ML20134B169
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c UNITED STATES 4
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NUCLEAR REGULATORY COMMISSION b
E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS C
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W ASHINGT ON, D. C. 20555 N
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March 21, 198 h/
MEMORANDUM FOR:
Samuel J. Chilk, Se etary of the Comis fROM:
R. F. Frale, c.xecutive D. cto, ACRS
SUBJECT:
PROPOSED FEDERAL
- REGISTER MEETING NOTICE FOR THE 288TH ACRS HEETING - APRIL 5-7, 1984 Attached is the proposed meeting nof. ice for' the 288th meeting of the ACRS which will be held on April 5-7, 1984.
Please note that this meting notice will not met our norm 1 15-day notice period for ACRS meetings.
This has resulted from the limited time following the 287th ACRS meeting when the mtters to be considered by the Comittee at its April meeting were approved.
It is requested that notice of this rneeting be published as soon as possible.
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Attachment:
Proposed Federal Register Notice for the 288th ACRS Mtg. - 4/5-7/84 cc: w/att.
ACRS Members and Staff J. G. Davis, HMSS
- 0. E. Bassett, RES R. F. Fraley, ACRS H. Denton, NRR K. R. Goller, RES H. Norman Schwartz, ACRS E. Case, NRR D. Ross, RES J. Kopeck, OPA D. Eisenhut, NRR J. M. Allen, Region 1 R. L. Black, OGC L. Wheeler, NRR J. P. O'Reilly, Region II W. J. Dircks, EDO T. P. Speis, NRR J. G. Keppler, Region Ill T. Rehm, EDO R. Mattson, NRR J. T. Collins, Region 1Y V. Stello, EDO H. Thompson, NRR R. H. Engelken, Region Y R. C. DeYoung, I&E R. Vollmer, NRR R. Bernero, ASTP0 L. I. Cobb, l&E R. Minogue, RES J. G. Partlow, l&E G. A. Arlotto, RES E. L. Jordan, I AE F. Arsenault, RES J. M. Taylor,1&E M. Ernst, RES R. E. Browning, WM R. Cunningham, FC R. Burnett, SG Fo te L93 0000100S3D 000704 L
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I Federal Register Notice I
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS NUCLEAR REGULATORY COMMISSION Notice of Meeting In accordance with the purposes of Sections 29 and 182b. of the
" ' ' ~Atomic Energy Act (42 U.S.C. 2039, 2232b.), the Advisory Conmittee on Reactor Safeguards will hold a meeting on April 5-7, 1984, in Room 1046,,1717 H Street, NW, Washington, DC.
Notice of this meeting was published in the Federal Register on March 27, 1984.
The agenda for the subject meeting will be as follows:
Thursday, April 5,1984 8:30 A.M. - 8:45 A.M.:
Chairman's Report (0 pen) - The ACRS Chairman will report briefly to the Committee regarding items of current interest.
8:45 A.M. - 12:00 Noon.
Maintenance Policies and Practices (0 pen /
Closed) - The members will hear and discuss the report of its subcommittee and members of the NRC staff regarding maintenance policies and practices in nuclear power plants.
A portion of this session will be closed to discuss information provided in confidence by a foreign source.
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- i 1:00 P.M. - 2:00 P.M.:
Items for Meeting with NRC Commissioners (0 pen) - The members will discuss the ACRS position regarding matters to be discussed with the NRC Commissioners including the' proposed NRC Safety Research Program for FY 1985, ACRS activi-ties related to 0A/QC practices in the nuclear industry, and establish-ment of an NTSB type board for evaluation of nuclear power plant i
accidents.
2:00 P.M. - 3:30 P.M.:
Meeting with NRC Commissioners (0 pen) - The members will meet with the NRC Commissioners to discuss items noted above.
3:30 P.M. - 4:15 P.M.:
Implementation of Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident (0 pen) - The members will hear a briefing regarding the status of implementation of Regulatory Guide 1.97.
4:15 P.M. - 5:00 P.M. :
Subconmittee Action (0 pen) - The members will hear and discuss reports of designated Subcommittees regarding the status of assigned activities including provisions for ECCS and decay heat removal.
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Friday, April 6,1984 8:30' A.M. - 11:30 A.M. :
Ginna Nuclear Power Plant (0 pen) - The members will hear and discuss reports from its subcommittee, the NRC Staff, and the Licensee regarding the request for a full term operating license for this facility.
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. Portions of this session will be closed as necessa y to discuss Pro-prietary Material applicable to this matter.
11:30 A.M. - 12:30 P.M.:
Activities of HRC Regional Offices (0 pen) -
The members will hear and discuss a report from an NRC Regional Director regarding the activities of NRC regional offices.
1:30 P.M. - 2:30 P.M.:
Severe Accident Policy (0 pen) - The members will hear a briefing by a representative of the NRC Staff regarding the status of a proposed NRC policy statement regarding consideration I
of severe nuclear power plant accidents in the regulatory process.
2:30 P.M. - 3:30 P.M.:
Nuclear Power Plant Operating Experience (0 pen) -
The Committee will hear and discuss a proposed NRC Bulletin regarding operatien of undervoltage trip devices in nuclear power plant circuit breakers.
3:30 P.M. - 4:00 P.M.:
Passive Containment System (0 pen) - The Com-mittee will discuss a proposed ACRS reply to the request for a preapplication review of the passive containment system.
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.s 4:00 P.M. - 5:00 P.M.:
Preparation of ACES Reports (0 pen / Closed) -
The Comittee will discuss proposed ACRS reports-/ letters regarding items considered during this meeting.
Portions of this session will be closed as necessary to discuss
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Proprietary Information applicable to the matters being considered l
and to discuss information involved in.an adjudicatory proceeding.
Saturday, April 7,1984 8:30 A.M. - 9:15 A.M. :
Appointment of ACRS Members (Closed) - The members will discuss the qualifications of candidates proposed for appointment to thi Comittee.
I This portion of the meeting will be closed to discuss information the release of which would represent an unwarranted invasion of personal privacy.
9:15 A.M. - 12:30 P.M.:
Preparation of ACRS Reports (0 pen / Closed) -
The Comittee will complete preparation of repo~rts71e~tters re~garding items considered during this meeting.
Portions of this session will be closed as necessary to discuss Proprietary Information applicable to the matters be'ing considered and information involved in an adjudicatory proceeding.
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Procedures for the conduct of and participation in ACRS meetings were published in the Federal Register on September 28, 1983 (48 FR
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44291).
In accdrdance with these procedures, oral or written statements l-may be presented by members of the public, recordings will be permitted only during those portions of the meeting when a transcript is being kept, and questions may be asked only by members of the Comittee, its consultants, and Staff.
Persons desiring to make oral statements should l
notify the ACRS Executive Director as far in advance as practicable so I
that appropriate arrangements can be made to allow the necessary time during the imeting for such statements.
Use of still, motion picture and television cameras during this meeting may be limited to selected portions of the meeting as determined by the Chairman.
Information j,
regarding the time to be set; aside for this purpose may be obtained by a prepaid telephone call to the ACRS Executive Director, R. F. Fraley, prior to the meeting.
In view of the possibility that the schedule for l
ACRS meetings may be adjusted by the -Chairman as necessary to facilitate the conduct of the meeting, persons planning to attend should check with the ACRS Executive Director if such rescheduling would result in major inconvenience.
I I have determined in accordance with Subsection 10(d) P.L.92-463 that it is necessary to close portions of this meeting as noted above to discuss Proprietary Information and information provided in confidence by a foreign source [5 U.S.C. 552b(c)(4)], information involved in an b
adjudicatory proceeding [5 U.S.C. 552b(c)(10)], information the release of which would represent an unwarranted invasion of personal privacy
[5 U.S.C. 552b(c.)(6)3 Further information regarding topics to be discussed, whether the meeting has been cancelled or rescheduled, the Chairman's ruling on re-quests for the opportunity to present oral statements and the time al-lotted can be obtained by a prepaid telephone call to the ACRS Execu-tive Director, Mr. Raymond F. Fraley (telephone 202/634-3265), between 8:15 A.M. and 5:00 P.M. EST.
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Samuel J. Cnilk Secretary of the Commission i
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UNITED STATES j
j NUCLEAR REGULATORY COMMISSION y,
c ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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W AsmNGT ON, D. C. 20555 eh4 " * *(* d' March 21,1984 The Honorable Nunzio J. Palladino
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Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Dr. Palladino:
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SUBJECT:
ACRS REPORT ON DRAFT NRC REPORT TO CONGRESS ON IMPROVING QUALITY AND THE ASSURANCE OF QUALITY IN THE DESIGN AND CONSTRUCTION OF COMMERCIAL NUCLEAR POWER PLANTS During its 287th meeting, March 15-17, 1984, the Advisory Comittee on Reactor Safeguards reviewed the draft NRC report to Congress, " Improving Quality and the Assurance of Quality in the Design and Construction of Co=ercial Nuclear Power Plants," Revision 3, dated March 13, 1984.
An earlier version of the draft report was considered during a meeting of the ACRS Subcommittee on Quality and Quality Assurance in Design and Construction held.in Washington, D.C. on February 24, 1984.
In addi-tion, the Subcommittee reviewed and discussed the NRC's quality-related initiatives during meetings held on July 18, 1983 and December 6, 1983.
The report is both useful and constructive.
It gives thoughtful at-tention to the five alternatives which the Commission was required to consider under Section 13(b) of the Ford Amendment (Public Law 97-415) and reaches well-reasoned conclusions on each.
Further, the results of the pilot program mandated under Section 13(c) of the Ford Amendment substantiate the conclusion that comprehensive audits of nuclear con-struction projects by qualified third parties can provide significant additional preventive and detection capability as well as enhanced assurance that nuclear plants are built in accordance with their design and licensing commitments.
The report is candid in conceding errors of cmission or commission on the part of the NRC which have contributed to quality assurance deficiencies in the past.
During the Subcommittee's early review of the study, it suggested that the Commission take adgantage of the opportunity presented by Congress and expand the scope o} the study to address issues beyond those man-dated.
We are pleased that the report provides a more comprehensive picture of the Commission's actions and initiatives.
Although the report is well written, it is voluminou.s and repetitious.
A concise executive summary would improve the report.
This can be accomplished without delaying the submission of the report to Congress.
The lessons learned from past problems in the design and construction of commercial nuclear power plants are described.
As indicated in the little is said about the operation of plants although many of
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Honorable Nunzio J. Palladino March 21, 1984,
the same observations and lessons should apply.
Many of the problems described relate to the inability, or the difficulty, of assuring the quality of some plants as a result of shortcomings in quality assurance
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and/or quality control programs during design and construction.
Not addressed is whether'the QA/QC shortcomings had an effect on quality or had significant effect on public safety / risk.
The distinctions among quality, quality assurance and quality control, and their relationship to public safety / risk are, at times, not made clear in the report.
This is compounded by the NRC's continued inabili-
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ty to clearly identify those systems and components for which quality is essential to public safety and thus for which programs to control and to assure quality are necessary.
Probabilistic risk assessments (PPAs) could help in this regard.
We encourage the NRC to expedite the col-lection of the data necessary to clarify these issues.
Further, although recommendations are based en the findings of the case studies, pilot programs, and other initiatives, it is not clear whether their implementation will actually improve quality or enhance public safety or whether they will merely improve the public's perception of safety.
We recommend that the NRC Staff undertake to determine the relative risk significance of the various recommendations and proposed actions as well as determine whether safety would be enhanced by the proposed actions.
The NRC should then concentrate its efforts en actions which will enhance public safety.
The report does not contain priorities or schedules for further develop-ment of the various recommendations or proposed actions.
We believe that the NRC Staff needs to develop more specific recomendations following the submission of the report to Congress.
We recomend that in forwarding this report to Congress, the Comission make clear its intention to develop a plan for achieving 'the assurance of quality in the
- design, construction, and operation of nuclear power plants.
However, we caution that the development of a program plan should not be allowed to interfere with proceeding expeditiously with those actions found to improve public safety significantly.
The NRC Staff has identified management as a major factor affecting the success or failure in a.ssuring the quality and safety of nuclear power plants.
While we agre) that a poor qual.ity assurance program is an apparently good quality assurance indication of poor management, an We program does not necessarily imply the presence of good management.
organizationally independent quality assurance see the need for an department that reports to senior management; however, we fear that the emphasis on independence has in some cases led to the belief that the assurance of quality.is someone else's responsibility.
To assure and public safety, a strong sense of the need for and the quality benefits from quality, the assurance of quality, and professionalism The should permeate a licensee's and/or a vendor's entire organizatia.
v Honorable Nunzio~J. Palladino March 21, 1984 NRC should continue its efforts ~ to stimulate this kind of profession-alism in the nuclear industry.
One of the rec.ommendations from the management analysis conducted by N.
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Kist & Associates, Inc. is to establish a quality assurance program within the NRC.
Although noted in passing in the report, it remains a fallow recommendation.
The report does contain a recommenda-
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tion for performance audits of NRC QA activities.
However, we believe that the relationship between QA and prudent management, as discussed in Section 3.5 of the report and in this letter above, is equally applica-
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ble to the entire NRC.
Therefore, we suggest that the Commission give prompt and careful consideration to the recommendation that the NRC establish a program to assure the quality of its activities. We do not believe, however, that a formal QA program is necessary or desirable.
The recommendation that the NRC estat,lish a body of experts to advise the Commission on the capability of applicants to effectively manage a nuclear construction project is worthy of further consideration.
The ACRS currently does not contain extensive expertise of the types envi-sioned for the proposed advisory body, and to establish such expertise within the ACRS membership might sacrifice other requisite expertise.
The report has also recommended that future construction permits be conditioned on a demonstration of the licensee's continuing ability to effectively manage the project.
Those responsible for the development of these recommendations should consider the difficulties associated with judging such management capabilities.
The ACRS supports the NRC Staff's shift i r.
inspection emphasis from looking at the content of quality assurance plans to looking at actual plant quality and at the implementation and effectiveness of programs to assure quality.
However, we believe that the NRC Staff will experience difficulties implementing the modified insp'ection program until perfor-mance criteria are established.
Useful insights have been obtained from Integrated Design Inspections (IDIs),
Independent Design Verification Programs (IDVPs), and Con-struction Appraisal Team (CAT) inspections.
We recommend that for the present these inspection programs continue.
The concept of using fesignated representatives is worthy of further consideration.
In addition to augmenting NRC resources, it may be a way of stimulating and rewarding professionalism and dedication to quality in the workplace.
We would like to be kept apprised of the NRC Staff's efforts regarding the designated representative concept and other QA initiatives, and we would appreciate the opportunity to coment on them at a later date.
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i' Honorable Nunzio J. Palladino March 21, 1984 Additional comments by ACRS Member Glenn A. Reed are presented below.
Sincerely, l
Jesse C. Ebersole Chairman
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Additional Comments by ACRS Member Glenn A. Reed I consider the report to Congress to be deficient in its study of Alternative b(4), and I am concerned that Congress may continue endors-ing regulatory approaches that are too similar in many ways to those that have in the past proved ineffective.
I concur with this ACRS report concerning the above referenced report to Congress in most aspects, but in my opinion it does not go far enough, and is not crit-ical enough with respect to the following:
1.
The ACRS report states that the report to Congress "gives thought-fui attention to the five alternatives I disagree that thoughtful or appropriate in-depth attention was given to Alterna-tive b(4), which addresses improvements in the NRC's organization, methods, and programs for quality assurance.
2.
The report to Congress recommends that a body of experts be estab-lished to advise the Commission on an applicant's management capabilities.
The ACRS report states that this recommendation is worthy of further consideration.
I disagree, and do not feel such expertise, with the time and objectivity, could be constituted to undertake this activity.
Further, I disagree that such a body of experts is even desirable or necessary if a more astute study of Alternative b(4) is made.
3 What the ACRS report does not address, or recommend, is more in-depth consideration of the NRC's crganizational structure, and what obstacles this present structure may place in the path of achievir.g quality > in design and c~onstruction.
The present NRC structure does not motivate professicnalism and craftsmanship in the workplace.
In my opinion, high cuality can only be achieved by the enthusiastic and dedicated action of real professionals and crafts pecole who are motivated to standards of excellence by a regulatot* structure that better reccgnizes human factors.
I am aware of and have read an NRC Staff report which addresses the FAA designated representative (DR) system.
In my opinion, the report to Congress should not have glossed over the FAA's DR program, but should have included a detailed study of that system and its poter.tial for correcting the adversarial climate that is growing in the nuclear workplace.
Given the current structures of the nuclear
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Honorable Nunzio J. Palladino March 21, 1984 industry and the NRC, the genuine professionals and crafts people are somewhat overwhelmed by top brass and regulations, yet the answers for real quality in this highly technical nuclear industry lie with those professionals.
In my opinion, the achievement of a high degree of design and construction quality can come from a modified version of the FAA system of DRs in design and architect-engineer organizations and in manufacturer and constructor shops.
I would consider it appro-priate for these DRs to be nominated by their peers, approved by
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their employers and perhaps the NRC, then established in a quasi-regulatory role while continuing their regular duties.
Along similar lines, the NRC might cons'ider structuring some licensed personnel in nuclear power plants into a DR system somewhat similar to the way in which the Massachusetts Department of Public Safety has incorporated licensed operating encineers into its regulatory structure.
References:
1.
Public Law 97-415 NRC Authorization Act for Fiscal Years 1982 and 1983, Section 13 on Quality Assurance, dated January 4,1983.
2.
Draft NRC report to Congress, " Improving Quality and the Assurance of Quality in the Design and Construction of Commercial Nuclear Power Plants," Revision 3, dated March 13, 1984 f
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