the licensee.

Since there is no such policy, the GA0 does the next best thing; it recommends to Congress various and specific corrections based on GA0's interpretations of our Con-gressional mandate.

On the one hand, we expect the licensee to have an appropriate QA system that will " provide adequate confidence" to the Commission, that the licensee's i

management controls are in fact meeting agreed upon requirements (such as SAR commitments, technical specifications, etc.).

On the other hand, the NRC itself should hr >e an appropriate QA system that will " provide adequate confidence" in the r :blic's mind (i.e., Congress) that NRC's management controls do, in fac, implement the Congressional requirements.

The Commission could take a lesson from the 00E.

A major step toward estab-lishing QA institutionally within the DOE has been taken in 1979 when an internal study group was formed with the objective to develop a plan pro-viding for a strong QA/0C program that incorporated environmental, health, reliability and operational system safety concerns.

The work of this study group was a much needed impetus toward establishing the present QA policy, fonnalized in DOE's Order #5700.6A of July 1982, which states that QA activities shall be required, developed, funded, and managed as integral activities within all DOE programs.

Over the years, there have been many studies of NRC's QA activities.

I men-and Kemeny Commission, October 1981)g., NASA, July 1974; Sandia, Aug tioned three in my letter to you (e.

We now have another chance.

Section 13(b)(4) of the Ford Amendment asks the Commission to study OUR organization, methods, and programs for QA review and inspection. The review group is now being assembled, and could very well follow DOE's lead.

However, it is more likely that without a clear indication by the Commission to develop a OA

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Policy, the staff or the Review Group will end up with another soon forgotten review document.

In my opinion, it is very shortsighted and out of date, to look at the QA function merely as a " paper trail" or as a " checking" function.

QA is a multi-disciplinary system of management controls.

Of course, QA is not making decisions, nor is it to develop designs or processes.

It is here to assure that whatever has been agreed upon is, in fact, being implemented.

This includes Post-TMI requirements such as human factors, training, emer-gency plan, safety goals, etc.

If a requirement cannot be " assured" (by QA),

it couldn't very well become a regulation in a meaningful sense.

0A, properly used, is the most cost-effective way to manace mission-oriented orcanizations.

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Chairman Palladino MAY 121993 Regionalization could serve as an example.

It increases efficiency in manage-ment of the agency, without decrease in emphasis on public health and safety.

QA, as an NRC management tool, could contribute importantly to the effective-ness of regionalization.

Or, consider the issue of high-level waste.

By definition, a QA system of mangement controls is necessary to provide " adequate confidence."

The Waste Confidence Hearings could have been completed years ago if we had a QA Policy and the appropriate QA system to provide this elusive confidence.

Many more examples could be cited where a formal, and implemented, QA Policy would have saved much time and effort before Courts and Congress and, more importantly, provide credibility and raise public confidence in what we are doing.

Almost every week one can read about it in the papers; e.g., the ASLB questions the quality of NRC's investigation at Comanche Peak hearings; or, at the Shoreham hearings everybody is confused about important-to-safety and safety-related QA.

With PRA bound to play an ever increasing role, we should expect a steep increase in unresolved QA issues.

The required QA action will not come from the staff, not withstanding all our QA initiatives and the Ford Amendment.

What is needed is a clear directive by the Comission on reliability and quality assurance.

I urge you to consider such a move.

Y M

Frederick Forscher Quality Assurance Branch Division of Quality Assurance.

Safeguards, and Inspection Programs Office of Inspection and Enforcement cc:

Commissioner Gilinsky Comissioner Ahearne Comissioner Roberts Commissioner Asselstine R. B. Minogue, RES l

R. C. DeYoung, IE R. F. Fraley, ACRS l

W. J. Dircks, EDO i

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