ML20136B616
| ML20136B616 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, 05000000 |
| Issue date: | 12/23/1983 |
| From: | Gilinsky V NRC COMMISSION (OCM) |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20136B092 | List:
|
| References | |
| FOIA-84-293 NUDOCS 8601020690 | |
| Download: ML20136B616 (352) | |
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ME".ORANOUM TOR dHE OP.t'ISSIONEES 3(ge#4 smtLo St3 JECT: COP.MIRCIAL LICENSED OPERATING EXPET.!ENCE OF DIABLO CId; YON LICENSED OPERATORS (loe, I hc.e attachec c cer.pendiu.m, prepared at my request, on the ~
experience of personnel at Diabic Canycn. I was perticularly interested in the commercial licensed -
experience'of the operati:5 crews. .
Sadly, it appe.ars that oh.17 three of the licensed operators on shift cre represented as havine any prier-licensed corrercial experiened,74nd :tt.at was at IGt.E's Hur. belt 3ay -
power plant, a E5 .%'e-bc-iline water reacter which has been shut dow. for sene yecrs'. Sene of this experience is nore recen: than 10 year.s..~cic..cnd. ene of these opere ors had only about a year and a 3.31r'~s experience a s a centrcl operater.
I v:uld nr : describe snar of thir zs relevin: normerciel licent.ec experience. T'n i r , in cifect, pure Dic.52o Canya i:-
- .S c :-ame ct.tegory as Sh'drFhMr. and Grand Gulf.
This ii.e.n ensaticiactcry sta:r cf affairc. .
At a b'are mini. m, the Cc: .:ission should recuire tha any escension, to power be"it"gced deal more graduci than usur.1, -
cnd rubf.ect te formal writations at each stage by the Ocmpe.::y and the Cc. . .issien.,- /
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4 RECOGNITION OF ROOT CAUSES OF QA PROGRAM FAILURES -
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- For the site assessments conducted to date, we have always probed the area
' of how a utility recognizes or can learn to recognize when they have
, serious problems with their quality assurance program. We have visited utilities that have had serious program failures, some of which recognized
- it at the time and some that did not. We have also visited utilities that
- seem to be doing something right and avoiding what could be termed a complete quality program breakdown. What make's one program different from -
another? Why can one utility seemingly get to the root causes of programmatic short comings they may be experiencing? Why would another utility never get beyond the stage of treating only the symptoms of j quality program failures? This paper will explore these questions and try
[ to clarify why some utilities apparently have more success at identifying root causes of deficiencies in their programs than others.
..! First, let us examine some of the reasons why utilities have difficulty in recognizing root causes.
In all fairness to the utilities, the difficulty in recognizing root causes can apply to any industry or government agency for that matter. However, I .
industries involved in building a one-of-a-kind item like a nuclear plant are at a disadvantage when compared to those who are into mass production.
The mass, production industries can rely quite heavily on statistical tools to monitor the assembly line and traditional quality cost data to evaluate the success of the quality program. Utilities, in, building nuclear plants or even a fossil plant, are unable to use statistical approaches or quality 7~
cost data to any great extent. Instead, the utilities must rely on more j
' subjective methods of assessment based on rather diverse data which only -
provides clues to the relative soundness of the quality program. When the utilities were questioned along the line of how would they recognize
- whether their quality program had serious shortcomings, their answers were I
generally in two parts. First, they said there is no one thing they can look at and gauge the quality program performance. They have had to learn
! to read messages from many sources. Secondly, the interpretation of these --
l messages is difficult at best and subject to error because of the subtieness of the messages being conveyed.
l For instance, quality trend reports are used'as one important source of
- information. The reports are generally a compendium of various classes of i
inspection data (civil, mechanical, electrical,-etc.), inspection -
j surveillance input, discrepancy reports, corrective action data and audit i_
results. The data is presented in such a way that quality trends, both '
j positive and negative can be identified-in.all the reported categories, The reports, however, do not address more than the first level of causes of 1 problems. To get at root causes, (if there are any) requires skill on the I
I part of management in evaluating this data against other sources of information. Identification of root causes also requires management to
( recoguize that they, in some cases may be the source of major quality i prnoram deficiencies. Recognition that management may be at fault is difficult for many company executives to accept, i.e., the utility in e
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p Case A had a string of successes with the constructfon of ' fossil plants.
. O They expected similar success with their first nucle'ar plant by following the same management philosophy that had worked so well previously; that philosophy in retrospect was proven to be inadequate. At the time, however, senior management refused to believe anything really serious was
- wrong in spite of many messages to the contrary. All problems.were either thought to be isolated occurrences, due to more robust plant design, or growing pains of the organization. It was not until about six months after the-shutdown order was issued that management realized the true nature and extent of their quality problems and embarked upon sweeping changes in how -
the project was managed.
' It can be difficult for management to accept that they really do not understand how to successfully complete a project they have begun, that their judgment can be wrong, and that their management or oversight of a project may have. serious shortcomings. First it is difficult for anyone to admit they have made or may be making a mistake. This may be more
- ' difficult.in some cases for persons, such as senior management, that are h.igh achievers and are used to success. In addition, these people may be -
l the same ones who supported embarking on the nuclear project and be hesitant to admit to mistakes or errors in judgment. To do so may subject J them to criticism from the board of directors and stockholders and possible -
removal from their positions. In any case, management that is not willing 4
to subject themselves to a critical self-appraisal may let. quality program
] problems beccme intolerable before taking any action. ~
Management perspective enough to realize they must continually be wary of Q
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unknown programmatic deficiencies will seek out all the information they can. Once the information is available, there arises a new problem: how to interpret it. Accurate interpretation is confounded for several reasons:
- 1) The construction project organization is always in a state of flux.
i The life cycle of a nuclear plant from start of construction to the ,
i operations phase continually has new organizations appearing or j disappearing and new interfaces _being developed. Keeping up with the changes is difficult in itself let alone trying to assess their ~
effectiveness.
- j ' 2) Feedback on programmatic changes is slow in coming. It may be a
- month, a year,' or longer, before the effectiveness of a change 'can be fully analyzed and its effects known.
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' 3) No real basis exists for comparison of-information. It is difficult for a utility to know what is right when there really are no standards i
for measurement other than intuitive standards, e.g., are the number of discrepancies reported on concrete work more or less than should be
- expected? Are the number of design changes being processed excessive
..! at any-one point in time? Utilities that have already been through
! the constre:: tion of one nuclear plant have honed their intuitive 1 ), judgment, and thus, have a great advantage over those that are wrestling with their first. As~one senior manager stated, "You have
' to have built one of these things before so you really know what to look for." .
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- 4) The messages may be confusing. What one source says may be C contradicted'either all or in part by another. In the case studies, examples were seen where construction was :aying the nature and number of discrepancies being reported are not out of the ordinary while the Quality organization was saying the opposite.
- 5) The messages may be misleading. If messages do not carry an overtone of programmatic caution, information that management receives may give a false sense of security. Reports that state there were problems but I
they have been or are being fixed can lull management into a state of -
complacency. Messages which originate from the NRC focusing on any specific hardware issues can also reinforce a tendency to believe there are not any significant programmatic problems.
c6) The messages'may be incomplete. First of all, no 'one likes to admit I he cannot sn_1ve a problem.that is in his area of responsibility. Its
> solution may lie beyond his capacity but he may not recognize it.
j Thus, he may be hesitant to escalate it to higher management.
- Secondly, he may find that management's receptiveness to hearing 'Sout -
- problems is not very open and he may be the object of recriWt.on, j .
If this is the case, he will learn to live with his problers .a;.ier 4
than get them solved by escalating them to 'someon'e who has the '
authority to do so.
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What then can the utilities' management do to foster separation and identification of root causes from symptoms? The following are desirable management characteristics or practices observed at sites where significant h quality program deficiencies had not been observed, or where effective project management systems were in place.
j First, management must never have a sense of well being. They must always be on guard for anything seriously amiss 'that they have failed to recognize. As one manager at a successful utility stated, "We certainly do a lot of looking over our shoulders to avoid being unpleasantly surprised."
j j Secondly, management must obtain performance information on their project "
from as many sources a's possible. The more sources that are used, the
- !' better perspective management will have. This means in addition to developing comprehensive in-house reporting systems on quality performance and identification of systemic problems, external sources of.apprais'al frequently obtained. These include the use of INPO evaluators, i
I construction assessment teams, NRC esident and regional inspectors, ASME -
.1 survey teams, and special consultants. Very importantly, the senior
.,I management must also frequently visit the construction site to discuss with the doers how things are progressing and observe for themselves what is
.l happening. This can be an immense help in putting all the messages in perspective and arriving at any programmatic problems.
.I h Manaaement must also be willing to swallow their pride and cause' change i when evidence shows that the. system is not working or needs improvement.
'l At the same time, they must address problems with an open mind and always
- i , remember to attack the problem and not the people who surfaced it. To do l
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.- t g otherwise wil'l cause programmatic problems to remain hidden and unresolved" which will lead to great frustration on the part of .those trying to work with an inadequate system.
Skill must be developed in interpreting the messages received. Management at all levels.and specifically middle management must recognize most messages will be couched in terms of specific data points such as the number of non-conformances' or audit results pointing out non-compliances.
They must learn to look beyond this data and perform a subjective analysis to answer whether a systematic fault exists. This skill is developed ~
primarily through experience but can also be developed by visits to and sharing information with other utilities. '
Once a programmatic problem is identified, care must be exercised to ensure that the root causes of the problem are addressed. It does no good to apply a superficial fix. If the underlying causes are not addressed, the problem will surface again later. " Band aid fixes" will do little to stop a massive hemorrhage. The problems Case A utility experienced with their :
nuclear quality program are a very good example of this, point. Their '
repeated fixes to chronic symptoms did little to make the~ root'causes go away. Learning to identify root causes is sometimes looked upon as a black art; however, the principles of systematic problem assessment are known*-
and must be learned and applied by management; and finally, management must be committed to infusing a systematic approach to problem solving at all levels in the organization so that problems are solved at the level which can best provide the solution.
b In summary, the identification of root causes as well as symptoms is a very necessary part of management of a nuclear construction project. i It is a ,
difficult process due to the. one of-a-kind nature of the job, the constant state of project change, slow feedback on effectiveness of changes, and the subtle performance. and differing messages that are received by management on program .,
The process of identifying root causes, however, is not an impossible one. Key elements of the process require management to be open >
minded to criticism, to create an atmosphere where problems can be solved, ..
to have developed skills in interpreting feedback, and to cultivate as many feedb:ck channels as necessary for a balanced perspective. Most importantly management must. make it clear to everyone on the. project there is an expectation that programmatic problems need to be continuously identified and resolved at all levels of the organization. "
P For example, the book, The New Rational Manager, by C. H. Kepner and B. B. Tregoe, Copyright 1981, Princeton Research Press.
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NRC REVIEW .
i JOHN L..HEIDENREICH
$ RICHARD M. KLECKNER
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NRC REVIEW SCOPE:.
o REVIEW OF PAST AND PRE'SENT NRC PROGRAMS FOR THE ASSURANCE OF QUALITY IN DESIGN,: PROCUREMENT AND CONSTRUCTION.
o REVIEW AND ANALYSIS-0F MANAGEMENT RELATIONSHIPS -
ASSOCIATED WITH IMPLEMENTATION OF.NRC PROGRAMS FOR THE ASSURANCE OF QUALITY IN DESIGN, PRO-CUREMENT AND CONSTRUCTION.
o DETERMINATION OF-ROOT CAUSES OF NRC:
- INABILITY.TO PREVENT PROBLEMS; h - SLOWNESS TO IDENTIFY /ACT ON PROBLEMS;
. AT DIABLO CANYON, MARBLE HILL, MIDLAND, SOUTH TEXAS AND ZIMMER.
- o. REPORT OF FINDINGS AND' RECOMMENDATIONS.
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-4 NRC REVIEW ELEMENTS OF REVIEW:
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o ENABLING LEGISLATION o STANDARDS PROGRAM FOR ASSURANCE OF QUALITY o LICENSING PROGRAM FOR ASSURANCE OF QUALITY !
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, o INSPECTION PROGRAM FOR ASSURANCE OF QUALITY o LICENSEE CONTRACTOR AND VENDOR INSPECTION PRO-
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..4 GRAM b o ENFORCEMENT PROGRAM o PREVIOUS STUDIES OF NRC PROGRAMS FOR ASSURANCE '
0F QUALITY, THEIR FINDINGS AND RECOMMENDATIONS,.
AND NRC RESPONSE 6 o LICENSEE AND CONTRACTOR COMMENTS ABOUT NRC DURING SITE ASSESSMENT CASE STUDIES L
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ASPECTS OF REVIEW:
l o NRC CHARTER AND CHARTER OF MAJOR FUNCTIONAL ORGANIZATIONS.
- o. ORGANIZATIONAL STRUCTURE.
j o PHILOSOPHY O'F MAJOR FUNCTIONAL ORGANIZATIONS o,
FUNCTIONAL RESPONSIBILITIES o RESOURCES
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o QUALIFICATION AND TRAINING OF PERSONNEL o INTERFACES .
o VERIFICATION OF PERSONNEL PERFORMANCE o VERIFICATION OF PROGRAM IMPLEMENTATION o QUANTITATIVE ANALYSIS-0F INSPECTION. PROGRAM IMPLEMENTATION 9
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o VISITS TO NRC HEADQUARTERS I
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o REPORT OF FINDINGS AND RECOMMENDATIONS L s
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o INITIATION OF LITERATURE REVIEW o VISIT TO REGION II (JULY 12 & 13) y .
o VISIT TO REGION IV. (AUGUST 16 & 17) o VISIT TO NRC HEADQUARTERS (AUGUST 30 & 31) 4 M-4 ,
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ll PRELIMINARY FINDINGS o MORE PRESCRIPTIVE CRITERIA MAY BE NECESSARY
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- QA REQUIREMENTS
- SAFETY-RELATED ITEMS
- INSPECTION PROGRAM
', o. METHOD OF HANDLING ALLEGATIONS AND.SPECIAL INVESTIGATIONS-NEEDS IMPROVEMENT a
o ANALYSIS AND SHARING OF INFORMATION NEEDS IMPROVEMENT -
o EMPHASIS.NEEDS TO BE CHANGED FROM REACTIONARY TO PREVENTIVE o IMPROVED COORDINATION OF RESIDENT, REGION AND HEADQUARTERS PROGRAMS MAY BE NECESSARY o-INCREASED TRAINING OF PERSONNEL-MAY'BE NECESSARY o RESONRCESAREINADEQUATEFORWORKTOBE PERFORMED
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o INCREASED ENFORCEMENT OF REQUIREMENTS IS NECESSARY o TEAM INSPECTIONS HAVE BEEN SUCCESSFUL o
NRC NEEDS MORE FORMALIZED QA PROGRAM a
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. l CONSTRUCTION CONTRACTING AND LABOR AGREEtiENTS O
9 I. CONSTRUCTION CONTRACTING AT NUCLEAR POWER PLANTS The purpose of this paper is to discuss preliminary conclusions, based on the first three site visits, relative to the impact of construction contracting and contractors on quality in the power plants. Major problems with construction work quality have been identified at one of the three sites and not at the other two. Further, there are both similarities and differences in approaches and practices between all three sites in contracting and managing construction work.
Four major factors have'been identified in this area. Although these will be discussed separately they are closely interrelated. The factors are:
e Fixed price vs cost reimbursable contracts
, e Level of management control exercised by the utility e QA/QC by the construction contractors or by the utility e Experience a,nd know-how.
Q l. Fixed Price vs Cost Reimbursable Contracts The time honored method of contracting for regular commercial construction work by fixed price contracts awarded by competitive bidding can result in problems for several reasons. One of these is that nuclear plant construction work is not only more demanding but is more difficult than commercial work.
Concrete placement, for example, is more difficult because there is generally ~
more congestion of re-steel and enbedments and the concrete is required to be of 'a significantly lower slump than in consnercial practice. Greater skill and care in placement is theref>re required, and many bidders may not recognize this.
Another problem in fixed price contracting is the more extensive QC inspec-tion practices. .It can come as a big surprise to the contractor when the ~
specifications are rigidly enforced, which is not always the case in commercial practi ce'.
Fixed price contracting is not suited to accommodating large numbers of changes, and there are lots of changes for lots of reasons during the construc-tion of nuclear plants. This situation can rapidly erode any cost advantage that
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might be gained over cost reimbursable contracting.
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. One of the worst situations for the construction manager and/or owner is to have a fixed price contractor on the job who is losing money. The approach to solving problems tends to become adversarial rather than cooperative, inter-pretations of requirements will be contested, minimum effort applied, and the owner suddenly finds he has lots of probl. ems.
Only one of the three sites visited 2 date has used fixed price contracting extensively, and this is the only one that had experienced serious problems in ~
construction work quality. Part of the corrective action at that site was to change all the major construction contracts to some type of cost reimbursable form. Which brings us to the second point in this discuss son, the level of management control by the utility at the construction site.
- 2. Level of Control of Construction the Utility '
At all of the first three sites '
the on-site construction activities are now closely managed by the utilit. s has been accomplished in part by the extensive use of cost reimbursable co. ion contracts.
Work planning, sequencing, coordinating between contractors, and s'.:affing h levels are directly controlled by the utility's onsite staff. The construction contractors contribute their expertise in these matters but the decisions are "made by the owners.
This is considered to reflect a conclusion by utility management that t'he owner is ultimately responsible; therefore, they have established a situation where the owner is also in control. Hence this extensive use of cost reimbur5'-
able contracts. An incentive fee arrangement is commonly utilized to help control costs and schedule. -
- 3. QA/QC by Contractors or Utility
- The practice of general contractors c'oing their own QA/QC is still a relatively new situation in the construction industry. Although this may be
. feasible.it is the kind of change that requires a long time to become accepted.
and to be effective.
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'. . Assigning inspection to CpFF contractors was tried many years ago at O
Hanford. This was quickly abandoned in favor of inspection by engineering, the operator, or the owner.
There are some notable exceptions where fixed price contractors provide their own QA/QC successfully. These seem to be primarily contracts for specialty items that are under the ASME code requirements.
The notion behind contractors doing their own QA/QC is that it is part of ~
keeping the contractor responsible for quality. However, the contractor can still be held responsible for the quality of his work without extending to him the determination of whether or not the quality requirements have been met. At all of. the sites there seemed to be an attitude of "Do it right the first time."
However, "right" has to be defined by someone and delegating this detennination to the construction contractor is risky. '
There are variations in QA/QC between the three sites visited; however, all three are connon in one respect: the utilities maintain an extensive QA/QC I
effort of their own. This function is performed directly by the utility on some parts of' the work, and an extensive, active surveillance is maintained h over contractors doing their own QA/QC.
This practice is one of the early major changes made at the site that.had serious construction quality problems.
- 4. Experience and Know-How ,
i The level of experience and know-how provided by the crafts people that " ,
actually do the constructior, work is relatively independent of the contractors.
In general they all rely on the labor union hiring halls to provide the workmen.
There are some workmen that go from job to job with the same contractor but this i is generally a very small number. ~
Qualification testing is required of some crafts but not all. Some job sites are conducting craft training programs, and in general there is at least an orientation program to acquaint workmen with the special job requirements and high standards expected.
This factor of experience, therefore, is most important relative to the '
construction contractor's management people. At.the sites we visited these s v
. _4 managers were at least experienced and knowledgable regarding construction and mos't had experience in nuclear work.
It is necessary, however, to evaluate such experience carefully. For example, the utility at the site that had construction quality problems had relied on the contractor's previous experience building nuclear plants. When this was probed with a contractor site manager it was found that the contractor had been on other nuclear projects but had actually functioned only as a labor -
broker and the utility really managed the job. Experience of this type is of
. / only limited value in providing a full understanding of nuclear plant construc-tion.
Another example of the need to carefully evaluate the worth of previous experience is that cited by another contractor at another power plant. The previous experience cited was the construction of three earlier reactor plants. *
'On the basis of personal knowledge, the contractor had no involvement in quality control functions on those projects; therefore, that experience was of limited value.
Previous experience in and knowledge of nuclear plant construction can be h very valuable. However, the worth of such experience must be carefully evalu-ated on the basis of the functional responsibilities the individuals in the contractor's management really had.
During the three site visits a sampling of contractor management and craft supervision revealed a range of attitudes about nuclear plant construction:
a) Some are challenged by this work and want to continue in it. ~
b) Some are concerned that their indoctrination in the more demanding nuclear work will make it difficult for-them to compete in other connercial construction.
c) Some react negatively to the more structured and controlled environ-
- ment of nuclear work-including the additional paper work, and wild' prefer to return to nonnuclear projects..
The' differences between traditional commercial construction and nuclear plant construction are very great. It is essential that these differences be recognized and understood in order to assure that the required quality is obtained.
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9
II. LABOR UNION AGREEt1GTS
- -f Subsequent to the three site visits additional information has been obtained about the agreements with the construction craft unions.
t At two of the sites the utilities have established " Site" or " Project" agree-i ments with the local unions. This is not the case at the third site visited. In l that instance each contractor has its own agreement that has basically been l established through the Association of General Contractors (AGC). That site is ~
the only one of the three that has experienced a major work stoppage due to union issues. The stoppage occurred in 1974 and lasted five (5) months. The two sites with Project agreements include the following similarities:
e No-strike clause e No scheduled coffee breaks .
- Agreement effective 'to completion of construction e Employer selects all supervision, including foremen and general foremen e ~ All contractors must abide by the agreement.
The followi.ng table identifies some of the differences between these two Project agreements. In addition to those shown there are also some differences in the handling of shift work and in the bases for overtime payment; however, these are not discussed here.
Item Case A Case B
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- 1. Definition of Includes the utility. Contractors only.
" Employer"
- 2. Use of Union Can reject any referred Not specific, but owne3 Hiring Hall applicant. , reserves rights.
If union does not fill employee requisition i within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, employer can hire direct.
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- 3. Use of Apprentice Union must provice appren- Policy is to use maximum Helpers and- tices, helpers and number of apprentices, Trainees trainees to maintain at helpers and trainees in least one to every five separate, local agree-a journeymen, or employer' ments; no recourse may hire directly to provided.
maintain that ratio.
- 4. Purchased material Employer not restricted Utility only not and equipment and (includescontractors). restricted.
- installation of
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CONSTRUCTION WORK l-
- CASE A - MAJOR PROBLEMS IN 1979, NOW
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. ASME CODE COMPLIANCE CASE B - NO SIGNIFICANT PROBLEMS ,
i CASE C - NO SIGNIFICANT PROBLEMS l
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i FIXED-PRICE AND PROBLEMS t e NUCLEAR CONSTRUCTION MORE DIFFICULT THAN USUAL COMMERCIAL .
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e MANY CHANGES e TROUBLE IF A CONTRACTOR IS LOSING MONEY.
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LEVEL OF CONTROL BY UTILITY l e UTILITY IS THE ONE RESPONSIBLE '
e ALL-THREE CASES - UTILITY IS
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! QA/QC BY CONTRACTORS OR UTILITY i .
j e RELATIVELY NEW TO CONSTRUCTION
. INDUSTRY i '
e RESPONSIBILITY ~FOR QUALITY OF WORK ~
e SEPARATE: DETERMINATION OF ACCEPTABILITY j
e "DO IT RIGHT THE FIRST TIME"- WHO DEFINES "RIGHT"?
e ABANDONED TRIED ONCE AT HANFORD (GE) AND QUICKLY e ALL;THREE SITES NOW HAVE HEAVY QA/QC -
BY UTILITY (MULTI-LAYERS) e EXCEPTIONS IN ASME CODE WORK
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i EXPERIENCE AND KNOW-HOW e lMPORTANT FACTOR IN CONTRACTOR l MANAGEMENT l
e SAME WORKMEN REGARDLESS OF
{ CONTRACTOR i
-QUALIFICATION TESTING OF SOME l -ORIENTATION AND TRAINING e EXPERIENCE OF CONTRACTOR MANAGERS IMPORTANT e EXPERIENCE MUST BE EVALUATED l
i CAR EFULLY~
-PROBE ACTUAL FUNCTIONAL RESPONSIBILITIES
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i e RANGE OF ATTITUDES AT SITES VISITED i '
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- LABOR AGREEMENTS 4
i i e 3PROJECT SITES AGREEMENT WITH UTILITY AT 2 OF .
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j e ONE SITE - CONTRACTORS HAVE OWN AGREEMENTS i
i e PROJECT AGREEMENT SIMILARITIES .
-NO STRIKE
-NO COFFEE BREAKS '
-AGREEMENT TO CONSTRUCTION COMPLETE ,
<-EMPLOYER SELECTS SUPERVISION
-ALL CONTRACTORS 1
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. EMPLOYER CAN REJECT NOT SPECIFIC
! HIRE DIRECT AFTER i 48 HOURS i
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! JOURNEYMEN OR CAN MAX. IN LOCAL
! HIRE DIRECT AGREEMENTS
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e i INSTALL ITEMS PURCHASIED EMPLOYER NOT RESTRICTED UTILITY ONLY NOT 4
RESTRICTED I
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, IMPACT OF LONG CONSTRUCTION TIME
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Page 1 of 4 U
IMPACT OF LONG CONSTRUCTION TIME FOR NUCLEAR POWER PLANTS i
I During one of our case studies, a highly regarded A/E project manager stated
. that every nuclear power plant construction project with problems has a common
- thread, the common thread being the extended time period from issuance of the construction permit to issuance of the operating license. Whether the long- -
- time period required to build the plant is actually the cause of the problem
! or a result of problems during construction is a matter which bears further 4
discussion.
i Five nuclear power plants receiving videspread attention as having had or l are currently having serious quality problems include:
Marble Hill Midland .
j Zimmer
- South Texas Diablo Canyon j As can be seen from Figure 1, these five plants now have scheduled construc-i tion -rimas which will run from nine to fif teen years.
1 The first four sites listed.are probably taking a long time to construct i
h because each of the utilities involved has, as a result of its own activities, created numerous delays at the site. These delays were caused when quality j problems surfaced and the fixes-of these quality problems resulted in license ~
suspensions, construction halts, or other delays in order to correct the problems. I suspect that these four utilities have not yet seen the end of i the extended time period because the time required for completion always j increases', it never decreases. Because of-the long construction period,'they
, may experience problems of a nature similar to those which caused the long l period for Diablo Canyon, resulting in further licensing delays'for these. --
plants.
{
! Regardless of the reason which caused the long time period for construction of th's plant, the long time period involved creates many problems which fur- .
! ther extend the period. Early dels.ys create additional delays as work pro-gresses toward the operating license. Some of these problems are shown on .)
Figure 2. ':
t 4
- 1. It is extremely difficult to keep a knowledgeable project team together j for the construction project because
i ;
{ a. people retire, eg. a Diablo Canyon operator retired without ever l operating the plant. (I also suspect that some die of old age
- during the project).
j b. personnel get promoted out of the project; it is normal that l personnel want to move on to more responsible positions and it ,
'may not be possible 'within the project. [
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Personnel changes break the continuity and it is difficult for anyone i to know why things were done in certain ways; when changes are made l
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Page 2 of 4 it is difficult to keep the details from falling through the cracks. r
,3 It is also difficult for the personnel involved to maintain much enthusiasm '
for the project resulting in lower morale. j 2.
Changes in the state-of-art may make additional modifications necessary.
Looking at an earlier plant design through today's eyes will usually generate a conclusion of marginal design / construction.
- 3. Changing and tightening regulatory requirements during the course of con-
+
struction requires both design changes and construction modifications to _
meet the new requirements; each (f these changes further increases the time period to build the plant. '
- 4. The longer time period subjects the construction to events which may cause further delays. Some exsaples of these are the Hosgri seismic problem at Diablo Canyon, enviromental reporting requirements due to the Calvert Cliffs' decision, retrofits result?.ng from the Brown's Ferry fire, and, of course, the retrofits required by the Three Mile Island incident.
S. Each day that a plant is delayed during construction creates additional opportunities for those opposed to the plant on principle to cause further delays. This factor coupled with events described in Item 4 can create additional delays and may take valuable manpower from the construction project to respond to the charges raised by the intervenors.
6.
The delays result in increased cost to the utility. Factors affecting the cost are:
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- s. Cost of repairs resulting from quality problems.
- b. Cost of modifications and retrofits resulting from changes in -
the state-of-art and in regulatory requirements. i
- c. Personnel requirements, both from increased numbers to. provide for -j repairs, modifications, and retrofits and from having to meet many additional payrolls.
- d. Inflation.
High rates of inflation and soaring interest rates during ..
the late 70's/early 80's has impacted the cost of delay much more ,
significantly than could have been imagined when the plant was started.
- e. Interest on construction borrowing. This is a factor if the state ;
has no CWIP. :
- f. Cost of power purchased from other utilities.
- 7. Does the long time period which is required to build some power plants . .
have a positive or negative impact upon the quality of the construction -
at the power plant? Let's look at each.of the above items and consider what effect it might have had on the construction of the power plant from a quality standpoint:
- a. Lack of continuity of personnel on the project will probably have a i negative effect on the overall quality. There is always a possibility ;
of errors creeping into the project from failure to understand the "why"'something_was originally done the way it was. '
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Paga 3 of 4
- b. Looking at an old plant design through today's eyes will probably Qv bring about additional changes. Each change is another opportunity for error to creep into the system.
- c. Each modification or retrofit due to regulatory changes will also provide another opportunity for errors.
- d. Retrofits caused by the unfavorable events also provide opportunities for errors;~e.g., the mirror image problem at Diablo Canyon,
- e. The effect of those opposed to the plant on principle is obvious.
- f. Increased costs resulting from the above factors.could cause more pressure to meet schedule with more corner cutting activities. -
It would appear that the effect of long construction time is negative.
From my coauments on the impact of long construction time periods for nuclear power plants, it appears advantageous to construct the plant in the shortest possible time period. Let's look at the advantages shown on Figure 3:
- 1. Continu'ity of project personeel provides for better knowledge of the "why" things were done. Morale should be better because personnel can see the positive results of their efforts.
- 2. The plant is constructed to the design according to.those codes, stan- '
dards, and state-of-art in effect at the time the construction permit is issued. During a relatively short time period, changes would probably be of a limited, nature and have a minimal impact on the construction of the plant. -
- 3. Regulatory requirements in effect at construction permit issuance would not normally change significantly in a short time period.
( _
- 4. There is less opportunity for events to occur which would result in modifications and retrofits during the construction period.
- 5. If Items, 1, 2, 3 and 4' work as described, there is less opportunity for those opposed to the plant on principle to have a major impact during the construction period. ,
- 6. All of the above factors contribute to reduced cost of the power plant by minimizing repairs, modifications and retrofits, reducing the number of personnel and total payrolls, reducing the effect of inflation, and ,
l significantly reducing the cost of borrowing money for the project.
- 7. The greatest impact ef a short constructica period is its favorable in- ,
j pact.on quality. Thja results from what it takes to build e quality j nuclear' power plant p ickly.
'a. The utility must s well organized with experienced personnel throughout the project organisation. i l b. ,
Management must be firmly committed to getting it done right i the first' time, j c. Design, procurement, construction, inspection and all related
- activities must be involved in the QA Pr'ogram. .[
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Page 4 of 4 i
- d. Astute selection of contractors including architect / engineer, construction manager, NSSS supplier and other vendors.
.)
Nuclear power plants in Japan are being completed in 48 mcnths from the first concrete pour to fuel load. They believe they could do it in 36 months with a certain amount of prefabrication work. Japan has a one-step licensing pro-cess. The only hearings are prior to issuance of the construction permit.
In the building of the power plant they must satisfy regulatory requirements or the operating license can be withheld.
A one-step licensing process could work satisfactorily in this country with hearings required to 'obtain the construction permit. All remaining activities would then be subject to approval by the NRC prior to issuance of the operating license. A one-step licensing process, if properly administered, could result in substantial savings in time and cost ,to bring a nuclear power plant on ;
line.
The short time period could have beneficial effects on the quality of -
construction of the plant. .
l Prepared by: R. M. Kleckner L N. C. Kist & Associates .
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Q I FIGURE 1 SCHEDULE YEARS * ,
PT. ANT C, P ORIGINAL CURRENT CP to OL MARBLE HILL 04/78 /82 12/86' 9 ZIMMER ,
10/72 /75 /84 12
' .12 SOUTH TEXAS' 12/75 10/80 MID 87.
MIDLAND 12/72 05/78 07/84 12 DIABLO CANYON 04/68 05/72 /83 15 ]_. .,
- NEAREST WHOLE NUMBER '
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! 1. LACK OF PROJECT PERSONNEL CONTINUITY fl '
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- 2. CHANGING STATE-OF-ART 6
- 3. CHANGINd/ TIGHTENING REGULATORY REQUIRE!!ENTS .
i 4. EIPOSURE TO DETRIMENTAL EVENTS Il 5. EXPOSURE TO THOSE OPPOSED ON PRINCIPLE i
, 6. INCREASED COST 4, 7. UNFAVORABLE EFFECT ON QUALITY e
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, FIGURE 3 IMPACT OF SHORT CONSTRUCTION PERIOD
- 1. PROJECT PERSONNEL CONTINUITY
- 2. MINIMAL CHANGE IN STATE-OF-ART
- 3. MINIMAL CHANGE IN REGULATORY REQUIRL%NTS
- 4. MINIMAL EXPOSURE TO DETRLMENTAL EVENTS
- 5. MINIMAL EXPOSURE TO THOSE OPPOSED ON PRINCIPLE 6.. REDUCED COST
- 7. FAVORABLE EFFECT ON QUALITI O
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r ORGAtlIZATIONAL SENILITY Richard Kleckner ff.C. Kist & Assoc.
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Pags 1 of 3 1
ORGANIZATIONAL SENILITY Bill asked me to talk on utility senility and its effect on the nuclear program, but I prefer to call my tdlk " Organizational Senility" because this is a disease j that affects not only utilicies but any type of organization whether it be in the private sector or a government agency.
As any type of organization grows, the founder finds he no longer can handle all ~
of the required activities. He has to establish an organization and bring in
- managers to handle the affairs of the business.
j Now human nature takes over. Top managers bring in as managers those people who
- basically think like them; af ter all, you don't really want people who make a lot of waves. In a conservative, old-line organization, promotions almost always come from within. It takes perhaps thirty years or maybe thirty-five years to reach.a real senior management position. After many years everyone thinka alike in the organization.
i To many' people, the senior management position may be looked upon as a " reward" for many years of service. At this point in a career a person realizes that the closer one gets to the top, the closer one is to the front door and has to have a real concern for job security. For a person with thirty or thirty-five years ,
service, retirement and a good pension are just around the corner. He certainly 7 doesn't want to rock the boat and would not want any of his subordinates to rock j the boat..
l
' () Organizational senility is self-perpetuating, and the. senility becomes like a cancer; it feeds on itself and continues to grow. The organization has arrived -
at a condition where it can be likened to an old elephant. There are always a
! few boat-rockers (the innovators, the doers) in any organization, and these i
people are always trying to get the elephant to move. They are usually behind the i
elephant pushing, trying to get that big, old animal to move along a little faster. Now we all know what comes from the back end of an elephant, and '
, unfortunately for these people it falls on them fairly regularly. These ,,
-people probably constitute no more than five percent of the organization.
j
-There is another group, probably another five percent of the organization and usually senior management personnel, who are on the front and of the elephant. . These people are trying to control its speed so it doesn't move '
too fast and to steer it so it doesn't wander very far from its current
., course. The other ninety percent of the people are simply not doing any-thing either way. They are just hanging on to- the sides 'of that big, old
~
elephant. And .the interesting thing,is that that' old elephant just keeps plodding along and very little that anyone does has any effect on its course or speed.
In a free enterprise system, where the organization is competing in the market place, one of two things happens. if the chain of senility remains unbroken.
' First, the ultimate disaster befalls ~ the organi:ation; it goes out of business.
Second,'the organization may encounter severe financial. problems, but if the
! crganization has the financial resources and makes drastic organizational changes, they may survive. We have seen this happen in the automobile industry
.( )f (Chrysler) in this country and see it beginning to happen in the steel indsutry.
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Page 2 of 3 Now let's see how organizational senility might apply to a utility. First of all, they have no competition from other organizations as they are a regulated j monopoly. No one else will be sneaking into their territory and supplying power ]' ;
to their consumers. Secondly, as long as they continue to produce power (there i j
is nothing more negative in the eyes of the consumer than not being able to have ;
the light go on when the switch is flipped) and they have an excellent relation- !
ship with their state rate commission and can pass their excessive costs due to senility through to the consumer, they probably won't have a serious problem {
with survival if the senility syndrome. is not broken.
I
.Let's also look at what some of.the utilities actually did prior to getting inc6 (
the nuclear business. Keep in mind that many utilities have done nothing l 4 xcept produce power.and negotiate with rate commissions. They have never even constructed fossil plants, i.e. all activities related to construction of a fossil plant were subcontracted. The utility simply turned on the plant when it was completed.
1 Suddenly, the utility craze, in anticipation of cheaper power, was " build a
, nuclear power plant". Many utilities had no concept of how to build even a -
simple item (fossil plant), and now they were tackling a very complex project.
The management structure of the utility, steeped in tradition and afflicted with
]^
the kind of senility discussed above could not adapt to a project which was so significantly different from the activities in which they had been involved.
' Here a very significant factor in organizational senility played a major role.
Inherent in organizational senility is the inability to _ bring in competent personnel at a.high level of management who have not " paid their dues" with years of, service in the organization. To bring in personnel at a high level of management would be very upsetting to the organization as a whole and par-h, . . ,
ticularly to the salary structure. We have aren this phenomenon in our case studies.
Perhaps the wrong type of organizations were actually charged with the respon-sibility for building nuclear power plants. Instead of the utilities building I the power plants, perhaps it should have been a G.E., a Westinghouse, Electric ,,
Boat or an aerospace firm. An organization with the experience of handling l complex projects on the leading edge of technology. The very early nuclear .
power plants were not built .by utilities _ but were subcontracted to other organizations much as those above. With some exceptions, it was not until i
~ utilities got into the picture of handling the construction of the plants, -l that we ran into significant construction problems, i Earlier, I pointed out what happens.to organizations competing in the market ,
place when organizational senility has become a serious problem. Only by top ,
management's recognition of the problem and a' strong commitment on their part to restructure the organization and reshape the policies which created - '
the problem, can the organization suceed in combating senility. But it usually.take's a crisis of catastrophic proportions to get top management's attention. And what attract's management's attention. that a catastrophe is impending? Usually.it is a condition .that has a very negative financial impact on the organization, such as an NRC stop work or show cause order j
which causes a long construction delay, a serious defect which could cause an unlicensable plant, or a.TMI type serious accident.
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1 Utilities without nuclear programs can probably survive with a relatively
()
severe case of organizational senility. If those utilities embark on a nuclear construction program, a catastrophic crisis will probably occur.
That some utilities have managed to avoid such crises may indicate no more than a moderate case of senility if it exists in those organizations. And if 4
some senility exists, experience of personnel on prior projects (for the same t
utility for those with ongoing programs, at other utilities, or at subcontractors) enables those personnel to perform their activities in a relatively effective i manner even though top management may not be actively committed to the project. ,
In fairness to utilities, I'think it appropriate to add a comment about quality f assurance and corporate management. Not only utilities have problems under- F standing.QA. The ASQC publica' tion QUALITY PROGRESS conducted a poll of chief i
! executives of several hundred of America's larger corporations and of the l
! consumers of the products manufactured'by these corporations. Only about one 1 i fourth of the chief executives responded to the poll. They consistently echoed 1 the theme that their products were of good quality, that if-there had been quality ;
Problems they had been resolved, and that today, their product quality was l certainly acceptable or at inast had improved dramatically in recent years. But ;
let's hear the users side of the poll. The users felt the' quality of the products {
they were purchasing was lower than in previous years and.their tendency was to '
purchase more foreign products and in particular, Japanese products. They j, i (users) believe that in foreign products they could obtain the quality which was absent from the American products. Interestingly, the Japanese say we taught them
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what we knew about quality; the difference is - that Japanese Management believed !
what we told them and set up programs (Management and QA) committed to achieving
-the desired quality level without penalizing cost and schedule goals.
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. Prepared by: R. M. Kleckner ~~
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HISTORICAL PERSPECTIVES- T i >
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Harold Harty [i Battelle-Northwest
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HISTORICAL PERSPECTIVES ON QUALITY ASSURANCE n .
The Atomic Energy Act of 1954 put the burden of responsibility for safety and operability of nuclear plants on the licensees. Many licensees, however, had typically depended on architect-engineers or equipment suppliers for overall integration of fossil generating station construction. The turnkey _
plants were a natural extension of this practice. When the turnkey era ended, licensees' capabilities to integrate plant design / construction were frequently inadequate. Some attempted to shift their responsibilities to architect-engineers and construction contractors, but with varying degrees of success.
Some eventually had their projects shut down by the Nuclear Regulatory Commission.-
The initial nuclear plants had quality built into them to the extent that they did because of capable, conscientious personnel. Because of the complexi.ty of
() thenuclearplantsand$hefactthatregulatcrsoftenlackedpracticalexperience in the technology, there'was a move to develop large numbers of standards. The .
use of standards is reasonable but, in many cases, they were introduced as a
~
comfort to regulators. Technical societies- contributed to the proliferation of standards, because there was no unanimity on the scope or application. The ,
balance that needs to be struck is between specificity and freedom to encourage ingenuity. bnfortunately, NRC tends to come down on the side of specificity.
The' turnkey approach gave good systems control, but did not involve utilities.,
Competent utilities are now assuming systems control responsibility.
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Into this background came the development of 10CFR50 Appendix B (the i quality assurance criteria). It was developed during the 1968-70 timeframe.
It was adopted as a regulation in 1970. The reaction to 10CFR50 Appendix B was one of confusion, complaint, and counter charges. Industry maintained
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there was excessive attention given to paperwork rather than substance. The AEC charged that there was a lack of adequate attention to quality assurance on the part of industry. These initial reactions gave way to the 'rainbcw books,' which were issued in 1973-74. The gray book pertained to design /
procurement quality assurance, the orange book to operations quality assurance, .
the green book to construction quality assurance.
Even as the quality assurance regulations were being promulgated, there were some in the utility industry that spoke out on the benefits of quality assurance.
One such-individual was Vincent Boyer of Ph'iladelphia Electric. His positive comments are listed in Table 1.
" Nuclear Industry" of 1974 had the following quotations from articles on QA appearing in it: " '
. "Our records show that there are fewer instances of gross error in '
construction and fewer of the dramatic construction mistakes than four or five years ago." J. P._0'Reilly, Region I
. "In today's market, it is hard to hire, keep, and motivate competent quality control people for construction sites."
Vincent Boyer, Philadelphia Electric Company ,
. " Good QA programs actually facilitate the timely completion of nuclear plant construction. QA accounts for 5-7% (mayb3'
10%) of project cost." L. Manning Muntzing
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,e O In 1974, the AEC promoted a number of new QA initiatives. These are 1
shown in Table 2. They include the Standard Review plan, regulatory guides, resident inspectces, compliance with codes and standards, and other initiatives.
Their findings from a review of licensee .QA plans in 1974 were as follows: '
. QA staffs are insufficiently trained
. QA plans are incomp'lete to the point of pinning down which people were to implement the various provisions
. Insufficient involvement by top management; lacked staff to implement; lack of provision for internal audit ,
With the formation of the Nuclear Regulatory Commission in 1974, the NRC spoke out strongly on quality assurance.
Mr. Mason said that the quality assurance)rogram "...is at the essence of the NRC's responsibilities. Strong, forceful, competent people assigned to the job are more important than the structure. We should pay closer attention to what paperwork is required -- what purpose does it serve. Quality assurance has been largely focused on the primary coolant system and safety systems to the detriment of plant reliability..."- , ,
Mr. Gossick said, "...it is ironic that the Regulatory Guides, designed to '
provide guidance, have frequently become major sources of frustration and confusion. Industry has complained -- and rightly so -- that the constant changes in the Guides create a moving target that is almost impessible to hit..."
It was.the result of this complaint that the NRC created theGdkRC -- the Ratcheting Connittee.
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1 ip Mr. Morrison spoke about the ANSI 45.2 Standard and its daughters. . . . You ought to apply only, first of all, those that are applicable and also those that are necessary to get what you want..."
-The comment was made in " Nuclear Industry" that industry's attitude toward QA this year was subtly but distinctly less petulant and more oriented to making
~
the system wurk more effectively. Industry spokesmen were' preaching the message of QA with conviction and from experience.
In 1975, the Brown's Ferry fire incident occurred. The~ following are quotat' ions from the March 1976 issue of " Nuclear Industry:"
. "The causes, course, and consequences of the fire are evidence of
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1 substantial inadequacies in the Brown's Ferry QA program."
"The evaluation of the events associated with the fire indicates that improvements are needed in NRC licensing, standards development, and inspection programs."
. "There is presently a notable lack of definitive criteria, codes, or standards related to fire prevention or fire protection in nuclear power plants." '
. "QA programs ~ of all nuclear power plant licensees should be reviewed.
QA programs in some plants are known not to meet current standards."
1
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In 1979, the Three Mile Island accident occurred. It is interesting to note
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that the emonyiReport did not address the problem as one of quality assurance.
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In 1982, quality assurance was revisited'by NRC. Commissioner Palladino is quoted as saying in " Nuclear Industry" that a number of QA deficiencies at some plants "...show a surprising lack of professionalism in the construction and preparation for operation of nuclear facilities...." He birmed the problems on management and a tendency to rely too heavily on contractors to
,- maintain QA programs. At the same time Mr. Dircks said, "...Where we think the problem occurs is in management attention..."
Based on our studies to date, we have ma' d e some tentative findings. They are as follows:
. As a result of TMI and NRC sanctions, licensee managements are taking a more active role in assurance of quality.
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. Top management'scommitment to and emphasis upon assurance of quality is absolutely essential to balance the competing pressures of schedule and cost. -
. Experienced personnel and adequate procedures are two other essential ingredients in assurance of quality.
. The assurance of quality approaches (and frequently-the manpower) used in the construction of alternative power generating facilities ..
are not adequate for nuclear power stations.
.. Sophisticated approaches to managing tssurance of: quality have been developed by some licensees, but these are not commonly adopted by the industry.
The use of sophisticated approaches d) assurance of quality and the development of. innovative construction methods have come a long way -
in- compensating for cost increases arising from QA requirements (apart from preventing rework).
. Some licensees have done a good job in integrating QA into the design / procurement / construction process; but for others, QA is still an outsider.
Progress in solving the assurance of quality problem is complicated
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by the need to upgrade or embue an entire industry with the need .for, and the.value of, quality in nuclear plants.
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6-O . Utilities which have not embraced nuclear plant assurance of quality will have a high mortality rate as generating entities.
. Probably the greatest contributions tSat the NRC can make to the nuclear industry are 1) to keep the pressure on assurance of quality,
- 2) to smooth the way toward greater standardization, and 3) to ensure that assurance of quality is thoroughly disseminated into the design and procurement process. _
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17')
CBSERVATIONS ON QA IN 1973 by Vincent Boyer, Philadelphia Electric
- 1. QA programs are paying off, but they can pay off significantly better when everyone gets up to speed. -
- 2. This will come only if QA is used to control and improve the entire process of design, procurement, fabrication, and operation.
~
- 3. Formal and detailed paperwork' is the mechanism by wh'ich this is accomplished. It can choke us or save us.
- 4. QA people cannot function by themselves. All of us must work with their findings to prevent problems or detect and resolve them early. .
~
- 5. The architect-engineer can help by submitting information in a form that facilitates decision making, rather than acquiring additional or repetitive work to clarify issues.
- 6. Vendors can help by assuring on their own initiative that their product meets applicable requirements of codes and standards and the specific requirements of the purchase order.
@ 7. AEC can help-by emphasizing substantive, rather than secondary, issues.
- 8. Utilities can help by assisting in' the development af clear and unambiguous codes and standards.
89
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9
Table 2 5 ,' ' ~ , <. .
/~T NEW INITtATIVES IN AEC CONDUCT OF OA PROGRAM - 1974 f
. Standard Review Plan - '
. Regulatory Guide
' ' ~
Detailed guidance on preparing the QA section of a pSAR
. Direct Inspection of QA activities of NSSS suppliers, and AEs. Subsequently, the LCVIP.
. Resident Inspectors
. Topical Reports -
on QA programs
. Regional, Consistency in performance of inspection functions
. Third Party Systems
({} the codes and standards rule 10CFR50.55a
. Total Enforcement
- to provide higher incentives Eo licensees to assurc viable
, QA programs e.Nist (fines) 1 R
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O-Case Study Methodology Statement of Objectives
+ Identify significant programmatic deficiencies or successes in the structuring and
! Implementation of nuclear construction
) Q'k programs f
+ Identify the root causes
- Compara results among utElties to Identify l
generic impEcations i
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i Methodology i
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- Designed to
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- Assess a sufficient number of utilities to satisfy l congressional mandate that NRC assess nucisar j
construction OA programs l
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- Provide management assessment j - Licensee
- Contractor and subcontractors
- NRC effectiveness cs 1824 M:C3 1824 JOB 4:000320 OPER/ID:Gordon DDS 1:0932 i
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Key Elements of Methodology Plan 8
- Team composition: IStC ProJoct Manager (leader),
project management, construction management,
!! QA professionals -
i j e Extensive research of and utMzation of available i!
data by the team on the selected utBtles '
4 Postulation of root causes of success or failure prepared prior to visit at construction prolact
- Skillful use of the Interview process
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- Selective use of the conventional QA audit process -
c3 1825 M:C3 1825 JOB 4:000320 OPER/ID:Gordon DDS 4:0932 s
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l Typical Questions j.
- Please tell us about yourself, your backpound,
! oducation, etc.
- What is the most important " message" concoming l
. quaEty that you receive from your management?
l How Is it conveyed or made manifest to you?
- What problems do you have in maintaining a balance among cost, schedule and quality?
j
! *- What routine Interface or Interaction do you have l with other organizations in the project and with whom?
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- Typical Questions (cont'd)
- Do you interface with NRC in any way?
With their QA program? (if yes, follow up with how, when, where questions) o How are workers Instructed as to requirements; i does this include process travelers or data sheets?
! o. What happens if a workman proceeds past an . .
- inspection holdpoint without the Inspection -
! being performed?
- What is your perception of the source of the emphasis on quality that this project has?
How Is it maintained?
ca 1s27 M:C3 1827 JOB #:000320 OPER/ID:Gordon DDS 4:0932 t
69 -
Q J' Phases of Case Study Methodology
- Develop methodology
- Prepare fe site visit
- Conduct site visit
- Review data and report preparation (site-asmellie)
- c. n a
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l Prepare for Site Visitl 4
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- IStC obtains and dstributes documentation on iI utlEty to team members I
- IGtC arranges visit with NRC regional office ;
- and utElty l
- 15tC approves composition of team and makes i team assignments l
- Team members study matarlais, develop postulated root causes of success or faBure, and develop site speclNo fleid notebook for team uso es me M:C3 1829 JOB #:000320 OPER/ID:Gordon DDS f:0932
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Conduct Site Visit i e IStC project team leader and selected team members conduct advance visit to NRC regional
- office and the utility corporate offices
- Entire team caucuses to acquaint team members l with results of advance visit 1
Team conducts site visit In a one-week to i two-week period 1 '
!
- Team caucuses daEy to revlow results and plan following day
- Team leader conducts exit conference with utlBty ce m.
W E:C3 1830 JOB 4:630320 OPER/ID:Gordon DDS t:0932 i
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- Typical Site Visit Team Composition Subtnam 1 - 15tC ProJoct Manager and QA professional i Assigned assas: Interview key utlRty managers at alto and in-depth assesament of QA program Subtesan 2 - Project management and QA professional Assigned areas: Pre >ct managar.=st, dealgn engineering, procumment subtmam s - canetmetson Management and QA professional i
, Assigned arman: Cenatmetion management,
- i. Interface
- between contractors and utility, l OiO ef COfMiruction I
Cs test l M:C3 1831 JOB #:000320 OPER/ID:Gordon DDS i:0932 I , ,
1 L. ___. _ _______ _ _ _ 1_______.. _ _-__ _ _ _ __. _ .___ ._ ______ _ _______
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< Post Site Visit Responsibilitie.s
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- Revlow any additional data obtained from site visit i
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- Reduce det: and field mates into subtsam reports i *
- . Complete key Indcators which are used to rate i
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QA program elements for offectiveness and Indicati
(' ./therossghness 'of resow l
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- Maintakt a caso study fee M rnatorials rsvtowed ~ ~ <
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- Prepare two part consoEdated team report:
l -4 Part one - Site specific data - ..
i Part two - Case study working paper -
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Results to Date
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- Methodoingy is. producing useful data and root
. causes of deficiencies and successes are being identiflod
- UtlEties express that this NRO task is one of the best programs that IEC has Irielemented for aldng the recovery of the nuclear power Industry
- Methodology contrbutes to open communication between the assessment team and both the NRC and the utElty being assessed
- C2 1***
! int'E:C3 1833 JOB #:000320 OPER/ID:Gordon DDS t:0932
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- Summary 1
- The foEowing key elements make this QA case j study methodology unique and successful:
i Advance research Interview process l
Access to NRC as a resourco Utilities reaction to the case study x Team composition Objer,tive evidence sought, if necessary l
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cs 1s94 M:C3 1834 JOB #:000320 OPER/ID:Gordon DDS #:0932 1
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Page 1 of 4 m NRC QA CASE STUDY 1
J TYPICAL INTERVIEW QUESTIONS AND APPROACH Attempt to set interviewee at ease with some preliminary conversation (about conmon acquaintances, interests, backgrounds, etc. perhaps gleaned from ;
previousinterviews). -
Give brief background to interview (i.e., Commissioners' concerns about quality ...
and the Staff's responses to those concerns, which includes these site spei:ific assessments)..
Obtain some information about interviewee; e.g., present position, time with -
licensee or other affiliation related to project, size of organization, etc.
All of the following questions are not appropriate to ask of all interviewees:
Lead-In Questions (develop follow-on questions based on responses)
M '
- l. What is the scope of your activities? That is, who do you interface with, what information do you receive and pass on, and what is it you -
do (in your group) to the information you receive?
- 2. What are your most important sources of information about the quality of work that is done in your group, or that you are responsible for? -
- 3. What is the most important " message" concerning quality that you receive from your management? How is it conveyed or made manifest '
to you? -
- 4. What. is the most important " message" concerning quality that you convey to your staff? How do you convey it to your staff?
- 5. What problems do you have in maintaining a balance among cost, schedule, and quality?
i V 6. What is your perception of the source of the emphasis on quality that this project has? How is it maintained?
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Page 2 of 4
- 7. Do you have any control of input into the quality of work you receive O
f 1 into your area of responsibility?
w .-
- 8. Do you interface with NRC in any way? With their QA program? (If yes, follow up with how, when, where questions.)
- 9. What do you attribute your lack of major QA deficiencies to in your ~
own group?
- 10. In what ways has the emphe.31s on quality changed over time on this project?
- 11. By what means does the quality assurance organization or the utility ,
management for that matter, ascertain that the QA Program is effective
~
and not suffering from major hidden progrannatic deficiencies?
- 12. For utilities that havd used QA . consultants:
cM E' a. For what reasons were the consultants hired?
- b. What information were they able to provide that you were having difficulty obtaining internally?
- 13. How would you characterize the involvement the utility has with the NRC at the a) headquarters level, b) regional level and c) resident inspector level? What has been of great benefit and what does not appear to work as well as it should?
d
- 14. Please tell us about yourself, your background, education, etc.
- 15. What do you consider your responsibilities to be on this project?
- 16. What routine interface or interaction do you have with other organizations on the project and with whom?
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- 17. How are workers instructed as to requirements? Does this include
! [ .s/) process travelers or data sheets?- "
7
- 18. What happens if a workman proceeds past an inspection hold point without the inspection being performed?
~
- 19. Why' do you feel quality is. emphasized on.this project or why do you -
4 feel quality is important on this project?'
How do you like working on a nuclear job?
20.
1
- 21. Describe your design change control process for field changes to a design. When can you proceed with work when need for a design change is identified? t+
~ ~~
- 22. How do you know when working in the field that a drawing on a stick file is the latest revision and reflects all field changes?
- 23. Describe your stop work authority and how it is imposed.
4
- 24. What is your' perception of your QA/QC personnel or organization as a professional discipline?
~
- 25. How would you describe the interface between QC and construction crafts or construction engineers and are their problems over inter-pretation of nonconformances? -
~
Questions on the Ford Amendment
- Describe briefly the Ford Amendment. All questions may not be appropriate for all interviewees. Develop follow-on questions as appropriate.
~
- 1. Would_ it be' helpful to you in assuring quality in your area of activities, or.the project in general, if NRC.were more prescriptive in defining
<tx 7 principal architectural and engineering criteria for construction of (iy
- t nuclear _ plants? -
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Page 4 of 4
, s, 2. Do you think it would be helpful to the nuclear industry if construction
(((j permits were conditioned on a demonstration by the licensee that it is capable of mounting an effective QA program?
- 3. Do you think it would be helpful to you or to the project to have evaluations, inspections, or audits of construction conducted by -
organizations which are completely independent of the project?
- 4. Do you think NRC's organization, methods, and programs for QA, as they. impact on you or the project, could be improved? What ways?
- 5. If the NRC requirements for a CP required the licensee to have independent .
inspectors to audit its QA Program, would you perceive that to be of help?
Other Questions Important to NRC gjg. Not for all interviewees.
p
- 1. What would you think about al an. inspection program similar to the FAA inspection method, 6ne with designated individuals representing NRC interests, and bl the use-of QA holdpoints similar to those used in
- -the aircraft industry? ..
~
- 2. What has your experience been with nuclear QA standards (e.g., ANSI,
- -ASME, NRC, etc.) or-the national standards process?
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BACKGROUND INFORMATION FOR THE -
FIRST REVIEW GROUP MEETING '
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, 3 CONTENTS
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- Tab
- 1. SECY-82-352, " Assurance of Quality," 8/20/82. 1 J Includes a detailed description of new NRC initiatives
, designed to improve assurance of quality in nuclear power 3 plant construction. Also provides information on
- j resources required to implement these initiatives and a brief account of some of the problems that led to
- recognition of a need for them.
t L:
- 2. HOUSE RESOLUTION 2330, Public law 97-415,1/25/83. 2 r'
{[ Text of legislation authorizing NRC expenditures for Fiscal Years 1982 and 1983. Section 13 relates to
, quality assurance.
r:
, b 3. CONF. REPT. NO.97-884, Section 13, " Authorizing .
3 Appropriations for the Nuclear Regulatory Connission;" -
g 9/28/82.
Section 13 of Report 97-884 was subsequently incorporated '
[,
into Public Law 97-415. This section contains the amend-J ment introduced by Senator Ford of Kentucky that mandates J the USNRC to evaluate and expand existing and alternative programs for improving quality of nuclear power plant r construction.
4 L
- 4. FEDERAL REGISTER, Vol. 48, No. 43, 3/3/83. 4 O
d A reiteration of the Ford Amendment and a solicitation for public connent.
1
- 5. SE. C3-32, "First Quarterly Report on Implementation of
!{
c th Quality Assurance Initiatives," 1/24/83.
5 Summarizes activities during the period 8/20/82 to 12/31/82.
L 6. SECY-83-32A, "Second Quarterly Status Report on Implementation 6
.q of the Quality Assurance Initiatives, 4/21/83. .
.] Sunnarizes activities during the period 1/1/83 to 3/31/83. -
,- 7. SECY-83-26, "Information Report on Certification of Licensee 7' Quality Assurance Programs and on Designated Representatives,"
1/15/83. .
[l An NRC staff review of ta) a program requiring certification ;
L3 of quality assurance compliance at certain hold points :
during nuclear power plant construction, and (b) a program, patterned after FAA practices, using designated representa-
{ tives to carry out activities on behalf of the NRC.
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.keus- 20. 1982 i Me- szcy-32-352 N;.Ohl f POLICY ISSUE Fer: The Comis(Notation Vote) r _
,u From: William J. Dircks-Executive Director for Operations
Subject:
ASSURANCE OF QUALITY Furcose: To inform the Commission of staff initiatives approved 3d within the authority of the Executive Director for Operations, to improve the assurance of quality in the design and con-struction of nuclear pr.ojects; and to obtain Ccmmission appr, oval TJ to pursue revision of the NRC's statutory authority to allow implementation of a system of designated representatives analogous to the system. employed by the Federal Aviation
~n Administration.
.s Discussion: The complexity and extent of problems that have been identified in the past few years at 5'of the 32 units now m' ,
under act'ive constructior have caused concern regarding the quality of the design and construction of nuclear projects. .
These problems include nonconforming structural steel welds t ", at Zimer, seismic design errors at Diablo Ca'nyon, inadequate soil ccmpaction at Midland, voids in concrete structures at 1_
harble Hill and design deficiencies at South Texas.
Enclosure 3 sumarizes recent experience at each of these 5 projects. --
Analysis of the experience at problem sites has resulted in l the classification of three primary problem areas: failure
^ of the project management team to provide adequate management -
controls to prevent a significant breakdown in quality frem occurring; failure of the owner's quality assurance pregram -
to detect the breakdcwn in a timely manner and to cbtain the -
i, appropriate corrective action; and failure of the NRC's
- j programs to recognize the true extant and nature of the problems.
The first two problem areas are'fundacentally derived frcm b a lack of total management cemitment to quality at the
- _ nuclear projects inception. This lack of cemitment has been exacerbated by the lack of understanding of the role r of quality assurance in' project management and the lack of R total understanding of what is required by personnel at all levels of the process.
J a CONTACT: 5. L. Jordan, IE 492 184A .l I
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- 1. .
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' 1 The C= rissien- a l
1
" The third problem area is two-fold in derivaticn.
_ the NRC's licensing and construction inspection programsHistoric have not sufficiently examined the project management w controls at sites under construction, but have been oriented towards establishing ad
' functional. areas, e.g.,equacy withinelectrical, concrete, major technical etc. Theand -
w systematic assessment of management perfomance and evaluation
- of all of level other effortavailable as operatinginfonnation have not received the sam sites. Second, previous NRC y
programs have not addressed desi and extensively as other areas. gn quality as specifically
( In response to the breakdowns in quality and quality assurance, the Chairman in a November 27, 1981 memorandum
' directed the staff to determine various approaches that could be-taken to strengthen quality assurance, and to
[' provide the Comission a preliminary evaluation of the.
approaches that appear most promising. On January 29, 1982 the staff briefed appeared to meritthe Commission further on initiatives that consideration.
Industr resentatives
~
from the Institute for Nuclear Power 0.perations (y INPO rep) met with the Ccmmission' on February 4,1982 to present their
_ plans for improving the assurance of quality at plants snder construction. On July 15, 1982 the staff again r
briefed initiativesthe Ccmission under on the actions taken to date and the consideration.
'L m The stiaff has developed initiatives that should lead to j' ,
effective improvements in quality and quality assurance programs.
While many of these initiatives req' ire u NRC ~
actions, the underlying principle in their developtent has
[ been that the ultimate responsibility for quality and safety remains with the nuclear industry, and ncne of the initiatives to the NRC. are intended to transfer this responsibility :
U The initiatives arc designed to establish ~
- - additional confidenca in the quality of design and construction activities and improve the management control of quality. ;
t 1 The initiatives are also designed to improve the~NRC 1 j capability to evaluate the implementation of licensee programs.
i
. Compliance with NRC requirements for the quality
, assurance in establishing this and program its implementation is a major consideration confidence.
Although a resident inspector is now assigned to every site at which construction is more than 15 percent comp 1'ete, the NRC
. (" is limited in its ability to assure compliance with all NRC
, requirements because of the limited inspection resourcis.
t
. The staff recem ends impleme'ntation' of h~ system of designated l- NRC representatives (analogous to the FAA system) to extend its inspection rescurces.
- 6
- =====_=_ _ _- . -
7 ..
} ,
- t The Cen:nission :_
During the development of the initiatives presented in this paper, several additicnal actions were censidered.
Where we were not able to establish an adequate basis to initiate additional actions at this time, further study is 4
' warranted. A long-term review will be conducted, utilizing-I kncwledge within and outside NRC to evaluate the merits of -
2
-additional actions, monitor the outcome of ongoing industry and NRC initiatives and initiate changes in program direction
. as appropriate. This review will satisfy the direction a provided the NRC in an amendment accepted by the House and Senate conferees in their joint consideration of the NRC's 7 FY 82-83 authorization bill. _.:_
~ Some of the actions considered and endorsed by the staff
- 3are associated with existing agency programs. The follewup' of allegations is an essential part of the NRC's inspection. -
program, and is an effective extension of inspection resources.
Allegations provide an opportunity for non-NRC personnel to enter potential problems.into the NRC's problem correction chain. The principal objective of the resultant NRC inspection
~ effort is to obtain sufficient information thrcugh independent
. in-depth examinations to establish-the-s-ignificance of the particular allegation and tc affect corrective action ecmmen-surate with it's significance. To encourage and provide 7 personnel an opportunity to make an allegation, NRC inspectors
- . wear hard hats that uniquely identify them. The resident inspector's office has a telephone answering device for 24-hour 1- response to callers, and the telephone numbers of the resident
~
ir.spector and NRC regional office are listed in the local tele-phone directory. Effective October 12, 1982 NRC postings,at the ' site ~ will identify the legal protection afforded people .
who provide allegations.
_ With respect to enforcement, the NRC has sufficient authority i to take appropriate enforcement action for inadequate quality assurance. The optiens extend over a broad range - -
from meeting with a licensee, notices of . violation and -
1 civil penalties to issuance of orders for modification, L
- J suspension or revocation of licenses. The staff intends to continue to take strong actions in response to significant l
- m quality assurance breakdowns and has expressed this intention l l_ in the enforcement policy. ' '
Current rules are not specific on whether or not a licensea !
or permit holder is required to notify the NRC of changes to I~ the quality assurance program description by the NRC in the Safety Analysis. ReportSAR). (previously accepted' Additionally,
} current regulations do not e'xplicit'ly rhquire licensees or J
permit holders to implement the accepted NRC SAR quality assuranc .
t i
l .
l - . . . - - . - .
9 *
! ihe Commission i P
d program description. Rulemaking action is currently in pregress which will clarify the NRC staff position regarding the types 4
[ of changes to the licensees' and applicants' quality assurance L program descriptions that can be made without informing the NRC ,
and clarify, in the regulations, the requirement to implement the accepted quality assurance program description.- -
J Actions have been initiated at near-term operating license facilities to improve staff confidence in the quality of
~
design and construction activities. These actions include self evaluations by licensees, and in most cases, an independent
- design review. The limitad experience to date with the independent desfgn reviev2 conducted at LaSalle and San Onofre (Enclosure 4) includes the identification of numerous
_ deficiencies (nonconformances with the original specificatic'ns),
which have required reanalysis. Relatively few of:these a
deficiencies have required hardware changes, and to date, none of the deficiencies identified would have prevented-
)~a safety-related components, systems, or structures from performing their intended function.
,p . The initiatives infthis paper are directed toward reactor
_ facilities not yet licensed for operation. At this time, the staff concludes a reasonable basis for not backfitting
! p these initiatives to operating reactors is provided by
' previous reviews of the facilities, their operating history, extensive startup test programs, and the reviews and upgrades
, in response to TMI and Bulletin acticns. Further consideration u will be given to operating reactors as part of the long-term review. ..
. The initiatives summari:ed below have been approved.within u . the authority of the Executive Director for Operations.
The staff will continue these actions that are already underway and implement the remainder of the initiatives as soon as
] practicable. Each initiative is described further in Encicsure 1.
r -
- Measures at Near-Term Ooeratina License Facilities I
, The NR'C will continue to employ the measures currently in
, r use to establish confidence in the quality and effectiveness !
of utility quality assurance programs at near-term operating !
license. facilities until other NRC or industry programs are capable of providing this confidence. These measures l
incitde applicant self evaluation, independent design ;
review and regional evaluations.
+
c q +
J The ~c =ission
. 1 R
<1 1
- Industry Initiatives The NRC will continue to interact with INFO in 'its development of industry initiatives, measure their effective-ness and adjust the corresponding NRC actions to provide
{ for effective use of both industry anc NRC resources. -
- Construction Procrams
, )
The NRC will increase the resources allocated torthe inspection of reactors under construction by an additional 0.3 (FY 83) and 0.5 (FY 84) staff years per unit under
~
construction.
The NRC will ccmplete development and implement planned
~ ~
. ~: revisions to enhance the effectiveness of its construction
), "
-u inspection procedures. - '- -
~
The NRC will complete development and implement its program for construction assessment team inspections at
~
selected facilities to provide a basis for evaluation of the management performance essential to quality constructio.-
The NRC will complete development and implement the m integrated design inspection process to assess the quality
~ of design activities including examination of as-built configuration at near-term operating licensee facilities.
i
} .
The NRC will expand its capability to identify generic design and construction deficiencies by computerized ..
' analysis of information reported by vendors, construction -
> J permit holders and NRC inspectors.
--
- Management -
Quality management seminars for top level managers with. -
facilities under design and construction should'be sponsored
- rv by industry. The seminars would focus recent experience of iE selected managers and recognized experts in the design and construction of nuclear projects.
- The NRC will request that each utility with a facility under construction reevaluate its quality assurance program and
. implement improvements in areas where the evaluations identify
- {_ .
a need.
The NRC will take actions to improve the enforcement of 4
I L
existing standards for qualificat' ion of quality assurance and quality control personnel-and pursue establishment of a system of third party qualification and certification for such personnel.
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The Cc mission . _ . .
. The NRC will continue to explore with labor and other
~ organizations, potential methods and incentives to assure quality. in design and construction related production u :
activities.
p
- Long-Term Review .. -
L The NRC will commence a long-term review for continuing evaluation of quality and quality assurance problems
. I"- related to design, construction, testing and operationsr
- . " and potential solutions to those problems and their impact on the adequacy of NRC quality assurance policies.and programs. ,
.
- Quality Assurance Plannino and Evaluation -
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The NRC will make~ organizational realigninents to combine r m within a single organizatica the functions of research, standards development and inspection program development a for quality assurance at reactors.- The . licensing function will remain in NRR until the current backlog of licensing actions is completed.
The Office of Inspection and Enforcement is designated c.
~
lead office. with responsibility for development of NRC
" policies and programs for quality assurance and for
- implementation of the quality assurance initiatives.
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t u The following staff.reccmendation is provided for Comission consideration and, approval. ,,
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- Designated Reoresentatives
' The NRC should pursue revision of its statutory authority F to allow implenentation of a system of-designated representa-
'L tives analogous to the system employed by the Federal .
Aviation Adminiatration.
- v -
Il ~ The staff has devaloped resource estimates and implementation schedules for the. new initiatives. The resource estimates, implementation schedules, and staff iesponsibilities for implementation are discussed in Enclosure 2. The staff responsibilities are assigned consistent with the organizatier.al realignment. The resource estimates to
~ implement the initiatives are consistent with the NRC FY-
,- 83-84 budget. The NRC resource estimates are summarized below.
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The Cc mission i
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- 1. Estimated HRC Staff Resources
- [" 25 staff years new effort in FY 83 24' staff years new effort in FY 84 !
- 2. Estimated NRC Contractor Resources -
(2.2 million new effort in FY 83 ._ .
$1.4 million new effort in FY 84
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Recor=endation: That the Comission approve the staff pmosal d sumarized above.
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Executive Director for Operations Enc 1csures:
_ 1. Initiatives .
- 2. Resources,- Schedules and Staff Responsibilities
- 3. Examples of Recent Quality Assurance Problems :
~
- 4. Independent Design Review for Near-Tenn Operating .I 1.icense Facilities .
commissioners' comments should be provided directly to the Office of the Secretary by c.o.b.-Wednesday, September 8, 1982. l Commission staff office comments, if any, should be submitted..to the f' Ccmmissioners NLT Tuesday, August 31, 1982, with an'information
[ copy to the Office of tne Secretary. If the paper is of.such a
' nature that it requires additional time for analytical review and
- _ comment, the Commissioners 'and the Secretariat should be apprised
[- of when comments may be expected.
DISTRIBUTION: '
l Ccmmissioners i L OGC !
- OPE i 4
- j. ' SECY l
[ REGIONS l OCA i i.,. OIA l l OPA !
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ENCLOSURE.1 i .
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Enclosure 1 INITIATIVES
, I. Introduction q'
The Commission has considered quality assurance to be a key factor in the
- design, construction and operation of nuclear pcwer plants for many years.
Proposed versio'ns of the General Design Criteria used in 1967 recognized -
J the interest in quality assurance. Appendix B to-10 CFR.50, published in
-June 1970, described mandatory criteria for acceptable quality assurance progtams for safety-related features.* Subsequently, a nurdber of national _
- standards and regulatory guides providing additional guidance have been issued to upgrade quality assurance programs. In the_1973 time frame, the m Atomic. Energy Commission expe~nded major effort to communicate to industry
', the framework, e.g., plans, procedures, organization, of a quality assurance program that would be acceptable to AEC. This framework is reflected in current quality assurance programs that.have been approved by NRC. -
E~
II. Problem Statement
~
Examination of the problems that have been identified recently indicates that~the fundamental cause of most design and constryction deficiencies is
~
the lack of total management comitment to quality. This lack of comitment has been intensified by the lack of understanding of the role of quality
. assurcnce in project management and the lack of total understanding of what is required of personnel at all levels of the process.
" The owner's project management team is respo,sible for the overal1 planning and management of the design, construction, and testing of the nuclear
- power plant. If the senior management has a strong comitment to quality, and if that comitment is imbued in a capable project management team, then the subsequent actions'of this team will communicate that commitment
- to all involved parties. The project management team comunicates and --
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"As used in this paper and defined;in Appendix B, quality assurance comprises
- all those planned and systematic actions necessary to provide adequate confidence i
that a . structure, system, or component will perform satisfactorily in service.
Quality assurance includes quality control, which ccmprises those. quality
, assurance actions related to the physical characteristics of a material, structure, c:aponent, or system which provide a means to control the quality of-
] the material, structure, component, or system to predeterinined requirements.
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a obtains through contractural and procedural arrancements with the designers,
~
fabricators, and constructors a level of quality commensurate with the
, owner's commitment. The commitment to cost and schedule must be-properly
- u balanced with quality through these contractual and procedural arrangements.
For example, if the constructor earns contractual credit strictly with the schedule of physical installation, the message from project management is
. g~ production. On the other hand, if' earned credit is commensurate with the -
l schedule of owner accepted, adequately documented installation, the
!- message is quality production.: The latter case provides the proper
' ~ ji incentive for getting work accomplished right the first time. This is j
t then. reflected in the policy and procedural direction to the various
. . organization sub-tisrs.
1 c-ik Similarly, the role of quality assurance in the project management team is
} determined by the senior management's ' commitment to quality. Proper ,
i m implementation of the quality assurance criteria is an important element
_ in, successful project management. However, quality assurance programs cannot substitute for poor project. management or a lack of comitment to -'
quality. Quality assurance must be an integral part of all of the project L
planning and management activities from the projects inception, and its '
role must-be comunicated and fully understood by all participants in the
, design and construction process (from senior management to the craftsman).
- For example, if the inspection. function is planned and conducted as an integral part of physical installation activities, then early detection !
and correction of procedural or other inadequacies will result in enhancing .
. F1 quality, cost, and schedule. All participants must be adequately trained
- d to understand and obtain these benefits.
~ ,
f:- Weaknesses in the existing approach to assuring quality are apparent. They
, ,~ are evidenced by the frequency and severity of design.and construction ;
i
'defici'encies, and by the failure or delay of industry and NRC recognition.,
- E of the extent and . nature of the breakdowns. t L Previous efforts by the NRC to assure program content and structure have i
not been balanced with comparable efforts to assure successful program j [' ~
implementation. The NRC's licensing and in.ipection programs have not j u sufficiently examined the project management controls at sites under .
- . construction, but have been oriented towards assuring the adequacy within j major technical and functional areas, e.g., concrete, electrical, etc. The
!-]a systematic assessment of management performance and evaluation of all available information at construction facilities did not receive the same level of
- p effort as operating sites. Previous NRC programs have not addressed design
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quality as specifically and extensively as other areas. '
In sum the fundamental ~ issues can best be characterized as the lack of L total management commitment to.. quality and the uncertainty in industry's L and HRC's ability to detect and correct the resulting deficiencies. The need to resolve these issues is the basis for the folicwing initiatives.
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U III. Initiatives 4
A. Measures at Near-Term Operatino License Facilities For those plants in the Near-Term Operating License (NTOL) status, i
the NRC has implemented three interim measures to provide additional
{n confidence' that required quality assurance programs have been successfuily implemented and completed during the design and construction of the
, _ nuclear facility.. These measures will be continued until replaced by adequate industry programs or permanent changes in the present.NRC.
j u orogram. .
I *
- 1. Self Evaluation i .
, An applicant for an operating license will perform a comprehen- .
a m sive self evaluation of the-effectiveness' of the quality assur-
" and'e program for design and construction. This requires.an i overall description of the project's quality assurance-program
! - , for design and construction. The self evaluation is a survey of a
the overall quality assurance program. The survey will describe
- the development and history of the program, management involve-
_)
ment, audits, reviews, significant problems and corrective
. . actions. The NRC staff reviews the self evaluation and provides
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J the results of its review to the licensee. Additional work,
, such as corrective actions or further audits, may be required in -
! 7 particular areas. In addition, the Chief Executive Officer 6r l e his designee is required to certify that the facility has been
, designed, constructed, and tested in accordance with the Final j-Safety Analysis Report and other licensing comitments.
- 2. Regional Evaluation ..
I On e'ach new operating license, the NRC staff considers whether there .is a need for additional irspections of selected areas t
based on an evaluation of the project's inspection and enforce-ment history. This assures consideration of the need for a i
better assessment of perfonnance in potentially weak areas. The -
project's inspection and enforcement history is evaluated with ,
' 7 particular attention to the significant problems that have been C noted at other construction sites. Other information considered includes known problem areas, results of KRC inspections'and the
' Systematic Assessment of Licensee Performance program, and problems noted elsewhere with the same contractors. Additional i
1 inspections are performed as warranted in potentially weak w areas.
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~1 J 3. Indecendent Desian Review
- (- Pised upon results of the self evaluation and regional evaluation,
~
an applicant for an operating license may be requested to have an independent design review conducted. The . criteria for determining which facility, and the scope and extent of the DJ design review also include the combined nuclear experience of -
the licensee, architect-engineer, and contractors. The review
, provides an evaluation of the quality of design based on a 1 detailed examination of a small sample. The staff specifies a '
o sample area appropriate to the particular project. For LaSalle, the mechanical and structural loads on the residual heat removal system under blevdown and operating basis earthquake conditions L were specified. Th'e independent review addresses programmatic areas, e.g., classification of systems and components, design and verification records, interface control and interdisciplinary . '
.'b ' review, consistency with FSAR, nonconformances and corrective' -
actions, and audit findings and resolutions. The review includes
, e verification of specific design features by independent calculations
'm and ccmparisor of installations against as-built drawings. The O NRC staff revitws the selection of the independent review
,, organization aid the plan before implementation, audits the work' in progress, ai.d reviews the results.
B. Industry Initiative r
$ The industry initiative is not an NRC staff prv.ral, but a program that the industry is presently developing. Tht. #'.C staff is moni-toring this program in order to take best advantage 'of the' industry h efforts.
, The Institute for Nuclear Pc ter Operations (INPO) is developing i
criteria which will be used to evaluate quality assurance for design and construction. As with tie existing INP0 criteria. for plant operation, they will be based on "best practice," rather than minimum
.G standards of acceptability. Licensees will use-the criteria for L self-initiated evaluations (which can be performed either by an .
independent group within the utility or a contractor). The.self-q initiated evaluations will be submitted to INP0 by the end of 1982. '
3 During this trial process, the NRC staff will be involved by review-ing the criteria and observing some of the evaluations. Details of p the staff involvement have not yet been developed.
The industry will decide, by early 1983, on the direction of a continuing program. At present, the primary alternatives appear to
[_ be: INFO will either begin ccnducting quality assurance evaluations at individual construction facilities, er a.. form of self-initiated evaluation will continue.
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' L INP0 is also conducting management workshops '(May 1980, September l 1981 and October 1982) with utility chief executive officers and
[ plant managers in an effort to strengthen the utility ccmaitment to Q safe operation. NRC will coordinate its quality management seminars (Enclosure 1, Section D.1) with the industry efforts.
lT Construction Insoection Program
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q 1. - Procedure Changes 4 ..
- 2 The NRC does not have sufficient inspection resources to fully l implement ~all of the existing pocedures in the reactor construction 7 inspection The FY 83-84 NRC budget allocates an additional 0.3 (FY 83) program.and 0.5 (FY 84) staff years per construction project a
to execute the construction inspection procedures. The staff is .
O presently revising the individual inspection procedures for the 4
L vaFicus technical disciplines to better match the budgeted resources.
The main goals of, the procedure revision are: (1) to facilitate
. .-: performance of the procedures by resident inspectors with reduced input from regional-specialist inspectors; (2) eliminate redundancies
! in the procedures;~ (3) reexamine scope or frequency of some i inspections based on limitations on inspector resources; and i (4). shift emphasis of inspection from record review to observation d of work. This staff effort is continuing. The first' series of i revised procedures which cover inspection of mechanical systems are
[
in the final stages of issuance.
! 2. Construction Assessment Team Inspections i .
2 This initiative will extend the concept of the NRC's Performance-i Appraisal' Team (PAT) inspection pregram for operating reactors ..~
to about four selected plants under construction per year.
i .
.. This initiative was directed by the Commission in response to i" -
SECY 82-150. dated April 8,1982, "The Performance Appraisal Team g (PAT) Inspection Program."
I ~-- The procedures for performing management control inspections at .
i nuclear construction sites were' revised by the staff in 1981.
7 The procedures. covered licensee management performance in the
,j following construction areas: Quality Assurance, Design Controls, Project Management, Construction Controls, and Procurement p' Controls. During 1981, eight trial inspections were performed
~
by regional-based inspectors using the revised procedures.
These inspections were effective in identifying management -
- control problems not identified by the routine . inspection program. The manpower. demand in these eight inspections caused the Regional Administrators to defer further performance of this
~
. type of inspection. ~ '
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I"j Enclosure 1 a
D b- The Construction Assessment Team inspections to be initiated by the IE staff would be similar to the construction inspections r perfomed previously by the Regional Offices. A team"of approximately
~1 six individuals with skills in the various areas to be inspected, including contractor personnel with appropria.te backgrounds, will visit the selected construction site for two to three weeks. Additional site visits will be scheduled if necessary to collect additional infomation or clarify initial observations.
_ The first site inspection has been tentatively scheduled for Bellefonte in September / October 1982.
The construction assessment will complement the integrated design inspection. . The latter is focused on a narrow area of a technical inspection, while the construction assessment is designed to assess tne broader programatic controls. Like the integrated design inspection, the sccpe of construction assessments'
~
will be modified to be responsive to unique conditions at a particular facility.
m
- 3. Integrated Design Inspections .
' The objective of this initiative is to expand NRC examination of' quality assurance into the design process. The staff is developing u -
an inspection approach which provides a comprehensive examination of the design development and implementation for a selected system and structure on a given project., This evaluation will i encompass the total design process from the formulation of principal design and architectural criteria thr
- and translation of the design and its revisions.ough
. Itthe willdevelopment conclude with onsite verification on a sampling basis, of the design of the installed system and structure. This' inspection
- will integrate and augment selected activities of NRR, IE, the ~~
vendor inspection program, and the regional office. Following e development of the evaluation methodology, the staff will i
conduct a' trial inspection with contractor assistance. Subsequent
,,,i inspections will be perfomed with a substantial amount of
_ contractor assistance. The results will be prov'ided to the .
at.propriate regional and headquarters offices to be used as:
i n input to the overall NRC assessment prior to issuance o.f the -
- j operating license.
The evaluation will be a. multi-disciplined review that' will address areas such as mechanical, electrical, structural, instrumentation and control. The evaluation will include
- . checking sample calculations, however, the emphasis will be- .
on the syste.matic management of the total design process. The 4 procedures to implement this approach are presently under development. A discussion of the conceptual Togic r.ecessary ,
f" . to evaluate the design process fo11cws.
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L The evaluation will start with development of a logic or ficw network of the design process. Each functional entity within the design organization will be identified. For each of these
,~, .
entities, internal and external design ~ interfaces which involve transmittal of. design information will be specified. From this 1 -, network, critical design areas or areas with the least tolerance for error will be identified. Within each of the design entities,-
the specific procedures for the verification and transmittal of 4 design information will be ' reviewed for conformance with the i
overall quality assurance program, and to identify specific - --
l {E weaknesses in the design. process, Based on the results of the j procedure review and the identification of critical design 7 '
areas, a specific sample of the system and structure will be audited. Crite'ria will be preestablished for expanding or
- terminating the audit when problem areas are identified.
"~ . ' In. examining a system or structure and its specifications, the j review will focus on topics such as: .
i 'I a Validity of design inputs and assuinptions. t L . b Validity of design specifications. .
c Validity of analyses.
} d Identification of system interface requirements.
i J e Potential synergistic effects of changes.
! f Proper component classification. ~
7 (g Revision control.
l J (h Documentation control.
, (i) Verification of as-built condition. ,
l
- The scope of the evaluation can be modified'to be responsive to ;
! unique conditions for a particular facility, or known or suspected i _ generic problems. This approach will examine all facets of the" i
! design management process for a limited sample.
- 4. Evaluation of Reported Information -
T
! L Improvements are planned in the current program for systen;atic .
i review of infonnation pertaining to design and construction ,
q quality that is now reported pursuant to 10 CFR 21, " Reporting" 1.j of Defects and !!ancompliances," and 10 CFR 50.55(e), " Construction !
, Deficiency Reports." This program would have objectives similar :
1
, to those of the Office for Analysis and Evaluation of Operational >
Data (AEOD) for nuclear power plant operations. - Computerizeri.
" djagnesk would be used to enhance identification of relationships
, that may not be evident in the manual screening that is done now. ;
- l'o expansion of reporting requirements is currently planned but
- i revisions are expected to facilitate computer input of key information. -
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Enclosure 1
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i D. Desionated Reoresentatives
'Ij Federal Aviation Regulations (14 CFR 183) prescribe the requirements for the issuance of designations to private persons to act in tee' capacity of FAA representatives in the examination, inspection and
, ~ testing necessary for the issuance of aircraft certificates by the _
q- Administrator. . Nominees meeting the requirements for appointment are authorized to represent the FAA in determining the compliance of aircraft, aircraft components, and their repair or alterations with the requirem i
l d .of the Federal Aviation Regulations.
of the FAA in the performance of duties and are guided by the same
' requirements, instructions, procedures and interpretations as FAAThese employees in the performance of those duties.
-the Designated Manufacturin'g' Inspection Representative The DER represents -(DMIR) the and the Designated Engineering Representative (DER). .
J FAA in helpiog to determine that the aircraft design complies with the j relevant requirements of the regulations and the DMIR represents the FAA These in certifying certain product and manufacturing functions.
designations are effective for one year but may be'renewod for additional
' periods of one year.
A similar technique of using the designated representatives would 'se J useful to the NRC inspection effort. It would increase the number of inspectors available .to implement the inspection program by provic:ngUsing
' an immediate source of qualified experienced personnel.
NRC representatives to check key aspects of the design, fabricaticc, and u
construction of a plant at.the specific time increased inspection effort is warranted, would significantly raise the NRC's confidence For example, duringlevel theof quality assurance in nuclear power plants.
preoperational and startup testing phases of a plant, d
~
.all tests are monitored rather than a selected few.
effort could also be applied at problem construction sites without having
_", to reduce the routine level of inspection effort at other construction sites. Under a s'tatutory regime and regulations like those of the FAA, NRC cculd ensure that the designated representative would not be subjected to harassment as he would be under the same protection as NRC emp".oyees. *
.j The aviation industry uses holdpoints in the manufacturing prccess that require inspection and certification by an FAA inspector before the process
- can continue. The designated representative, provided by the aviation industry and acting for FAA, can provide that certification when required, It is therefore an
" which allows the process to continue without delays.
advantage to the aviation industry to provide designated There representatives is no and prevent costly delays in their manufacturing process.There are no 8
J analogcus situation to that. process at nuclear plants.
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f" preestablished holdpoints (other than CP and OL issuance) in the constrt'ction or operation of a nuclear plant that require NRC approval F before the process can continue. Therefore, for the designated b, representative program to be successful for the NRC, program incentives would have to be developed .to encourage the utilities to support the.
~
program. , -
Unde'r the Atomic Energy Act of 1954, as amended, and the Energy
- Reorganization Act of 1974, as am' ended, as well as other pieces of l 1egislation; the Comission does not have the authority to de.signate licensee personnel as inspectors in a manner similar to the . Federal
, Aviation Administration's authority under its legislation and .
regulations (see 49 U.S.C. 1355, 31 U.S.C.'483a, and 14 CFR 183).
3
- The FAA has .the authority to issue designations to provide persons
' .to act in the capacity of FAA representatives while remaining in their -
? origina) . employee status as far. as receiving pay. To act in a similar c - way the NRC would have to have the Atomic Energy Act amended a_nd-would have to promulgate regulations based on this amendment. -
F The staff proposes to pursue the statutory change _s necessary to implement L .a designated representative program and to contipue development of program
- specifics. ,
E. Management
~
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- 1. Management and Quality Improvement Programs _
The objective of this initiative is to improve attitude and performance throughout all levels of licensee and contractor organizations. The problems that have arisen at construction sites are closely. associated with management attitudes and ~
i
- - practices. Quality in design and construction is invariabiy
" associated with the highest-level of management being totally l
3 comitted to quality. Senior managers are personally committed 4
and are unrelenting.in their demands on their staffs and contractors -
for a similar commitment. .
]' The NRC will coopecate with industry in sponsoring a continuing I series of seminars in which top level nuclear managers can -
! L. ccamunicate the advantages that can be gained through strong management involvemant in their own 0A programs. The seminars
!r will be conducted with assistance from independent quality
'I professicnal, utility and contractor representatives and the HRC. The seminars will,be highlighted by the participation of managers frcm utilities which have experienced serious quality lJ q
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] Enclosure 1 (j assurance problems and those which have managed highly successful programs. The independent quality professionals will convey the
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improvement. principles and techniques of implementation. The fld utility and contractor representatives will identify incentives for defect prevention based on direct experiences. The expected
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outccmes of these seminars will be recognitio'n on the part of licensee and contractor management that positive incentives and _
. benefits are achievable through enthusiastic implementation of aggressive quality assurance programs. While this initiative is directed to facilities under construction, participation by facilities in testing and operation will be strongly encouraged.
10 CFR 50, Appendix B, Criterion II requires-each utility to ~
h", regularly review the status and adequacy of its quality assurance program. The extent and nature of the recent breakdewns I,
in quality assurance programs have indicated that this review has'not been effective in maintaining an adequate quality b assurance program at several facilities under construction.
f' Each utility with a facility under construction will be requested b to reevaluate its quality assurance program, and to implement improvements in areas where the evaluations identify a need.
Each utility should identify a senior executive with overall b, responsibility for the evaluation and implementation of the necessary improvements. The NRC will monitor the evaluation
- and implementation of the necessary improvements. It is expected that improvements in the cuality assurance program will ' incorporate actions such as those listed below.
~
(a) Conduct training sessens for its personnel involved in design and construction.- These sessions should emphasize the importance of each individual's contribution to ensuring
. quality and the enhancement to the cost and schedule goals which can be achieved with a positive program.: The result.
of these sessions would be to get supervisors and employees p in the h'abit of talking positively about quality.
(b) Provide better evaluaticn on a routine basis of status- ~-
reports to detect both trends and current nonconformance
,i problems. Based on this informat%n, meaningful corrective J. actions can be promptly taken to prevent recurrence of both the specific prcblems and the root cause. The result would
[ be defect prevention as a routine part of the operation.
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a j Enclosure 1
} (c) Provide feedback on the achievements of the cuality assurance program, emphasizing the improvements from all involved in the program to maintain the concern and enthusiasm on the project tcward ensuring quality.
-. (d) Establish a system through which all parties are encouraged to ccmmunicate to management the situations that make it -
difficult for the employee to. perform quality work. This information will be included in the system for taking corrective actions. The result of this system would be di that employees know that their problems can be heard and addressed.
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'l 2. Qualification and Certification of 0A/0C Personnel A significant and prevalent prob' lea in the construction of nDelear power plants is the qualification status cf personnel working in-the quality control and quality assurance areas.
_ Some utilities'have waived, without suitable bases, the education and experience requirements for these people. The NRC has not sufficiently enforced these requirements .through its inspection efforts.
Currently, various standards exist for the qualification of QA/QC personnel, for example:
(a) ANSI N45.2.6, Qualification of Testing & ' Inspection Personnel (b) ANSI N45.2.23,- Qualification of QA Audit Personnel
- ('c) ANSI N625.3 (Draft), Qualification & Duties of Personnel
., Engaged in ASME Boiler & Pressure Vessel Code,Section III, Division 1 & 2 Certifying Activities
_ (d) ASME Section III, Division 2, Appendix VII Qualification of Concrete Inspection Personnel e (e) ASNT, Certification of Level III Nondestructive: Testing
~
M Personnel (f) AWS QCI-82, Qualification & Certification of Welding "
_ Inspectors .
NRC will direct more attention to the enforcement of the 7
j existing standards for.the qualification of QA/QC persennel- .
Certification 6f personnel engaged in QA/QC inspections would provide a cadre of industry personnel that have been qualified to minimum standards and certified to.have demonstrated inspection capabilities. ,
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Enclosure 1 i L A program for third party certificaticn of Nondestructive
- Testing (NDT) personnel is currently undenvay with coordination >
l p between the Electric Power Research Institute (EPRI),.. member "j
i utilities, American Society of Nondestructive Test 1ng (ASNT) and NRC. The program includes developing a standard written practice n- for the qualifications of the level III NDT inspectors as well q y as administering basic and method examinations and specific and practical examinations in the respective areas of nondestructive
~
. . , _ testing. A registry of- personnel holding the required qualifications
- , . . and certification would be maintained by the third party organization.
i 2 Unsatisfactory performance would result in removal from the regit s ry through an established procedure. Programs similar to p this could be established in other areas such as welding, inspectors, t QA auditing, concrete inspectors, and laboratory testing personnel.
i Formal certification of various' levels of QA/QC personnel will be . '
considered as part of the long-term review (Enclosure ,1, Section i ["-
III.F). ,
P
[-
- 3. Craftsmanship
" The staff has initiated discussions with labor unions involved ,
in nuclear construction in an effort to explore the potential
% methods and incentives to enhance the crafts role in assuring i 4 the quality of construction activities.
I Feedback from the labor unions included the following points:
(a) Craftsmen are not well informed of their role in the QA/QC !
process. , ;
_ (b) ' Continuous rework as a result of 'hanges c has a demoralizini -
effect on craftsmen and effects the quality of the final j 2 work. -
~
5 (c) Utilities ~and contractors have not provided adequate
. training to craftsmen regarding quality. -
i r} (d) Utilities are not convinced that quality assurance is a '
y cost effective approach to construction. Labor perceived ;
the utilities to think QA/QC was a "high cost" item rather l
- 7 than a " cost saving" tool. i L 1 4
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(e) Improved front-end engineering and procurement would reduce the amount of change and rework.
(f) A Nuclear Stabilization Comittee has been established with
~
representatives from labor, utilities and contractors to n improve relations between labor and management.
3,
'The staff proposes to continue these discussions as part of the long-tem review.
& F. Lone-Term Review Long-term NRC quality assurance policies and programs will be based
, on a review which assesses existing agency and industry quality assurance activities in a broad manner and then recommends an integrated n long-term agency plar. for quality assurance. Additionally, the review will focus the viewpoints of various sectors of the public and the regulated comunity. The review will be conducted by the NRC
_ staff and will include representatives from headquarters, the
~
regional offices, and cc .sultants to the NRC.
s
~
The primary function of the long-term effort wiIl be to conduct a thorough review of contiwing quality and quality assurance problems, a and to propose solutions to improve the quality assurance programs for djesi_gn_,Jonstructior. __t_esting.an_d_gperation.; This review will
~ _
incluce a detalled assessment of the. problems that developed at facilities such as Diablo Canyon, South Texas ~, Midland, Marble Hill, and Zimmer. The object of this assessment will be to identifv, as' c concisely as possible, specific problems that have occurred and their i~ root causes, particularly in the area of programatic deficiencies.
Additionally, the review will evaluate existing programs at facilities
_ which have programs that are functioning properly in order to identify the positive aspects of those programs that should be applied generically.
L Both this review and the review of programs at problem facilities will involve site visits by the personnel performing the revie>:. .
n
_ Proposed solutions to. generic and plant-specific quality and quality ,
- assurance problems will be reviewed critically to determine whether p the recommended actions would actually resolve the identified problems.
j The review will .devalnp estimates of the qualitative and quantitative .
value/ benefit and imoagcost. of proposed solutions, and ways in which they should be implementec for opera,t_ing plants, plants presently under construction, or for plants to be constructed in the future.
2 I
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T Enclosure 1 l The Hcuse and Senate in their current joint consideration of the NRC's FY 82-83 authorization bill have accepted in conference an
~
amendment which directs the NRC to study ways to improve quality assurance programs. Implementation of this review is consistent with.
~
] 4 that direction.
~~
G. Quality Assurance Planninc and Evaluation _
The reccmmendation to form a single orcanizational unit dedicated to ,
the various aspects of quality. assurance was made in a report prepared.
3' for the 'HRC by Sandia " Labs in August 1977, entitled "A Study of the
' Nuclear Regulatory Cc= mission . Quality Assurance Program."* The'
, centralization of quality assurance functions-has been or.e of. .
j continualf inte. rest and now more than ever needs to be achieved. ;
The NRC presently views responsibility for quality assurance as -
threefold:. first, to determine the adequacy of the licensee's
.2 quality assurance
- program description contained in the safety-analysis report; second, to ascertain that the licensee 'has established and adequately implemented the approved quality assurance program and to verify ccmpliance with NRC regulations; and third, to develop the l regulations, standards and guides addressing QA~in the design, construction and operation of nuclear facilities.
The responsibility for these three functions is currently divided
, among three. separate offices, NRR, IE and RES, with execution of the inspection function from five regional offices. These three functional areas are not separate and discrete areas but are highly interrelated, requiring continual interface. For example, the inspection experience needs to be continually factored into the licensing effort, inspection
- program development and development of regulations ard standards.- In addition,recentqualityassuranceissues(e.g.,Ciablo-Canyon, - --
P.arble Hill, South. Texas) have been highly reactive and have required
. rapid NRC management attention and response from the three separate offices for their various quality assurance functional areas.
.iJ
- a *Page 60, "A Study.of. the Nuclear Regulatory Commission Quality Assurance Frogram," NUREG-0321 .
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Enclosure 1 L
< r i" The functional quality assurance areas need to be realigned for the following reasons:
(a) To more effectively utilize the limited staff resources and expertise in quality assurance engineering.
~
(b) To~ establish a more discernible policy and. position cn cuality -
U ' assurance issues.
(c) To establish unity of control and to provide both information 1 and coordination with industry.
(d,) To bring together the licensing, inspection and standards functi'ons on interrelated issues. ,
, (e) To provide industry a signal that NRC management considers goality a leading part of th~e NRC operation and 'of sufficient importance to depart from the existing organizational structure.
F It is recognized that most NRC activities are quality assurance L related and that the NRC review process is an interdisciplinary function involving many organizational compcnents. NRC headquarters activities which relate to the develop 4nt of MRC policy, rules, standards and guides, and review and evaluation of the implementation of licensee's QA programs are to be consolidated at this time. The
- censolidation will occur'in the Office of Inspection and Enforcement.
The licensing function will remain in NRR until the current backlog of licensing actions is completed.
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Enclosure 2 Resources, Schedules and Staff Responsibilities The nuclear industry currently expends substantial resources for qua'lity assurance at power reactors. For example, about 7500 positions are currently devoted to quality control and quality assurance on construction projects.
~
The NRC Regional Offices devote about 130 positions to inspection of pcwer reactors under construction and vendors. These inspections are concerned, to a great degree, with the effectiveness of the quality assurance programs in the various areas that are being inspected. This effort, which provides a measure of the overall effectiveness of the quality assurance programs, is the largest segment of the NRC's efforts related to quality assurance at construction projects. A smaller part of this inspection effort (about 28 positions) is narrowly directed towards inspecting the quality assurance programs.
In 4. broad sense,..the headquarters offices also devote considerable efforts to quality assurance. In the narrow sense, they devote about 16 positions to direct professional work on quality assurance programs as follows: 4 positions licensing; 7 positions inspection program (QA related) development and development of QA initiatives; 5 positions research and standards development.
Much of this effort can be considered applicable to constcuttien projects.
NRC. contractor work has previously been at a level of about $400,000.per year for research/ standards development in quality assurance.
The esticated resources for the initiatives discussed in this paper are provided in Tables 1 and 2. These estimates are consistent with the NRC FY 83-84 budget. They can be summarized as follows:
- 1. Estimated Industry Resources
.(a) In FY 83 (i) 280 man years new effort (ii) 420 man years altogether (b) In FY 84 (i) 310 man years new effo..
(ii) 390 man years altogether ,
- 2. Estimated NRC Staff Resources (a) In FY 83 (1) 25 staff years new effort ;
(ii) 46 staff years altogether (b) In FY 84 (i) 24 staff years.new effort ,
t
- (ii) 34 staff years altogether
T .
2- Enclosure 2
)
i 3. Estimated NRC Contractor Resources (a) In FY 83 (1) $2.2 million new effort i
} (ii) $2.2 million altogether (b) In FY 84 7 (i) $1.4 million new effort -
3 (ii)$1.4-millionaltogether
- New efforts correspond to the new initiatives developed by the staff, i.e.,
l
.. those that are not already underway and well established.
Generally, additional efforts are,'not large in comparison to the resources already
! ~
. devoted to QA. The improvements will come mostly from redirection cf existing l resources. NRC staff and contractor resources can be redirected as necessary to accemplish the., initiatives without dropping any. planned accomplishments '
i although the depth and schedule of some planned accomplishments will necessarily be affected. .NRC staff responsibilities with respect to development and implementation of the initiatives are indicated in Table 3. The schedules for acccmplishing the initiatives are provided in Figure 1.
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Table 2 - Estimated llesearces for QA Initiatives (Altogetier)
FT 83 III ff U4 I i
NaC NRC IllDUSTAT NRC flRC 44 INiilATIVt5 staff CONTRACT 'INDil5TRY STAFF $
JWI 1R) (STA{J VR) ($ 11100.) -(MAN VR) (staff TR)
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- 1101. - Self Evaluation (2) 10 i
2.5 3.6 0.9 IIVOL - llegional EvaluationII 0.8 8.5 0.3 3.0 Nf0L - Independent Design ReviewII ,63 ~
i 5.9 23 1.P
- InJustry Initiative 74 2.t 54 -
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i Inspection Program Changes 13.0 16.0
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I.4 320 1
Evaluation of Deported Information
$ 0.2 250 j
0.2 350 Designated liepresentatives n.5 84 1
I 2.0 itanagement ... Programs 270 .1.4 100 200 i
0.8 Qualification ... Personnel 2.7 0.8 20 0.8
{ Craftsmanship -
0.4 ,
tong Tene Revlew 1.8 750
~ 0.I 100 Quality Assurance ... Evaluation 1DTAts: I3I 420 46 2200 fiOIES: ,
390 34 140 [
1 (1) ,
a Resnurce reduce tielsestimates variation.for initiatives related to licensing peak sharply in FT 83 and drop sharply in ff 84 Construction delars mar . *
(2) i (3) ti!OLTotalsprograms are rounded maytotietwo reduced significantlieglanine figures.In old FY 83 as other NRC and ladustry initlatives tale ef fect .
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- ENCLOSURE 3 .
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_. Enclosure 3 Examoles of Recent Quality Assurance problems d
During the past few years, there have been serious quality assurance problems
[
at nuclear power plants. Some examples are listed below:
- 1. Marble Hill m _
y In June and July 1979, NRC confirmed allegations of impro6erly repaired concrete imperfections at Marble Hill. The imperfections were generally
_ ' identified as concrete consolidation problems (honeycomb and voids), and improper repair'(patching) of these imperfections.
NRC inspections confirmed that:
- a. An excessive amount of honeycomb and air voids had occurred. Approxi-mately 4000 concrete patches existed.
g b. In many Instances these imperfections were improperly repaired, and/or unacceptable materials were used for the repair.
n I
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- c. Quality control records traceable to the repairs were either non-existent or inadequate.
- d. Personnel responsible for such repairs were inadequately trained and
- supervised.
- e. The licensee was not in control nor sufficiently aware cf the above F- circumstances.
These events led to a halting of all safety-related work 'at the' site in August 1979. Work was not permitted by flRC to resume until December 1980, when the utility's quality assurance program and that of its contractors,--
_ had been substantially upgraded and the adequacy of completed construction work had been verified. .
- 2. Midland Excessive settlement of the diesel generator building was cbserved in 1978. The unexpected settling was subsequently attributed to inadequate ,
q and pcorly compacted soil under the building. Other safety-related U systems and structures were affected. t;RC's investigation determined that design and construction specifications had not been followed during
-- placement of the soil . fill materials and that there was a lack of centrol
,- . and supervision of the soil placement activities by the utility and its centractors . Extensive rework has begun, and the operating license
._ application is currently being litigated before an NRC Hearing Board.
b c
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4 Enclosure 3 D
il
- s. Zirrer L
Allegatiens received in January 1981 prcmpted an tiRC investigation of quality assurance problems at the Zimmer site. The investigation has
- . identified a large number of quality assurance related problems. The L majority of the problems identified focus on the ineffectiveness of L controls implemented by the licensee and its contractors for assuring the quality of work performed. . In that regard, numerous deficiencies have been found concerning traceability of materials, handling of nonconfor- -
iu mance, interface between construction and quality centrol, quality records,
'j and the licensee's overview of ongoing work.
. An extensive review of the as-built plant is being performed. Limited independent measurements were performed by the tiRC in selected areas of
, concern in an attempt to characterize the actual safety significance of these deficiencies. Although a few problems requiring corrective action were identified, the majority of the tests and examinations disclosed no Sardware problems. The licensee will perform a ccmprehensive cuality i{
confirmation program and resolve identified problems before an operating license is issued.
- 4. South Texas' b .
In response to allegations that QC inspectors were being threatened if I~ they reported unacceptable items during concrete placements, the 11RC
" initiated an investigation through its Region IV Office in July' 1977. Ten investigati.ons of allegations were performed during the period July 1977
. to tiovember 1979.
The results of these investigations established that the allegations .of
_' harassment, intimidation and lack of support of QC inspectors were sub-
- stantiated. The investigation demonstrated shortccmings in the l
management and that the implementation of the QA/QC program at the South ..
i Texas Project did not meet the standards required to assure that the facility will be constructed to tiRC requirements. Safety-related work
_ was stopped in 1980. tiRC allowed restart in designated areas only after l QA for that area was upgraded and verified by the tiRC.
' f~
L In January 1981, the licensee initiated a design review of those portions of the engineering design work performed by Brown and Root, Inc. The Quadrex Corporation assisted the licensee in this review. Briefly, the 7] Quadrex report fcund that Brcwn and Root failed to properly implement an overall design censistent with the needs of a nuclear pcwer plant. The
_ licensee replaced Brown and Root with Bechtel Fcwer Corpration as architect-engineer in September 1981, 11RC is monitoring the performance of Bechtel as they resolve the problems identified in the Quadrex report.
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4:3. Enclosure 3 i m !
!]
- a. Diablo Canyon S 4
!"l At Diablo Canyon, the Pacific Gas & Electric Company (PG&E) provided i i incorrect information to an expert consultant, who. used the information in !
- _ developing the seismic response spe'ctra for the design of certain seismic i l piping and equipment restraints. NRC investigators have fcund that there i
! ol was a lack of rigor and formality in the procedures used for verifying the !
accuracy of information transferred by PG&E to its consultants. Yhese !
procedures .did not ccmply with NRC requirements calling for verift:ation -
i a of design information at each stage of the process by an independelt !
person qualified in the pertinent disciplines. Proper quality assurance j controls were not employed in technical and procurement corrunications E
- with, service-type contractors. Nor were document controls adequato to !
assure that those involved in design had ready access to the most ecent !
information available. I i
Folicwing discovery of these errors in seismic design, the recently -issued j operating 1*canse for Unit I was suspended in late 1981. Prior to ;
I the NRC'i reinstatement of tne operating license the licensee will be L [
required to ccmplete an extensive design reverification program for those i areas in question. ,
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- Independent Design Review For j Fear-Tem Operating License Facilities L ,
!' C In order to provide further staff confidence in the quality of design and
! construction at near-term operating license applicants, licensees have been p requested to conduct an independent verification of selected ~ design and -
construction activities. The independent verification would be performed by IL an independent contractor with qualifications acceptable to the NRC.
l- Independent verification efforts have been completed at LaSalle Unit 1 and 2
, and San Onofre Unit 2 and 3. Reviews are presently in process at Grand Gulf, Suscuehanna, Shoreham, Watts Bar, Palo Verde, Sumer and St. Lucie.
I
- I At LaSalle, the licensee hired an independent contractor, approved by NRC, to L perfom a review of the mechanical'and structural design of loop C residual heat removal system excluding all branch piping ,less than 3 inches, in the j
functioning mode of the low pressure injection system using loads resulting
'l % from"the actua'ti6n~of the automatic depressurization system in conjunction j with the operating basis earthquake to verify that this system has been 3
designed and constructed in accordance with the application and that the NRC requirements have been satisfied. Comonwealth Edison contracted the Teledyne
,~ Engineering Services (Teledyne) to perform this review with NRC approval.
1- .
- ihe preliminary findings by Teledyne resulted in 21 Error / Deviation and 31 i
" open-items reports which were transmitted to the licensee and the N9C staff.
Upon submittal of all Teledyne's preliminary, findings, the licensee
'f transmitted it responses to Teledyne and the NRC staff and, in addi* ion, the L licensee received pemission from the HRC staff to establish a dialogue' between Teledyne and its Architect-Engineer (Sargent & Lu.ndy) to discuss the
- ~ potential errors found in the Teledyne review. Of these 52 reports Which
, involved various problems in the design area and none in quality assurance, 39 were closed by Teledyne based on the acquisition of additional infomation ~
i and/or clarification of existing information. The 13 remaining reports were
{ '
reviewed by Teledyne's Project Review Internal Comittee. This comittee, composed of three senior level Teledyne engineers who together had the expertise to resolve the technical issues, and the Teledyne Project Manager
'(L concurred that none of these reports have the potential for significant safety impact.
O The NRC staff reviewed those open-items and error-deviations reports submitted J to the Project Review Committee and concluded that these reports can be categorized as not having a signific' ant safety impact on LaSalle. In
'[ addition, the NRC staff feels that Teledyne has performed an in-depth ~ review L of the analytical procedures and design calculations used in the piping,
, equipment, and ccmponent support design to assure the adequacy of the design bases, the adequacy of the design implementation, and the consistency between
! the design dccuments and the Final S.afety Analysis Report cemitments.
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Enclosure 4
' i he indepe' dent design verification program conducted by Teledyne on the loop
. C residual heat removal system indicated that the quality assurance centrol and implementation, design process, procedures and Final Safety Analysis Report connitments are acceptable except in the area of response spe.ct;ra, l i which was reviewed by NRC staff. The results of the limited review provide increased assurance that the quality assurance program established and implemented by the licensee and its principal contractors did effectively control the overall program and construction activities for the LaSalle -
County Station. While several design deficiencies were identified, the overall design and construction activities.were adequately performed so that
.no adverse impact on , safety was found.
At San Onofre the licensee contracted with Torrey Pines Technology, a subsidiary of the General Atomic Company (GA), to perform an independent evaluation of the seismic design and quality assurance program for San Onofre d
2 and 3.
~
The design verification enccmpassed a review'of the seismic design of San Onofre 2 and 3 to:
verify that the design process converted the seismic design basis a.
, specified in the San Onofre 2 and 3 Final Safety Anal,ysis Report (FSAR) into the design documents that are transmitted to the constructor or fabricator, and
- b. evaluate the SCE quality assurance (QA) audit plan and its implementation at the construction site and the fabricator's shops.
The design process perfonned by the equipment fabricators was not part of this review program.
. The work was divided into eight major tasks: ,,
Task A. Design Procedure Review
. Task B. ' Design Procedure Implementation Review Task C. Seismic Design Technical Review Task D. Audit Plan Review Task E. Processing of Findings Task F. Reports
, Task G. Pipe Segment Walkdown '
Independent Calculations Task H.
The review was conducted by individual GA reviewers investigating each area i covered by Tasks A through 0, G, and H. When a reviewer found a deficiency I that might have safety significance, it was documented in a " Potential Finding Report." .
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7: :
Enclosure 4 l,
After the Potential Finding Repor (PFR) was written, it was sent to the "criginal design organization" that was responsible for the area covered by the PFR. The original design organization (0D0) then investigated the PFR and
, responded in writing. The PFR and the 000 respense was then reviewe.d.by a GA ccmmittee, and the PFR was classified as (1) Out of scope, (2) Invalid, (3)
~
Observation, or (4) Finding.
~
Out of scope items are those which are beyond the original scope of the
~
review. For example, the review was oriented towards design verification.
' Procurecent items are considered out of scope. Invalid Findings are the
~
result of apparent deviaticns, uncovered in the course of the independent verification, that are resolved to the satisfaction 'of project perscnnel, usually during the Potential Finding review by the Original Design c Organizations. Observations are valid deviations that are judged not to have the potential for significant impact on the seismic design adequacy of San Onofre Units 2 and 3. Findings are valid deviations that could have potential
~
, for significant impact on the seismic design adequacy.
" Of the total of 170 PFRs that were initiated, 77 were determined to be invalid after additicnal information was reviewed. Of the 93 PFRs that were determined to be valid, .7 were classified as findings and 86 as observations.
4 The numbers of findings and observations for Euch of the v.arious tasks are as follows: .
a Task Findinos Observations A 3 2 .
B 1 35 C 1 41 n D 2 5 0 2 G
' H 0 1
~
Total 7 86 y ..
The staff has concluded, based on its re' view of the results of the design
~
v'erification program, that the GA design verif' cation program has not -
- m. discovered anything that would cause the staff to change their previous conclusions that the San Onofre 2 and 3 quality assurance and seismic design programs are acceptable, and provides additior.41 assurance that plant design -
j and ccnstruction have been appropriately accomplished.
J k -
H. R. 2330 j Rinttg sttent 1 Ongress o' tLit Enitti Etates o' 9mtrit
, } AT THE SECOND SESSION f
m Begun and held at the City of W*ashington on .1fonday, the twentyfifth day ofJanuary,-
one thousand nine hundred and eighty two bN bd.
To authorize a propriations to the Nuclear Regu! story Commission In acco-lance with secuen f51 of the Atomic Energy Act of 1W. as amended, and seccan 305 of the Energy Reorganuation Act et 1974. as amended, and for other purpcees.
Be it enacted by the Senate and House of Representatices of the United States ofAmerica in Congress assembled, At,*rHoaInAMON OF APPRcPRIATIONS
- l j Secr:cN 1. (a) There are hereby authori:ed to W appropriated to the Nuclear Regulatory Commiuien in accordance with the provi.
sions of section 261 of the Atomic Energy Act of 1954 (42 U.S.C. 2017) and section 305 of the Energy Reorgam:ation Act of 1974 (42 U.S.C.
5875), for the fiscal years 1982 and 1983 to re=ain available until expended, 5485,200.000 for fiscal year 1982 and 3513,100,000 for fiscal year 1983 to be allocated as follows:
(1) Not more than $30,700,000 for fi. scal year 1982 and
$77,000,000 for fiscal year 1983 may be used for " Nuclear Rese.
ter Regulation", of which an amount not to exceed 31.000,000 is
~ authori:ed each such ascal year to be used to accelerate the effort in gas-cooled thermal reactor preapplication review, and
" an amount not to exceed 36,000,000 is authori:ed each such fiscal year to be used for licensing review work for a fast ~
^
breeder reactor plant project. In the event of a termination of such breeder reactor project, any unused amount appropriated
~ pursuant to this paragraph for licensing review work for such project ~ay be used only for safety technology activities.
1 (2) Not more than $62,900,000 for fiscal gear 1982 and 169,850,000 for fiscal year 1983 may be used for Inspection and Enforcement".
(3) Not more than 342.000,000 for fiscal- year 1982 and ,
.' 347,059,600 for fiscal year 1983 may be used for
- Nuclear Mate.
rial Safety and Safeguards".
(4) Not more than 3240,300,000 for fiscal year 1982 and 3257,195,600 for fiscal year 1983 may W used for " Nuclear Regulatory Research", of which-(A) an amount not to exceed $3,500,000 for fiscal year 1982 and 54,300,000 for fiscal year 1983 is authorized to be i
used to accelerate the erTort in gas cooled thermal reactor safety research:
l (B) an amount not to exceed $18,000,000 Is authorized each such fiscal year to be used for fast breeder reactor safety research; and (C) an amount not to exceed 357,000,000 is authorized for a such two fiscal year period to be used for the Mf Fluid Test Fac:11ty research program.
In the event of a termination of the fast breeder reactor plant project, any unused amount appropriated purwant to this pars-
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- . H.R. 2330-2
' graph for fast breeder reactor safety research may be used -
i b generally for " Nuclear Regulatory Research".
, (5) Not more than $21,900.000 for nseal year 1982 and l -
S20.197,500 for Escal year 1983 may be used for " Program ,
i Technical Support". r i (6) Not more than $37,400.000 for Escal year 1982 and i 841,797,000 for fiscal year 1983 may be used for " Program
. m Direction and MmWmtion",
i (b) The Nuclear Regulatory Comminion may use not more than 1 4 "L percent of the amounts authorized to be appropriated under subsec.
4 tion (aX4) to exercise its authority under section 31 a. of the Atomic -
} 9 Energy Act of 1954 (42 U.S.C. 2051(a)) to enter lnto grants and
~
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. cooperative agreements with universities pursuant to such section.
i Grants made by the Comnussion shall be made in accordance with
! , the Federal Grant and Cooperative Agreement Act of 1977 (41 1 I U.S.C. 501 et seq.) and other applicable law. In making such grants 1
L and entering into such cooperative agreements, the Comminion
. shall endeavor to provide appropriate opportunities for universities ;
l c in which the student body has historically been predominately :
- j comprised of minority groups.' !
i t (c) Any amount appropriated for a fiscal year to the Nuclear ;
l Regulatory Commission pursuant to any paragraph of subsection (a) ;
f -
for purposes of the program omce referred to in'such paragraph. or any activity that is within such program omce and is specined in j L such paragraph, may be reallocated by the Comrmssion for use in a program omes referred to in any other paragraph of such subsec. l
! tion, or for use in any other activity within a program ofEce, except 1 i
that the amount available from appropriations for such f! scal year ;
for use in any program omce or specided activity may not, as a ..
result of reallocations made under this subsection, be increased or C" reduced by more than 8500.000 unless-
. [
i (1) a period of 30 calendar days (excluding any day in which either House of Congress is not in session because of an adjourn. ,
ment of more than 3 calendar days to a day certain or an ;
j,] 'sdjournment sine die) passes after the receipt, by the Commit. !
. _. tee on Energy and Commerce and the Committee on Interior -
4 and Insular Affairs of the House of Representatives and the
! , Committee on Environment and Public Works of the Senate, of -
notice submitted by the Comaussion containing a full and com- i
- U[ t plete statement of the reallocation proposed to be made and the - [
} facts and arcumstances rolled upon la support of such proposed i
- n reallocation; or !
j f' (2) each su<.h committee, before the expiration of such period, !
t u . transmits to the Cornetasion a written notification that such ;
l # committee does not object to such proposed reallocation. (
1 0 !
dt Atmioarrr To asTADf craTADf AMOUMS asCEIVID I I r Sac. 2. Moneys received by the Nuclear Regulatory Commission .
i for the cooperative nuclear research program and the material !
access authorisation program may be retained and used for salaries i and esponses associated with such programs, notwithstanding the E
~
provisions of section 3617 of the Revised Statutes (31 U.S.C. 484), and !
- [1 shall remain avanable until expended.- -
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AUTHOarTr TO TsANSFIa CErrAIN AMotDfr5 TO OTHER AGENCIES _
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' SEc. 3. From amounts appropriated to the Nuclear Regulatory Commission pursuant to section 1(a), the Commission =av transfer j to other agencies of the Federal Gover==ent sums fer salaries and f expenses for the performance by such agencies of activities for i
> which such appropriations of the Comminston are made. Any sums i j ,
so transferred may be merged with the appropriation of the agency !
1 to which such sums are transferred.
- l J '
LDCTATION oN SPENDING AttrHOs1TY 7 Sec. 4. Notwith-Al= any other provision of this Act, no _ _
! j anbrity to make paymeni.s under this Act shall be effective except - -
1 to such extent or in such amounts as are provided in advance m i appropriation Acts.
_1 !
< j AUTBCarTY TO tSstJE 1.! CENSES IN AssENCE OF EMIRGENCY ;
- PaEFAREDNEss PLANS
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~
SEc. 5. Of the amounts authorized to be appropriated under
! section 1, the Nuclear Regulatory Comminaion may use such sums as -
l~ may be necessan, in the absence of a State or local emergency preparedness plan which has been approved by b Federal Emer. t i gency Management Agency, to lasue an operstmg license (including a temporery operating license under section 192 of the Atomic ;
Energy Act of 1954, as amended by section 11 of this Act) for a nuclear power reactor, if it determines that there exists a State,
) _' local, or utility plan which provides reasonable assurance that ,
'. public health and safety is not endangered by operation of the l facility concerned. ~
., . Nucz.EAa SAFETT GCALS f
< j SEc. 6. Funds authorized to be ap [
be used by. the Nuclear Regulatorhristed mmission under to expedite this Actthe shall ~ i establishment of safety goals for nuclear reactor regulation. The i
.]
r development of such safety goals, and any accompanying methodolo. !
4J gies for the application of such safety goals, should be expedited to
- i
- the maEimum extent !
goal by the Commt=# n notpracticable later than December to permit establishment 31,1982. of a safety j t !
a tassoF.rt.cm TEST FACII.frT j Sac. 7. Of the amounts authortred to be used for the Iose.of Fluid i j
Test Faciligin accordance and 1983, Commissionwith shall section provide 1(aX4) funding for through fiscal years 1982 contract ;
!a with the organization ations for a detailed tec asible for the I4es.of. Fluid Test oper.
cal review and analysis of research i .l results obtained from the I.oes.cf. Fluid Test Factifty research pro-gram. The contract shall provide funding for not more than twenty J
. man years in each of fiscal years 1982 and 1983 to conduct the i tachaie=1 review and analysis.
! l jj wuct.EAa DATA 1.INE Sac. 8. (a) Of the amounts authorized to be appropriated under
- this Act fer the Escal years 1982 and 1983, not more then $200,000 is 1 Lj authorised to be used, by the Nuclear Regulatory Commission for-
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i H.R.2330-4
- (1) the acquisition (by purchase, lease, or otherwise) and -
. J installation of equipment to be used for the "small test proto-1 type nuclear data hnk" program or for any other program for l , the collection and transmi== ion to the Commission of data from
! licanad nuclear reactors danng abnormal conditions at such .. .
I reactors; and .
J (2) the conduct of a full and complete study and analysis of-3 (A) the appropriate role of the Commi== ion during _
1 ; abnormal conditicos at a nuclear reactor licensed by. the y Commissing; i
(B) the informatica which should be available to the .
Commi= ion to enable the Commi== ion to fulfill such role ._ . .
j- ~
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and to carry out other related functions; . .
(C) vanous alternative means of assuring that such Infor-
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mation is availabirto the Ca==i= ion in a timely manner;
- and .
1 (D) any changes in =*ia- Commission authority neces-I i sary to enhance the Commission response to abnormal i conditions at a nuclear reactor licensed by the Commission.
j ) The small test prototype referred to in paragraph (1) may be used by ~
j the Commi== tan in carrying out the' study and analysis under para-j graph (2). Such analysis shall include a cost. benefit analysis of each
. alternative exanuned under sub ph (C). -
1 (bX1) Upon completion of the and analysis required under l !
subsection (aX2), the Co==i=ia= s submit to Congress a detailed
- report setting forth the results of such study and analysia.
j (2) The Commi==ian may not take any action with respect to any
- alternative described in subsection fax 2xC), unless a period of 60 i calendar days (excluding any day in which either House of Congress -
t is not in session because of an adjournment of more than 3 calendar -.
j days to a day certain or an adjournment sine die) passes after the receipt, by the Committee on Energy and Commerce and the Com. ' "
i c
mittee on Interior and Insular Affairs of the House of Representa- -
i -
tives and the Committee on Environment and Public Works of the - -
t* Senate, of notice subadtted by the Comminaian containing a full and - ' i
! I compi,ete statement of the action proposed to be taken and the facta j i and circumstances relied upon in support of such proposed action. -
9
- OrTEROS CONSOLIDATION OF OFFN
- Is
$ Sec. 9. (a) Of the amounts authorized to be appropriated pursuant to ph 6 of section 1(a), such sums as may be necessary shall
,. be a le for interim consolidation of Nuclear Regulatory Com-mission headquarters staff ofRces.
(b) No amount authorized to be appropriated under this Act may be used, la connection with the interim consolidation of Nuclear i Regulatory Commi==ian of5ces, to relocate the ofHees of members of-the Commission outside the Distnct of Columbia.
Tnass uit.s isturn Sac.10. (a) No part of the Amds authorized to be appropriated -
under this Act may be used to provide a==idaaea to the General Public Utilities Corporation for purposes of the decontamination.-
cleanup, rui; air, or re!ahe11*=rian of racill*ian a Three hiile Island
.- Unit 2.
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$ r.. (b) The prohibition contained in subsection (a) shall not relate to -
! r.' the responsibilities of the Nuclear Regulatory Comminion for moni-L ,
toring or inspection of the decontamination, cleanup, repair, or '
4 -
rehabditation acuvities at Thne Mile Island and such prohibition shall not apply to the use of funds by the Nuclear Regulatory i e L
Commission to enrry out regulatcry functions of the Commission '
- - ~
under & Atomic Energy Act of 1954 with respect to the faciuties at j Three Mile Island.
(c) The Nuclear Regulatory Commission shall include (n l '
annual report to the Congress under section 307(c) of the Ene.rgy Its Reorganization Act of 1974 (42 U.S.C. 5877(c)) as a se a desc-iption of the coUaborative efforts undertaken,parate or proposed chapter to i
be undertaken, by the Commission and the Department of Energy-with respect to the deconesmmation, cleanup, repair, or rehabuita-e tion of facilities at Three h Island Unit 2.
(d) No funds authorized to be appropriated under this Act may be m used by the Commission to approve any willful release of " accident-generated water" as defined by the Commission in NUREG-0633
(" Final Programm,atic Environmental Impact Statement" p.1-23),
from Three Mile Island Unit 2 into the Susquehanna River or its 4
1 watershed.
- _J TzneonAar otraATING !.!CENSIS I
Ssc.11. Section 192 of the Atomic Energy Act of 1954 (42 U.S.C. -
t c , 2242)is amended to read as follows:
a "Sze.192. TruronAa7 Orzaarzno IaczNar.-
"a. In any proceeding upon an application for an operating Ucense i
' for a utilizauon facility required to be licensed under section 103 or 7 104 b. of this Act,in which a hearing is otherwise required pursuant E t- - tion 189 a., the applicant may petition the Commission for a i
ey operating license for such facility authorizing fuel load. --
- 7, and operation at a specific power level to be determined h, .
mission, pending final action by the Commission on the
- _, ~-
appdcatw. The initial peution for a temporary o rating Ucense '
~
for each such facility and any tempo operatic license issued
~
for such facility based upon the initial
~~
~
tion, s be umited to power levels not to exceed 5 percent o rated full thermal power.
E' '
i
, " Fonowing Le'-- by the Commi=ian of the temporary operating -
License for each such facility, the licensee may file petitions with the
- i~ Commission to amend the Hemnam to allow facility opration in ' ;
' staged increases at specific power levels, to be determmed by the *
[ Commi=mn, exceeding 5 percent of rated full thermal power. The initial petition for a temporary operatirt license for each such faciuty may be filed at any time after the fuln of:(1) the report of the Advisory Committee on Reactor required by section
- 182 b.; (2) the filing of the initial Safety valuation Report by the Nuclear Regulatory Commission staff and the Nuclear Regulatory
~ Commission staff's first supplement to the report prepared in response to the report of the Advisory Committee on Reactor
~ Set ' for the facility;(3) the Nue!aar Regulatory Commission i
s final detailed statement on the environmental impact of the faciHey prepared pursuant to section 1022XC) of the Nauonal Envi-
~[, ronmental Policy Act of 1969 (42 U.S.C. 4332(2XC)); and (4) a State, local, or utiuty emergency preparedness plan for the facility. Peti-i tions for the tasuance of a temporary operating license, or for an amendment to such a license allowing operation at a specific power level greater than that authorized in the initial temporary operating
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B.R.2330--s [
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" license, shan be accompanied by an amdavit or afEdavits setting ,
i forth the specific facts upon which the petitioner relies to justify 1
! - issuance or the temporary operating license or the amendment thereto. The Comm:ssion shall publisa notice of each such petition in the Federal Register and in such trade or news publications as .
the Ce==i== ion deems appropriate to give reasonable notice to -
) >-
persons who might have a potential interest in the grant of such temporary o rating license or amendment.thereto. Any, person i
may file vits or statements in support of, or in opposition to, the petition within thirty days after the puhucation of such notice in i
- the Federal Register. -
m 3' "b. With respect to any petition filed pursuant to subsection a. of i 1
~
this section, the Cammiman may issue a temporary operating 2. -
1 license, or amend the license to authorize temporary operation at each specific power level greater than that authorized in the initial 3 7 -
tem operating Ucense, as determined by the Comminaion, upon fin that- >
"(1) ,au respects other than the conduct or completion of i 1
any required hearmg, the requirements oflaw are met;
"(2) in accordance with such requirements, there is reason-i;. able assurance that o a of the facility during the period of
! the temporary o Hennae in accordance with its terms
- ~ and conditions will y adequate protecdon to the public -
health and safety and the environment during the period of -
su$ tem perating license will result in '
i'" delay between the date o construction of the facility is sufficiently completed, la the judgment of the Commission, to
' permit issuance of the temporary operadng Ucense, and the !
i date when such facility would otherwise receive a final operat- ..
_' inglicense pursuant to this Act. .
The temporary operating license shall become ehetive upon issu.
ance and shau contain such terms and conditions as the Commission -
! '" ~
i
~ may~ deem necessary, including the duradon of the license and any~ ' f^'
on for the er:ension thereof. Any final order authorizing the
!{
m or amendment of any tem ant to this section shan recite with justifying the findings under this ting license pursu-the facts and reasons .
n and shan be transmit-ted upon such issuance to the Committees on Interior and Insular -
i Afaars and Energy and Commerce of the House cf Representatives
' ]L -
and the Committee on Envimament acd Puhuc Works of the i
' hasta. The final order of the Ce==*n with respect to the ' '
issuance or amendment of a temporary operating license shall be ;
- subject to , udie al review pursuant to chapter 158 of title 28, United
,i_.
States Coce. The requimments of secdon 189 a. of this Act with respect to the issuance or amendment of faciUty licenses shall not j'
apply to the issuance or amendment of a temporary operating license under this secdon. ,
i i_. "e Any hearing onthe application for the final operating license L
i for a facility required pursuant to secdon 189 a. shall be concluded 1 - i as promptly as practicable. The Commission shan suspend the '
I temporary ope lleense if it finds that the applicant is not 4 L the app for the final License with due l
~ nee. of a te m He=ame under subsec- . -
b of this secdon shall be wi s to the right of any '
-!.L ',-- party to raise any lasue in a hearing pursuant to section ;
189 a.; and failure to assert any denial or limitation of a ,
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t i H.R. 2330-7 .
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- temporary operating'lleense shall not bar the assertion of such -
' ground in connection with the issuance of a subsequent final operat-ing license. Any party to a hearing required pursuant to section 189 7 a. on the final operstm' g license for a racility for which a temporary operating license has been issued under subsection b., and any; _
" ~
member of the Atomic Safety and Licensing Board conducting such' -
" hearmy, shall promptly notify the Commission of any information m indicanng that the terms and conditicas of the temporary operating -
license are not being met, or that such terms and conditions are
" not sufficient to comply with the provisions of paragraph (2) of
- subsection b.
i - -
"d. The Commission is authorized and directed to adopt such -
~
ad=iai=trative
=iai=i= remedies as the Commi= ion deems appropriate to ~
" the need for issuance of temporary operating licenses pursuant to this section. -
I
-' "e. The authority to issue new temperary operating licenses under :
this section shall expire on December 31,1983."
orEaATWG UCENs3 A.MENDMcfr MEAamCs 71 !
j Sec.12. (a) Section 189 a. of the Atomic Energy Act of 1954 (42
< U.S.C. 2239(a)) is amended-(1) by inserting "(1)" after the subsection designation: and (2) by adding at the end thereof the foHowing new paragraph:
] "(2XA) The Com=8a-%n may issue and make immediately effee.
tive any amendment to an operating license, upon a determination by the Commi= ion that such amendment involves no significant i hazards consideration, notwithstanding the pendency before the
.Comaussion amendment may of abe request issued for andamade hearmg(=from any person. Such
~ ~
==diately etfective in advance of the holding and completion of any required hearing. In "
determinmg under this section whether such amendment involves 1
.C- no significant hasards consideration, the Commission shall consult t
., .~. ~~
with the State in which the faciHty involved is located. In an other ,
4
~
~ ~ " 7
' ~
respects such amendment shau. meet the requirements of this Act. !
"(B) The CommI==ian shan 4
~
i than once every thirty days)periodicaHy publish notice (but of anynot amenaments less frequently issued, or proposed to be issued, as provided in subparagraph (A). *i 1
Each such notice shan include all amendments !ssued, or proposed to be issued, since the date of puhucation of the last such periodic .
notice. Such notice shall, with respect to each amendment or pro-posed amendment (D identify the faculty involved; and (1D provide a i i ,
brief description of such amendment. Nothing in this subsection shall be construed to delay the effective date of any amendment.
"C The Commission shall, during the ninecy. day period following the effective date of this paragraph, promulgate regulations estab.
4 lishing(D standards for dete whether any amendment to an operan'ag license involves no si
. cant hazards consideration:(ii) x criteria for providing or, la emergency situations, dispensing with .
! prior notice and reasonable opportunity for public comment on any !
such determination, which criteria shall take into account the
.-} eEigency of the need for the amendment involved; and (ilD proco-dures for consultation on any such determination with the State in J which the facility involved is located.".
i 4 (b) The authority of the Nuclear Regulatory Commission, under j ;
the provtsions of the aaneedmont rnade by subsection (a), to issue and to make im==diataly effective any amendment to an operating '
7
, , , ,e,. .,
e' :
.'1
, J ii H. R. 2330-8
!d license shall take effect upon the promulgation by de Commission j _ cf de regulations required in such previsions.
}
, ; qw.nv Assatacn
~ Sze.13. (a) The Nuclear Regulatery Co-luion is authori:ed and dincted to !=plement and accelerate de resident inspec:ct pro- ~
gram so as to assure the assign =ent of at least one resicent inspec-tor by the end of Escal year 1982 at each site at which a ecmmercial nuclear powerplant is under c=nstructica and cons:=c:ics is more
}' ~
2 than 15 percent ec=plete. At each such site at which cons:ruction is .
not more dan 15 percent complete, the Comminion shall provide
,- that such inspection personnel as the Comminion dee=s appropri-ate shall be issuance cf t$e ecastructionhysically present at the sito at such ti=es follow C judgment of the Commission. permit as may be necessary in the (b) The ComMuien shall conduct a study of ez:sdng and alter =a.
- tive programs fer improving quality assurance and quality control
' - in the construe:ica of commercial nuclear powerplants. In condtet-i= the study, the Commission shall obtam de ec==ents of the
- lie, licensees of nuclear powerplants, the Advisory Com=ittee on j r Safeguards, and organizations ccmprised of professionals
~
ha'ving exper:ise in appropriate fields. The study shall include an
. analysis et the following:
(1) providing a basis for quality assurance and quality control, inspec:icn. and enforcement accons through the adoptien of an .
approach which is more prescriptive than that currently in.
praccce for den *g principal architectural and engineering criteria for the construe:!on of commercial nuclear powerplants; (2) conditioning the issuance.of construe:ics permits for com.
3
- mercial nuclear powerplanta on a de=custration by de licensee
- that the licensee is caa.able r of indepeMantly =anaging the etTec:ive perfor=ance of all quality assurance and quality con-
- trol responsibinties for the powerplant; (3) evaluations, ',r@na, or audits of ecm=ercial nuclear ..
- powerplant eerscue:icn by or-Mna ecmpr' sed of profes-sionals having expr:ise in appropr: ate Eelds which evaluaticus, mese: ions, or audits are more. effec:ive than those under cur N -
~ rent pac: ice; n: - -
~- -
(4) unprovement of the Commininn's organization, =ethods','
and pregrams for quality assurance development, review, and
~ inspec: ion:and -
(5) conditiening the issuance of constructica permits for ecm.
ii_. mercial nuclear powerplan:s on the permit:ee entering into "
!d s
contracts or other arrangemen:s with an independent inspecter to audit the qualit ance performance.y assurance program to ver:fy quality assur- -
{n L Tor purposes of paragraph (5), the tenn " Independent inspec:or"
- L means a person-or other entity having no responsibility for the
' design or construction of the plant involved. The study sm, all also include an analysis of quality assurance and quality control pro-F1 grams at regresentative sites at which such pre .
- i - are operating j
ur'*h-crily and an ==-ent of the reasons t enfor.
' (c) For purposes of-N (1) determming the best means of assuri=g that ecmmercial nuclear powerplan:s an constructed in accordance with the
. fi u
a- .- - - - - - - - - - - - - - - - -
--. . - ,- . - - . _ - . =
n
'm, .
i
- l
!c t.
H. R. 2330-9 applicable safety require =ents in effect pursuant to the Atomic 4
Energy Act of1954: and e (2) assessing the feasibility and bene 5ts of the various means listed in subsection (b); -
the Comminion shall undertake a pilot program to review and.
evaluate pregrams that include one or more of the alternative concepts identi5ed in subeection (b) for the purposes of assessing the feasibility and benedts of their implementation. The pilot program f shall include programs that use independent ins ectors for auditing quality assurance responsibilities of the licensee for the construction of commercial nuclear powerplants, as described in paragraph (5) of subsection (b). The pilot program shall include at least three sites at .
which commercial nuclear powerplants are under construction. The.r_ -
CommI= ion shall select at least one site at which quality assurance _ _
and quality control programs have operated satisfactorily, and at.
least two sites with remedial programs underway at which major m construction, quality assurance, or quality control denciencies for any combination thereoD have been identified in the past. The Comminion may require any changes in existing quality assurance
~ and quality control organizations and relationships that may be i
necessary at the selected sites to implement the pilot pregram.
i ~ (d) Not later than SReen months aRer the date of the enactment of this Act, the Commission shall complete the study required under
~ subsection (b) and submit to the United States Senate and House of Representatives a report setting forth'the results of the study. The
- report shall include a brief summary of the information received '
from the public and from other persons referred to in subsection (b)
and a statement of the Commmion's response to the signincant comments received. The report shall also set forth an analysis of the
~ results of the pilot program required under subsection (c). The _
report shall be accompanied by the recommendations of the --
~ Comm= ion, including any legislative recommendations, and a de-scription of any =Ammi trative actions that the Commission has .
~
undertaken or intends to undertake, for improvmg quality assur- .
ance and quality control programs that are applicable during the: ;-. . _; .; . 3 construction of nuclear powerplants.
F i L LIMrrATION ON USE Or sFECtAL NUCLEAa MATERIAL
- Sec.14. Section 57 of the Atomic Ene Act of 1954 (42 U.S.C. -
1 1 2tyt7) is amended by addmg at the end t ereof the following new
" subsection:
"e. Special nuclear material, as defined in section 11, produced in facilities licensed under section 103 or 104 may not be transferred.
' (L repr~~=i used, or otherwise made available by any instrumental- i ity of the, United States or any other person for nuclear explosive
- purposes.
' anstocrr INsFECTOss l
'*3 4 Ssc.15. Of the amounts authorized to be appropriated under section 1, the Nuclear Regulatory Commission shall use such sums t
- .1 as may be n-eary to cenduct a study of the financial hardshipe incurred by resident inspectors as a result of(1) regulations of the J C--i-ion requiring resident -mspectors to relocate periodically from one duty station to another; and (2) the requirements of the C==i= ion respecting the domicile of resident inspectors and J l l
~ ~ - - ^ ~ ~ " ~~
v : .
i.
i J
~1 A
H.R.2330-10 j _
D respecting travel between their domicile and duty station in s'uch manner as to avoid the appearance of a conflict of interest. Not later than 90 days after the date of the enactment of this Act, the Commission shall submit to the Congress a report setting forth the .- -
a - findings of the Commission as a result of such study, together with a - -
legislative proposal (including any supporting data or irformation) -
r relating to any assistance for resident inspectors determined by the Commission to be appropriate.
sAnorAct or NucuAm FACH.mEs on TUrt. .
Szc.16. Section 236 of the Atomic Energy Act of 1954 (42.U.S.C.
- 2284)is amended to read as follows:
"Sze. 236. SAsoTAGE oF NUCMA IAcn.rrtzs on Fuzz.-
~ "a. Any person who intentionally and willfully destroys or causes physical damage to, or who intentionally and willfully attempts to
- destroy or cause physical da= age to-
"(1) any production facility or utilization facility licensed
" under this Act:
"(2) any nuclear waste storage facility lic~ensed under this Act; L Of
"(3) any nuclear fuel for such a utilization facility, or any -
. spent nuclear fuel from such a facility; shall be fined not more than $10,000 or imprisoned for act more
~ than ten years, or both.
"b. Any person who intentionally and willfully causes or attamats to cause an interruption of normal operation of any such facility i through the unauthorized use of or tampering with the machinery, components, or controls of any such facuity, shall be fined not more -
than 810,000 or imprisoned for not more than ten years, or both.".
~
1" ' '
nerAarMzNT or zNzacY INFonMATtoN
_...'._l.~_..
~, - - Szc.17. (a) Section 148 a. (1) of the Atomic Energy Act of 1954 (42 -
U.S.C. 2168(aX1)) is amended by inserting after " Secretary')" the
.. following: ", with respect to atomic energy defense programs." -
-(b) h,on 148 of the Atomic Energy Act of 1954 (42 U.S.C.'
2168)is amended by adding at the end thereof the following new '
subsections:
-) "d. Any deter:zunation by the Secretary concerning the applicabil -
ity of this section shall be subject to judicial review pursuant to
- section 552 fax 4XB) of title 5, United States Code.
"e. The Secretary shall prepare on a quarterly basis a re
- made available upon the request of any interested person. port to bedem the Secretary's application during that period of each regulation or
- order prose.ded or issued under this section. In particular, such report shall-
] "(1) identify any information .
ant to such regulation or order: protected from disclosure pursu.
- "(2) specifically state the Secretary's justification for deter-i mining that unauthorized dissemination of the information pro.
- tacted from disclosure under such regulation or order could reasonably be expected to have a significant adverse effect on
~'
t the health and safety of the public or the common defense and j security by s2gmficantly meressmg the likelihood of illegal production of nuclear weapons, or theft, diversion, or sabotage
. - - - . = _ - -. - . - - _. . . - - _
- i :
Pt ti I
L ,
H.R.2330-11 e
~
a of nuclear materials, equipment, or facilities, as specified under subsection a.: and
"(3) provide justification that the Secretary has applied such
~
regulation or order so as to protect from ciselesure only the _
minimum amount of information necessary .to rotect the . . - -
health and safety of the public or the common [efense and-security.".
h w rrANDAaDe AND REQLTIREStEMS LTNDER sECTION 273 Sec.18. (a) Section 275 of the Atomic Energy Act of 1954 is -
amended-(1) by striking in subsection a. "one year aner the date of -
enactment of this section" and substitutmg " October 1,1982" and by adding the following at the end thereof: "Aiter Octo-m ber 1,1982, if the Admmistrator has not promulgated standards I
L in final form under this subsection, any action of the Secretary of Energy under title I of the Ursnium Mill Tailings Radiation
- Control Act of 1978 which is required to comply with, or be '
taken in accordance with, standards of the Administrator shall comply with, or be taken in accordance with, the standards proposed by the Administrator under this subsection until such
- time as the Admimetrator promulgates such standards in final form.";
- (2) by striking In subsection b. (1) " eighteen =enths after the enactment of this section, the Admini<trator shall, by rule, m promulgate" and inserting in lieu thereof the followin ber 31,1982, the Administrator shall, by rule,ose, propg:
and "Octo-
" within 11 months chareafter promulgate in final form.
(3) by adding the following at the end of subeection b. (1): "If ..
~ the Administrator fails to promulgate standards in final form <
under this subsection by October 1,1983, the authority of the !
~
Admiaierator to promulgate such standards shall terminate,- -
_. and the Comminion may take actions under this Act without- 2: .. ;
' regard to any provision of this Act requiring such actions to - -- -
comply with, or be taken in accordance with, standards promul- ,
~ gated by the AAmimetrator. In any such case, the Commission '
shmH promulgate, and from time to time revise any such l standards of general application which the Com minion
!], deems necessary to carry out its responsibilities in the conduct -
~ of its lice activities under this Act. Requirements es-A-lished by the mminion under this Act with respect to byprod.
P uct material as defined in section 11 e. (2) shall confor= to such I! standards. Any requirements adopted by the Commiaion re-
" ' such byproduct material before promulgation by the mmassion of such standards shall be amended as the Commis-sion deems necessary to conform to such standards in the same jl manner as provided in subsection f. (3). Nothing in this subsec-d tier. shall be construed to prohibit or suspend the implementa-tion or enforcement by the Commiazion of any requirement of the Commission re.p<cdag byproduct material as def'med in l section 11 e. (2) pendmg promulgation by the Commmion of any 4
U ' such standard of general application.";
(4) by adding the following new subsection at the end thereof:
"f. (1) Prior to January 1,1983, che Com== ion shall not imple-g ment or enfotte the provisions cf the Uraniunt Mill Licensing L R.qhnts published as final rules at 45 Federal Register 65521
- m. . . - - - ,
F ,.
- i
. i.
i s
H. R. 2330-12
~
L to 6553S on October 3,19SO (hereinafter in this subsection referred to as the ' October 3 regulations'). After December 31,1992, the
- Commission is authori:ed to implement and enfor:e the provisions of such October 3 regulations (and any subsequent =edineations or I
additions to such regulations which may be adopted b -
sion), except as otherwise provided in paragraphsand (2)(3) y the Commis-of this subsection.
"(2) Following the proposal by the Administrator of standards
= under subsection b., the Commission shall review the October'3 regulations, and, not later than 90 days after the date of such p propcsal, sus nd implementation and enforcement of any provision
- i of such tions which the Comminion determines after notice k and opportunity for ublic comment to require a major action or j
major commitment licensees which would be unnecessary if-4 F "(A) the stan ds proposed by the Administrator are promul-
' gated in final form without mod 15 cation, and
~ "(B) the Commission's requirements are modined to conform to such standards.
- r Such suspension shall terminate on the earlier of April 1,1984 or the date on which the Commtnion amends the October 3 regulations
" to conform to final standards promulgated by the Administrator under subsection b. During the period of such suspension, the
' Commission shall continue to. regulate byproduct material (as defined in section 11 e. (2)) under this Act on a licensee-by. licensee basis as the Cornminion deems necessary to protect public health, safety, and the environment. .
" "(3) Not later than 6 months after the date on which the Adminis-trator promulgates final standards pursuant to subsection b. of this section, the Commission shall, after notice and opportunity for public comment, amend the Octol.wr 3 regulations, and. adopt such ~
modifications, as the Comminion deems necessan to conform to such final standards of the Adminiatrator.
e- .
"(4) Nothing in this subsection may be construed as affecting the authority or res asibility of the Comminion under section c4 to .
promulgate tions to protect the public health and safety and
[_ the environment.".
L (bXI) Section 108(a) of the Uranium Mill Tailings Radiation Con- .
trol Act of 1978 is amended by adding the following new paragraph
. at the end thereof:
,] ,
"(3) Notwithstanding paragraphs (1) and (2) of this subsection, after October 31, 1982, if the Admini<tra:or has not promulgated 4 . standards under section 275 a. of the Atomic Energy Act of 1954 in (L
final form by such date, remedial action taken by the Secretary under this tttle shall comply with the standards proposed by the Administrator under such section 275 a. until such time as the 1
Admmistrator promulgates the standards in final form.".
(2) The second sentence of section 108(aX2) of the Uranium Mill Tallings Radiation Control Act of 1978 is repealed.
rw AGaEEMENT STATES L
- Ssc.19. (a) Section 274 o. of the Atomic Energy Act of 1954 is amended by adding the following at the end thereof: "In adopting requirements pursuant to paragraph (2) of this subsection with q respect to sites at which ores are procensed prunarily for their
- i U source material content or which~ are used for the dis-M of byproduct material as defined in section 11 e. (2), the State may
_ 1 er e-.a -.- p. m mewe . ..m-%#w . , , . . . . - - -
9 '
, 1 .
] .,
u
~
H.R.2330-13 M" adopt alternatives (including, where appropriate, site-specine alter-nanves) to the requirements adopted and enforced by the Commis-sion for the same purpose if, after notice and opportunity for public
~
hearmg, the Commtuien determines that suen alternatives will -
achieve a level of stabilization and contam=ent of the sites con- ~
corned, and a level of protection for public health, safety, and the environment from radiological and nonradiological hazards asso--
[- cisted with such sites, which is equivalent to, to the extent practica-F" ble, or more stringent than the level which would be achieved by standards and requirements adopted and enforced by the Commis-sion fer the same purpose and any final standards premulgated by -
O the Mmi-trator of the Environmental Protection Agency in.
U accordance with section M5. Such alternative State requirements may take into account local or regional conditions, including
_ geology, topography, hydrology and meteorology.".
. (b) Section 204(hX3) of the Uranium Still Tailings Radiation Con-L trol Act of 1978 is amanded by inserting the followi=g before the period at the end thereof: ": Pmeided, however That, in the case of a r - ' State which has exercsed any authority under State law pursuant to an agreement entered into under section 274 of the Atomic L Energy Act of 1954, the State authority over such byproduct material may be terminated, and the Comminion authority over ..
- such material may be exercised, only after compliance by the Com-
! mission with the same procedures as are applicable in the case of L termination of agreements under section 274 j. of the Atomic Energy Act of 1954.".
AMENDMENT TO SECTIoN 84 Szc. 20. Section 84 of the Atomic Energy Act of 1954 is amended ..
by adding the following at the end thereof:
"c. In the case of sites at which ores are processed primarily for 4 _. their source material content or which are used for the disposal of -ra J- ,-
, byproduct material as defined in section 11 e. (2), a licensee may : a propose alternatives to spec 2He requirements adopted and enforced ~ ~;" ,
I by the Commission under this Act. Such alternative proposals may take into account local or regianal conditions, including geology, b topography, hydrology and meteorology. The Comminion may treat such alternatives as sacsfymg Commission =ents if the -
1 Commission determines that such alternatives achieve a level of
'~
! stabilization and contamment of the sites concerned, and a level of protection for public health, safety, and the environment from radiological and contadiological hazards associated with such sites, R which is equivalent to, to the extent practicable, or more stringent U than the level which would be achieved by standards and require.
ments adopted and enforced by the Comminion for the same pur.
pose and any final standards promulgated by the Admimtrator of
[l d
the Environmental Protection Agency in accordance with section 275.".
EDGEMONT O Sec. 21. Section 102(e) of the Uranium Still Tailings Radiation d Control Act of IM8 is amandad by adding the following at the end thereof.-
,, "(3) The Secretary shall designate as a processing site within q the m of secnon 101(6) any real property, or improvements i b thereon,in emont, South Dakota, that-t
i n l 6
4
-i n,
d
- H.R. 2330-14
>j a "(A) is in the vicinity of the Tennessee Valley Authority uranium mill site at Edgemont (but not including such site), and r "(B)is determined by the Secretary to be contammated with k" -
- - residual radioactive materials. .:.
In rmking the designation under this paragraph, the Secretary shall consult with the Administrator, the Commmion and the State of
- q South Dakota. The provisions of this title shall apply to the site so
- I designated in the same manner and to the same extent as to the
" sites designated under subsection (a) except that, in applying such provisions to such site, any reference in this title to the date of the -
- enactment of this Act shall be treated as a reference to the date of r'I . the enactment of this paragraph and in determining the State share
.N under section 107 of the costs of remedial action, there shall be credited to the State expenditures made by the State prior to the R date of the enactment of this parag.aph which the Secretary deter-fj mines would have been made by the State or the United States in carrymg out the requirements of this title.".
ADDIT!ONAL AMENDMENTS To sECr!ONs 34 AND 273
] Szc. 22. (a) Section 84 a. (1) of the Atomic Energy Act of 1954 is amended by inserting before the comma at the end thereof the -
following: ", taking into account the risk to the public health, safety, and the environment, with due consideration of the economic
, costs and such other factors as the Commission deter *es to be appropriate,". .
F- (b) section 275 of the Atomic Energy Act of 1954 is amended-
[ (1) in subsection a., by inserting after the second sentence thereof the following new sentence: "In establishing such stand ..
_ ards, the Admuustrator shall consider the risk to the public health, safety, and the environment, the environmental and
__ eccnomic costs of applying such standards, and such other facters
,,g . as the Arimimetrator determines to be-appropriate."; -
D (2) by adding at the end of subsection b. (1) the following new .
sentence: "In establishing such standards, the Administrator LJ shall consider the risk to the public health, safety, and the .
environment, the environmental and economic costs of applying - '
.I such standards, and such other factors as the Admtzustrator
-4 determines to be appropriate.".
i IMANItTM stJPP!.T l
W Sec. 23. (aXI) Not later than 12 months aAer the date of enact-i ment of this section, the President shall prepare and submit to the
, Congress a comprehensive review of the status of the domestic
)] uramum minine and milling industry. This review shall be made
'j available to the appropriate committees of the United States Senate and the House of Representatives.
,, (2) The Comprehensive paragraph (1) shallinclude-review prepared for submission under
- d. .
(A) projections of uranium requirements and Inventories of
' domestic utilitiest
_ ' (B) presentiand future projected uranium production by the
~ domestic miri g and milling industry; i - (C) the pres nt and future probable penetration of the domes.
tic market by steign imports; .
_ -- - - A -
a :
1 .
O
.I l !
U e q -
H.R.2330-15 I (D) the size of domestic and foreign ore reserves: '
L (E) present and pro ,
expenditures and plans; jected domestic . uranium exploration !
- (F) present and projected employment and capital investment -
in the uranium industry; i (G) an estimate of the level of domestic uranium producticA '
necessary to ensure the viable existence of a domes:ic uranium n industry and protection of national security interests; H (H) an estimate of the percentage of domestic uranium. .
f 4 W demand which must be met by domestic uranium production through the year 2000 in order to ensure the level of domestic !
I m production estimated to be necessary under subparagraph (G);~ '
(D a projectica of domestic uranium production and uranium n ,
" price levels which will be in effect both under current policy i and in the event that foreign import restrictions were enacted '
" by Congress in order to guarantee domestic production at the level estimated to be necessary under subparagraph (G); ,
(J) the anticipated effect of spent nuclear fuel reprocessing on the demand for uranium; and i (K) other information relevant to the consideration of restric.
m tions on the importation of source material and special nuclear !
7 material from foreign sources.
t (bX1) Chapter 14 of the Atomic Energy Act of 1954 is amended by adding the following new section at the end thereon "Sec.170B. Ununtru Suppr.y.-
'l
, u "a. The Secretary of Energy shall monitor and for the years 1983
- to 1992 report annually to the Cong.-ess a,nd to the President a .
determi.tation of the viability of the domestic uranium mmmg and L mimng industry and shall establish by rule, after public notice and -
in accordance with the requirements of section 181 of this Act, ~~
m within 9 months of enactment of this sec: ion, specific criteria [
which shall be assessed in the annual reports on the domestic _.;
1 .
uranium indus:rfs viability. The Secretary of Energy is authorized- .
to issue regulations providing for the collection of such information J
' p' i
as the Secretary of Energy deems necessary to carry out the moni.
toring and reporting requirements of this section.
t l
de "b. Upon a satisfactory showing to the Secretary of Energy by any ,
person that an section, would,y information, or portion thereof ootained under this I q if made public, divulge proprietary infor=ation of j such person, the Secretary shall not disclose such information and "
disclosure the ect shall be pimWhle under see:ica 1905 of title 18, United States Code. ;
i [ "c. The criteria referred to in subsection a. shall also include, but
> r not be limited to- ,
' t
"(1) an === ment of whether executed contracts or options '
for source material or special nuclear material will result in - '
E greater than 37% percent of actual or projected domestic '
uranium requirements for
[ .
being supplied by source ma.ter.al any two-consecutive or special nuclearyear period
=aterial [
from foreign sourcesi t
T "(2) projections of uranium requirements and inventories of b domestic u:ill:ies for a 10 year period; [
" "(3) present and ,
by foreign impor:s; probable future use of.the. domestic market '
i "(4) wtiether danestic ocenomic reserves can supply all futurv 4 needs for a future 10 year period; 6
. , , _ . . , _ . _ _ , _ _ _ . , _ _ _ . . _ _ . , _ , , , , , _ , _ _ . . . . _ , _ , , . . _ _ _ _ , . , _ . . _ . . , . m..___. . . _ . . _ , , , _ , , , _ . . , .
.+=
n :
7, 7
( .}
l
)
H.R.2330-16 7 _
l "(5) present and pro expenditures and plans: jected domestic uranium exploration t
"(6) present and projected e= ploy =ent and espital invest- , . _
] ment in the uranium industry; t _
"(7) the level of domestic uranium preduction capacity sun cient to meet projected domestic nuclear power needs for a 10 year period; and 7j "(8) a projection of domestic uranium production and ura-nium price levels which will be in efTect under various assump.
tions with respect to imports. '
"d. The Secretary or Energy, at any time, may determine on the --~
l ~- -
basis of the monitoring and annual repcrts required under this U section that source material or special nuclear material frem foreign
- sources is being imported in such increased quantities as to be a m W=tial cause of serious injury, or threat thereof, to the United States uranium mining and milling industry. Based on that determi-nation, the United States Trade Representative shall request that
{ q the United States International Trade Commtasion initiate an inves-tigation under section 201 of the Trade Act of 1974 (19 U.S.C. 2251).
' j' "e. (1) If, during the period 1982 to 1992, the Secretary cf Energy determines that executed contracts or options for source material or -
special nuclear material from foreign sources for use in utilization 1 facilities within or under the jurisdiction of the United States j . represent greater than 37% percent of actual or projected domestic uranium requirements for any two consecutive J ear period, or if the Secretary of Energy determines the level of contracts or options involving source material and special nuclear material from foreign sources may threaten to impair the national security, the Secretary --
of Energy shall request the Secretary of Commerce to initiate under
- - - - J- c a section 232 of the Trade Expansica Act of 1962 (19 U.S.C. IS62) an
-- ~~" investigation to determine the effects on the national security of :: :- _
imports of source material and spec:~al nuclear material. The Secre- r-tary of Energy shall cooperate fully with the Secretary of Commerce ~
~) m carrying out such an investigation and shall make available to
-] the Secretary of Commerce the findings that lead to this request and -
such other information that will assist the Secretary of Commerce ,
in the conduct of the investigation.
] "(2) The Secretar y of Commerce shall, in the conduct of any investigation requested by the Secretary of Energy pursuant to this section, take into account an information made available by the
, Secretary of Energy, inclu information regarding the impact on :
national security of proj or executed contracts or options for !
source material or special nuclear material from foreign sources I or whether domestic production capacity is suiEcient to supply !
projected national security requirements. I J
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H. R. 2330-1" m "(3) No sooner than 3 years following completion of any investiga-
,i tion by the Secretary of Commerce under paragraph (1), if no recommendation has been made pursuant to such study for trade
~ adjustments to assist or protect domestic uranium production, the Secretary of Energy may initiate a request for another such investi. .-
gation by the Secretary of Commerce.".
Speaker of the House ofRepresentatives.
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Vice President of the United States and :
1 President of the Senate.
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d 977x CONGRESS ' HOUSE OF REPRESENTATIVES . REroar 2d Session No.97-584 1
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AUTHORIZING APPROPRIATIONS FOR THE NUCLEAR REGULATORY COMMISSION Serrzussa 28,1982.--Ordered to be printed 7
LJ Mr. UDA1.L, from the committee of conference, submitted the following -
a CONFERENCE REPORT
~ ~ '
[to accompany H.R. 2330)
The committee of conference on the disagreeing votes of the two Houses on the amendment of the Senate to the bill (H.R. 2330) to authorize appropriation to the Nuclear Regulatory Commission in accordance with section 261 of the Atomic Energy Act of 1954, as u amended, and section 305 of the Energy Reorganization Act of 1974, as amended, and for other purposes, having met, after full ,
and free conference, have agreed to recommend and do recommend to their respective Houses as follows:
That the House recede from its disagreement to the amendment of the Senate and agree to the same with an amendment as fol-c lows-In lieu of the matter proposed to be inserted by the Senate L amendment insert the followiny.
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AtiruoaszAnox or Arraorassrtoxs 1 '.
Szcnox 1. (a) There an hereby authorized to be appropriated to
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the Nuclear Regulatory Commission in accordance wsth the provi. ,
sions of section 261 of the Atomic Energy Act of1954 (42 U.S.C 2017) and section 305 of the Energy Reorganization Act of1974 (42 U.SC 5875), for the fiscal yars 1982 and 1983 to remain available .
~
until expended, $485,200,000 for fiscal year 1982 and $513,100,000 .
for fiscalyear 1983 to be allocated as follows:
(1) Not more than $80,700,000 for fiscal year 1982 and
- 2. $77,000,000forfiscal year 1983 may be used for " Nuclear Reac.
tor Regulation , of which an amount not to exceed $1,000,000 is authorized each such fiscal year.to be used to accelerate the
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] mize the need for issuance of temporary operating licenses pursuant
} to this section.
"e. The authority to issue new temporary operating licenses under
, this section shall expire on December 31,1983. ". -
a orsnAnxa ucesse Autxoutsr uzAarscs Szc.12. (a) Section 189 a. of the Atomic Energy Act of 1954 (42 U.S.C. 2239(a))is amended-(1) by inserting 'Y1)"after the subsection designation; and
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(2) by adding at the end thereof the following newpamgraph.-
'Y2XA) The Commission may issue and make immediately effec-
' tive any ameridment to an operating license, upon a determination by the Commission that such amendment involves no significant
~
hazards co'ssideration, notwithstanding the pendency before the Commission of a request for a hearing mm any rson. Such amendment may be issued and made imm(ediately e fective in ad-vance of the holding and completion of any required earing. In de-
^ termining under this section whether such amendment involves no significant hazards consideration, the Commission shall consult with the State in which the facility involved is located. In all other respects such amendment shall meet the re YB) The Commission shall than once every thirty days) but periodically not less frequently publish notice of any amendments (quirements of this
- - issued, or proposed to be issued, as pmuided in subparagraph (AL Each such notice shall include all amendments issued, or proposed
- to be issued, since the date ofpublication of the last such periodic notice. Such notice shall, with t to each amendment or pro-posed amendment (i) identify the ility involved; and(ii)pmuide a brief description of such amen ent. Nothing in this subsection
~ shall be construed to delay the effective date of any amendment.
"(C) The Commission shall, during the ninetv-day period follow-
- ing the effective date of this pamgraph, promulgate regulations es.
tablishing (i) standards for determinsng whether any amendment to
.a an operating license involves no significant hazards consideration:
(ii) criteria for providing or, in emergency situations, dispensing ~
with prior notice and reasonable opportunity forpublic comment on any such determination, which crsteria shall take into account the exngency of the need for the amendment involved; and (iiil pmce.
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dures for consultation on any such determination with the State in which the facility involved is located. "
1 (b) The authority of the Nuclear Regulatory Commission, under
! the provisions of the amendment made by subsection (a), to issue .
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and to make immediately effective any amendment to an operatslng license shall take effect upon the promulgation by the Commsssion -
of the regulations required in such provssions.
i.
QUA!JTY ASSURANCE Szc.13. (a) The Nuclear Regulatory Commission is authorized
_1 and directed to implement and accelerate the resident inspector pro-
.] gram so as to assure the assignment of at least one reside"nt inspec-tor by the end offiscalyear 1982 at each site at which a commercial nuclear powerplant is under construction and construction is more q than lipercent complete. At each such site at which construction is l
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! not more than 15 percent complete, the Commission shall provide that such inspection personnel as the Commission deems appropri-ate shall be phpically present at the site at such times following n issuance of the construction permit as may be necessary in the judg-ment of the Commission.
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ib) The Commission shall conduct a study of existing and alterna-tive programs for improving quality assurance and quality control in the construction of commercial nuclear powerplants. In conduct-fa ing the study, the Commission shall obtain the comments of the public, licensees of nuclear powerplants, the Advisory Committee on
' . Reactor Safeguards, and organizations comprised of professionals having expertise in appropriate fields. The study shall include an analpis of the followsng:
{a (1) pmviding a basis for quality assumnce and quality con-trol, snspection, and enforcement actions through the adoption
- of an approach which is more prescriptive than that currently in practice for defining principal architectural and engineering
- u. criteria for the construction of commercial nuclear ponerplants; (2) conditioning the issuance of construction permits for com-
- mercial nuclear powerplants on a demonstmtion by the licensee that the licensee is capable ofindependently managing the ef.
- fectitt performance of all quality assumnce and quality control
- responsibilities for the powerplant;
, (3) evaluations, inspections, or audits of commercial nuclear powerplant constructson by organizations comprised of profes-
. sionals having expertise nn appropriate fields which evalua-tions, inspections, or audits are more effective than those under current practice; (4) improvement of the Commission's organization, methods.
_ and programs for quality assurance development, review, and inspection; and (5) conditioning the issuance of construction permits for com-mercial nuclear powerplants on the permittee entering snto con-C tmets or other arrangements with an independent inspector to audit the quality assumnce program to versfy quality assurunce
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performance-For purposes of paragraph (S), the term " independent inspector" means a person or other entity having no responsibility for the design or construction of the plant involved. The study shall also ..
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include an analysis of quality assurance and quality control pro.
grams at representative sites at which such progtums are operating satisfactorily and an assessment of the reasons therefor.
(c)Forpurposes of (1) determinsng t he best means of assuring that commercial nuclear powerplants are constructed in accordance with the ap-
, plicable safety requirements in effect pursuant to the Atomic u Energy Act of1954; and -
(2) assessing the feasibility and benefits of the various means
, listed sn subsection (b); '
l) a the Commission shall undertake a pilot program to review and evaluate programs that include one or more of the alternatitt con-cepts identified in subsection ib) for the purposes of assening the feasibility and benefits of their implementation. The pilot pmgram u
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.a 10 shall include progmms that use independent inspectors for auditing m quality assurance responsibilities of the licensee for the construction
) of commenial nuclear powerplants, as described in paragmph (5) of J
subsection (b). The pilot program shall include at l east three sites at which commercial nuclearpowerplants are under construction The Commission shall select at least one site at which quality assurance -
,l L and least quality two sitescontrol programs with remedial progmms haveunderway operated and at at satisfactorily,h whic major construction, quality assurance, or quality control deficiencies (or y any combination thereoD have been identified in the past. The Com.
msssson may require any changes in existing quality assurance and quality contml organizations and relationships that may be neces.
sary at the selected sites to implement the pilot progmm.
(d) Not later than fifteen months after the date of the enactment of this Act, the Commission shall complete the study required under
^
subsection (b) and submit to the United States Senate and House of Representatives a report setting forth the results of the study. The report shall include a brief summary of the information received
(' from the public and from other persons referred to in subsection (b)
" and a statement of the Commsssion's response to the significant comments received. The report sha!! also set forth an analvsis of the
~ results of the pilot program required under subsection (c) The report shall be accompanied by the recommendations of the Commsssion, including any legislative recommendations, and a description of any administrative actions that the Commission has undertaken or in.
m tends to undertake, for improving quality assurance and quality control programs that are applicable during the construction of nu.
. clearpowerplants. s LIMITATION ON USE OF SPECIAL Nt.? CLEAR MATER!AL 3 SEc.14. Section S7 of the Atomic Energy Act of1954 (42 U.Sc
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1 2077) is amended by adding at the end thereof the following new subsection:
"e. Special nuclear material, as defined in section 11. produced in n
- a facilities licensed under section 103 or 104 may not be transferred,
'J reprocessed, used, or otherwise made available by any instrumentali.
ty of the United States or any other person for nuclear explosive -.
purposes. ,.
RESIDENT INSPECTORS SEc.15. Of the amounts authorized to be appro tion 1, the Nuclear Regulatory Commission sha!!priated use such sumsunder as sec-a may be necessary to conduct a study of the /inancial hardships in.
a curred by resident inspectors as a result of (1) regulations of the Commissson requiring resident inspectors to relocate periodscally from one duty station to another; and (?) the requirements of the -
, Commission respecting the domicile of resident snspectors and re.
specting travel between their domicile and duty station in such manner as to avoid the appearance of a confic! of interest. Not later than 30 days after the date of the enactment of this Act, the .
Commission shall submit to the Congress a report setting forth the findings of the Commission as a result ofsuch study, together with d a legislative proposal (including any supporting data or informa.
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i 9106 Federal Register / Vol. 48. No. 43 / Thursday March 3,1983 / Notices q
i The agenda for the subject meeting Request for Pub!!c Comment on comments provided in response to this shall be as fo'Jows: Pianned Studies of Quality Assurance . Federal Regin'er Notice as input into the Programs for Construction of Nuclear quality assurance studies required by Eriday March.13. Isas-a:30 a.m. Until Power Plants Required by Pub. L 97 . the NRC Authorization Act.
- the Conclusion ofBusiness 415, NRC Authorization Act-Saturday. Sfa:ch 19,1983-&30 a.m. Until ostss: Submit comments by May 1.
, t!s Conc /csion ofBusiness Acency: Nuclear Regulatory 1983. Comments received after this date Discussion of the topics noted above. Commission. wdl be ccasidered if it is practical to do so, but assurance of consideration During the initial portion of the meeting the Subcommittee, along with Action:R quest for public comment. cannot be given except to comments any ofits consultants who may be "#
suasssaav:The NRC Invites pub!!c Q",n ch an comment on methods ofimproving the Aoonass: Send comments to: Secretary..
quality of nuclear p wer plant U.S. Nuclear Regulatory Commission.
considered durms the balance of the construction.The NRC Authorization
, Washington. D.C. 20555.' Attn: Docketing Act. Section 13. Quality Assurance, for and Service Branch.
h Subcommit, tee will then hear fiscal years 1982 and 1983. directs the presentations by and hold discussions NRC to conduct a study of existing and Hand deliver comments to Room 1121.
al unaun pr grams f rimproving 1717 H Street NW Washington. D.C.
eir consul and therint quality assurance and quality contr Iin between 8:15 a.n and 5:00 p.a 7 persons regarding this review.
j the construc "" '
For further information regarding w, a p lot Examine comments received at: The ts.
topics to be discussed. whether the program to review and evaluate certain NRC Public Document Roon 1717 H meeting has been cancelled or alternative concepts.The Act directs the Street NW Washington. D.C.
] j rescheduled. the Chairman's ruling on requests for the opportunity to present b
b in con u th f th th tu y.The NRC oral statements and the time allotted is to provide a report to Congress on the Ten L Harpster. Gef. @aby therefor can be obtained by a prepaid Assurance Branch. Division of Quality 1 telephone call to the cognizant "sul f d dpu p Assurance. Safeguards, and Inspection and the omme dations ,
j Designated Federal Employee Ms. R. C. actions taken to improve quality Programs. Office ofInspection and Tang (telephone 202/634-1414) between Enfecement. (301) 492-4774.
assurance and quality control programs 8:15 a.a and 5.100 p.m EST.
. for nuclear power plants under marrAny speeonesarion m Deted: February 25.1983. construction. Sections 13(b) 13(c), and following paragraphs have been g lohn C. Hoyle. 13(d)of the NRC Authorization Act are reproduced from the NRC Authorization Adnsory Comminee Management Officer. reproduced under Supplementary Act. Sections 13(b).13(c), and 13(d):
ya o,. ein.e m ee , Information below, saume cosa rume es-a The NRC will consider public == coca reso.ei-a e
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(4) improvement of the Cohumission's organtration, methods,
- 13(b) The Ctanission shall conduct a study of entsting and alterna.
and programs for quality assuredce development, review, and tive programs for taproving quality assurance and quality control Inspection; and in the construction of commerClel nuclear powerplants. In conduct.
(5) conditioning the issuance of construction permits for com.
ing the study, the Commission shall obtain the connents of the mercial nuclear powerplants on the permittee entering inte pubitc. Itcensees of nuclear powerplants, the Advisory Cosmittee on contracts or other arrangements with an independent inspector lleactor Safeguards, and organtrations comprised of professionals **s to audit the quality assurance program to verify quality assur. 1 having espertise in appropriate fields. The study shall include en ,
ance performance, k analysts of the following:
Forpurposesofparagraph(5),theterm'independentinspector* f (1) providing a basis for quality assurance and quality control.
inspection, and enforcement actions through the adoption of an means a person or other entity having no responsibility for the f design or construction of the plant involved. The study shall also approach which is more prescriptive than that currently in E-*
include an analysis of quality assurance and quality control pro.
practice for defining principal architectural and engineering h grams at representative sites at which such programs are operating Z criterta for the construction of ceaunercial nuclear powerplants; settsfactorily and an assessment of the reasons therefor, (2) conditioning the issuance of construction permits for com.
U mercial nuclear powerplants on a demonstration by the licensee 13(c) For purposes of .
that the licensee 15 capable of independently managing the #
3 (1) determining the best means of assuring that comercial g effective performance of all quality assurance and quality con. x*
nuclear powerplants are constructed in accordance with the trol responstbt11ttes for the powerplant; appIlcable safety requirements la ef fect pursuant to the Atostc k:r (3) evaluations. inspections, or audits of cosmercial nuclear f.a Energy Act of 1954; and powerplar.t construction by organizaticns comprised of profes.
(2) assessing the feasibility and benefits of the various means sionals having empertise in appropriate fields which evaluations. '
Ilstedinsubsection(b); Z inspections, or audits are more ef fective than those under cur.
E.
I 9 rent practice; I
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the Commission shall undertake a pilot program to review and evaluate from the public and from. o'ther persons referred to in subsection (b) programs that include one or more of the alternative concepts identi- .
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andastatcmentof[theCommission'sresponseto :he significant fled in subsection (b) for the purposes of assessing the feasibility
- commentsrecahed. ' The report shall also ' set forth an analysis of the and benefits of their implementation. The pilot program shall include results of the pilot program required under subsection (c). The programs that use Independent inspectors for auditing quality assurance report. shall be accompanied by the recommendations of the Cornission, responsibilities of the Ilcensee for the construction of commercial including any legislative recossendations, and a description of any nuclear powerplants, as # scribed in paragraph (5) of subsection (b).
administrative actions that the Commission has undert4 ken or intends The pliot program shall include at least three sites at which c m to undertake, for improving qual (ty assurance and quality control mercial nuclear powerplants are under construction. The Commission prograars that are applicable during th'e construction of nuclear shall select at least one site at which quality assurance and quality powerplants." g control programs have operated satisfactorily, ar.d at least two sites a - coes nas-e w: E with remedial programs underway atit.ica major construction, quality 4 4
assurance, or quality control deficiencies (or any combination thereof) A fu have been identified in the past. The Commisstor. may require any %
o changes in existing quality assurance and quality control organt24tions A u
and relationships that may be necessary at the selected sites to implecient the pilot program.
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13(d) Not later than fifteen months after the date of the enactment E of this Act, the Commission shall complete the study required under
.u subsection (b) and submit to the United States Senate and House of E$
Representatives a report setting forth the results of the study. The 8 report sh.11 include a brief s ry of the information received Z O
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. UNITED STATES '
[.g.) NUCLEAR REGOLATORY COMMISSION ,
'+gf '
" Office of Public Affairs
. Washington, D.C. 20555 No. S-14-82 -- -
FOR IMMEDI ATE RELEASE Tel. 301/49.2-7715 -
~
~ ~~ ._ Remarks by -
Nunzio J. Palladino, Chairman
. U. S. Nuclear Regulatory Commission 's . .
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at the INPO Conference of Chief Executive Officers .
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Nuclear Facilit'fes.
Atlanta, Georgia " ,
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October 5, 1982 -
" MEETING THE CHALLENGE FOR A NUCLEAR FUTURE" _
- - = * -
Your ' utilities need public c'nfidence to survive and
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o prosper. It seems to me'that confidence in civilian nuclear activities requires two things to happen: first, nucleer power plants must provide reliable, affordable -
electricity without accidents for a long pe,riod of time; -
and, second, t'.ere must be a broad public perception that th.e nuclear industry maintains the highest standards, .: ; '
, virtually unsurpassed anywhere else in busines's and the
. professions. Said in another way, I think con'fidence in --
civilian . nuclear p.ower r' equires solid indications of a ~~
genuine determination by you to.run a very tight ship and ,
to take firm responsibility .for public safety. . .
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..For today- let me concentrate ort iconstructionIquality -
assurance.
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s I continue to be con 9
. to shore up your own,cerned and the that some ofconfidence public's you need. toin do more the f. -
c cuality assurance of your c'onstruction operations. .
t Quality-assurance, or' QA, should be the central focus now b ,
- for all the utilities building nuclear plants. The !
Commission has considered quality assurance to be a key E factor in the. design and construc; tion of nuclear power E plants for many years. The proylems that have been !
identified recently indicate th'at the fundamental cause of l m'ost design and construction de?iciencies is the l'ack' of [:
i total managc.nent commitment to quality. .
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If senior managers such as you h,av.e a strong commitment to ;
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CONGRESS'IONAL AND COMMISSION INTEREST -
A NUMBER OF CONGRESSIONAL HEARINGS AND COMMISSION MEETINGS HAVE BEEN HELD RECENTLY ON THE SUBJECT OF QUALITY ASSURANCE IN THE NUCLEAR INDUSTRY. RESULTS OF THIS HIGH LEVEL ATTENTION INCLUDE:
~
, CONGRESSIONAL LEGISLATION (FORD AMENDMENT) REQUIRING NRC TO CONDUCT AN INDEPTH STUDY OF QUALITY IN CONSTRUCTION, INCLUDING A PILOT PROGRAM TO TEST SEVERAL ALTERNATIVES COMMISSION APPROVAL OF A SERIES OF NRC INITIATIVES DESIGNED T ASSURE QUALITY IN CONSTRUCTION AND NRC'S ABILITY TO MONITOR AND EVALUATE IT --
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, -FORD AMENDMENT .
AT LEAST ONE RESIDENT INSPECTOR AT EVERY CONSTRUCTION SITE GREATER THAN 15%
COMPLETE (ENDFY82) ,
STUDY OF EXISTING AND ALTERNATIVE PROGRAMS FOR IMPROVING QUALITY ASSURANCE MORE PRESCRIPTIVE APPROACH FOR PRINCIPAL ARCHITECTURAL AND ENGINEERING CRITERIA CONDITIONING CP ON DEMONSTRATION OF QA MANAGEMENT CAPABILITY USE OF AUDITORS / INSPECTORS FROM ASSOCIATION OF PROFESSIONALS IMPROVEMENT 0F NRC ORGANIZATION AND PROGRAMS FOR QA CONDITIONING CP ON LICENSEE USE OF INDEPENDENT INSPECTORS
, TO AUDIT ITS QA PROGRAM PILOT PROGRAM
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REVIEW AND EVALUATE AB0VE CONCEPTS INDEPENDENT INSPECTORS FOR AUDITING QA AT LEAST THREE CONSTRUCTION SITES REPORT TO CONGRESS 15 MONTHS AFTER ENACTMENT ACCOMPANIED BY COMMISSION. RECOMMENDATIONS TO INCLUDE INPUT RECEIVED FROM PUBLIC, LICENSEES, ACRS AND
~ PROFESSIONAL GROUPS ,
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INITIATIVES CONTAINED IN S$CY-82-352, PAPER ENTITLED " ASSURANCE OF QUALITY,"
- DATED AUGUST'29, 1982 INITIATIVESAREDESIGN5D'TO: ,
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ESTABLISH ADDITIONAL CONFIDENCE IN THE QUALITY OF DESIGN'AND CONSTRUCTION ACTIVIT.IES e
IMPROVE THE MANAGEMENT CONTROL OF' QUALITY, .
IMPROVE THE NRC CAPABIl.ITY TO EVALUATE THE IMPLEMENTATION OF LICE,NSEE ,
PROGRAMS. -
SATISFY THE DIRECTION PROVIDED THE NRC IN AN AMENDMENT ACCEPTED-BY .
THE HOUSE AND SENATE CONFEREES IN THEIR JOINT CONSIDERATION OF THE ,
U C'S FY 82-83 AUTHORIZATION BILL. l
INITIATIVES FALL INTO THE FOLLOWING CATEGORIES:
A. MEASURES AT NEAR-TERM OPERATING LICENSE FACILITIES
- 1. SELF EVALUATIONS -
- 2. REGIONAL EVALUATIONS 3.,- INDEPENDENT DESIGN REVIEWS ,
B. INDUSTRY INITIATIVES
- 1. INPO. EVALUATIONS
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- 2. UTILITY AND THIRD PARTY EVALUATIONS -
C. CONSTRUCTION INSPECTION PROGRAM CHANGES
- 1. REVISE PROCEDURES AND INCREASE RESOURCES
- 2. CONSTRUCTIONASSESSMENTTEAMINSPECTIONS(CAT) -
- 3. INTEGRATED DESIGN INSPECTIONS (NRC)
. 4. EVALUATION,0F REPORTED INFORMATION D.
DETERMINE FEASIBILITY OF DESIGNATED REPRESENTATIVES (LIKE FAA)
. . ._ ._E , , MANAGEMENT _OF QUALITY -
- 1. MANAGEMENT SEMINARS
- 2. QUALIFICATION & CERTIFICATION OF QA/QC PERSONNEL
- 3. CRAFT'SMANSHIP F. LONG-TERM REVIEW O
a
LEAD NRC STAFF RESPONSIBILITIES FOR OA INITIATIVES i
NTOL - SELF EVALUATION NRR NTOL - REGIONAL EVALUATION REGIONS' -
NTOL - INDEPENDENT DESIGN REVIEW NRR -
4 INDUSTRY INITIATIVE .
IE CONSTRUCTION INSPECTION PROGRAM CHANGES IE CONSTRUCTION ASSESSMENT ... TEAM' INSPECTION , . IE . .
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' INTEGRATED DESIGN INSPECTIONS -
_ IE EVALUATION OF REPORTED INFORMATION IE .
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, DESIGNATED REPRESENTATIVES IE g O.
MANAGEMENT ... PROGRAMS IE CERTIFICATJON ... PERSONNEL IE
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T'
, . CRAFTSMANSHIP IE .
LONG TERM REVIEW '
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PU'RPOSE OF VISIT
, THIS TEAM OF NRC AND CONTRACTOR SCIENTISTS, ENGINEERS, AND QUALITY PROFESSIONALS IS HERE AS A RESULT OF BOTH THE CONGRESSIONAL MANDATE TO STUDY QUALITY IN CONSTRUCTION AND THE NRC INITIATIVES IN QUALITY ASSURANCE .
THE PURPOSE OF OUR VISIT IS TO STUDY YOUR PROJECT MANAGEMENT AND QUALITY ASSURANCE PROGRAMS AS ONE OF A SERIES OF CASE STUDIES AT NUCLEAR PLANTS ACROSS THE NATION
- I . .
nt 0
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t LONG-TERM REVIEW STUDY MANDATED BY
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- 1. SECY 82-352
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- 2. NRC'SFY82-83AUTHORIZATIONBILL(FORDAMENDMENT) -
OBJECT
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- 1. COMPREHENSIVE LOOK AT PAST QUALITY PROBLEMS T0-DETERMINE ROOT CAUSES
, 2. " REVIEW 0F PROGRAMS IN WHICH QUALITY PROBLEMS HAVE NOT BEEN IDENTIFIED
. TO DETERMINE REASONS FOR APPARENT SUCCESS ,
- 3. PROVIDE RECOMMENDATIONS FOR FUTURE NRC QA PROGRAM
- 4. SATISFY REQUIREMENTS IN FORD AMENDMENT 6
- s 1 -
- - - _ - _ _ _ _ _ _ _ - _ - - _ _ - _ _ - - - - - _________v_
LONG-TERM REVIEW
- APPROACH ' i
. t 1.
DEVELOP SERIES OF QUALITY ASSURANCE CASE STUDIES AT SELECTED LICENSEE -
i PLANTS. VISIT SEVERAL UTILITIES HAVING HAD SERIOUS QUALITY PROBLEMS AT
' SEVERAL THAT HAVE NOT.
t
- 2. FROM THE CASE STUDIES, DETERMINE ESSENTIAL UNDERLYING CHARACTERISTICS OF SUCCESSFUL AND UNSUCCESSFUL PROGRAMS. ALSO, DETERMINE WHAT ACTIONS
. [
NECESSARY TO SOLVE PROBLEMS AND VALUE/ IMPACT OF SOLUTIONS. '
4
- 3.
INTERGRATC RESULTS OF PARALLEL SUBSTUDIES WITH SERIES OF CASE.' STUDI .
DEVELOP FINDINGS, RECOMMENDTIONS, REPORTS.
- ri
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LONG-TERM REVIEW s.
LTR SUBTASKS ,.
- 1. QUALITYASSURANCECASE-STUDIES (INCL.SITEVISITS)
- 2. REVIEW AND ANAliSIS OF NRC'S QA PROGRAM -
- 3. REVIEW AND ANALYSIS OF OUTSIDE PROGRAMS -
- 4. STUDY ON QUALIFICATION / CERTIFICATION 5.
ANALYSIS OF FORD AMENDMENT ALTERNATIVES (INCLUDING PILOT PROGRAM)
- 6. PILOT PROGRAM
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- 7. ESTABLISHMENT OF ADVISORY PANEL .
,e
, 8. STUDY OF CONTRACTS AND PROCUREMENT PROCESS --
9 .- INTERFACE WITH OUTSIDE GROUPS
- 10. WRITING OF REPORTS '
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- .* , , . .{} , ._. , - - - , . .. ...
. - ,e LTR TASKS I. QUALITY ASSURANCE CASE STUDIES PRE FIELD ACTIVITY DEVELOPMENT OF ASSESSMENT PLAN AND METHODOLOGY PLANT VISITS MUST CONSIDER LTR ISSUES AND FORD ISSUES -
SCHEDULING FAMILIARIZATION WITH PLANT AND PLANT QA PROGRAM AND -
HISTORY FIELD ACTIVITY VISIT TO REGIONAL OFFICE VISIT TO CORPORATE OFFICE
- ~
VISIT TO PLANT SITE DISCUSSIONS WITH REGIONAL AND RESIDENT INSPECTORS
~
DISCUSSIONS WITH LICENSEE PERSONNEL, CONTRACTORS ,
REVIEW OF QA PROGRAM, SELECTED RECORDS PLANT WALK THROUGH POST FIELD ACTIVITY .
9 ANALYSIS'0F FINDINGS POSTULATION AND EVALUATION OF DIFFERENT APPROACHES INPUT TO GENERIC REPORT l- . ~
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NEED FOR UTILITY INFUT AND ASSISTANCE THE GENERIC RESULTS OF THIS SERIES OF SITE SPECIFIC CASE '
STUDIES AND PARALLEL STUDIES OF GERMANE TOPICS WILL FORM THE BASIS OF -
REPORTS TO THE NRC COMMISSIONERS
. REPORT TO CONGRESS NRC'S FUTURE POLICY AND PROGRAM IN
. QUALITY ASSURANC,E THE EMPHASIS OF OUR EFFORT WILL.BE TO DETERMINE UNDERLYING PROGRAMMATIC CHARACTERISTICS OF PROJECT MANAGEMENT AND -
QUALITY ASSURANCE THAT EITHER
? .
CONTRIBUTE TO THE 0VERALL SUCCESS OF THE PROJECT CONTRIBUTE TO THE DEVELOPMENT OF RESULTS THAT FAIL
, TO MEET THE STANDARDS OF THE INDUSTRY, THE NRC, AND THE PUBLIC FOR QUALITY IN A NUCLEAR POWER PLANT ,
\
THIS IS NOT AN INSPECTION. WE ARE NOT HERE TO INSPECT OR AUDIT'
~
OR SECOND GUESS. WE ARE TO LEARN AND TO DEVELOP REAL WORLD ..
INFORMATION TO HELP STRUCTURE CONGRESSIONAL, NRC, AND INDUSTRY P0L,ICIES FOR[ QUALITY IN THE NUCLEA,R ' INDUSTRY FOR
~
THIS: DECADE AND BEYOND -
TO BE' SUCCESSFUL, WE NEED YOUR HELP, COOPERATION, AND CANDOR. -
WE.THANK YOU FOR YOUR PAkTICIPATION IN THIS MAJOR NRC POLICY STUDY .
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SUMMARY
LONG-TERM REVIEW REASON -
- ~
COMPREHENSIVE STUDY TO DETERMINE ROOT CAUSES OF QUALITY PROBLEMS AT PLANTS WITH IDENTIFIED DEFICIENCIES DETERMINE UNDERLYING CHARACTERISTICS OF SUCCESSFUL QUALITY PROGRAMS DEVELOP BLUEPRINT FOR FUTURE FOR NRC AND LICENSEE QUALITY .
. PROGRAMS SCOPE ,
NRC STAFF STUDY PERFORMED BY NRC STAFF LED BY HQ, ASSISTANCE FROM REGIONS, CONTRACTORS EXAMINATION OF EXISTING PROGRAMS AND PAST PROBLEMS WILL INCLUDE ,
REVIEW OF EXISTING DOCUMENTATION (PLANS, INVESTIGATIONS, ETC.)
VISITS / DISCUSSIONS WITH REGIONS AND RESIDENTS
.- VISITS TO PLANT SITES (TWELVE TO FIFTEEN) , ..
...EU :':?? : EMPHASIS ON GENERIC IMPLICATIONS INCLUDES BOTH PLANTS UNDER CONSTRUCTION AND OPERATING SITES .
WILL EXAMINE NRC QA PROGRAM AND POLICIES AS WELL AS LICENSEES / VENDORS /
CONTRACTORS WILL LOOK AT OUTSIDE QA PROGRAMS (NON-NUCLEAR AND FOREIGN NUCLEAR)
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SURVRY LONG-TERM REVIEW OTHER REVIEW WILL BE RESPONSIVE TO FORD AMENDMENT .-
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FORD AMENDMENT SETS FIFTEEN MONTH TIME FRAME .
WILL SOLICIT INPUT FROM PUBLIC, LICENSEES, ACRS, PROFESSIONAL SOCIETIES, UNIONS.
- ~
PLANTOESTABLISHAD.VISdRYPANEL '(- ^
, EXPECTED RESULTS -
CHARACTERIZATION OF SUCCESSFUL AND UNSUCCESSFUL PROGRAMS,. ROOT CAUSES RECOMMENDATIONS FOR CHANGES / IMPROVEMENTS IN NRC AND LICENSEE QA
- ' ' IDENTIFICATION OF NEEDED LEGISLATION '
REPORT TO CONGRESS TO SATISFY REQUIREMENTS OF FORD AMENDMENT
- l. -
1
CHRONOLOGY CONGRESSIONAL OVERSIGHT HEARINGS ON QA HELD IN THE HOUSE OF REPRE _
SUBCOMMITTEE ON ENERGY AND ENVIRONMENT; COMMITTEE ON INTERIOR AND INSULAR AFFAIRS - NOVEMBER 19, 1981 SUBCOMMITTEE ON ENVIRONMENT, ENERGY, AND NATURAL RESOURC,ES; .
COMMITTEE ON GOVERNMENT OPERATIONS - DECEMBER 14, 1981 .
" ~ ' NOVEMBER 27, 1981 - CHAIRMAN DIRECTED STAFF TO ASSEMBLE ~ APPROACHES TO STRENGTHEN QA DECEMBER 1, 1981 - CHAIRMAN PALLADINO, IN A SPEECH TO AIF, CHALLENGED THE NUCLEAR INDUSTRY TO REEXAMINE AND UPGRADE ITS QUALITY ASJURAN ,' -
JANUARY 29, 1982 - NRC STAFF BRIEFED COMMISSION ON PRELIMINARY EVALUATIONS .
0F VARIOUS QA INITIATIVES FEBRUARY 4,1982 - INPO BRI.EFED COMMISSION ON INDUSTRY ACTIONS
- F ;:.i. ::: ::_'II; FEBRUARY 10, 1982 - STAFF DIRECTED TO PREPARE MORE DEFINITIVE PLAN, INCLUDING SCHEDULE AND RESOURCES -
MARCH 4, 1982 - QA PRESENTATION TO ACRS APRIL 12, 1582 - MEETING WITH INPO TO EXCHANGE QUALITY ASSURANCE INFORMATION MAY 19, 1982 - SENIOR AGENCY MANAGEMENT MEETING TO DISCUSS QA STRATEGY
.~ -, e * ** - b
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l CHRONOLOGY JUNE 10, 1982 REGION III ADMINISTRATOR TESTIFIES BEFORE CONGRESS
~
JULY 15, 1982 NRC STAFF BRIEFED COMMISSION ON STAFF PLANS FOR QUALITY -
ASSURANCE AUGUST 20, 1982 EDO SENT STAFF PAPER ON ASSURANCE OF QUALITY TO THE COMMISSION (SECY 82-352) ,
SEPT. 14, 1982 REGION III ADMINISTRATOR TESTIFIES BEFORE CONGRESS SEPT. 20, 1982- IE BRIEFED COMMISSION'S ASSISTANTS, CHAIRMAN ON QA INITIATIVES IN SECY 82-352 SEPT. 29,- 1982 COMMISSIONBRIEFINGONSECY82-352 OCT. 5, 1982 CHAIRMAN PALLIDINO SPEAKS BEFORE INP0 CONFERENCE OF CHIEF EXECUTIVE OFFICERS, SAYS QA SHOULD BE CENTRAL FOCUS FOR UTILITIES BUILDING' NUCLEAR PLANTS
- ~~
OCT. 13, 1982 CHAIRMAN PALLIDINO SPEAKS BEFORE AMERICAN SOCIETY OF QC, INDICATES EFFECTIVE QA NECESSARY TO RESTORE PUBLIC CONFIDENCE IN NUCLEAR POWER .
. . . . . s GCT. 18, 1982 COMMISSIONER ASSELSTINE SPEAKS BEFORE ANS EXECUTIVE -
CONFERENCE ON QUALITY ASSURANCE ,
1 4
6 I
d NRC'S QUALITY ASSURANCE INITIATIVES SPECIAL STUDY OF NUCLEAR QUALTlY ASSURANCE (LONG-TERM REVIEW)
BRIEFING SLIDES FOR PRESENTATION i- .
FEBRUARY 16,1983 AT '
.BATTELLE, PACIFIC NORTHWEST LABORATORIES l
, RICHLAND, WA i DR. W.D. ALTMAN, PROJECT MANAGER
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. . e NRC ORGANIZATION COMMISSIONERS
(
EXECUTIVE DIRECTOR DIRCKS i
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NUCLEAR NUCLEAR l
REGULATORY MATERIAL NUCLEAR INSPECTION
- RESEARCH SAFETY AND REGULATORY AND SAFEGUARDS RESEARCH ENFORCEMENT DENTON -
DAVIS e OUNG 4
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OFFICE OF INSPECTION AND ENFORCEMENT '
R.C. DeYOUNG, DIRECTOR J.H. SNIEZEK, DEPUTY DIRECTOR TECHNICAi. TRAINING CENTER C.W. TH AYER, DIR ECTOR PROGRAM SUPPORT BRANCH
- J.L. BLAHA, CHIEF ENFORCEMENT STAFF J.A. AXELRAD, ACTING DIRECTOR
?
DIVISION OF QUALITY ASSURANCE.
SAFEGUARDS, AND INSPECTION .
DIVISION OF EMERGENCY PROGRAMS -
PREPAREDNESS AND
~
J.M. TAYLOR, DIRECTOR ENGINEERING RESPONSE B.K. GRIMES, DEPUTY DIRECTOR
', E.L. JORDAN, DIRECTOR S. A. SCHWARTZ, DEPUTY DIRECTOR QUALITY ASSURANCE BFkANCH T.L. HARPSTER, CHIEF -ENGINEERING AND GENERIC
. COMMUNICATIONS BRANCH 1 R.L. B AER, CHIEF I REACTOR CONSTRUCTION PROGRAMS; BRANCH '
EVENTS ANALYSIS BRANCH R.F. HEISHMAN, CHIEF W.R. MILLS, CHIEF l
OPERATING REACTOR PROGRAMS BRANCH INCIDENT RESPONSE BRANCH J.G. PARTLOW, CHIEF f 9 K.E PERKINS. CHIEF SAFEGUARDS AND MATERIALS PROGRAMS BRANCH ' EMERGENCY' PREPAREDNESS 4
L.I. COBB, CHIEF ,
BRANCH s
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4 BACKGROUN O ' " '
J~ e OVER THE PAST SEVERAL YEARS THERE HAS BEEN A SERIES
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AND ENGINEERING) AT SEVERAL NUCLE
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PLANTS
-MARBLE RECEIVING HILL WIDESPREAD ATTENTION INCLUDE. !
-M'DLAND -
k -ZIMMER 1
-SOUTH TEXAS
\
-DIABLO CANYON
{ e-THE PERCElVED SEVERITY OF THE QUALITY PROBLEMS i
j ' PUBLICITY NRC COMMISSIONERS ANDTOPUBLIC QUESTION INTEREST HAVE CAUSED THE CO '
-THE A i
I, BILITY CONSISTENT WITH OFPUBLIC INDUSTRY SAFETY' TO CONSTRUCT NUCLEAR PLANT j -THE ABl(ITY OF THE NRC STAFF TO PROVIDE ASSURANC a
HAS CONSTRUCTED PLANTS IN A MANNER CONSISTENT W SAFETY IN THE PUBLIC'S CONFIDENCE IN OUR ABILITY TO ,
OPERATE NUCLEAR POWER PLANTS IN A MANNER CONSIS SAFETY l
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November 2 7, 1 9 81 "'", ,'", ", , , , , . . .
MEMORANDUMf0R: William J. Dircks '"
Executive Director for Operhtiohs -
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FROM: Nunzio J. Palladino QUALITY ASSURANCE _
NRC needs to take actions that will result in improved quality assurance at Nuclear Power i Plants Steps we are taking or planning, as well as other steps that could be taken, v' vere brought up during our testimony to Congressman Udall's Subcommittee last week. A list of corrective measures would include improvements to our inspection and enforcement program as well as considerations such as third party audits, strict sanctions against non performers, approved bidders lists, and certified independent performance audits of each utility's OA activities. i
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1
, I would like you to pull together the various approacIAs that could be taken to stcengthen Quality Assurance, and provide the Commission a preliminary evaluation of the ones that appear most promising from an effectiveness and cost. standpoint, tt'3- i i believe it is desirablNo'have an initial paper on your recommendations by December 11, 1981. The Commission can then focus on the areas deemed worthy of implementation for !
further study by the staff
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COMMITTEE ON INTERIOR AND INSULAR
~
AFFAIRS ENVIRONMENT SUBCOMMITTEE D'N EN'ERGY AND TH i
4 OVERSIGHT HEARING ON O.UALITY ASSURANCE A ZIMMER NUCLEAR STATION
! STATEMENT OF THE HON. MORRIS K. UDALL j
TUESDAY, SEPTEMBER 14,9:45 a.m.
i On June 10 of this year the Subcommittee held an oversight hearing to consider t j quality assurance (QAl breakdown at the Zimmer nuclear powerplant. In this case 4
possibly others there has been a widespread failure to adhere to the y NRC's q assurance requirements. At Zimmer, the severity of the problem was recogniz j
after construction was virtually complete. MY PRIMARY CONCERN NOW C
{
ON THE NRC'S <
ryy ABILITY TO DETERMINE THAT A REACTOR i OPERATED FOLLOWING A QA BREAKDOWN LIKE THAT AT ZIMM .
j To give some idea of the extent of the Zimmer problem, I will indicate ure ofbriefly some of the issues t, hat, must be addressed prior to issuance of ag operating lic 4
-Deficient weld procedures .
ii -
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-Apparent falsificati n of weld procedure test data '
i -Insufficient documentation to demonstrate that many of the 2000 welders wh j informed me that, "The potential impact of the records is that a ,
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. -The chemical and physical properties of certain safety related piping cannot'be documented. The NRC staff has stated that, "The potential impact of the loss of traceable piping is that a substantial amount of sucli$iping may have to be replaced."
~
- -Significant quantities of safety.related materials were purchased i from vendors not qualified to supply such materials. The NRC has l stated that, "The potential impact of the material purchases is that
! installed materials may have to be replaced."
- While the June 1 O hearing yielded useful qualitative information, NRC I
staff were vague with regard to specifics. Testimony at the hearing and subsequent correspondence CAUSES ME TO QUESTION l WHETHER THE NRC STAFF IS ON TOP OF THE PROBLEM. Today's j hearing is a direct result of my not being satisfied with information j that we have been provided to date.
i j in addition to our having been provided incomplete information, there j . are other disturbing aspects of this matter. I am concerned, as I said
!- on June 10, that the NRC staff has not required an independent audit
! of the Zimmer plantt IT SEEMS UNREALISTIC TO HAVE CONDIFENCE TH AT THE COMPANY THAT NEGLECTED QUALITY ASSURANCE Fy)S SO.MANY YEARS WILL ON ITS OWN FULLY .
j . UNCOVER THE DEFICIENCIES RESULTING FROM ITS NEGLECT.
An independent gif di t is.even more important in view of the NRC suggesting that they have i
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No. S-14-82
' FOR IMMEDIATE RELEASE Tel. 301/492-7715 4
REMARKS BY
'"MUNZIO J. PALLADINO, CHAIRMAN
U.S" NUCLEAR - REGULATORY COMMISSION >
AT THE t - -
INPO CONFERENCE OF CHIEF EXECUTIVE OFFICERS OF NUCLEAR FACILITIES ATLANTA, GEORGIA ,
October 5,1982 1 -
)
! MEETING THE CHALLENGE FOR A NUCLEAR FUTURE"
}. Your UTILITIES NEED PUBLIC CONFIDENCE TO SURVIVE AND PROSPER. It seems t
' confidence in civilian nuclear activities requires two things to happen:- first, nuclear power plants i must provide reliable.. affordable electricity without accidents for a long period of time; and. second.
l there must be a broad public perception that the nuclear industry maintains the highest standards, f virtually unsurpassed anywhere else in business and the professions. Said in another way, I think confidence in civilian nucfear power requires solid indications of a genuine determination by you to.
run a very tight ship and to cta,ke firm responsibility for public safety. ,
t For today let me concentrate on construction quality assurance. .
1
- n. i i continue to be concerned that some of YOU NEED TO DO MORE TO SHORE UP YOUR O ,
AND THE PUBLIC'S CONFIDENCE IN THE QUALITY ASSURANCE OF YOUR CONSTRU OPERATIONS.
i QUALITY ASSURANCE, dE'QA SHOULD BE THE CENTRAL IOCUS NOsV FOR ALL THE l
j UTILITIES BUILDING NUCLEAR PLANTS. The Commission has considered quality assurance to be a ~
key factor in the design and construction of nuclear p - -r plants for many years. The problems that ;
i have been identified recently3i ndicate that the fundamental cause of most design and construction deficiencies is the lack of total management commitment to quality. '
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CONGRESSIONAL AND COMMISSION l i
INTEREST i l
I A NUMBER OF CONGRESSIONAL HEARINGS AND COMMISSION MEETINGS HAVE BEEN HELD
, RECENTLY ON THE SUBJECT OF QUALITY ,
i ASSURANCE IN THE NUCLEAR INDUSTRY. RESULTS 1
\
i OF THIS HIGH LEVEL ATTENTION INCLUDE:
l i
e CONGRESSIONAL LEGISLATION (FORD
~
AMENDMENT) REQUIRING NRC TO CONDUCT AN !
' INDEPTH STUDY OF QUALITY IN CONSTRUCTION (DESIGN AND ENGINEERING)INCLUD,1NG A PILOT @'OGR AM TO TEST SEVERAL -
ALTERNATIVES
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o COMMISSION APPROVAL OF A' SERIES OF NRC INITIA.TlyES DESIGNED TO ASSURE QUALITY IN CONST,R.UCTION AND NRC'S ABILITY TO MONITO.R AND EVALUATE IT , ..- .
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FORD AMENDNi$NT AT l EAST THAN ONE RESlDENTINSPECTOR 15% COMPLEiTE,(END FY 82) AT EVERY CONSTRUCTION SITE G
.i STUDY OF ASSURANCE EXISTING AND ALTERNATIVE PROGRAMS FOR IMPROVING QU e MORE PRESCRIPTIVE ENGINEERING CRITERIA APPROACH FOR PRINCIPAL ARCHITECTURAL ,-AND t y '
e e CONDITIONING CP ON DEMONSTRATION OF QA MANAGEMENT CAPABIL ,
USE OF AUDITORS / INSPECTORS F' ROM ASSOCIATION OF PROFESSION e IMPROVEMENT OF NRC e.ORGANIZATION AND PROGRAMS FOR QA -
o CONDITIONING TO AUDIT ITS QA PROGRAM CP ON LICENSEE USE OF INDEPENDENT INSPECTORS PILOT PROGR AM '
e REVIEW AND EVALUATE ABOVE CONCEPTS e ' ' " " '
INDEPENDENTINSPECTORS FOR AUDITING OA 'i e AT LEAST THREE CONSTRUCTION SITES '
REPORT TO CONGRESS r,,,
e 15 MONTHS AFT,qp fNACTMENT- ,. , . . .
e ACCOMPANIED BY COMMISSION RECOMMENDATIONS e TO INCLUDE INPUT RECEIVED FROM PUBLIC, LECENSEES, ACRS, AND PROFESSIONAL GROUPS -.
~
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II INITIATIVES Ir: I
{ CONTAINED IN SECY-82-352, PAPER ENTITLED '
j i "A5'S URANCE OF QUA LITY," -
i (AUGUST 29,1982) i INITIATIVES ARE DESIGNED TO:
e
! ESTABLISH ADDITIONAL CONFIDENCE IN THE
! QUALITY OF DESIGN AND CONSTRUCTION ACTIVITIES
~
. QUALITY IMPROVE THE MANAGEMENT CONTROL OF i '
{ e IMPROVE THE NRC CAPABILITY TO EVALUATE THE IMPLEMENTATION OF LICENSEE PROGRAMS
! e SATISFY-THE DIRECTION PROVIDED THE NRC IN AN AMENDMENT ACCEPTED BY THE HOUSE AND
!, SENATE CONFEREES IN THEIR JOINT i
. CONSIDERATION OF THE NRC'S FY 82-83 i AUTHOHlZATION BILL k e< ,,
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i INITIATN8S FALL INTO THE "" FOLLOWING CATEGORIES: "
rur .1 -
, .r- -
3 A.
! MEAS 0N$S AT NEAR-TERM OPERATING LICENSE FACILITIES i
- 1. SELF EVALUATIONS ,
I 2. REGIONAL EVALUATidNS -
- 3. INDEPENDENT. DESIGN REVIEWS i
B. INDUSTRY INITIATIVES '
- 1. INPO EVALUATIONS
- 2. \
UTILITV AND THIRD PARTY EVALUATIONS C.
! CONSTRUCTION INSPECTION PROGRAM CHANGES -
i 1.
l 2. REVISE PROCEDURES AND' INCREASE RESOURCES l 3. CONSTRUCTION ASSESSMENT TEAM INSPECTIONS (CAT)
! 4. INTEGRATED DESIGN INSPECTIONS (NRC)
EVALUATION OF REPORTED INFORMATION
} D. .
j ETERIMlNE (LIKE EAA) , FEASIBILITY OF DESIGNATED RERRESENTATIVES E. MANAGliMENT OF QUALITY . .e iy.... ,
- 1. MANAGEMENT SEMINARS 2.
l QUALIFICATION AND CERTIFICATION OF QA/QC i
PERSONNEL 3.
CRANSMA_NSHIP ,n ,,,,.,,,
l F.
4 LONG-TE;FIM REVIEW / FORD AMENDMENT,STU,DY,
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LEAD NR',d',. STAFF RESPONSIBILITIES FOR QA INITIATIVES '
i NTOL - SELF EVALUATION NRR i
- NTOL - REGIONAL EVALUATION i REGIONS i NTOL-INDEPENDENT DESIGN REVIEW NRR INDUSTRY INITIATIVE IE CONSTRUCTION INSPECTION PROGRAM CHANGES lE CONSTRUCTION ASSESSMENT. . . TEAM INSPECTION IE i
INTEGRATED DESIGN INSPECTIONS
~ .
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EVALUATION OF REPORTED INFORMATION lE DESIGNATED REPRESENTATIVES
<.<> lE !
! MANAGEMENT . . . PROGRAMS i IE CERTIFICATIO'$:. . . PERSONNEL 1
"t IE CRAFTSMANSHIP '
i IE i
LONG TERM REVIEW '
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LONG-TERM REVIEW
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STUDY MANDATED
,s , , BY e SECY8'F352 ' ' '
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i NRC'S FY 82-83 AMENDMENT) AUTHORIZATION BILL (FOR j OBJECT 6~
i 4
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COMPREHENSIVE LOOK AT PAST QUALITY
- PROBLEMS TO DETERMINE ROOT CAUSES i
REVIEW OF PROGRAMS IN WHICH QUALITY PR.OBLEMS HAVE NOT BEEN IDEN.TIFIED TO '
i # DETERIMNEtur REASONS FOR. APPARENT SU 1
- PROVIDE QA PROGRAMRECOMMENDATIONS FOR FUTURE
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SATISFt'kEQUIREMENTS IN FORD AMENDM art- ,
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APPROACH
'1 e ' DEVELOP SERIES OF QUALITY ASSURANCE CASE STUDIES AT SELECTED LICENSEE PLANTS. VISIT SEVERAL UTILITIES HAVING HAD SERIOUS QUALITY PROBLEMS AT SEVERAL THAT HAVE NOT e FROM THE CASE STUDIES, DETERMINE i ESSENTIAL UNDERLYING CHARACTERISTICS OF i >
SUCCESSFUL AND UNSUCCESSFUL PROGRAMS. :c .,
{ ALSO, DETERMINE WHAT ACTIONS NECESSARY ^
) TO SOLVE SOLUTIONS PROBLEMS AND VALUE/ IMPACT OFf e INTERGRATE RESULTS OF PARALLEL SUBSTUDIES WITH SERIES OF CASE STUDIES. DEVELOP FI N DI N G K,, R E C O M M E N D ATIO N S, R E PO R TS
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LONG TERM .,.,,
REVIEW / FORD AMENDMENT STUDY r
- \-
PROPOSED FUNDING 1.
' QUALITY ASSURANCE CASE STUDIES- '
- 2. $325 REVIEW OF NRC, INDUSTRY, AND GOVERNMENT QA i
PROGRAMS --
- 3. 275 STUDY OF-QUALIFICATION PERSONNEL /dERTIFICATION OF QA/QC
- 4. '
0 5.
PILOT PROGRAM AND ANALYSIS OF FORD ALTERNATIVES 200 REVIEW PANEL *
- 6. 100 STUDY OF CONTRACTS AND PROCUREMENT 100 i 7.
CONTACT WITH OUTSIDE GROUPS '
0 8.
ANALYSIS OF FINDINGS AND WRITING,OF REPORT O'
4 OTHER RELATED ACTIVITIES ~$1000 9.
i 10. HOLDPOINT/ CERTIFICATION STUDY AND DEVELOPMENT i DESIGNATED REPRESENTATIVE STUDY AND DEVELOPMENT 1
i
'THIS ACTIVITY 'sp WILL' BE FUNDED WITHIN THE ABOVE PROJECTS 4'
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LONG TERM REVIEW / FORD ,
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! AMENDMENT STUDY /OTHER l'
e QUALITY ASSURANCE CASE STUDIES i - INITI ATED SEPT. 82 i -
e REVIEW OF NRC, INDUSTRY, AND GOVERNMENT QA PROGRAMS . -
DEVELOPING THE 189 1 e PILOT PROGRAM AND ANALYSIS OF FORD ALTER N ATIVES -
DISCUSSION STAGE e R EVIEW. PAN EL -
189 TO DOE e STUDY OF CONTRACTS AND PROCUREMENT lf -EXCHANGED PREPROPOSAL i
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! QUALITY ASSUR'ANCE CASE STUDIES ,,
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) e PRE FIELD ACTIVITY '
-DEVELOPMENT OF ASSESSMENT PLAN AND METHODOLOGY
-PLANT VISITS MUST CONSIDER LTR ISSUES AND FORD ISSUES '
l -SCHEDULING i -FAMILIARIZATION WITH PLANT AND PLANT QA PROGRAM AND '
i HISTORY
} e FIELD ACTIVITY I I -VISIT TO REGIONAL OFFICE
! -VISIT TO CORPORATE OFFICE -
l -VISIT TO PLANT SITE ,
-DISCUSSIONS WITH REGIONAL AND RESIDENT INSPECTORS -
-DISCUSSIONS WITH LICENSEE PERSONNEL, CONTRACTORS l
-REVIEW OF, OA PROGR AM, SELECTED RECORDS i j -PLANT WALK THROUGH "' '
!1 1
J, e P.OST FIELD ACTIVITY
~
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-ANALYSIS OF FINDINGS
-POSTULATION AND EVALUATION OF DIFFERENT APPROACHES
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LONG-TERM REVIEW REASON e
' ' COMPREHENSIVE STUDY TO -
-DETERMINE ROOT CAUSES OF QUALITY PROBLEMS AT PLANTS WITH IDENTIFIED DEFICIENCIES
-DETERMINE UNDERLYING CHARACTERISTICS OF SUCCESSFUL QUALITY PROGRAMS
-DEVELOP BLUEPRINT FOR FUTURE FOR NRC AND LICENSEE QUALITY PROGRAMS SCOPE .
e NRC STAFF STUDY l
-PERFORMED BY NRC STAFF -
-LED BY HQ, ASSISTANCE FROM REGIONS, CONTRACTORS e
EXAMINATION OF EXISTING PROGRAMS AND PAST PROBLEMS WILL INCLUDE
-REVIEW OF EXISTING DOCUMENTATION (PLANS, INVESTIGATIONS, ETC.)
-VISITS / DISCUSSIONS WITH REGIONS AND RESIDENTS
-VISITS TO PLANT
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SITES (TWELVE TO FIFTEEN) e '
EMPHASIS ON GdNERIC IMPLICATIONS e
INCLUDES BOTH PLANTS UNDER CONSTRUCTION AND OPERATING SITES e
WILL EXAMINE NRC QA PROGRAM AND POLICIES AS WELL AS LICENSEES / VENDORS / CONTRACTORS e
WILL LOOK AT OUTSIDE QA PROGRAMS (NON-NUCLEAR'AND FOREIGN NUCLEAR) .
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SUM M A5N,if . . >i, -
. LONG-TERM REVIEW (CONTD OTHER -
e REVIEW WILL BE RESPONSIVE TO FORD AlhENDMENT
. e FORD AMENDMENT SETS FIFTEEN MONTH TIME FRAME e -
WILL SOLICIT INPUT FROM PUBLIC, LICENSEES, ACRS, PROFESSIONAL SOCIETIES, UNIONS e
PLAN TO ESTABLISH ADVISORY PANEL .
EXPECTED RESULTS e
CHARACTERIZATION PROGRAMS, ROOT CAUSES OF SUCCESSFUL AND UNSUCCESSFUL e
RECOMMENDATIONS FOR CHANGES /IMPROVEMiiNTS IN NRC AND LICEN-SEE QA PROGRAMS e IDENTIFICATipN OF NEEDED LEGISLATION e '
REPORT AM ENDM ENTi TO' ' CONGRESS TO SATISFY R$d'UIREldNhS OF FO n tr,<
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' CHRONOLOGY ,
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CONGRESSIONAb O,VERSIGHT HEARINGS ON QA HELD IN THE HOUSE OF REPRESENTATIVES,;, ,, .,
e AND SUBCOMMITTEE INSULAR AFFAIRS ON ENERGY AND ENVIRONMENT:
- NOVEMBER 19,1981 COMMITTEE ON INTERIOR e SUBCOMMITTEE ON ENVIRONMENT, ENERGY, AND NATURAL RESOURCES; COMMITTEE ON GOVERNMENT OPERATIONS - DECEMBER 14,1981 NOVEMBER 27,1981 - CHAIRMAN DIRECTED STAFFTO ASSEMBLE APPROACHES TO STRENGTHEN QA DECEMBnR 1,1981 - CHAIRMAN PALLADINO, IN A SPEECH TO AIF, CHALLENGED THE NUCLEAR INDUSTRY TO REEXAMINE AND UPGRADE ITS QUALITY ASSURANCE PROGRAMS JANUARY 29,1982- NRC STAFF BRIEFED COMMISSION ON PRELIMINARY EVALUATIONS OF VARIOUS QA INITIATIVES FEBRUARY 4,1982-INPO BRIEFED COMMISSION ON INDUSTRY ACTIONS FEBRUARY'10,1982- STAFF DIRECTED TO PREPARE MORE DEFINITIVE PLAN, INCLUDING SCHEDUI'E AND RESOURCES MARCH 4,1982 - QA PRESENTATION TO ACRS APRIL 12,1982 - MEETING WITH INPO TO EXCHANGE QUALITY ASSURANCE INFORMATION s avn MAY 19,1982 - SENIOR AGENCY MANAGEMENT MEETING'TO DISCUSS QA STRATEGY 8'r it i t, o ." , ,
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JUNE 10,1982 Bi REGION lli ADMINISTRATOR TESTIFIES BEFORE CONGRESS
- JULY 15,1982-
! NRC STAFF BRIEFED COMMISSION ON STAFF PLANS FOR i QUALITY ASSURANCE l
i AUGUST 20,1982 l EDO SENT STAFF PAPER ON ASSURANCE OF QUALITY TO THE i COMMISSION (SECY 82-352)
SEPT.14,1982 '
REGION 111 ADMINISTRATOR TESTIFIES BEFORE CONGRESS SEPT. 20,1982
- l. INITIATIVES IN SECY 82-352 .
! S EPT. 29,1982 , COMMISSION BRIEFING ON SECY 82-352 i OCT. 5,1982
.. CHAIRMAN PALLIDINO SPEAKS BEFORE INPO CONFERENCE w OF CHIEF EXECUTIVE OFFICERS SAYS QA SHOULD BE CENTRAL FOCUS FOR UTILITIES BUILDING NUCLEAR PLANTS OCT.13,1982
' CHAIRMAN PALLIDINO SPEAKS BEFORE AMERICAN SOCIET
' 'd'F'QC. INDICATES EFFECTIVE QA NECESSARY TO RESTORE PUBLIC CONFIDENCE IN NUCLEAR POWER OCT.18,1982 COMMISSIONER ASSELSTINE SPEAKS BEFORE ANS EXECUTIVE CONFERENCE ON QUALITY ASSURANCE
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OBaHelle Pacific Notthwest Laboratories P.O 80=999
._ R,chland. Washington 99352 T i onon, < son 376-4908 Tele = 32 6345 February 28, 1983 .
Mr. Ken C. Carroll
~~ EG&G Idaho Inc.
P.O. Box 1625 Idaho Falls, ID 83415
Dear Ken:
Review of Generic Key Indicators for Diablo Canyon Attached is my evaluation of the generic key indicators for the Diablo Canyon nuclear plant. The primary purpose of this writeup is to provide a basis for discussion of'our evaluations of Diablo Canyon. My conclusions should be considered tentative.
S cerely,
- /
rold H rty Project Manager HH:nb c: 6 - DOE HQ
, MG Patrick - BCL Fo/A-71443 p 's'
EVALUATION OF GENERIC KEY INDICATORS FOR DIABLO CANYON NUCLEAR PLANT
,1 1.0 Diablo Canyon project management appear to firmly eb' lie /e that their plant has been and is being built with adequate quality, maybe excessive quality. Certainly it is their intent to build a quality facility.
The seismic-related errors recently uncovered at Diablo Canyon suggest -
that the commitment to quality failed to ensure that adequate procedures were in place. Now'the commitment to quality seems related to obtaining an operating license. Rated 3. -
2.0 There appear to be clearly defined policy guides to define responsibilities for authorities for nuclear power plant construction and operational quality. Apparently good experience in designing, constructing, and operating other types of power generating facilities led the licensee to assume that similar procedures would be adequate for Diablo Canyon.
The Diablo Canyon project has been a long time in the design and construction phase. Contractor responsibilities and authorities and changing interfaces failed to keep up with the fomalization of NRC regulations over the past decade. This failure occurred, at least in part, because the project has' been on the verge of completion for about eight or more years, and the need to change was not pressing nor thought necessary. Rated 3.
3.0 Overall the work force employed on Diablo Canyon appears well qualified.
The licensee's engineering staff had limited nuclear experience entering ..
into the Diablo Canyon project and the staff was not large measured by present-day standards. Where the engineering work force was not qualified, liberal use.of consultants or contractors was employed, apparently for the most part, quite successfully. The use of many non-PG&E entities .
reouires that adequate quality assurance procedures be in place and '
followed carefully. This does not appear to have been the case with Blume and Associates and other early contractors. The construction work forces which were employed appear to have adhered to good construction practices. Rated 4.
4.0 Instructions, procedures, and drawings were not reviewed in detail apart j from those associated with loadirfgs for Blume's seismic analysis. While s
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2 the drawings were indadequate in this one case, there was no evidence of pervasive inadequacies in design drawings. Because of the long period to bring the project to completion, there has been a continuing change in NRC requirements concerning instructions and procedures. As previously stated, implementation of revised instructions and procedures may have lagged because of the expectation for early startup of the two plants.
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Rated 3.5.
5.0 The licensee appears to have been thoroughly convinced concerning the adequacy of the as-designed and constructed plant. Wherever quality deficiencies were noted, they were apparently reported promptly and corrected. However, QA program deficiencies may not have been regarded j with the same intensity as construction deficiencies as far as corrective ,
action was concerned. Rated 3.5.
6.0 Specific information was not acquired. The licensee corrected any ^
deficiencies in quality brougnt to its attention, but whether its corrective action program went beyond these individual actions is not clear. Not rated.
7.0 The procedures for design review appeared to be similar to those ;
successfully used in the design and construction of other types of generating facilities. Among other things the overall designs are reviewed by chief (discipline) engineers. No data were obtained on the numbers and types of field changes. Not rated.
8.0 No data were obtained on control of design input data apart from the Blume seismic data previously mentioned. Not rated. .
9.0 There was nothing inherently deficient in the organizational structure which impeded attainment of quality.in.the Diablo Canyon plants. However, .
as previously stated, through the early phases of the project the procedures and policies were not conducive to the level of quality assurance control required in present day construction activities, nor to those. presently in effect on the Otablo Canyon project. Not rated.
10.0 No data were obtained on the planning, scheduling, and budgeting for resources to construct- Diablo Canyon. Resource availability did not appear to be a significant problem area. Not rated.
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3 11.0 No data were obtained on the design control process apart ffom the Blume incident previously discussed. Not rated.
! 12.0 No data were obtained on work package development and control. Not rated.
I II 13.0 No data were obtained on procurement control. Not rated.
14.0 No data were obtained on nonconformance control. However, quality work appeared to prevail at the construction site. Not rated.
15.0 No data were obtained on special process control. Accepted procedures appeared to prevail at the construction site. Not rated.
16.0 No data were obtained on examination, test, and inspection control. Not rated.
17.0 No data were obtained on calibration control. Not rated.
18.0 No data were obtained on records. Not rated.
!; 19.0 No specific data were obtained on au'dits. The use of audits in the early years of the project appears to have been limited to those typically done >
in projects involving other types of generating facilities. There appeared
- ! ' to be no formalized program of audits. Not rated.
i 20.0 No data were obtained on corrective action. Not rated. ;
1 21.0 No data were obtained on the identification and control of material and items. Not rated.
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SITE VISIT NO. 3_ DR'o.FT l PACIFIC GAS AND ELECTRIC - DIABLO CANYON PLANT l
Key Indicators 1.0 Licensee is fully conunitted to a program for assurance of quality This licensee through its Construction Organization appears to have supported a good QA/QC effort in the on-site construction activities; however, this diligence has not, in all cases, extended to materials suppliers. Prior to 1982, such a commitment was obviously lacking with' respect to the engineering activities on the project.
This is reflected in the lack of management follow-up that allowed .
the violations of. procedures and inadequate management reviews ap--
parent in 1977 to remain undetected for four (4) years.
Many of the management decisions over the years indicate an attitude of "do anything and everything to expedite bringing the plant on line". The current Independent Design Verification Program (IDVP) and establishing, in 1982, the Project Completion Team under Bechtel's direction reflect this attitude. However, the extent to which these changes reflect a real commitment to assuring quality ..
rather than providing " cosmetics" is not totally clear.
The apparent unbalance between ." construction" and "en-gineering" in assuring quality is considered to reflect srre lack of e .
commitment at the top levels of corporate management. "
Rated 3 2.0 Responsibility and authority are clearly defined and properly implemented Manuals, Procedure and Contract documents were not reviewed to establish the R&A delineations. The discussions at the construction site demonstrated a good clear understanding of this point. Further,
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the Project Completion Team members interviewed seemed clear as to l trieir understandings also.
However, there was some fuzziness in this regard on the part of the residual Chief Engineers in the utility relative to their relationship with the Project Completion Team. ~
The Corporate Manager of QA expressed a clear understanding -
of his responsibilities and authority.
Rated 4 3.0 Qualified work force is utilized
- Although documents on this indication were not reviewed, those in key management positions appeared, in general, to be well qualified. Some reservations evolved relative to the Corporate QA staff. These came, in part, from impressions in one of the group meetings, and, in part, from opinions expressed by an NRC Region V inspector.
Rated 4 4.0 Instructions, procedures and drawings are clear and adequate The " mirror image" issue and related problems and subsequent difficulties clearly resulted from a significant break-down in clarity of design documents. .There was no indication, however, that -
a corresponding lack of clarity carried over to the infonnation for the construction of the plant. The lack of clear information occurred mainly in the communications between the utility's engineering group and its consultants and engineering service contractors.
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3 Further, the application of QA to the engineering activities was not clearly understood. It should be noted that the engineering l work currently being done by the utility /Bechtel combined Project i Completion Team is guided by the utility's engineering Procedures and Bechtel's QA Manual. Since this hybrid team has existed for
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j less than one year, one would be surprised indeed if there have not j been communications problems. It was not possible to-probe deeply 1
- enough to identify any such problems, however.
I Rated 2 i
l 5.0 Quality /QA Program deficiciencies are sought out and reported promptly This factor seems to be strongly and effectively supported j at the construction site. There is a concern, however, about the effectiveness of earlier inspections and audits of material suppliers, i
i notably one supplier of electrical system:supportse Further, the " mirror image" problem indicates a weakness in j this regard in the engineering activities.
{ It must be noted, however, that deficiencies, once dis- ~~
4 covered, have been promptly reported.and addressed.
f Rated 3
-1 6.0 Corrective action program is effective -
Not investigated 7.0 Design review activities detect and resolve design deficiencies
, The " mirror image" and related problems represent major deficiencies in the area'of Design Review. Although, the problem was eventually, discovered and is being resolved, the discovery was 6
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4 more fortuitous than the result of an orderly process. At the present time, of course, very extensive design reviews are in progress.
1976 to 1982 Rated 2 1982 to present Rated 5 8.0 Design input data is adequately controlled It is indicated that performance in this area was probably satisfactory during the original plant design process. There was obviously a major breakdown, probably due to schedule pressures, in 1977. It is equally obvious that major efforts are currently _being __ _ ___.___
applied. In fact, to an unprecedented extent in the IDVP.
Rated ?
9.0 Organizational structure is conducive to attainment of quality No fault was identified with the formal organization structure. However, the less formal position of power on the part of Engineering is strongly suspected _ to have resulted in a successful resistance of QA application. This _ level of informal power now appears.to have been significantly eroded.
._ r . ; 3.:3_;,3-. Rated ? - -
10.0 Planning, scheduling and budgeting provide the resources to do the job '
The engineering problems which have been so costly appear to have resulted from very heavy schedule pressures. This was ex-
_ tended to the initial efforts at a design verification program, which
- produced an additional set of problems. There were no indications of lack of resources currently. This case is virtually a classic of
" haste makes waste".
l Rated 2 i
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1 11.0 Design Control Process As identified in numerous earlier indicators, this is the major fault which occurred on this project. During the past year
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this has been overcorrected with a very extensive IDVP and internal "Look Back Program". ~
Before 1982 Rated 2 Currently Rated 5 12.0 Work package development and control Not investigated
- 13.0 Procurement control Evaluating to this indicator is very difficult because of the time period of this project. Even the IDVP consultant auditing the QA program has conceded-that the numerous, significant deficiencies that have been identified are deficient by today's standards, and are not by the standards existing at the time the procurements were accomplished.
Rated ?
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15.0 Special process control There were repeated indications.that there had been no significant QA/QC problems at the construction site.
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Rated 5 4
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6 16.0 Examination, test and inspection control This point was not probed in depth, but NRC Region V and
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expressions at the site indicated that the construction site efforts were excellent.
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Rated 5 17.0 Calibration control Not investigated 18.0 Records .
Although major problems have resulted from weak documenta-tion practices in engineering, the available records led to discover-ing the error four (4) years after it occurred. Further, we were advised by an NRC Region V inspector that the records and traceabil-ity. relative to construction (materials, heats and location) was unusually extensive and accurate.
Rated 5 19.0 Audits ~
, The audit program has been very extensively strengthened during the past year. Therefore, reflecting that it was found to be somewhat lacking previously. '
Rated 3 20.0 Corrective action Good, once that a prob 1cm has been identified.
Rated 5
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7 21.0 Identification and control of material items This was only superficially investigated. However, a Region V inspector, specifically connented the utility had been far above average in this regard.
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Rated 5
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WP e
- DIABLO CANYON
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POSTULATED ROOT CAUSES AND SYMPTOMS ,
1 I. Lack of understanding of merit of institutionalized QA program.
A. . Management did not implement an' effective design control program. _
- 1) Word of mouth or informal transmittal of design criteria.
- 2) Assigned cognizant lead engineers to handle: interface;:however, ~~ ~~-
l this concept not 'tilized.u
' 3) Apparent lack of proceduralization of responsibilities between PG&E- and subcontractors.
- 4) Lack Hof good design files retained by PG&E. - ~ ~ - - '
- 5) Wrong data / criteria for weights discovered by PG&E/BLUME informally resolved. '
- 6) Apparent familiarity with and confidence in URS/BLUME caused lack of formality in following good or normal engineering procedures.
([) 7) Lack of internal communication; i.e. , cognizant engineer responsible for electrical- cable trays not being advised of criteria change.
- 8) Lack of adequate design inputs control resulted in use of out-dated drawing revisions. -
2 B. ~ Management did not implement an effective Procurement Document / i Services Control Program. ~
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Interface responsibilities, including required documentation , , . - .. ...
and personnel responsibilities, not fornelly enforced.
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- 2) Apparent familiarity with URS/BLUME led to informalit9 of' " ' '
' interface (URS/BLUME known involvement in seismic criteria -
development could be a factor). ,
L 3) Contract.did not' formally address QA program requirements
'of this subcontractor'until 1977 (requirement existed
'since 1970, 10 CFR 50, Appendix B issue date).
-4) Apparent' lack' of understanding by the utility of the need for formalized service contracts as opposed to hardware contracts (Ref: NSC letters dated.1975,'AEC QA Program i
requirements).
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Diablo Canyon l Q_ Postulated Root Causes and Symptoms !
j Page 2 l
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- 5) Subcontractors appear more aware of. need for formality of f transmittal of design documentation than PG&E.
- i C. Management's apparent lack of implementation of procedures and firm j document control practices and adequate record control. L i
- 1) Contractors working to outdated drawings.
2 j; 2) Possible ~use of " diagrams" rather than released drawings. j I
1 3) Suspected . failure of subcontractor to inform or caution PGAE j
that their submittals were insufficient in documentation. l
- 4) Inability of Cloud and Associates to locate PG&E documentation
- relative to transmittal of. design inputs. '
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-II. Lack of assertiveness of NRC during period of 1969 to 1977, 78.
- [r A. NRC approved PG&E QA Manual as early as 1970;' however, internal [
engineering control procedures were not prepared and implemented i
,j until 1977-78.
! b B. QA p ogram verification activities between the years 1970-1978 i jj must have been manual review not implementation verification.
C. Utility e'xposed a long standing problem that was apparently not I recognized by NRC through their reviews / audits.
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DRAFT February 17, 1983 BACKGROUND
-* PG&E was A/E and Construction Manager for Diable Canyon.
-Support in design by contracted design consultants Engineering strong, but not expert in everything--needed consultants j in some areas.
Had a lot of consultants up to (200?)--more interfaces you create harder project.is to manage, more chance for things to fall through cracks.
Reedy e GA program for design not adequate in policy, procedures, emp1.
- General weakness in internal and external interface and DOE controls e No provisions for document control of correspondence and design documents.
- No controlled procedures for design control, design interfaces and design
- e. -PG&E did not r4 quire design consultants to complement QA requirements.
- review committees focused on operations--did not review QA program for design and construction of P.C. .
- PG&E audit system and corrective action not effective.
- Formal corrective action not invoked on engineering..
- Design consultants not required to implement QA prograns. --
e PG&E did not require design contractors 'to perform design reviewing of their wn ed. *
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- Different organizations or engineers.with different revisions of same '
document. -
e Cases where different version of same drawing revision in use. -
e No effective method for controlling seismic data which was distributed within PG&E and to consultants.
NRC ORDER e PG&E QA program did not appear to effectively exercise control over the review and approval of design information passed to and received from e
, 'l e
- PG&E QA Program did not appear to adequately control details of design information from Blume in their affected internal PG&E design group.
- e. PG&E Program did not appear to define and implement adequate QA procedures and controls over other service related contracts.
Lot of things ongoing right now--lot of studies of pre or post June /1978 for QA cn contracts and other safety related.
IDVP of PG&E interviewed.
Technical reports on basic course of all design error identified by their program, their significance, and impact on facility design.
e Hence little premature to talk about what the problem, why---the rest.
Recognize lot of studies still underway. Lot of final reports not in yet. Our effort not to reinvent the wheel or redo or do in the same technical depth what the other studies did or have done. However, some studies have been completed, reviewed by PG&E and NRC, particularly Reedy studies of QA related to seismic and design activity in 78.
Also look at QA in construction activities 78. Think those, regional inspection reports, and interviews with PG&E, Bechtel and RD staff, as well as plant visit give us sufficient information to arrive at some lessons learned from the D.C. experience. Lessons that will serve as input to our study of repre-sentative QA programs as required by the Ford Anendaent and the Commission.
Would like to structure presentation as follows:
- Definition of the problem .,
o Primary root causes e Secondary root causes e Generic implications e Implications of this case for NRC's QA .
- Implications of this case for Ford Amendment. ,
I recognize my remarks nay make some of you either personally or corporately uncomfortable. Please understand my role here is not to criticize any of you or your corporatioa, but rather to try to understand the process that led to your design problem, how it happened, what it nay mean for other plants, and the way they and the NRC do business. It is a lot easier to do what I am doing, i.e.,
2
We 4pb V!J pM R. F. REEDY, INCORPORATED 236 N. Santa Cruz Avenue f#e#p Los Gatos, California 95030 * (408) 354-9110 March i, 1982 3 @@{(V/(y s
. ., ; 2IE i Robert L. Cloud and Associates, Inc.
125 University Avenue L
-W' W
Berkeley, CA 94710 -
Subject:
Report of R. F. Reedy, Inc.
Review of Cygna Energy Services (EES)
Dear Mr. Cloud:
Attached is a copy of our Quality Assurance Review report of Cygna Energy Services (EES).
Quality Assurance Program as We have reviewed the EES it rele.ted to seismic safety-related design services performed for Pacific Gas and Electric Company prior to June, 1978. All details of our review are contained in this final report.
I am transmitting a~ copy of this report to Mr. Harold Denton of the NRC.
4 Ver ly yo -
oge F. R edy, P. E.
R. REEDY, INC.
RFR:na cc: Mr. Harold Denton Encl.
O 9
Fe/A-14413
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SEIS'4IC SAFSTY-RELATED DESIGN SERVICES PERFORMED FOR PG&E .
By j
?! CYGNA ENERGY SERVICES (EES) 7 .
i 3- P210R TO JUNE 1978
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- EES - March 1, 1982 1/43 i
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. Quality Assurance Program Review Report J'
' Phase I ku Seismic Safety-Related Design Services !$
Performed for PGSE 1 By j f CYGNA ENERGY SERVICES (EES) j-
- Prior to June, 1978 -
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2 Introduction ;
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Scope:
! 1982, R. F. Reedy, Inc. completed the y]
j On January .14, and Audit of Cygna. Energy p f
Quality Assurance Review ,
Services (EES). l The purpose of this review and audit was to address the j adequacy of EES' quality assurance procedures, controls the development, accuracy and concerning and practicesof seismic safety-related information by EES transmittal The basis of this to PGEE and other consultants to PG&E. determine if the EES Quality ,
review and audit was to as implemented prior to June 1978 met Assurance Program for the related requirements of 10CFR50, Appendix B, design services performed the for scismic safety-related PG&E's Diablo Canyon Unit 1 Plant..
Type of Design Services:
During the time in question, EES performed re-analysis of design review of piping selected piping systems, supports, analyzed Class 1 piping and re-evaluated all Class 1 supports.
Contracts: .
1977, was the only 5-16-77, dated March 9, Contract The scope was to contract during this time period. of selected ninine .systemn ,
perform sei smic re-ann 1vnis and design review of pipe supports for PG&E's Units 1 and Diablo Canyon Site, in accordance withEES'_ contractor's proposal 2, February 18, 1977.
(EES)- proposal dated will use response spectra for an states that analysis postulated on the Hosgri fault.
earthquake occurrence August 15, 1977, added Change Order Number 1, dated analysis of Class 1 piping and re-evaluation of supports -
for all Class 1.
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Evaluation Criteria: 40 '
Our Quality Assurance Review of EES used the applicable Standard of 10CFR50, Appendix B, and We requirementsN45.2.11 as the Quality Assurance Criteria to be met.EES - March 1982 1,
. 2/43
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evaluated the EES Quality Assurance Manuals used at the time of the contract and reviewed documentation and
- records to evaluate implementation compliance with the Quality Assurance Program. .
4 Conclusions t
S On the basis of our review of EES' Quality Assurance i
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Manuals and documentation applicable during this time
[ period, we believe that:
3 Assurance Prcgram, EES' Quality
- 1. The Quality
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Assurance Manuals Rev. 2 (January 30, 1976) through Rev.
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4 (December 28, 1977) in comparison to 10CFR50, Appendix B, minimally addressed the applicable criteria.
- 2. Program implementation was inadequate as evidenced by the two findings and seven observations summarized as
,follows:
Findings
- 1. There was a lack of interfnco enn+"al regarding input from PG&E. EES could not verify that one support (out of a sample of 5) sent from PG&E had ever been analyzed or deleted as a requirement. There was no
- interface control procedure.
It is recommended that this problem be investigated to determine whether or not this was a generic problem.
- 2. " Controlled" memos were not adeauately controlled as to content and distribution. Memos did not indicate whether they superseded previous memos and were not specific in referencing other material.
It is recommended that the applicable controlled reviewed determine whether conflicting memos be to instructions were issued and evaluate potential impact on the work performed.
findings are included in the Audit Finding Both Reports included in Appendix B to this report. .
Observations - no corrective action required:
- 1. A PG&E letter dated August 16, 1976 was referenced 9 the project criteria by an EES memo 9-as being part of dated 11/21/77. The referenced PG&E letter could not be located in the project files.
EES - March 1, 1982 3/43 I
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/ 3. Formal r,ecords of the computer program verification
/ of SAP IV were not available and the verification could
/ be confirmed only with the aid of the personnel involved. ___
, / Because of the significance of the computer runs to proj ec t design it is recommended that a retrievable record of the verification be developed.
5 3. No Quality Assurance procedures other than the N and Quality Assurance Manual itself were developed I implemented; for example, conducting audits.
g h 4. Quarterly management review meetings were not held i
k- quarterly.
d 5. All revisions of Quality Assurance Manual were not ,,
). formally transmitted to the, Project Engineer Manager.
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- 6. Audits were not timely or comprehensive. Only calculations and computer binders were audited. There -
l was no evidence of effective corrective action.
- 7. Other than the basic QA indoctrination and training '~~
session there was no evidence of auditor training and qualification.
Method of Review The method of our review for EES consisted of the following steps enumerated as 1 through 4 below:
- 1. An introductory meeting was held with EES personnel on December 28, 1981. The purpose of this meeting was to obtain some understanding of the EES organization and the type of design services they
, performed. We also indicated the type of Quality i
Assurance review we would be making. Our questions during this meeting were based on a preliminary
~
review of the EES Quality Assurance Manual.
Attachment A lists the EES, PGLE and R. F. Reedy, Inc. personnel in attendance at all meetings with-
, EE3. -
- 2. We reviewed the EES Quality Assurance Manual, Rev.
2, (January 30, 1976), prcvided as applicable to activities for contrLet 5-16-77. This review ,
consisted of a comparison of the Program against the 10CFR50, Appendix B, criteria requirements for (I)
Organization; (II) Program; (III) Design Control; (V) Instructions, Procedures and Drawings; (VI)
Document Control; (XVI) Corrective Action; (XVII)
Quality Assurance Records; and (XVIII) Audits.
EES - !Jarch 1, 1982 4/43 ew-re~mmmmm.6afghgagm g
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J 1-4 These criteria of Appendix D were selected as being
,. applicable to a design organization such as EES. ,;
l 4 The program Review Checklist is included as Appendix !
C of this report. Where the Program Review
- J d . Checklist indicates a programmatic omission or question the issue was included for consideration li -- .during the audit. ,
j[
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- 3. An audit chncklist responsive to the referenced
' lh Appendix B criteria and ANSI Standard N45.2.ll, ,
10 The completed Audi.t Section 6.3.1, was prepared.
. '4' Checklist is included as Appendix D of this report.
i k Quality Assurance audit of EES was performed on The I
I 4. It immediately became 3 January 13 and 14, 1982.
evident that Quality Assurance Manual Rev. 3 l -I i (September 13, 1977) and Rev. 4 (December 28, 1977)
[ -
had been applicable during the time period prior to i
i June 1978. These were reviewed and our audit Rev. 5 (April j' j checklist was revised accordingly.
not included as its effectivity was
? 18, 1978) was too close to the June date to have any significant f effect on the audit.
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EE3 - March 1, 1982 5/43
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R. F. REEDY, INCORPORATED 236 N. Santa Cruz Avenue Los Gatos, California 95030 * (408) 354-9110 t! arch 3, 1982 Robert L. Cloud and Associates, Inc.
125 University Avenue Berkeley, CA 94710
Subject:
Revision 1 to Review of Cygna Energy Services (EES)
Dear !!r. Cloud:
. Attached are revised pages 3 and 7 to replace those issued in our March 1, 1982 report.
The change on page 3 is to clarify the meaning of the word " minimally".
.The change on page 7 is to editorially correct B.
Good's company affiliation.
Very y yours oger . l.e *
.E.
R. F REEDY, INC.
RFR:na-Encl cc: Mr. Harold Denton ImM@M[MMT l
' l MAR - 51982 ,L i
, Roger F. Mcedy, P.C. - Engineering t'on-ntiene
yw . .
. evaluated the EES Quality Assurance Manuals used at the time of the contract and reviewed documentation and
, records to evaluate implementation compliance with the Quality Assurance Program.
Conclusions -
On the tasis of our. review of EES' Quality' Assurance Manuals and documentation applicable during this time
, period, we believe that: -
- 1. The Quality Assurance Program, EES' Quality Assurance Manuals Rev. 2 (January 30, 197G) through Rev. 4 (December 28, 1977) in comparison to 10CFR50, Appendix B, did address applicable basic criteria, but was inadequate in **
specific detail.
- 2. Program implementation was inadequate as evidenced by the two findings and seven observations summarized as follows:
Findings
- 1. There was a lack of interface, control regarding input from PGLE. EES could n,ot verify that one support (out of a sample of 5) sent frbm PGSE had ever been analyzed or deleted as a requirement. There was no interface control procedure.
It is recommended that this, problem be investigated to determine whether or not this was a generic problem.
2.
" Controlled" memos were not adequately controlled as to content and distribution. Memos did not indicate whether they superseded previous memos and were not .
specific in referencing other material.
It is recommended that the applicable controlled ..
memos be reviewed to determine whether conflicting instructions were issued and evaluate potential impact on the work performed.
..Both findings are included in the Audit Finding Reports included in Appendix B to this report. .
Observations - no corrective action required:
- l. A PGLE letter dated August 1G, 197G was referenced as being part of the project criteria by an EES memo dated 11/21/77. The referenced PGLE letter could not be located in the project files.
EES - March 3, 1982
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EFS ATTENDANCE LIST Ques, tion Meeting Audit Name Company 12/28/81 1/13&l4/82
, .F. Zerebinski PG&E x x S. Tandowsky CYGNA x x H. Suryoutomo CYGNA x x N. Chauhan CYGNA X
- P. Didonato ,
CYGNA X X R. Rauson CYGNA x W. Gang CYGNA R. Petrokas RFR,Inc. x W. dibbons RFR,Inc. x x R. Falciani CYGNA P. Herbert RFR,Inc. x R. Reedy RFR,Inc. " ' x O* B. Good CYGNA x Part-time
_ . = . . - _
EES - March 3, 1982 7/43
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R. F. REEDY, INCORPORATED 236 N. Santa Cruz Avenue
. Los Gatos, California 95030 * (408) 354-9110 March 1, 1982 Robert L. Cloud and Associates, Inc.
125~ University Avenue -
Berkeley, CA 94710
Subject:
Report of R. F. Reedy, Inc.
Review of Wyle' Laboratories
Dear Mr. Cloud:
Attached is a copy of our Quality Assurance Review report of Wyle Laboratories (WYLE). We have reviewed the WYLE Quality Assurance Program as it related to 1
seismic safety-related design services performed for Pacific Gas and Electric Company prior to June, 1978.
All details of our review are contained in this final report. ,
I- am transmitting a copy of th'is report to Mr. Harold Denton of the NRC.
Very uly yours, a
Roger . e y, . .
R. F REEDY, INC.
RFR:na ec: Mr. Harold Denton Encl.
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QUALITY ASSURANCE REVIEW REPORT PHASE I SEISMIC SAFETY-RELATED DESIGN SERVICES PERFORMED FOR PG&E -
BY WYLE' LABORATORIES '
PRIOR TO JUNE 1978 i
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s Quality Assurance Program Review Report Phase I Seismic Safety-Related Design Services Performed for PG&E By -
WYLE Laboratories Prior to June, 1978 9
.. Introduction Scope:
i On January 14, 1982, R. F. Reedy, Inc. completed the Quality '
Assurance Review and Audit of WYLE Laboratories (WYLE).
3 The purpose of this review and audit was to address the j adequacy of WYLE's quality assurance procedures, controls and i practices concerning the development, accuracy and transmit-l tal of seismic safety-related information by WYLE to PG&E and other consultants to PGEE. The basis of this review and i audit was to determine if the WYLE Quality Assurance Program as implemented prior to June 1978 met the applicable requirements of 10CFR50, Appendix B for the seismic safety-related design services performed for PG&E's Diablo Canyon Unit 1 Plant.
- Type of Design Services
- .
1 During the period of January 1974 until June 1978, WYLE j performed a variety of seismic safety-related design activities which consisted of:
f (1) Seismic testing of 10 instruments January 1974 through April 1975.
(2) A seismic evaluation of basic scope for Diablo Units 1 and 2 to define seismic design problem areas and --
to recommend seismic testing activities WYLE could
- perform to aid PG&E in verifying their dynamic analysis of various items of equipment.
~~
! (3) Actual seismic testing of items of equipment defined under (2) above.
Contracts:
On January 11, 1982, the Audit Team was advised by WYLE that PGEE contracts 5-61-77, 5-66-77 and P.O. #4R2494 were applicable for seismic safety-related services they provided to PG&E prior to June 1978. However, a review of correspondence disclosed that WYLE was requested (R. V.
Bettinger letter to Mr. Drexel Smith dated September 28, 1977) to provide PG&E with their quality assurance procedures NYLE - March 1, 1982 2/61
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L' to be used for assuring WYLE's performance od' safety-related
. systems, structures, or components under pGLE contracts 5 77, 5-66-77 and 5-67-77.
The Audit Team requested a copy of contract 5-67-77 for a review to determine if 1,t's scope was for WYLE -activities related to seismic safety-related design efforts by PGEE. WYLE advised the Audit Team that they had'no
, , , record of such a contract number.
The Audit Team then requested that Mr. W. T. Spitzer (the PG&E observer 'during our audit) verify with PGEE whether or not 5-67-77 was a valid contract for WYLE seismic safety-related design services. Mr. Spitzer, after phone discussions advised the Audit Team that contract No.that5-67-77 PG&E records-in San Francisco indicated had not been exercised. This is considered to be an open . item 'to be verified during the independent audit of PG&E for pre June 1978 seismic safety-related design activities.
On the _ basis of the above then, the Audit Team doncentrated -
its review on contracts 5-61-77, 5-66-77 and P.O. . #4R2494.
Contract 5-61-77 ,
i Contract 5-61-77 was executed between August 1977 and February 1979 and was subdivided by WYLE into s internal WYLE task numbers, ND26286, ND58255, ND58378, ND26291, ND26207, ND26301, ND26308 and ND58215. --
ND2628G ,
This WYLE task consisted of.a feasibility seismic evaluation
. study of basic scope for Diablo Unitc #1 and #2 to-define for 1 PG&E problem areas in their seismic safety-related design work-and made recommendations for seismic testing for verification of dynamic analysis. -
ND58255 and ND58378 4
The actual seismic testing performed by WYLE was controlled under these two task numbers. g ND26291, ND26297, ND26301, ND26308 and ND58215 These WYLE tasks were ~ de~ scribed as not ' covering ceismic testing / design and were not considered further by the Audit- -
Team.
Contract 5-66-77 Contract 5-66-77 was executed between Sbptember 1977 and-October 1977 and was given a-WYLE task #ND58228. This task WYLE - March 1, 1982 .
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did cover ~ seismic testing activities for safety-related items.
P.O.#4294 PG&E P. O. #4R294 was executed between January 1974 and April 1974 (WYLE Task #ND53744) and it consisted of seismic testing of 10 instruments.
P. O. #4R294 PGEE P.O.#4R294 was executed between January 1974 and Apri,1 -
1974 (WYLE Task #ND53744) and it consisted of seismic testing of 10 instruments.
During this review, it was determined that. UYLE did not perform any dynamic design analysis activities for PG&E prior to June 1, 1978.
. Evaluation Criteria The charter of the Audit Team for this review and audit of WYLE, as stated above in the scope, was to determine if the seismic safety-related design activities performed by WYLE were controlled in a manner that they complied with applicable criteria of 10CFR50 Appendix B.
Prior to this audit, the WYLE Quality Control Manual SPP-518Q dated , April 30, 1975 and Quality Control Procedures Manual SPP-518 were provided to R. F. Reedy, Inc. as the WYLE Quality Assurance Program Manual and Quality Assurance Procedures under which WYLE controlled their -pre June safety-related design / testing activities. 1978 seismic were reviewed prior to performing the audit intwo These manuals the R. F.
Reedy, Inc. offices during which several questions developed related to the adequacy of the WYLE program to meet were ,
the applicable criteria of 10CFR50, . Appendix B.
questions were given to WYLE on January 4, These~~
1982 request 'that WYLE be prepared to discuss the questions and with a verbal provide to the Audit Team on January ll, 1982~ answers which would be used by the Audit Team in the performance of the implementation audit. Attached as Appendix A to this report is the Program Review Checklist prepared for discussions with '
WYLE. '
During the discussions between the Audit Team and WYLE held on January ll, 1982 the Audit Team was not provided with adequate answers to its questions which would permit an acceptance of WYLE's Quality Assurance Program being adequate (SPP-518Q and SPP-518) as as written to meet the relevant criteria of 10CFR50, Appendix B.. Attached as Appendix B to this report is t
.the attendance list for the review and audit of WYLE. .
s WYLE - March 1, 1982 e 4/61 I
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Further discussions and reviews of correspondence and contractual files were then performed by the Audit Team in an effort to determine if PG&E had imposed other than SPP-518Q and SPP-518 quality assurance requirements on WYLE for pre-June 1978 seismic safety-related design activities. The following are the observations of these discussions and 4
reviews made by the Audit Team.
i The details of this portion of the Audit Team's review are ~
l' reported in Appendix C to this report. In summary, the first contractual requirement ifor quality assurance requirements i were imposed on WYLE in contract change order No. 5 to contract 5-61-77. This change required that WYLE perform their tests in accordance with PG&E's " SPECIFICATION FOR CONTRACTOR'S QUALITY ASSURANCE PROGRAM".
I
! -Note: The specification PG&E actually attached to this change order is titled " SPECIFICATION FOR TESTING LAB'S QUALITY ASSURANCE PROGRAM". Change Order No. 5 required the
) above to be effective on December 1, 1978 and contained no
! provisions for re-evaluation of alreadycompletedseismic}
i testing for compliance.
i It was the decision of the Audit Team to prepare a revised -
4 Audit Checklist (Appendix D to this report) and to Audit I WYLE's imposed controls during their pre June 1978 seismic I testing activities to determine if WYLE's Engineering
- l. Practices controlled their seismic testing activities in a manner that they could be accepted as meeting the intent of the applicable 10CFR50, Appendix B criteria. Appendix D to this report als,o contain the. details of the Audit Teams Findings and Observations recorded.
j It should be pointed out that. the date of the earliest -'
q 4 s.
seismic testing WYLE performed commenced in January 1974 well after the effective date of the NRC 10CFR50, Appendix B.
] criteria whiers was published in 1970.
Conclusions:
On the basis of our review and audit it was concluded that: .
(1) WYLE's Quality Control Manual SPP-518Q, April 30, 1975 and Quality Control Procedures Manual SPP-518, G* geed vN April 30, 1975 were not implemented in a manner whereby WYLE was able to provide objective evidence of compliance with applicable criteria of 10CFR50, Appendix
- B, for pre June 1978 seismic testing activities, t
{ (2) Contractually, WYLE was required by PG&E in Change Order No. 5 to contract 5-61-77 to perform their Quality WYLE - March 1, 1982 5/61 m
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Assurance in accordance with Pd&E's " Specification for Contrcctor's Quality Assurance Program" as' stipulated in Attachment A to Change Order No. 5 and/or in accordance with the " Specification for Testing LAB's Quality Assurance Program" which is -the actual Attachment B to Change Order No. 5. Whichever specification is determined to be applicable for WYLE's -
QA program, the Audit Team was not able to verify
- during the audit that WYLE did comply- with either specification. The Audit Team was advised by WYLE that their Quality Assurance records applicable for the PG&E contracts had been destroyed without authorization during their QA Department's move from one building to
~
another. As such, a meaningful audit of objective
, documented evidence of WYLE's QA program implementation was not possible. -
(3) Since WYLE provided insufficient documented evidence of compliance with any Quality Assurance Program, the Audit *-Checklist prepared to audit for verification against WYLE's Quality Control Manual SPP-518Q and Quality Control Procedures Manual SPP-518 was ,
used to interview responsible WYLE personnel. This was to determine if WYLE's compliance to their Engineering Practices could be used to establish a QA Program equivalent to the applicable criteria of ;
Appendix B. The answers provided to the Audit Team and 10CFR50, ;
absence of documented evidence of implemented controls verify in the opinion of the Audit Team that the pre June 1978 seismic safety-related testing performed.by '
WYLE was not performed in a manner that met the '
criteria of their not SPP-518Q & SPP-518 Manuals and did.. ..
meet the anolicable criteria of 10CFR50. Appondir ;
.3.:-
(4) It is the opinion of this Audit' Team that the seismic safety-related testing activities performed by
- WYLE for Diablo Canyon cannot be accepted as'having .
been performed and controlled under a Quality Assurance ;
Program which met the applicable criteria of'10CFR50, '
Appendix B.
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Summary of Findings and Observations The primary findings of this Audit Team is that a contractual requirement that WYLE perform the seismic safety-related testing activities under the controls of a Quality Assurance Program was not in effect prior to December 1, 1978. Insufficient objective evidence was submitted to the Audit Team to indicate that WYLE's seismic testing activities performed prior to December 1, 1978 were in compliance with a Quality Assurance Program.
It should be verified by review of PG&E purchase records that Contract No. 5-67-77 was not initiated with WYLE.
v .
WYLE - March 1, 1982 7/61 e -* - ~ + -,4-m-,
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REPORTABLE EVEitT'FOR v3/v2)a3 CL Ah4IF IC AfiUll: PHYdT C AL bECHRITY SA8-ECalARDS /
FACILITY: . DREdPEll 1,2 & 3 REGION: T DATE OF EVElli: Oi/st}U3 NUTIFIED ilRE: SAHilPERS ~~
.... DATE Il0TI IFD: Oi/v2}03 ENTERE0 REPO R T: G0HLP TIME OF Liit: 1 701 kST TIrlE HOTIFIEn: 0958 kST 3ECURITY REPORT-
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CAUS E: ll/A -
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BREAKWATER UHE TO llEAVY AW VE ACTION, AND IllTO Tile IHTAKE -nAY AREA. YliE INDIVID lALS HERE Rg' PLACIHc DRUKEll AllCil0P C ABLES WHIEll E
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HD0/RDO ACiiall: HOTIFIED REG III (J. CREED) h)[Lhl-DESCRIPTIOrl. BOTH SECH RITY C0hPH TERS FAILgD FOR i SHORT DilRATI ill . APPRnPRTATE COMP L.
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, o R. F. REEDY, INCORPORATED $, jd.
236 N. Santa Cruz Avenue \ (1,F Los Gatos. California 95030 * (408) 354-9110 f.! arch 5, 1982
\p@@@0N 19R 10 $92 Robert L. Cloud and Associates, Inc.
125 University Avenue L
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~
_ Berkeley, CA 94710 L
~~
Subject:
Report of R. F. Reedy, Inc.
Review .of URS/J.A. Blume & Associates, Engineers
Dear Mr. Cloud:
Attached is a' copy of our Quality Assurance Review.
report o'f URS/J.A. Blume & Associates, Engineers
_. (URS/Blume). We have reviewed the URS/Blume Quality Assurance Program as 'it related to seismic safety-related design services performed for Pacific Gas and Electric Company prior to June, 1978. The details of our review are contained in this final report.
I am transmitting a copy of this report to Mr. Harold Denton of the NRC.
Very uly yo r ,
oger . Reedy, P. E. ,,
R. F. REEDY, INC.
RFR:na
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QUALITY. ASSURANCE REVIEW AND AUDIT REPORT PHASE I By: R. F. REEDY, INC.
On:URS/J.A. BLUME & ASSOCIATES, ENGINEERS .
~
/, ' SEISMIC SAFETY-RELATED DESIGN SERVICES
-PERFORMED FOR PG&E PRIOR TO JUNE 1, 1978 '
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- s Quality Assurance Program Review and Audit Report Phase I Seismic Safety-Related Design Services Performed for PG&E
... .By URS/J. A. Blume & Associates, Engineers.
Prior.to June, 1978
~
Introduction Scope: .
On January 26,1982, R. F. Reedy, Inc. completed the Quality Assurance Review and Audit.of URS/J.A. Blume &
-Associates, Engineers (URS/Blume).
The purpose of this review and audit was to address the adequacy of URS/Blume's quality assurance procedures, controls. and practices concerning the development, accuracy and transmi,ttal of seismic safety-related information by URS/Blume' to PGaE and other consultants to PG&E. The-basis of this review and audit wasuto determine if the URS/Blume Quality Assurance Program as implemented prior to June 1978 met the applicable requirements of 10CFR50, Appendix.B, for the seismic safety-related design services performed for PG&E's Diablo Canyon Unit 1 Plant.
Type of Design Services:
During the time period in question, URS/Blume performed
-structural design and analysis, prepared seismic critoria, dynamic analyses of pioing, reanalyses, and various consulting services.- ,,
Contracts: ,
a.
Appendix B to this report is the listing provided to us of URS/Blume work performed for the PG&E Diablo Canyon Project. As is evident from this listing, most of the work performed was seismic safety-related. In addition, work was subcontracted from URS/Blume to others, including "
GEO-RECON, Inc. (geophysical explorations and laboratory testing), Woodward-Clyde-Shepard & Associates (laboratory
- tests), Jason Bloom (independent review of turbine -
building) and Wyle Laboratories.
Evaluation Criteria:
Our Quality Assurance Review of URS/Blume used the .
URS/Blume - March 5, 1982 2/42 0
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applicable requirements of 10CFR50, Appendix B, and Standard N45.2.ll as the Quality Assurance Criteria to be met., We evaluated the URS/Blume Quality Assurance Manuals used during the time the activities were performed and reviewed documentation and records to evaluate implementa-tion compliance with the-Quality Assurance program.
Conclusions 10n the basis of our review of URS/Blume's Manuals and documentation applicable during this time period.(pre .
June, 1978), we conclude that:
- 1. URS/Blume did not establish or i mpl oman t n nnality Assurance program _ that met the applicable re-quirements of 10CFR50, Appendix B.
- 2. There was no objective evidence that an equivalent
. program or system .of controls was in effect during this time period.
Findings -
- 1. URS/Blume did not establish or implement a Quality Assurance program that met the applicable require-ments of 10CFR50, Appendix B.
- 2. The Hosari Reoort was not developed or issued by URS/Blume as a controlled design document.
Observations The results of the URS/Blume review were categorized as comments rather than Observations because no QA program was used' for .this work. -Selected comments noted during ~~
the review are included in Appendix.E to this report.
Method of Review The method of our review for URS/Blume consisted of the following steps enumerated as 1 through 5 below:
- 1. An introductory meeting was held with URS/Blume personnel on December 28, 1981. The purpose of thi~s meeting was to obtain some understanding of the .
URS/Blume organization and the type of design services they performed. We also indicated the type of Quality Assurance review we would be making. Our ;
questions during this meeting were based on a URS/Blume - March 5, 1982 i 3/42 l l
l
. . s pr inary review of the URS/Blume Quality Assurance Manual. Atta'chment A lists the URS/Blume, PG&E and R. F. Ikedy, Inc. personnel in attendance at all meetings with URS/Blume. *
- 2. We reviewed the URS/Blume Quality Assurance Manual, Rev. 2 ,- (November 19, 1976), provided as applicable
. . . . to URS/Blume activities prior to June 1978. This -
review consisted of a, comparison of the Program against the 10CFR50, Appendix B, criteria re-quirements for (I) Organization; (II) Program; (III) -
Design Control; (IV) Procurement Document Control; (V) Instructions, Procedures and Drawings: (VI)
Document Control; (VII) Control of Purchased Material, Equipment, and Services; (XVI) Corrective Action; (XVII) Quality Assurance Records; and (XVIII)
Audits. These criteria of Appendix B were selected as being applicable to a design organization such as URS/Blume. The Program Review Checklist is included as Appendix C .of this report. Where the Program
- Review Checklist indicates a programmatic omission or question the issue 'was included for consideration during the audit.. (Subsequent to the Manual review we were informed 'that the Quality Assurance Manual was not invoked in PG&E orders prior to June, 1978.)
- 3. An audit checklist derived from the URS/Blume QA Manual and which was responsive to the-referenced Appendix B criteria and ANSI Standard N45.2.11, Section 6.3.1, was prepared. During the audit (4.,
below) it became evident that our audit checklist'was not applicable and it was not used; and, therefore it is not included in this report.
- 4. The Quality Assurance audit of URS/Blume was performed on January 18 and 19, 1982, with a follow- -
up visit' on January 26, 1982. During review of the listing of work performed by URS/Blume for PG&E (Appendix B to this report) it was stated that a partial URS/Blume quality assurance program had been applied only for contracts *: 6907-27(0902) In-vestigation' and Design of Turbine Building for New -
7.5 magnitude Hosgri, started July 1976; 6902-28 Diablo Piping Reanalysis, started March 1977; 6902-29 Diablo Unit 2 Hanger Review, started October 1977; and, 6902-30 Diablo G-Line Anchor Review.
URS/Blume stated that'the partial program was defined as that outlined in an August 30, 1977, letter DAL to JOS, (Included in Appendix D to this report.) Prior Shown with a single asterisk in Appendix B.to this report.
.URS/Blume - March 5, 1982 4/42 e g 4 ,1 0
4 to that time, August 1977, Blume informal program of " good engineeringstated practices" that an had been used. Blume further stated that the Quality Manual was not applied to PG&E work in its entirety until June 1, 1978. Blume informed us that the Quality Assurance program was
, ,, required by the client. not. invoked unless PG&E letter, further work FFM to JAB July 11, 1978, required all conducted in on the Hosgri seismic evaluation to be . ~
accordance with the URS/Blume Quality Assurance Manual dated December 16, 1977. Note that this is QAM Revision 4, which was approved by PG&E in the letter JP to RFR, March 1, 1978.
At.this point we
~
review, determined that for the Phase One had not an. adequate formal Quality Assurance program been established for PG&E work performed by 3 .
i URS/Blume. We then attempted to review existing objective evidence against -our l
determine audit checklist to whether or not there was documented evidence that " good, engineering practices" were used which could be evaluated as an informil equivalent -
controlled system. The objective evidence reviewed did not support such an' equivalency having been in i
effect prior to June, 1978. There was no evidence of design inputs or design documents being controlled or of design verification being performed. -
- 5. On January 26, 1982 we revisited URS/Blume to determine June, 1978 whether or not the work performed prior to :
provisions was reverified of an acceptable after that date under the ,
program. Quality Assurance If URS/Blume had reverified the Hosgri evaluation under the provisions of an acceptable QA ~
program this would provide a chance to minimize the ,
impact of the design 1978. work performed prior to June did not do During this visit it was determined that Blume 'l a complete reevaluation of the Hosgri design work under this later -;
program. version of the QA ,
I i
t URS/Blume - March 5,'1982 5/42 i
t
,e s.
, w .g,9 shre g *w m *8Fa* -***epare
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N APPENDIX A ,
URS/BLUME ATTENDANCE LIST -
y URS/Blume - March 5, 1982 6/42 G 4 8*
-n - . . *- - .s e - - --e =
. .s
- e. . .
'. . . ~
m N
m URS/BLUME ATTENDANCE LIST Q g y y a s s s a e c) e a r-4 N
.l bC s s %
C H H H u er a e e c e c e .a w .4 E o y y e e o e o e e 4 o n n m
.e4 e a e a en + + +
e o c c Name Company $ $ $ $
R. F. Reedy R. F. REEDY, INC. X X X X a
P. J. Herbert R. F. REEDY, INC. X X X
-W. S. Gibbons R. F. REEDY, INC. X X X X
,R..F. Petrokas R. F. REEDY, INC. X i
D. A. Lang , URS/I}LUME X X X X
~
N. Aden-Gleason URS/BLUME X - X X X j R.'Gallagher URS/BLUME X X J. P. Nicoletti URS/BLUME X L.1Malik URS/BLUME X X i
R. E. Skjei URS/BLUME X X X
.i l D. Jhaveri URS/BLUME X
~~
- V. J. Ghio PG&E X
- F. Zerebinski PG&E X X X X e T
7 4
URS/Blume - March 5. 1982- '
4 7/42 n
. o e
APPENDIX B '
URS/BLUME WORK FOR PG&E ON DIABLO CANYON r
URS/Blume - March 5,'1982 8/42 i -
. Paga 1 of 4 7...
URS/Blume Work for PG&E on Diablo Canyon .
The following is a compilation of all known job numbers and associated work scopes of Blume work on Diablo Canyon. The start date is based on the date the job num-ber application form was submitted; the end date is based on the final billing date.
I. Vork Begun Before June 1 1978:
Start End Date Date Job Ho. Scope Comments 10/66 12/66 6633. Consulting services to establish EQ exposure and design criteria.
8/67 8/68 -01 Site response investigation studies.
5/68 -02 Prepare seismic design criteria for use in Safety Analysis Report.
12/66 4/69 6868 Unit 1 Turbine Building, Final Design construction drawings, exterior structural framing.
S/66 -01 Checking of shop drawings for Not relevant except structural steel. "as-built" drawings.
3/70 4/70 -02 Pipe Anchor, structural analy-sls and design.
5/70 7/70 7015 olabio Canyon Unit 2, prepare construction contract drawings, exterior turbine building ,,
structure.
-01 Shop drawings. Not relevant, except "as-built" drawings.
-02 Pipe anchor structural analysis. '
9/70 1/71 7038 Provide design and consultation assistance to PGEE staff.
8/71 7124 Special reviews concerning the '
new intervenor, questions on Unit 2.
11/71 12/71 7143 Seismic consultation for vibka-tion testing of safeguard
- electrical relay panels in Turbine Building. UIS/Blume - March 5, 1982 9/42 t . _
- ~ _ _ - - - - , . + - - . - - - -,- - --- -.
Paga 2 of 4 s .
Start End End Date Ja' No. Scoce Comments 1/69 6902 Diablo Canyon Units.1 & 2, (0902) seismic analysis and consultation.
6/69 -01 Unit 1, develop criteria for
-. . screening pipes for analysis.
6/69 -02 Perform dynamic analysii of main steam pipes. . _
6/69 -03 Perform dynamic analysis of feed-water pipes.
'6/69 S/69 -04 Analysis and report, Turbine Not relevant Building Unit 1.
11/69 -05 Finite element analysis of containment structure.
1/70 -06 Dynamic analysis of contain-ment spray pipe.
3/70 -07' Piping ' analysis report.
1/71 12/75 -08 Piping analysis, containment spray feeders 1 & 2.
1/71 2/73 -09 Piping analysis, accumulator coolant loops 1 & 2.
2/71 4/75 -10 Piping analysis, component cooling water system.
5/71 7/74 -11 Piping analysis, pressurizer surge line, dynamic analysis. ..
6/71 3/75 -12 Residual heat removal system, loop 3 & 4, dynamic analysis
- t
- ~. a t: of piping.
6/71 3/75 -13 Seismic analysis of safety .
Injection loops 3 & 4.
2/72 12/72 -14 Boric acid concentration supply, dynamic analysis of piping.
2/72 5/75 -15 Auxiliary feed water supply system, dynamic and dead load analysis of piping systems.
5/72 12/74 -16 Analysis of boron injection tank, t URS/Blume - March 5, 1982 10/42 11/72 7/74 -17 Assist PGSE in preparation of FSAR.
%ew u- -,%# m m,e eg g ge,. s e-- e ve 4 ..a>=e <,e --e e 4 e, m ,, .
S tart End Page 3 of a
+ Otto Data Job No.
2/73 Scopa 8/73 -18
- l Dead load analysis system. Comments 7/73 of piping .
-19*Hosgri Review seismicor cr'Iteria fault and updated NRC f
requirements.
- Containment Structure
- Auxiliary Building
- Outdoor Storage Tanks
- intake Structure
- Cranes (4):- Turbine Building & Pedestal
~
Polar Fuel Handling intake Turbine 9/73 10/73 6902-20 (0902) Analysis of exhaust vent or f
and missiles. capability to sresist wind load
- 4/74 11/74 -21 investigate effects of pip e structural Turbine Building.
stabillty of therupture Not -relevan t- in EQ re 11/74 3/75 -22 Review impact of new seismi ' c Structure. require.t.ents on Containment Not relevant 5/75 4/76
-23 Ing for 0.4g 00E, Parkfl 9 0.5 Reanalysis of Turbin Eq's. eid, and 0.5 Not relevant 6/75 9 Castaic 9/75 -24 Initial studies on coupled ..
/3 11/75 3/76 -
interiorforstructure analysis Hosgri motions and S '
NSSNot relevant
-25 .
4/76 6/79 sis on Class 1 pip'Ing. consultation review '
-26* Seismic analysis of Intake -
7/76 10/79 Structure for 0.75g Hosgri EQ .
-27* Investigation and'redesi gn of magnitude Hosgri work) (0&C
. EQ. Turbine Building for n 3/77 8/78 '
- P
'f
~~
-28* Diablo Piping Reanalysls. .
.. .o s URS/Blume - March 5, 1982 11/42
. .,p. u ~
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tO ..
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'"'D p_whY .
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_ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . __ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ . _ _ _ _ . _ _ _ _ . _ . - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ . _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . - _ _ _ _ _ _ _ -.____._.______._._as
. . . -. . -- .. - _- . _ -. . . . .- ...~ -. .. - . -
- s.
, Page 4 of 4.
Start End !
Date Date Job No. Scoce
~
Comments i -
J 10/77 12/81 -29* Diablo Unit 2 Hanger Review.
4/78- 5/79 -30* Diablo'G-Line Anchor Review, '
i
,,-S..
II. Work Beaun After June 1, 1978:
7/78 5/81 6902-31** Fire Protection System.
(0902)
J 7/78 10/78. -32** Dsc work on cranes (redesign i
of cranes in Turbine Bldg.,
Auxiliary Bldg. and Contain-ment Structure).
L 7/78 10/78. .-33** ocC work on pedestal mods j
(redesign Turbine Bldg.
i pedestal).
1 ,
j 8/78 11/78- -34** D&C design reviews on Con-s tainment Structure, Turbine 81dg .& Pedestal, and Cranes:
- Polar, Fuel Handling, intake
& Turbine, Outdoor Water -
i l Storage Tank.
i 4/80 7/80 -35** Diablo Fire system Base j-Plates Analysis. '
4/80 5/80 4
-36** Diablo Civil-Mechanical .
Loads Coordination.
l 1 !~
I
. i i
i
! l
,
- Partial QA Project *
- Full-QA Project l l . '
I URS/Blume - March 5, 1982 l 12/42 P
i.
i I '
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i
'.Q APPENDIX C PROGRAM REVIEW CHECKLIST URS/BLUME
\
~
\
URS/Blume - March 5, 1982 ,
13/42
~.~ ;
=
, , , R. F. REEDY, INC.
PROGRAM REVIEW CHECKLIST
'/
ORGANIZATION: URS/ John A'. B'liime & Associates, Engineers ADDRESS: 130'Jessie S'reet t
San Francisco,'CA' 94105 .
QA PROGRAM
REFERENCE:
QA Manual, Rev. 2 November'19, 1976 REVIEW CONDUCTED BY I M xx , DATE: />!2./!O/
REVIEWED BY: hM DATE: / E 82 -
DATE: / 82 ~*
v a4/1 DATE:3 7d.
vy- .
l l Y
' NO. OF PAGES: 20 1
i
- i l
URS/Blume - March'5, 1982 14/42 i
h --
y'- e N v ryrMmvwFTeTw--WM+-M4-W"**-*'r4emMMM' N
~
PROGRN{ REVIEW CHECKLIST
!ROJECT: Diablo Canyon Sub]ect: I ntganizatiin (Ann. R) Page 1 of p PROGRAM AND ITEM
- YES REQUIREMENT PROCEDURE NO N/A REVIEW C0KMENTS NO. REFERENCES
- 1. The applicant shaLL be responsible QA Manual Section 2.1 is marked Rev.0, x
. for the establishment and execution Revision 0 5/1/75; other Sections marked of the quality assurance program. 5/1/75 or The applicant may delegate to 8/15/75 Rev.0 are dated 8/15/75. -
? others, such as contractors, agents, or consultants, the work of estab-Lishing and executing the quality assurance program, or any part
< thereof, but shaLL retain responsi- , ,
bility therefor
- 1 4
i .
I
- 2. 'The authority and duties of per- 3.1 x Responsibilities are described.
sons and organizations performing activities af fecting the safety-1 related functions of structuras, systems, and components shall be i
clearly established and delineated ?
in writing. These activities l~
include both the performing func- ,
tions of attaining quality objec- .
tives and the quality assurance
! f unc tions. The quality assurance
- functions are those of (a) assuring that an appropriate quality assur-l ance program is established and "
- ef fectively executed and (b) veri-:
l fying, such as by checking, audit- URS/Blume - March 5, 1982 i, ing, and inspection, that activi- .
15/42 l ties af fecting the safety-related j, functions have been correctly I
r , , , , ,-
l: ,,..:, ,
i a i.,
l- .
! , , URS/DLUME Page 2 of 20
" " .I , ,
i~ PROCRM REVIEW CHECKLIST , ,
j . . , . . ,
?ROJECT: Diablo Canyon
- S6bjecti I Oroanizaticn (Ann B) Page 2 of 2 l **
- PROGRAN AND 4 ITEM '"
PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT NO. '*
REFERENCES
..,, ...6 .
3, The persons'and organizatibny ' pier- 3.1 x forming quality assurance fun'et'ib'ns, OA Manager reports directly .
to Executive V.P. However, shaLL have sufficient authori't'f and QA Engineers are selected from organizational freedom to identify ' staff, and report to QA Manager quality problems; to initiate, -
for QA functions, but for hiring recommend, or provide solutions; and.
to verify implementation of solu- .
and salary purposes they apparentl3 report to a manager who is tions. Such persons and organiza-
, responsible for the work being l tions performing quality assurance ,
verified.
i functions shaLL report to a manage-l ment levet such that this required.
I authority and organizational free-dos, including suf ficient indepen-dence from cost and schedule uhen ,
opposed to safety considerations, ,
are provided.
i 1
l -
- 4. ...the individual (s) assigned the 3.1 x OA Manager reports.to Executive l responsibility for assuring ef fec-v P.
tive execution of any portion of tl.e quality assurance program at any l Location uhere activities stbject to this Appendix are being per-formed shaLL have direct access to such Levels of management.as may be necessary to perform this function.
- URS/Blume'- March 5, 1982 16/42
URS/BLUME Page 3 of 20 -
, PROGRAM REVIEV CllECKLIST
'ROJECT: .Diablo Canyon " Subject II Program ( App. B) Page 1 of 3 PROGRAM AND
'. TEM '
- REQUIREMENT
- PROCEDtJRE YES NO N/A REVIEW COMMENTS NO. .
REFERENCES
, te-
- 1. ,
The applicant shalt establish at ,
OA Manuali x No supporting proceduras are l the earliest practicable time, con- Revision 0 referenced, but the QA Manual I sistent with the schedule for accom- 8/15/75 says that organizational and plishing the activities, a quality procedures manuals do exist and assurance program which complies with amplify QA Manual requirements.
the requirements of this Appendix.
This program shaLL be documented by written policies, procedures, or -
instructions, and shall be carried out throughout plant Life in accor- / '-
dance with those policies, proce- , I dures, or instructions.
! 2. The applicant shalt identify the 2.1 x
! structures, systems, and components Applicable to any project that to be covered by the quality assur- requires quality assurance.
ance program and the major organiza- No specifics provided.
tions participating in the progra:n, together with the designated func-tions of these organizations.
. URS/Blume - March 5, 1982 17/42
f , .
- I ,
k ,.'... URS/BLUME Pago 4 of 20 g .
j ..v.
l l- ! PROGRAM REVIEW CIIECKLIST,
- l , ; .. .
l' i >ROJECT: Diablo Canyon
Subject:
II Program ( App. 8) Page y of 3 PROGRAM AND '
- TEN REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS
, NO. -
l REFERENCES i
- 3. The quality assurance program d that considered.
shall provide control over activi-ties af fecting the quality of thel j identified structures, systems, and ' -
l ,
l components, to an extent consistent .
with their importance to safety.
0
- 4. Activities af fecting quality x
- shalL be accomplished under suitably controlled conditions. Conditions include the use of appropriate equip-ment; suitable environmental condi- -
tlons for accomplishing the activ- '
~
ity, such as adequate cleanness; and -
assurance that aLL prerequisites for the given activity have been satis-fled.
i i
- 5. The progras shall take into X
! account the need for special con-i trols, processes, test equipment, ,
7
! tools, and skills to attain the re- ,
l quired quality, and the need for
- URS/Dlume - March 5, 1982 l - verification of quality by inspec- *
~ , 18/42 l tion and test.
_- -e
URS/BLUME Page 5 of 20 .-
PROGRAM REVIEW C1!ECKLIST l~ 'ROJECT: Disblo Canyon Subjee:: II Program (App. R) Page 3 of 3 PROGRMi AND REQUIREME!.T .. PROCEDURE YES NO N/A REVIEW C0h1ENTS
- 30. REFERENCES
- 6. The program shaLL provide [or? ' ;3. 3 x Performed by OA Manager and indoctrination and training 'of
- per- l Project Manager. Specific content sonnel performing activities af fec- t of training and indoctrination ting quality as necessary to assure -
programs is probably not document-that suitable proficiency is ed. ~
achieved and maintained.
l
- 7. The applicant shall regularly 3.2 x Annual report by OA Manager to review the status and adequacy of Executive V.P. No other review the quality assurance program. Man- by uoper management than reading agement of other organizations par- OA Manager's report. .OA organ-ticipating in the quality assurance ization is apparently not p'rogras shall regularly review the reviewed, status and adequacy of that part of the quality assurance program which they.are executing.
- +
URS/Blume - March 5, 1982 19/42
1 URS/BLUME Prga 6 of 20 .'
PROGRAM REVIE1J CHECKLIST .
Page 1 of f, 8R03ECT: Diablo Canyon Subjecc: III Desion Cnntrnt ( Ano. g)
PROGRAN AND YES NO. ti/A REVIEll COMMENTS NN REQUIREMENT PROCEDURE i
NO. REFERENCES 6 -
- 1. :leasures shall be established to 4,1_3 x assure that applicable regulatory '
4,g_3 requirements and the design basis, .
as defined in Para. 50.2 and as specified in the License applica-tion, for those structures, sytems and components to which this Appendix applies are correctly translated into specifications, '
drawings, proccJures, and instruc-tions.
These measures shaLL include 4.1-3 x Quality Assurance input to desigt 2.
provisions to assure that appropri- 4.8-3 criteria is not addressed.
ate quality standards are specified and included in design documents 4.10-3 Revisions made after a design review are not required to be and that deviations from such stan-dards are controlled. reviewed.
s URS/Blume - March 5, 1982 20/42 D
.ii. .
4.
URS/BLUME Page 7 of 20: -
PROGRAM REVIEW CIIECKLIST .
?ROJECT: 'Diablo Canyon ,
Subject:
'T T Y nesign rnntril (Anr_ n3 Page 3 of t PROGRAM A!G ITEM J0 REQUIREMENT PROCEDURE YES fl0 ft/A ,
REVIEW C0mfENTS REFERENCES I
- 3. Measures shaLL also be estab- I 4.8-3 x Lished for the selection and ~
review for suitability of appli-cation of materials, parts, equip-ment, and processes that are ,
essential to the safety-related functions of the structures, systeos, and components.
6
- 4. Measures shall be established 4.6 x Interface control procedures for the identification and control are required to be developed of-design interfaces and for coor- and reviewed. They are not dination among participating described in the QA Manual..
Jesign organizations.
- 5. These measures shaLL include 4.6 x See item 4 above.
the establishment of procedures among participating design organi-zations for the review, approval, release, distribution, and revi-sion of documents involving design .
interfaces. URS/Blume - March 5, 1982 21/42
1L -
- - (, .
,y 4
,s l[. URS/BLUME Page 8 of 20 1 *
- i -
.l ~~,
PROGRAM REVIEW CllECKI,IST ,
PROJECT: Diablo Canyon
Subject:
III Desion Cont ol (Ao). g) Page i of t i!
- )' ITEM
,,,,, PROGRAM AND ,.. n RIQUIREMENT .,.,, PROCEDURE / YES , NO N/A REVIEW COMMENTS - ~ ', '
- NO. .
, REFERENCES ' I : -
'l l[
l- 6. The design control measures 4.10 s shaLL provide for verifying or x Methods of desigk heview are checking the adequacy of. design, not described. Qualificati6n such as by the performance of design requirements for design i'
personnel are not clear., review Design revieus, by the use of alternative review criteria are to be or simplified calculational methods, .1 established, and are not des-
! or by the performance of a suitable
- i. testing program. The verifying or ~
cribed in the QA Manual.
checking process shaLL be performed .
~
j by. individuals or groups other than
- those uho performed the original 2
design, but who may be from the s. .
same org'anization. .Where a test program is used to verify the ade- -
I quacy of a' specific design feature ,
in lieu of other verifying or ,
checking processes, it shaLL in-
! clude suitable qualifications test- - -
ing of a prototype u.r;t under the w
- most adverse design 1
- onditions.
, Desien control measures shaLL be ..
applied to items'such as the fol-
- Lowing: reactor physics, stress, ,d
( thermal, hydraulic, and accident *
~
1 i analyses; compatibility of mater- L ials; accessibility for inservice
! inspection,rn ihte'nar.ce, and '
! repair; and deline'ation of accept / - -
l ance criteria for inspections and. // ,
- ' ' ~ '
tests.
. . \
URS/Blume March 5, 1982 y
- t 22/,42 ,
y
--_% <_ _ _ _ _ _ _ _ _ _ . _ - _ - - - _- - - - - , - --- - - = r w *
.. r v. r .
.e.. .'
i ,
s..> .: +
. URS/BLUME- Page 9 of 20 "' '
n,,-
, PROGRAM REVIEW CHECKLfST PROJECr: Diablo Canyon '
' 'Subjectt_ III Design Control ( App. 8)'
- ITEM
, PROGRAM AND Page 4 of 4 3 !
NO. - REQUIREMENT I PROCEDURE YES NOI N/A!
! REFERENCES I REV'IEW ComfENTS 1
- 7. j Design changes, including field .
4,10 changes, shaLL be subject to design x See item 2 above.
control measures commensurate with -
those applied to the original ~
design and be approved by the or-ganization that performed the ori- -
ginal design unless the applicant Jesignates another responsible /
organization.
URS/Blume - March 5, 1982 23/42 s
- v. -m -
sw . w w. wrw m .c e- e- w---< - - -. .w-- n- . . . - - -
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REQU i f ,:
1 IREMENT U Sub PROGR .
t
- . ee t: IV AM REV RS/DLU ME Me
%g. - asure Pr IE1J Page 10 U. ocur em rassur s
y CHECKLIST of1 n
et
- 4) e r
equir e thatsp hall be s
PROGRAM AND Docum s,' N. equir em en ts ap lic ablee tab PROCEDURE ent Co to em n s r lished REFEREN ba to
' f CES ntrol (App.
assure e ts ,whichde ign ses egulato YES '
mably included ry
, : ents fo r adequa te are or qualinec e,s adn 49 'NO N/A B) puequipme cha n procure t, a mrefere ty arsary othe, e i
- -, \l:
- . r its c nsd e nd n et nc ed si-ut Pa
. .; :.V o tr by theser vic \ of in do c X
s e1
{ -(_
- ac to es REVIEWCO a,ntwhethermaterial, u-1 ,
r or applic y;7 t '
subc n MMENTS 4a t" 't ,
o tr co rb Not 3,
a tor.y addres
.}; sde fo r y .
2 1 ., . \ subc To the x -
docume h,[?-
1 1 or u nts e ten t ne i ty as bco trshall ces sary
\ ;;X . ' n r h with ssurance acto r equire pro cur th the pr s to pr c on tr emet is Ap perti ogr n
c am oiv de a to rs 49 pen dix. nen t pr co a qua l-
- a. v ~
' o isionsiste ns n t
,'3 $ of X x e
k
\' -
Not addres e
sd m' -
fo r.
subc n o tr t
i
, l actor
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- 1 I / '[.)j{ * - '
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I, . . U L ;'?q; ? ' ltYy ij NS/DIum0 _b .% . - . - a-
l URS/BLUME Page 11 of 20 l i s I- . PROGRAM REVIEW CHECK!.IST
?ROJECT: Diablo Canyon
Subject:
V Instructions, Procedures, and Drawings (App. B)
- Page 1 of 1 ID PROGRAM AND '
NO. REQUIREMENT PROCEDlTRE YES NO N/A REVIEW C0!EENTS REFERENCES I , f
- 1. Activities af fecting quality shall 4.1-3 x Criteria are developed and
', be prescribed by documented instruc- documented.
i tions, procedures, or drawings of -
; a type appropriate to the circum- ,
l stances and shaLL be accomplished
- in accordance with these instruc-
,j tions, procedures,'or drawings.
1
- h I
i 1
- 2. Instructions, procedures, or draw- 4.1-3 x '
See Item 1 above. irigs shall include appropriate or qualitative acceptance criteria for determining that important activi-ties have been satisfactorily aciomptished. , URS/Blume - March 5, 1982 25/42
'l
'.i.
l i . . , . { URS/DLUME Page 12 of 20 - . 4 . 4 ., P'ROGRAM REVIEW CHECKLIST - i 03ECT: Diablo Canyon
Subject:
VI Document Control (Asp. B) ! Page 1 of 1
, PROGRAH AND ,
REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS
- 0. REFERENCES ! . i
{ 4.
. Measures shaLL be established to x criteria, calculatioris, computer ~
control the issuance of documents, 5.1 pkograms, drawings, reports, and such as instructions, procedures, , specifications are reviewed and . and drawings, including changes approved. Distribution is not thereto, which prescribe aLL activi- adequately described. ties, af fecting quality. l
. These measures shaLL assure that 4. x See Item 1. Document control documents, including changes, are 5.1 procedures do not cover control reviewed for adequacy and approvqd , of distribtGion of procedures, for release by authorized personnel, instruction:4- and drawings, and are distributed to and used at
- the Location where the prescribed
, activity .is performed. i i l . Changes to documents shall be 4.10-3 x Revisions made afte- a design review reviewed and approved by the same are not required tra ne reviewed. , organizations that performed the original review and approval unless the applicant designates ahother :
~
l responsible organization. URS/Blume - March 5, 1982 26/42 -
i . f ,- URS/BLUME.Page 13 of 20 . ( I PROGRAM REVIEW CHECKLIST l VII Control of Purchased Haterial, i )ROJECT: Diablo Canyon e
Subject:
Equipment, and Services ( App. B) Page 1 of 2 ITEM '" REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS i NO*
- REFERENCES ;
- 1. Measures shall be established to 4.3 x What procurement documents? '
assure that purchased material, Vendor-supplied computer programs equipment, and services, whether are verified and certified, purchased directly or through con- , tractors and subcontractors, con-form to the procurement documents.
- 2. These measures shall include pro- 4.9 x The QA Manager audits applicable visions,,as appropriate, for source portions of the subcontractor's evaluation and selection, objective program; no procedures or criteria.
evidence of quality furnished by are given. The Project Manager the contractor or subcontractor, ,/ maintains. surveillance; noi) ihspection at the contractor or procedures or criteria'are iiven. subcontractor source and examina- J tion of products upon delivery.
,.4 URS/Blume - March 5, 1982 27/42
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m i.. . . , i URS/DLUME Page 14 of 20 , t
- j PROGRAM REVIEW CHECKLIST .
!j. VII Control of Purchased Material,
;~ IOJECT: Diablo Canyon
Subject:
Equipment, and Services ( App. B) Page 2 of 2 ;
! PROGRAM AND TEM PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT 1 ,, .10. '
REFERENCES
!> \
Documentary evidence that material i 4.3 x Procurement requirements and l 3* 4+9 verification of compliance with
- and eqeipment conform to the pro-I curement requirements'shaLL be them are not required to be..
j available at the nuclear power- . documented .
- ' plant... prior to installation or -
use of such material and equipment. l; This documentary evidence shaLL be retained.at the nuclear power- / tl plant...and shaLL be s,uf ficient to identify the specific' requirements, such as codes, standards, or spect- !! fications, met by the purchased material and equipment. , L .
.}
The e f fectiveness of ~ the controt 49 x No QA review of subcontracted 4.
- of quality by contractors shaLL be services is require.d. (Project assessed.by the applicant or desig- Manager " maintains sufficient
- nee at intervals consistent with -
surveillance".) Effectiveness the importance, complexity, and of his program is not required ' j quantity of the product or services , to be verified. 1
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URS/Blume - March 5, 1982
- . , 28/42
! URS/BLUME,Paga 15 of 20- ,
1 PROGRAM REVIEW Ci!ECKLIST -
Subject:
XVI -Corrective Action ( App. B) Page 1 of 2 8R03ECT: Diablo Canyon
' PROGRAM AND (TEli PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT NO. '
REFERENCES i 6.1 x The only reference to correc'tive
- 1. Measures shall be established to . action is for internal audit I
assure that conditions adverse to , deficiencies. There is no mentia t quality, such as failures, malfunc- of using corrective action to I tions, deficiencies, deviations, prevent recurrence rather than te defective material and equipment, resolve discrepancies. and nonconformances are promptly . identified and corrected. l t - f f 5 i ll
- 2. In the case of significant condi- 6.1 x See item 1. Cause and precludinc tions adverse to quality, the sea- repetition are not. mentioned.
r sures shall assure that the cause. ' I i of the condition is determined, and h corrective action taken to preclude h rep,etition. i e 4
\
2 $ . URS/Blume - March 5, 1982 If 29/42'
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1 URS/BLUME Page'16 of 20
; i :
PROGRAM REVIEW CHECKLIST I t l ?ROJECT: Diablo Canyon Stibject: NVI Corrective Action (App. B)l ! Page 2 of 2
, PROGRAM AND ITEM NO.
REQUIREMENT ' PROCEDURE YES NO l'N/A REVIEW COMMENTS < 1, REFERENCES I i 3. The identification of the signifi- 6.1 x cant conditions adverse to quality, * -Audit report is
, ;- the cause of the condition, and the circulated to Division .
i 'l corrective action taken shaLL be Director and Executive V.P. li documented and reported to appropri- , ate , Levels of management. l i j . 1i l
- l i
1 i f - URS/Blume - March 5, 1982
; 30/42 (t
', .i l, URS/BLUME Page 17 of 20
~
[ -~ PROGRAM REVIEW CllECKLIST
~)POJECT: Diablo Canyon
Subject:
XVII Quality Alsirance Records (Aco. B) Page 1 of 2 PROGRAM AND ITEM REQUIREMENT PROCEDURE YES NO N/A. REVIEW COMMENTS NO. REFERENCES l ' i ; x'
- 1. Su'f ficient records shalL be main- 5.1 All quality-related tained to furnish evidence of activi- 5.2 ties af fecting quality. records are controlled. -
I
- 2. The records shall include at least 5.1 x the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. -
The records shaLL also include - closely-related data such as quati-fications of personnel, procedures, and equipment. 30 Inspection and test records shaLL, x as a minimum, identify the inspec-
~
tor or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. URS/Blume - March 5, 1982 31/42
+
URS/DLUME Page la of 20 .
' PROGRAM REVIEW CHECKLIST
?F0 JECT: Diablo Canyon Sub 3e c t : XVII Quality Assurance Records (App. B) Page 2 ~ of 2 i PROGRAM AND .
N '"" REQUIREMENT PROCEDURE YES NO N/A : REVIEW COMMENTS NO. i i.... REFERENCES I
; 4, ,
Records shall be identifiable and 5.2 x Retention schedule is included; retrievable. Consistent with appli- location requirements are not cable regulatory requirements, the specific. - applicant shall establish require-ments concerning record retention, such as duration, location, and assigned responsibility. 1 i . 1 4 URS/Blume - March 5, 1982 32/42
, , -- .y-, m ~ y -,m - , .r, . , - - - , ,- ,-,.,,,-,..-,,,,-*y., , , . , . ~ , + - - , , - , . , . , . . , , - , - - , , , - - , - . - ,m-.-.-7 ,, , , _,y.y- ,- . -- , , ,iy-m.,4-.w. un,-__3 y-_ ,,_ - ,
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- URS/BLUME Page 19 of 20; -
i- . PROGRAM REVIEW CllECKLIST
'ROJECT: Diablo Canyon
Subject:
XVIII Audits ( App. B) Page 1 of 2 PROGRAM AND ., ITEM REQUIREMENT PROCEDLTRE 'YES NO N/A REVIEW C0!O!ENTS NO. REFERENCES I i ! 1.- A comprehensive system of planned 6.1 x ' Audit schedule is blank. Each and periodic audits shaLL be carried project is audited at least - out to verify compliance with aLL once. The scope may include aspects of the quality assurance only a portion of the project, program and to determine the effec- It is not clear whether each tiveness of the program. ' department within the company is auditedl It appears that QA is never audited. i
- 2. The audits shaLL be performed in 6.1 X accordance with the written proce- Checklists are used;.
. dures or. check Lists by appropri-
- indeoendence is required.
ately trained personnet not having Training of auditors is not addressed. direct responsibility in the areas being audited. i , 3. Audit results shaLL be documented 6.1 x Project Manager gets report. and reviewed by managernent having ' l responsibility in the area audited. j , URS/Blume - March 5, 1982
- i 33/42 4
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l . . l URS/BLUME Page 20 of'20 i
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PROGRAM REVIEW CHECKLIST i... ,
} ?RO. JECT: Diablo Canyon
Subject:
XVIII Audits (App. B) Page 2 of 2 TEM PROGRAM AND REQUIREMENT PROCEDURE _ YES NO N/A
! N0* REVIEW COMMENTS REFERENCES l l l l - ;i 4. Follow-up action, including reaudit 6.1 x-I of deficient areas, shaL L be taken Project Manager performs correct-ive action, QA Engineer where indicated. ' verifies it.
I i 2
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URS/Blume - March 5, 1982 34/42
r
. e APPENDIX D.
~
_ Letter, D. A. Lang to J. O. Schuyler Quality Assurance for URS/Blume work for the Diablo Canyon Project 8/30/77 E URS/Blume - March 5, 1982 35/42
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URS JCHN A. SI UME & ASSOCIATES, ENGINEERS Mf.','.!!,* , ,.3 133 JEsslE sTAEET (AT NEs'. t/onTCof.*E AYi F * ** m' D C ,~ SAN FRANC:sCo. CAUFORN:A 94 tC5 a TEL:(415) 397 2525 N'.N no ven
,CASLE: BLU*.*ENo As 'QQ'fl' August 30, 1977 U$N[.7 [
10"'.1"^ Mr. J. O. Schuyler . r J. GECtr/ED 0.7 Manager, Nuclear Projects k iPJCLEAR PROHC S CES JSH P'icific' Gas 6 Electric'Co=pany DEPARTMENT- [ > 77 Beale.S:ree:,. Room 2645B gp j g77 San Francisco, CA 94106 l Fil.E '
SUBJECT:
Quality Assurance for URS/Blume Work ! for the Diablo Canyon Project 7
REFERENCE:
URS/Blume Quality Assurance Manual t
Dear Mr. Schuyler:
This letter su= marines the quality assurance procedures followed in the ccurse of our work on the Diablo Canyon project. the present 10CFRSO, Appendix B quality assurance Due torequirements
- ne fact that came i t ,
no
- s. to separate our work into three parts, existence well after our s
- Since our work on the DDE analysis of Diablo Canyon (pre-Hosgri) pred including checking of all calculations, cecouter , and reports.
nrocram Our work on the Hosgri evaluation of the Diablo Canyon structures e the same thorcugh engineering practices and in addition included ma ny of-the B. for:a1 quality assurance requirements specified in 10CFR50 , Appendix Our present and future work on the structural modifications to the
, Turbine Building will employ complete quality assurance require =ents accordance with the URS/Blume Quality Assur:nce Manual. -
areas of action during the course ofdesign' control, and audits. a project:In control, documen general, th the following eleven categories: Design control requires confor:ance to regulations ;
- 1. Criteria, or Basis for Design -
~
' a. Will be clear and onplete.
b.
- c. URS/Bluce Project Manager is responsibic for development, URS/Blume Divisir client agree =erc.sn Director is responsible for approval and ,
d .-
- Cannot be chraged informally. All changes will be made according to Quality Assurance Manual section on revisions.
%. 2. Calculations .
- a. UR'/Blume S - March 5, 1982 May be hand or computer. 3,6/42 t
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- c. . . WNN as..u=...,.u..e. m Mr. J. 0.-Schuyler - 2.-
- .,..,,g,.n 3
- August 30, 19f7
; t s
b.
. c. Index for all calculations will be included. i' i Will show all applicable criteria, assu=ptions, ahd refer-ences. . '
- d. .
Will show enough so that any qualified engineer not familiar t
- e. with the project can understand what is being done.
i 1- ,'" Verification of results: sign off by originator and checker. ! 4 URS/Blu=e Project Manager signature indicates co=pletion. i
- f. - Revi ions according to quality Assurance Manual. ~- '
4 3. Ceacuter-Programs . - i
- a. L t
All programs used on quality assurance projects are verified progeens. i (In the event an unverified program is used, a ;
- b. lsecond program will be run as a check.) ,
All certified programs will be logged with name, version,
- c. principal use, and personnel available for consultation.
- d. In-house programs will be certified by our computer group - .
Certification involves documentation of everything that went .
~ (
into making up the program (flow charts, listings, user "
- manuals,
- e. Outside programs: and verification of output).
Where verification is done outside the co=pany, docume l
- . , will be on file as part of the project-documents.
}' j
- f. Modifications: -
by the URS/Blume Division Direc or.all modifications to programs wi! .' ' Modifications will be a made only to copies of the program, never to original versions, All codifications will be documented. Modified progrs=s will i l been certified.be logged with proper version of identification after th 4 Drawints -
, n. -
All drawings project criteria. will be checked for co=pliance to calculations, " ( b. { c. Final approval by the URS/Blume Project Manager. . j j _ :t:.~
-- rt. : rndprikevisions to drawings.will be documented and 2;r_ checking procedures as originals.
{ . . 4 t i S. Field Investigat' ion = i 1 '
~ ~ .
a .' j { b. All '5illdIwork will be documented. Ecuipment and instrumentation used in the field will bc cali- I 1 brated, and-calibration records will be filed with the project documents. i
- 6. Interface Control t
. a.
URS/Blune Project Manager is responsible for est:blishing the } procedures between URS/Bluce and other organi:ations (architects 4 or other engineers). i ' URS/'31uae - March 5, 1982 i -37/42 I 6 .
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, Mr. J. O. Schuyler ,
. August 30, 1977 b.
URS/Blu=c Quality Assurance Mansi;er reviews all procedures c .- to assure compliance with quality assurance procedures, A1.1 procedures are documented. d. Objective of interface contro.' is to keep all involved
. . . . p.rties infor:ed and prevent unnecessary rework.
- 7. Reoorts '
a. URS/Blu=e Division Director has overall responsibility for infor.ation and recommendations. *
- b. 'URS/Blu=e Project Manager responsible for preparation.
- c. -
Revisions docu=ented and reviewed; one copy to project files. S. Suecifications .
. a..
- b. URS/Blume Project Manager has major responsibility. . .
. - All specifications shall be checked for agreement to project.
drawings and other project requirements. ~
- c. Handled similarly to reports.
- 9. Subcontractors .
a.
-- Must have quality assurance program or-be subject to pro-cedures of URS/Blu=e Quality Assurance Manual, .
b. URS/31u=e Project Manager responsibic for selecting subcontrac- , tors. c.
- URS/31u=e Quality Assurance Manager responsible for subcontrac-tors' co:pliance to a quality assurance program. Must approve subcontractors before selection.-
- 10. Desien Reviews a.
There projectwill be at least one review per project, depending'upon site, b. A review-will be a check of selected portions of a project to
'1'" "~ " ~. assure conformance to the project criteria and project require-ments as well as a spot check of calculations.
- c. Ifnenever possible, the quality assurance review will be
- d. All perfor=ed by qualified, persons not working on the project.
e. discrepancies will'be identified and documented. ~
- A design review report will summarite all discrepancies and corrective action taken.. -
- 11. Revisions a.
No revisions will be made without proper documentation.
- b. ' Revisions documents.
and all necessary documentation apply only to approved 7,2 The control of quality-related documents require that file registers or docu entation is stored. indexes be maintained at all locations where qu The retention of all documents will .be as directed URS/Blume - March 5, 1982
. 38/42 . _.. . ~ . -
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, . . os c.r t ne.4* c-mg pa*P t 51. ,*.s t ut b
- ti n
' gr. J. O. Schuyler August 30, 1977
,f m---a:w -
y.37." ?ed ;! s by PGSE. An inde.x of all caterial in the Documen Centrol Center will be ".*?N Y5: n'ain::ined by URS/Slume. * * -- "' ey . , Intern 21 audits will be performed within URS/!!1eme to verify th:: quslity assurance standards have been prcperly implemented and are functioning - effectively. Audit teans will be c:de up of.me=bers of the firm not in-vbived in the project. Pre- and pos -audit meetings will be held to prepare for the audi: and':o discuss any discrepancies fcund. All audits will be co:ple:ely dcct=ented. . A compilation of the quality assurance rechirements which have been or are - 0. , " de-bein; met for the Turbine Building modific't.tions and the recent Hosgri evaluation work are shown in Attachment A. ih%W
.m2 :
The neasures described herein represent a sum:. cry of the quality assurance 'Mr* i requirements specified in the URS/51u=e Quslity Assurance Manual. We will be happy to provide you with a core detailed description should you require. Very truly yours, URS/JC.% A..BLU'iS 6 ASSOCIATES, ENGINEERS ,
.jt. h- k dw -
Davi fA. Lang , Project Manager - - DAL: ben Attach =ent cc: Mr. Vince Ghic/PG5E - Mdarrell-li olley/PCSE .
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URS/Blume - March 5, 1982
*39/42 :ll< L.;f
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, ATTACiEENT A A URS/3LUME OUALITY ASSURANCE DIAELO CANYON NUCLEAR POKER PLANT -
DESIGN CONTROL TURBINE BUILDING
, MODIFICATIONS REC 5:$T 110SGF.I REEVALUATIC:: E0':.7
- 1. CRITERIA .
e e
- 2. CALCULATIONS .
e
. e
- 3. CO.\1PUTER PROGRAMS ..
e e 4 DRAWINGS e
* ! . e S. FIELD INVESTIGATIONS e .
- 6. IhTERFACE CONTROL e
o 7,. REPORTS
- 8. SPECIFICATIONS e r *. N/A .
,. 9. SUBCChTRACTORS e .
o*
- 10. DESIGN REVIEWS e e
- 11. REVISIONS e
' DOCIRT.T CONTRO
. .e ..; ,.
AUDITS . ~- e e u
. ~.
e REQUIRE!.2NT MET OR BEING MET
. o REQUIREMENT NOT !1ET
' N/A NOT APPLICABLE
"--} ...
URS/Blume - March 5, 1982 40/42 e l .
O APPENDIX E
- Comments Noted During the URS/Blume Review J
r URS/Blume - March 5, 1982 41/42 1982 l
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_ _ - -.. _ _ .. _ ..._____ _ _ _ _ _ _ . . _ . , , _ , . _ t
I. Ig. O QA Review Group Meeting p June 8-9, 1983 2030 M Street, Suite 800
~
Washington, D.C. Revised Agenda June 8 8:30 Welcome, Introduction F. Albaugh, R. DeYoung 8:45 Background and Overview of Project J. Taylor 9:45 Role of Review Group ,F. Albaugh, B. Grimes 10:15 Break-10:30 NRC QA Review Activities W. Altman
,q 11:15 , Group Discussion F. Albaugh 12:00 Lunch 1:00 QA Case Studies, Methodology, and W. Altman, H. Harty, .
Preliminary Results K. Carroll 2:15 Group Discussion F. Albaugh 2:45 Break 3:00 Congressional Amendment Pilot Program J. Taylor 3:45 More Prescriptive A/E Criteria B. Grimes, E. Baker 4:15 Group Discussion 5:00 Adjourn 6:30 Social Hour, No Host Ramada , 7:30 Dinner Ramada 8:30 Remarks R. DeYoung F0/A-T Y-213 d4f .
h c:
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June 9 I l 8:30 Introduction of Second Day Activities F. Albaugh ; 8:45 Construction (CAT) and Design (IDI) J. Taylor !
. l Assessments 9:30 Study of NRC and Outside Programs E. Brach !
10:00 Break i t 10:15 Group Discussion F. Albaugh i 10:45 Study of Contracts and Procurement W. Altman, M. Walsh 11:10 Study of-Qualification.and M. Malloy r Certification of QA/QC Personnel f 11:30 Group Discussion F. Albaugh ; 12:00 Lunch ! 1:00 Study of Designated Representatives E. Brach . , and' the Reaffirmation Program -
) [
1:30 Special Topics W. Altman et al 2:30 Group Discussion F.~Albaugh (
, 3:15 Closing Remarks F. Albaugh, R. DeYoung 3:45 Future Review Group Activities F. Albaugh ;
4:00 Adjourn P k 1
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7 .' NRC SPECIAL STUDY OF NUCLEAR QUALITY ASSURANCE REVIEW GROUP i Fred Albaugh Independent Consultant, Past Director, Battelle Chairman Pacific Northwest Laboratories. Manhattan Project, General Electric, Battelle. .
** John Amaral Corporate Manager of Quality Assurance, Bechtel Power Corporation. Former Chairman, Energy Division, American Society for Quality Control.
9 Spencer Bush Consultant, Battelle Pacific Northwest Laboratories. "~ Member, Advisory Co::raittee on Reactor Safeguards, 1966-77 (Chairman 1971). Manahattan Project. Thomas Cochran Senior Staff Scientist, Natural Resources ' Defense Council. C '
' George Coulbourn Co-Director, Nuclear Power Systems, Boeing.
Former Vice-President, Boeing Construction. Former Construction Manager, Indian Point f3. 1
- John Gray' President, International Energy Associates Limited. !
Chairtnan, Energy Policy Committee, Atlantic Council ' of U.S. Former Manager, Shippingport. General
, Electric, Westinghouse.
John Hansel Project Manager, Gaseous Centrifuge Enrichment Plant, System Development Corporation. Former Director, Quality Assurance, Apollo Spacecraft, Space Shuttle Orbiter, and Launch Operations. President-Elect, . American Society for Quality Control. Robert V. Laney Independent Consultant. Retired Deputy Director, - Argonne National Laboratory. Project Manager, l l Seawolf prototype. Bettis Laboratory. Fonner Vice-President, General Dynamics. Eugene O'Rourke General Manager, Domestic. Boiling Water Reactor Projects Department, General Electric Company. Former Vice-President, High Temperature Gas Cooled Reactor Projects, General Atomic Company,
,. 3 Manhattan Project.
U F0/A-N-293
p NRC Special Study of Nuclear
.)
Quality Assurance i NRC Staff and Contractor Participants NRC i Richard DeYoung Director, Office of Inspection and Enforcement (IE) James Sniezek Deputy Director, Office of Inspection and Enforcement James Taylor Director, Division of Quality Assurance, Safeguards, and Inspection Programs (QASIP), IE Brian Grimes Deputy Director, Division of Quality Assurance, Safeguards, and Inspection Programs, IE Willard Altman Project Manager, Special Study of Nuclear Quality
. Assurance, QASIP, IE l Ernest W. Brach ' Senior Quality Assurance Analyst, QASIP, IE I
[$) Edward Baker Reactor Construction Inspector, QASIP, IE l Melinda Malloy Quality Assurance Specialist, QASIP, IE i
.t 9
e 9 4
** h
') .
2-Contractors Harold Harty Senior Staff Engineer, Battelle Pacific Northwest , Laboratories (PNL)
~
Miles Patrick Manager, Project Management Procedures and Training, Battelle Columbus Laboratories Robert Sorenson . Manager, Regulatory Analysis Section, Battelle PNL James Christensen Senior Research Scientist, Battelle PNL Marilyn Walsh Acting Director, Law and Justice Study Center, Battelle Human Affairs Research Centers Mary McGuire Research Scientist, Law and Justice Study Center, . Battelle Human Affairs Research Centers Ken Carroll , Branch Manager, Quality Procurement'Progams, and _ Construction Branch, Idaho National Engineering Laboratory O'-
- Larry Kubicek Branch Manager, Quality Standards and Systems Branch, Icaho National Engineering-Laboratory
- Richard Kleckner Vice President, N.C. Kist,& Associates John Heidenreich Vice President, N.C. Kist i Associates Robert Dellon Vice President, Dellon Associates ..
4 m 9
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i NRC.,SPECIAL STUDY OF NUCLEAR QUALITY ASSURANCE t' , FIRST REVIEW MEETING JUNE 8-9, 1983 l '.-
-S LIST OF ATTENDEES
+
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NAME AFFILIATION WORK PHONE
;
- John Amaral Bechtel (415) 768-7900
! *Leland Bohl General Electric (408) 925-6608 l
- Spencer H. Bush Review & Synthesis Assoc. (509) 375-2223
, l
- John E. Gray IEAL (202) 342-6726
- Fred Albaugh, Chairman -Consultant to Battelle- (509) 375-2575
- Northwest
- Thomas B. Cochran NRDC (202) 223-8210
- Robert V. Laney Private Consultant (617) 585-8912
- George Coulbourn Boeing (206) 575-5638
.
- John L. Hansel System Dev. Corp. (615) 576-2206 l
t Marilyn Walsh Battelle-HARC (206) 525-3130 Robert Soren. son Battelle-Northwest (509) 376-4437 i' Larry Kubicek EG&G Idaho Inc. (208) 526-1685 Bill Brach USNRC, IE (301) 492-4932
; Bob Dellon ~Dellon Assoc. (301) 279-0267
[ Melinda Malloy USNRC, IE (301) 492-4532
; : Harold Harty Battelle-Northwest (509) 376-4908 l -Dick DeYenag USNRC, IE (301) 492-7397
[ Ed Baker USNRC, IE (301) 492-4540
! Bill Altman USNRC, IE (301) 492-8490 Brian K. Grimes USNRC, IE (3 1) 492-4614 James Taylor USNRC, IE . (301) 492-9696 i J.A. Christensen Battelle-Northwest (509) 376-1641 John'L. Heidenreich N.C. Kist & Assoc. (312) 357-1180 Richard M. Kleckner N.C. Kist & Assoc. (312) 357-1180 -
EG&G Idaho Inc. Kenneth C. Carroll (208) 526-1422 i Miles G. Patrick Battelle-Columbus (614) 424-4863 Mary McGuire Battelle-HARC (206) 525-3130 i i f k 6
-ume
- Panel Members n
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O O ) : l . l l NRC SPECIAL STUDY OF NUCLEAR l- O.UALITY ASSURANC i l BRIEFING SLIDES FOR PRESENTATION f - l JUNE 8,1983 l i BY I W. ALTMAN, NRC AND
- M. WALSH, BATTELLE - HARC <
i I - TOPIC: QUALITY ASSURANCE IN CONTRACTS AND PROCUREMENT ! 2 ~ ! 'T E I I. C n i Y , N i . L_______._____.-___ _ _ _ __ ___-_ ._ _ __ _ .__ _ . - . -
O O .O .-
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l - J ' i b I a PURPOSE i i i TO DETERMINE HOW " QUALITY" RESPONSIBILITIES ARE DELEGATED, MANAGED AND CONTROLLED BY THE LICENSEE IN THE CONTRACT AND PROCUREMENT PROCESS AND TO ASCERTAIN WHETHER CHANGES IN THE CONTRACTING AND-
;, PROCUREMENT PROCESS MIGHT. ENHANCE'THE QUALITY OF NUCLEAR POWER PLANT CONSTRUCTION.
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"lF SENIOR MANAGERS HAVE A STRONG COMMITMENT TO QUALITY AND IN TURN INDOCTRINATE ~
CAPABLE PROJECT MANAGEMENT TEAMS WITH THAT COMMITMENT, THESE TEAMS WILL BE ABLE
.TO COMMUNICATE THAT COMMITMENT TO ALL OTHER INVOLVED PARTIES. SPECIFICALLY, THE
- PROJECT MANAGEMENT TEAM COMMUNICATES AND OBTAINS THROUGH. CONTRACTUAL AND PROCEDURAL ARRANGEMENTS WITH THE DESIGNERS, FABRICATORS, AND CONSTRUCTORS A LEVEL OF QUALITY '
I COMMENSURATE WITH THE OWNER'S COMMITMENT. '
"IHE COMMITMENT TO COST AND SCHEDULE MUST BE PROPERLY BALANCED WITH QUALITY THROUGH
'THESE CONTRACTUAL AND PROCEDURAL ARRANGEMENTS.
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l "f0R EXAMPLE, IF A CONTRACT EMPHASIZES .PRIMARILY THE SCHEDULE FOR PHYSICAL I'NSTALLATION, l THE MESSAGE FROM PROJECT MANAGEMENT IS PRODUCTION. ON THE OTHER HAND,/IF THE CONTRACT j ALSO EMPHASIZES OWNER-ACCEPTED, ADEQUATELY-DOCUMENTED INSTALLATION, THE MESSAGE IS QUALITY AS WELL AS PRODUCTION. THE LATTER CASE l'ROVIDES THE PROPER INCENTIVE FOR
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) GETTING WORK ACCOMPLISHED RIGHT THE FIRST TIME. THIS IS THEN REFLECTED !N THE POLICY ' AND PROCEDURAL DIRECTION To THE VARIOUS ORGANIZATION SUB-TIERS." } l I 1 s , j . . . }- , REMARKS BY NUNZIO J. PALLADINO, CHAIRMAN, j _ U.S. NUCLEAR REGULATORY COMMISSION, AT THE AMERICAN SOCIETY FOR-QUALITY, CONTROL NINTH ANNUAL NATIONAL ENERGY DIVISION - CONFERENCE, ORLANDO, FLORl'DA, OCTdBER 1982. s : j j ' 4 . , l e
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SPECIFIC OBJECTIVES ! (1) TO CHARACTERIZE THE ASPECTS OF CONTRAC.TS AND PROCUREMENTS WHICH APPEAR TO AFFECT QUALITY DURING CON'TRUCTION S OF A NUCLEAR POWER PLANT. j (2) TO DETERMINE THE TYPES OF CONTRACT AND PROCUREMENT PROVISIONS AND i ARRANGEMENTS THAT COULD CONTRIBUTE MOST TO ENHANCE QUALITY. I. 4 j (3) TO DEVELOPS TO THE EXTENT POSSIBLE, GUIDELINES FOR CONSTRUCTION CONTRACTS AND PROCUREMENTS THAT COULD ASSIST IN ACHIEVING OVERALL QUALITY OBJECTIVES. i b i s 11t ,11
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4 i , e PROPOSED INFORMTION SOURCES' l- 0 UTILITIES CONSTRUCTING NUCLEAR POWER PLANTS , , i J-j e ARCHITECTS / ENGINEERS t I 0 NSSS VENDORS t
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O- O . D - t CONTRACTUAL FACTORS 8 SPECIFIC KINDS.OF CONTRACTS (E.G., FIXED PRICE VS. COST REIMBURSABLE) '
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i ORGANIZATIONAL FACTORS e PRIOR NUCLEAR EXPERIENCE 8 CONSTRAINTS PLACED ON THE PROCUREMENT PROCESS AS A RESULT OF THE TYPE OF LICENSEE (E.G., PUBLIC VS, PRIVATE UTILITY) } '. e ARRANGEMENTS FOR ENGINEERING, PROCUREMENT, MANAGER, AND CONSTRUCTOR RESPONSIBILITIES ' 4 LABOR ARRANGEMENTS (I .E., UNION, NON-UNION, UNION SHOP) e PROCUREMENT PRACTICES AND PROCEDURES e ' ' PUBLIC UTILITY COMMISSION POLICIES 0 jl GEOGRAPHICAL LOCATION OR DEMOGRAPHIC SITUATION
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QA PROGRAM FACTORS 3 i ) 8 REQUIREMENTS FOR DEMONSTRATION AND/OR APPROVAL OF CONTRACTOR'S QA PROGRAM i 1 e ASSIGNMENTS OF RESPONSIBILITIES AND RISK SHARING RELATIVE TO I QUALITY INCLUDING QA/QC e PROVISIO,N FOR SOURCE AND ON-SITE INSPECTIONS i
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G.) O , J : , I PHASE I: PRELIMINARY PROBLEM IDENTIFICATION O REVIEW LITERATURE, LAWS, DOCUMENTS O CONDUCT TRIAL SITE VISIT TO ONE CONSTRUCTION PROJECT 1 O PREPARE TRIAL SITE VISIT REPORT J
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(: O l : - PHASE II: INITIATE ASSESSMENT OF CONTRACT AND PROCUREMENT PROCESS 8 FINALIZE SITE VISIT PROTOCOL AND SCHEDULE
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4 0 CONDU.CT SITE VISITS TO TWO CONSTRUCTION PROJECTS AND . ONE ARCHITECT / ENGINEER e REVIEW EXPERIENCE / PRACTICES IN ONE OUTSIDE INDUSTRY
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j ,. i i f 1 i PHASE III: COMPLETE ASSESSMENT OF CONTRACT 8 AND PROCUREMENT PROCESS 4 i e CONDUCT SITE VISITS T0'THREE CONSTRUCTION PROJECTS, ONE i ARCHITECT / ENGINEER, ONE NSSS VENDOR, AND TWO SUBTIER CONTRACTORS e REVIEW EXPERIENCE / PRACTICES IN ONE OUTSIDE INDUSTRY t e PREPARE FINAL REPORT 4 l l 1 I il I t
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SUMMARY
OF PROJECT ACTIVITIES - EXAMINE THE CONTRACTING / PROCUREMENT PERSPECTIVES, EXPERIENCES, AND PRACTICES OF: 8 SIX UTILITIES INVOLVED IN NUCLEAR POWER PLANT CONSTRUCTION PROJECTS 8 TWO ARCHITECT / ENGINEERS e ONE NSSS VENDOR S TWO SUBTIER CONTRACTORS PROFILE THE CONTRACTING / PROCUREMENT EXPERIENCES AND PRACTICES IN TWO NON-NUCLEA INDUSTRIES . PREPARE PROJECT REPORTS,~ INCLUDING: e TRIAL SITE ISIT REPORT (JULY,1983) e INTERIM REPORT (OCTOBER 1, 1983) e FINAL REPORT (DRAFT - FEBRUARY 15, 1984) (FINAL - MARCH 31, 1984) .
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,q c STUDY OF
.I QUALITY ASSURANCE IN 1 CONTRACTS AND PROCUREMENT The study of quality assurance in contracts and procurement is being undertaken in' order to explore the relationship between the contracting process and quality assurance in the construction of commercial nuclear -
- power plants. The purposes of the study are (1) to determine how 2
" quality" responsibilities are delegated, managed and controlled by the .
licensee in the contract and procurement process; and (2);to ascertain whether changes in the contracting and procurement process might enhance the quality of nuclear power plant construction. The study has three specific objectives: O-
.e To characterize the aspects of contracts and procurement
- which appear to affect quality during construction of a .
nuclear power plant; e To determine the types of contract and procurement > i provisions and arrangements that could contribute most to enhance quality; and j e To develop, to the extent possible, guidelines for construction contracts and procurements that could assist
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in achieving overall quality objectives,- - h I - E 7 In order to accomplish these objectives the study will~ examine the ~
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perspectives, experiences, and practices of key groups involved in the , i construction of nuclear power plants: utilities currently constructing , nuclear power plants; NSSS vendors; architect / engineers; and subtier contractors. In addition, the study will briefly profile the contracting and procurement experiences and practices in two non-nuclear industries. l Information will be gathered by conducting personal interviews with l O ,. 1
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2 informed individuals in each of these groups and by reviewing appropriate and relevant reports, literature, and documents. The study is currently in the initial phase of problem identification. This phase of the project includes (1).a review of relevant legal and organizational literature and (2) planning for and
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conducting a trial site visit to one nuclear power plant construction site. This site visit will be conducted to gather information khat can be used to tinalize development of a site visit protocol and guide , subsequent site visits. Also, the trial site visit will seek preliminary information concerning the extent to which quality appears to be affected by a' variety of contractual, organizational, and QA program-related
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factors, such as the specific kinds of contracts established (e.g., fixed I Q price vs. cost reinbursable; the utility's prior nuclear experience; and the utility's procurement practices and procedures. The second phase of the project will involve finalizing the site 7 visit protocol and selecting and scheduling sites:for the. series of site visits; this will be done on the basis cf the results of Phase I. E Kdditionally, this phase will involve conducting several fite vfsits and i 5 E - E -
- - . . - _ 5
[ preparation of an interim project report (due October 1,1983) describ'ing - activities and results of the study to date. i-The third phase of the project will entail completing the series of site visits to construction sites, architect / engineers, NSSS vendors, and subtier contractors. A final project report will be drafted by l February 15, 1984, and finalized'by March 31, 1984 9
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( ANS EXECUTIVE CONFERENCE'ON GCVERNMENT AND SELF-REGULATION OF NUCLEAR POWER PLANTS A REGULATOR'S VIEW OF THE NEED FOR BETTER MANAGEMENT CONTROLS I Jam'es P. O'Reilly
~
. Regional. Administrator .
U. S. Nuclear Regulatory Commission . INTRODUCTION I am very pleased to have been invited to participate in the American - Nuclear Society's Executive Conference on : Government and Self-Regulation of Nuclear Power Plants.
. It is particularly appropriate that a meeting of this kind be held here in Colorial Williamsburg, the locale of the fire: capital of Virginia and close to the historic towns of Jamestown and Yorktown. This area 1,s a pleasant reminder of ot.r heritage of self government, and self-regulation, and the way in which we as Americans, when faced with challenges. have worked them out together.
And this point bears a relationship to the real business of this conference: determining how best we can improve the safety, performance and public accept-ance of a valuable and needed energy source. .. However, making substantive improvements will requif e. I believe. much. better manage .ent on the cart of both the re;uia ,or anc : e regulated. Any-
- .tr.g less will result in oar joint failure tc learr. frer. tne lessens cf sne past and will contribute, at best, to unacce tame centin;.ation of the. status ouo. ,
*J.'E RVI EA' From our separate vantage points, many' of i.s think we know what actions must be accomplished but, for a variety of reasons, we have not been able. to adcress these actions satisfactorily. My ex:eriences, both as an operator and regulator of nuclear plants, and as a particicant in a recent survey to review the impact of NRC requirements on plant safety, as perceived by utility representatives, have convinced me that more effective management is the key that can unlock solutions for many of our problems.
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This is net a hollow appeal for a-motherhood type of commitment that has oeen co readily given in the past. The persistent recurrence of major managecent deficiencies requires a critical look at managers and their manage-ment tcols. When deficiencies are minimized, problems of government. regula-tion economics, safety, and public acceptance will occur less-frequently. Initially, I will review nine areas of nuclear industry experience with - their resultant impact on economics, public apprehension, and regulatory concern. The greas selected for . review are important and have received considerable attention in the post-Three Mile Island era. This review of
- recent problems, painful to me as it will be to many of you, is necessary in order to put substance into the appeal for taking a hard look at ourselves. -
Secondly, I will highlight some of the more important things we at NRC are doing and wnat we have in mind to relieve unwarranted regulatory impacts on
'icensees, without reducing legitimate safety goals. My cojective here is to stress a new sense of overall responsibility that is guiding the NRC.
Fi . ally, as I was requested to do, I will adcress several areas where enanges can be made that would benefit the nuclear industry. SELECTED pR02LEM AREAS
- The management problem can be characterized by a summary of recent experiences:
(
- 1. Radiation protection Programs During 1980, as a special post-TMI action, the NRC undertook a major ef'ert~at.48 nuclear plants to appraise the adecuacy of radiation prc:ec-tion pregrams. The direct results of this program revealed the following problems:
. a. Many facilities demonstrated inacequate management support for rac'at'on protection programs. At those facil'ities, health physics ac:aarse to be a routine service crganization ra:ner than a ractatio-prc ection support function, integrated into t ,e fabric of plan:. -
coeration. Many managers assumed tnat radiation protection staff s cers were solely responsible fer ensurirg goed radiological werk '
- -acti:es. Ccnsequently. these manage-s scok c steos to ins:l -
suen practices in the entire' operating organization, or to discipline l serious violations of radiological crecedures. Furthermore, inade-i cuate management support was reflectec by failure to take timely technical or managerial actions on radiological problems that recuired corporate support. l b. Many facilities were inadeouately staffed in the radiation protection area and suffered shortages of technicians, foremen, and i l supervisors. Foremen and supervisors 'were often overburdened with administrative and clerical duties, often to the extent they could I not adequately supervise the technicians. Inadequate. staffing often led to adverse trends being unrecognized or incompletely evaluated. {
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- c. Usually, functional audits of radiation protection programs were
-performed. However, these audits were not adequate to determine the quality of staff performance, either through lack of direction or oversight or because audit personnel were.not qualified to judge performance. As a result, audits could not bring about substantive improvements.
- d. ' Weaknesses in the areas of personnel selecti.on, qualification, and training were identified at half of the facilities. The most frequently observed management support weakness was inadequate staff
- training. Training was conducted informally and mostly when con-venient. The training of health physics "first-line" supervisors was particularly neglected. -
- 2. Emercency preparecness procrams During 1981-82, NRC conducted appraisal programs at all operating nuclear power facilities to assess the state of emergency preparedness.
The fc11owing are examples of def~iciencies that we believe resulted from the lack of proper management attention: '
- a. Inadequate Planning and Direction (1) Eme.rgency implementing procedures were incomplete or unclear.
O- In many cases, procedures were not available. (2) Emergency Action Levels were not integrated into procedures for use by operating personnel . (3) Bases for recommending off-site protective actions to public officials were not fully developed. (4) Planning for emergency response . personnel was inadequate to assure that they could arrive on site ta augment the on-duty permanent staff. -
- b. Inadequate Training Programs (1) Training crocrams did not include key managers and any off-site response personnel. '
(2) Training programs for operating personnel frequently was inade-quate. In cases where training programs were adequate, the implementation was frequently deficient.
- 3. Quality Assurance (0A)
The experience of Region II field inspectors and their supervisors,
.w -
in conducting QA evaluations over the last several years serves as the 0 . t I
.. g L .mi primary input for the following observations. The bases are contained in j numerous NRC Inspection Reports: '
- a. Staff not held responsible for the quality of their actions, i
A good QA program must be implemented aggressivelf - Managers 1 j often do not provide incisive QA actions, and as a result, their - inactions become decisions. Decisive nanagement actions are crucial ' i for spccessful QA programs. ! If there is one issue that sums up many current QA related management problems, it is the issue. of responsibility. Management - { has relied on the QA organizations to provide the primary indication i ' of the quality of operations while not proportionately emphasizing I the resconsibility for quality by individuals doing the work. This approach results in a cascade of problems. Managers, including the - i very top levels, must stress eersonal responsibility for quality and i formally recognize quality actions of their employees. The lack of
' strong management support for quality by all workers can also lead to harassment of individuals charged with quality surveillance. Harass-ment is a serious and costly problem when viewed in the context of' employee frustrations. Specifically, actions to correct serious problems can be ignored. - This aspect of harrassment can lead to costly rework.
- b. Organizational conf.llets not resolved i * -
4 A 4 serious management _ problem occurs when quality concerns i conflict with the plant purpose of producing power. ' At some plants, .' QA and site operating organizations function as adversaries rather
- than operating as unified organizations. This adversarial relation-ship precludes problems being resolved locally. Even though such ..
problems .must be promptly corrected by top management, the problems 1 !
- are ef ten not even identified to tcp management. When management coes n
- t detect and resolve these ;:roblems expediticusly, the
{ ~ effectiveness of the overall coeration is, seriously damaged.
- c. Goed and workable procedures rot provided j
. All nuclear programs require prececures. .However, procedure - '
l develocment has, in many cases, lacked quality preparation. Managers have net committed sufficient resources to procedure preparation, i review, and evaluation to assure effectiveness. When utilities have a complex, multi-tier procedure system, with each lower tier invoking the ' one above it, requirements are not consistently implemented, conflicting guidance appears in different procedures, and a night-marish document control problem is created. 1 1 e
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- d. Training not provided Training is vital if-QA programs are to succeed. A frequently encountered problem is that management views training as relatively l- unimportant, not a necessary tool to assure proper and safe plant i
i operation. Managers sometimes delegate valuable training opportuni-ties to technically unqualified training staff members who train - personnel in matters neither directly related to their duties nor to , - their identified weaknesses. .
- 4. Report'ed Nonroutine Licensee Events "" ~ ~
A valuable safety tool of the-NRC is that it is informed of events }' that may signal serious developments at nuclear facilities. Operating events reported each year number in the thousands. All too frequently the
- corrective actions applied to reported events are directed towards rees- '
tablishing conditions as they existed before the' event--i.e.', operator proficiency is reestablished, pumps and valves are repaired, and instru- , ments are recalibrated. What is 'often lacking is the needed managerial emphasis, both at utility and industry levels, to stimulate analysis of
; the event to identify and correct root causes. If the analysis is not lacking, the follow-up action often is. Repetitive events are particu-larly indicative of this problem. An overview shows that the distribution of contributing causes to reported licensee _ events has not changed
- substantially over the last few years.
.i Causes of Events . '
!{. i' Data for 1978 Through 1981
- Component Failure 50!;
1 Personnel Error 16*. . l Design / Fabrication 12's ~ y Defective Procedures 5'i } . External Cause if, .
; Other 16', .
A good example of an operational problem continuing to cause shutdowns is the fact that reports - to the NRC Emergency Center in - l' Wasnington, DC, shew that feedwater problems persist as the .ause of 40 , percent of the reactor shutdowns at pressurized water reactors. Sometning should have been done.
- 5. Generic Issue Experience .
I Generic problems continue to surface. NRC screens these types of events and selects' the most significant for reporting to Congress as abnormal occurrences. A review of post-TMI items indicates that approxi-i
! O mately five to seven of ti.1ese significant events occur each year. Typical causes include design errors, construction inadequacies, operator errors,
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p deficient procedures for operating or testing, and faulty preventive maintenance programs. A single aspect common- to all these events is a failure of one or more management systems.
- 6. Enforcement Actions A review of routine and escalated NRC enforcement actions can provide additional insight into several management control issues.
- a. Routine Enforcement Actions The preponderance of violations of NRC requirements are -
processed as routine enforcement items. Since the incident at TMI, this category has accounted for 96 percent of enforcement actions. Althcugh routine, this category contains substantive information relating to the performance of managers. In 1951. there were 2000 viciations detected by NRC relative to operating reactors. An analysis of -Region II enforcement data relating to 26 operating reactors (603 violations) indicates the following: Analysis of Routine Enforcement Data Violations by General Area General managerial problems (Training, Reporting,QA) 3 3*. Radiation Protection and Emerg'ency Planning 16'; Security Programs 16*; Plant Operations 14'. Fire Protection Programs 10*4 Surveillance Testing 5'. Maintenance and Repair 5'.
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;iefueling Operations l'.
Viciations by Cause Personnel . 47% Management 4 0'. Oesign er Ecuipment 13'. ,
- c. Escalated Enforcement Actions An analysis of all escalated enforcement cases shows the following contributing factors as leading up to the event that prcmpted the enforcement action. The items are listed in descending order of prevalence:
(1) Inadequate management oversight, audits, and verifications. l .
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4 .; 1 (2) Inadequate safety reviews to evaluate hazards before plant i
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modifications, maintenance, or other work is done to _ assure appropriate procedures, trairing, and radiation piotection. , 1 (3) Inadequate attention to de: ail caused by poor training or l procedures, lack of-motivation, poor attitude, or all of the _ above, by managers and employees. l (4) Managers providing incomplete or~ misleadir.g 'information to the } NRC.
- I 7. Procurement of Equipment and Services
. Experiences of.NRC field inspecters and supervisors responsible for
- the inspection of vendors, reveals a real concern for many actions taken .
l -by utility managers in their dealings ,sith the suppliers of equipment and i services. Specifically, a review of utility' performance shows that overall procurement requirements and controls have not been effective. A high percentage of non-conformin'g supplied materials are being found during vendor inspections or inspections at sites, and a large number of services are found to be short on quality. Such conditions frequently ) require rework, rejection, 'or written Jt.stification- to use equipment or j services as they exist. The number of incidents varies depending on the purchaser's procurement documents, the purchaser's quality control surveillance at the supplier's shop, or ,the quality of consultant or. 1 support controls. These problems have resulted in increased costs and, in _'
' some cases, widespread public concerns as to whether the nuclear industry '
suppliers can produce quality products. Primary causes of such problems include the following: l a. Failure of managers in procurement departments. 4
- b. Failure of concerned managers to c:- unicate realistictily on produc deficiencies including those that #a'l to perfor:. intended functions.
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i j In looking at the above examples, the question arises 'as to why managers do not identify these types. o' ;roblems sooner and take proper corrective i ndus t ry . measures - corrective meas.res for themselves and for the l t !j Requ' ired rework, repair,.or justi'ication to use as-is are far more ; 1 expensive than had the job been perfom.ed to the requirements the first ' ] time. Managers, should not be rewarded for achieving short-range benefits ! 'at the expense of long range costs. i i d *
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- 3. Public Information Proorams I find that the utilities with which we deal have public information departments of varying levels of strength and sophistication. Some companies either try to say nothing unless the requirement to do so is thrust upon them, or else their spokesmen lack up-to-date information on a continuing basis and thus cannot respond effectively to inquiries. In many instances, public affairs staff members are not adequately trained in nuclear payer, or they lack the authority to respond on a definitive or timely basis. At least one utility announces so many events, which are all invariably described as " accidents" by the media, that frequently the public information channel is overloaded. We must be more ~ sensitive to -
public fears, not only in being open and candid, but in ~considering the proper level of response to expected problems--and I emphasi:e exoected-- such as minor personnel contamination or leaking components. We in the NRC are sharpening our sensitivities, whether dealing with documents that may becon.e public, responding to media inquiries, or talking with members of the public. When any r f the above type situations exist, they constitute' manage-ment problems--management problems that only worsen the major problems of public anxiety and skepticism about radiation and nuclear power. NRC has contributed to long-standing public anxiety about nuclear power by its multitudinous reporting requireme'nts. We are working to C] c remedy this problem within the NRC, but we need industry's cooperation in that effort. However, by " remedying" this problem, I do not mean restric-ting information. Industry must recognize this fact, or there will be no cure for the problem in public confidence. Clearly, all substantive information must be made available. Non-substantive information must be properly classified as such and not reported so that such information can be interpreted by the media as emergencies or related crises. ..
- .cact of Reculatory Activities
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i This area was left until last cecause I' wanted to terminate the painful process of talking about problems by overtly tying the NRC into tre areas already discussed. , The subject of management in the nuclear industry must include a ' ciscussion of the impact of regulatcry activities on managers. After the accident at Three Mile Island, NRC cegan the inevitable process of identifying and evaluating the broac soectrum of remedies that might offer
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assurances that such accidents would ce precluded in the future. The requirements imposed on licensees touched all personnel in the industry and all areas of plant operations, design, and planning. b
.____.-_______E[. _ _ _ _ _ _ _ _ _ . ___._E__
_g-m l By late 1980, it was evident that both industry and NRC resources were being severely taxed. NRC became concerned that tne burden ceing placed on the industry could have negative safety consequences. Accord-ingly, a high priority survey was conducted to asses; the impact perceived by utilities of NRC requirements on plant safety. This study contributed substantially to NRC full.y recognizing that it shared the management prcblems of the industry it regulated. True recognition of the problem has, and" is, leading to significant managerial and atj.itudinal improve-ments. Two major issues identified during the survey ,ere the following:
- a. Failure of NRC to appreciate the magnitude and impact of individual and combined backfit requirements, the scope of on-site activities necessary to meet those requirements, and the negative safety impact on operating staff proficiency when a nuclear plant is operated through a period of rapid and extensive plant modifications,
- b. Failure by NRC to recognize the impact on plant operation on needed, self-initiated improvements when utility personnel were directed to address NRC-mandated requirements.
SUMMARY
OF IDENTIFIED MANAGEMENT PROBLEMS A review of the issues represented by the details contained in the oreceding sections supports a conclusion that managers in the nuclear business must take a careful look at themselves. Managers should not look to anti-nuclear groups, the media, intervenors, allegers, financial institutions, or rate-setting groups as their only adversaries. A more constructive approach would be to look at ourselves for the solutions to correct the many problems
- hat continue to exist. ,
NRC MANAGERIAL IMPROVEMENTS My comments up to this coint have focused on the negative and painful sice
- f curreat issues. I will now briefly address several managerial initiatives ta(en by -he NRC to upgrace its perfor ance. '
NRC has recognized the pressir:g need to get its own house in order and things have been happer.ing. Rea! progress has been made in a nt.-ber of areas:
- e net 'esult cf which will De a better and Fore responsive agency. ,
Fcr example, the position of a Deputy Executive Director For Regional Operations and Generic Requirements was established to control tne imposition of requirements. This function has been aggressively pursued. A recent example of this function in action is exhibited in SECY 82-111, Emergency Response Facilities. This action helped bring order to emergency planning requirements for licensees. T, J t
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j A very positive overall impact will be realized by the Ccemission's determination to decentralize many of its established regulatory activities to regional offices. This program is moving ahead, with the expressed desire to bring the regulator closer to the regulated. Also, this approach will necessarily focus attention on achieving necessary improvements in policy and program areas that will remain in Washington. Both aspects of this management initiative should bring about substantive improvements. _ Continuing, problems in implementing the NRC enforcement policy are also recognized. Our experiences with the new policy are now being critically evaluated. It is evident that changes are needed to optimize the effectiveness of enforcement and that chances will be made.
- Recognized to be of major concern to both Itcensees and the Commission is the impact . of NRC reporting requirements. A- better balance needs .to be ,
achieved between NRC's need to be properly informed and the many faceted impacts on licensees resulting from unrealistically low reporting threshholds, particularly in the emergency area. A review of. reporting requirments is being conducted and I feel confident that changes will be forthcoming, Nowhere are the feasibility and soundness of self-regulation more strongly demonstrated than by the now well known Institute of Nuclear Power Operations. Perhaps, the most overall positive impact will be realized by the fact that at , NRC we strongly support this concept and encourage the development of similar 'i concepts whereby utilities can work together and share the burden of regulation - and share the most positive aspects of utilities' programs. The Commission's support and acceptance of the Institute of Nuclear Power Operacions concept has been clearly demonstrated in many areas and certainly by the recept signing of Memoranda of Understanding. INDUSTRY MANAGERIAL IMPROVEMENTS This brings me to the third subject. Industry Managerial Improvements. I will address two managerial improvement areas w lich, from my vartage peint. seem to be particularly deserving of attention. l
- 1. Management Direction and Control -
The electric utility industry alreacy has cemonstrated a willtrqness , and the ability to mobilize resources through many existing programs.
. Such programs, for example, inclu'de e :ergency transfers of major scare par.ts, power pools, inter-connecting grids, codes and standards com-mittees, industry forums, and reliability councils. And most recently, the nuclear power industry established the Institute for Nuclear Power Operations. This major commitment of financial and manpower resources which the Institute for Nuclear. Power Operations represents, demonstrates a serious dedication of the industry to nuclear safety.
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O, Without detracting from these examples of outstanding efforts, and tne'special case of industry support at TMI, I must state that I do not believe the accomplishments so far are sufficient to change the level
- o. public confidence in nuclear technology or in the capability of the industry to safely handle it. Many here today are attuned to self-regulation; but, there are not too many people outside this room who are now reacy to accept it for nuclear power plants.
Notwithstanding, the concept of se l f-regul ation", when properly defined, is both necessary and appropriate. There are many areas in which
- it can be effective'and acceptable to the public if certain attitudes in the industry change and industry performance improves. I certainly agree that you should move forward in the direction the Institute of Nuclear Power Operations' commitment represents. In moving forward, I believe that the following managerial concepts should be carefully considered if significant cenefits are to be achieved:
- a. Utilities operating or constructing nuclear power plants should be more closely affiliated by use of some more favorable organiza-ticnal arrangement that optimizes the management control of nuclear activities.
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- b. Although there are many excellent examples of cooperation, utilities must begin to think and act more in unison to solve N p robl ems. There should be mechanisms in place to solve problems as they are identified and prioritized, and a willingness to work as hard for mutual industry needs as for the individual utilities' needs. This means, where safety is concerned, sharing resources to attack industry's problems. Self-regulation cannot be a workable concept unless it is applied industry wide.
Several areas come to mind which can lend themselves very well .. to immediate self-regulation. This includes the areas of training, staffing, and orgaai:ational relationships. Unfortunately, these are a'so good examples of how poorly the incustry, in a historical sense, has performed. As I look back over the years, it seems that too many of the major initiatives in these areas were brought about by the Nuclear Regulatory Ccmmission. T-* s is one reason the public may not ce quite ready to accept nuclear industry self-regulation even in selected areas without additional proof of serious commitments. '
- c. Utilities should seize the initiative to make standarci:ation a reality. Unfortunately, I, and others, sometimes perceive an attitude of casual indifference towards standardization. But standardization is very important. It should go well beyond design and construction. It certainly should include, for example, training, the procurement of acceptable equipment and services, and the area of emergency planning.
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- d. Utilities should be more aggressive in managing solutions to the nigh level waste problem. Although this issue is a very complex one, the ultimate solution will affect every single facility utilizing nuclea- fuel. It is, as you know, a major fac.or causing public anxiety over nuclear power.,
If seme or all of the above, or similar industry initiatives, could ~ be acceepiisned, the image of the industry building and operating nuclear power plan;s would certainly improve with resulting benefits to all.
- 2. Puolic Info-mation Procrams This is a topic as important as any of a technical nature, for it involves the responsibility we all share of not causing unnecessary public anxiety anc of earning the public's confidence. This topic re-smphasizes an area I ac:ressed earlier in my discussion of current proble s.
I think it is very important to make special note of the fact that, while none :f us can control the press, we often can aid public uncer-standing' y the way we announce matters or respond to media inquiries. We should reme er that reporters dnd their editors, in making news judge-cents, tenc to rely on such factors as their trust in the source of information, choices of words, timing of announcements, numerical y rankings, ard the tone we used in discussing events. We see this media process at work when an emergency " alert" is declarec at a nuclear plant beca'use of a leaking valve in the drywell of a boiling water reactor, resul*.ing in nationwide news coverage: when another emergency " alert" is declareo because of a spill curing disassembly of a reactor coclLnt pump, generating region-wide publicity; and when a preliminary consultant's report on accident pro:abili ti e s, stimulates necia coverage throughout the nation that continues for weeks. ** Pu:T': :09cern and anxiety aoout r.c' ear :: wee wl l ' e at w'tn us for a ': ; -ime. It would be ur.reat i s-1: anc unac:eptasia to ig-ore th's fact. For these and other reaso ,s. s;ch pr:blems are Ones wnich nanagement ust address with appropriate aggressiveress anc resources.
a age e t'l responsibility extencs :: ass.-ing streng. wel*-staf#ec an: '
ace:.a:e', #'nanced pu:lic informatice :r:g-ans--:*: grams ar':r rave tne , s anding witnin an organi:ation that cefits their importance and tne full te:nnical s.: port and cooperation they need to functic'n crope-ly. Seeing snat plants are operated safely and reliably will, of course, prevent a great deal :f adverse publicity and public anxiety, but ar effective pu:lic aff a'rs program is a need in its own right. I do not see this need being met by all utilities.
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I D. EPILOGUE The nuclear industry is, at best, on a plateau at a time when uncertain-ties abound and some of the factors which af fect the future of our tecnnical field are beyond our control . - Yet I bel' eve this situation presents an excellent opportunity for the nuclear industry and the regulatory authorities to take stock of ourselves--to take an inventory, if you will, of our strengths and shortconings, and then summon the will to act on the findings of this self-examination. , Without this kind of management, and the results it can achieve, the cublic will not provide additional support to nuclear energy. The cnallenge is here for us all to do a better job. s. e . 9 si k - \
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- Consnercial Operation Plant MW Type Utility 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 Arkansas Nuclear One-1 850 We PWR/B&W Arkansas Power & Light Co. _ _
1,067 life Tennessee' Valley Auth. (AL) 1
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f i NUCLEARPLANTSRECEIVINGCONSTRUCTI0ilPEpITSIN1970 l ,. 1 Commercial Operation li Plant fH Type Utility 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 i k Braver Valley 1 833 We PWR/W Duquesne Light Co (PA) ; - Brunswick 1 821 We BWR/GE Carolina Power & Light (14C) : : Irunswick 2 821 We BWR/GE Carolina Power & Light (NC) ; e Diablo Canyon 2 1,106 We PWR/W Pacific Gas & Electric (CA) - g Duane Arnold 538 W e BWR/GE Iowa Electric L&P Co. - James A. Fitzpatrick 821 W e ' BWR/GE Power Authority of State of NY e e Millstone 2 870 MWe PWR/CE Northeast Utilities (CT) ; St. Lucie 1 777 W e PWR/CE Florida P&L Co. ; e Sequoyah 1 1,148 iWe PWR/W Tennessee Valley Authority ; : Sequoyah 2' l.148 We PWR/W Tennessee Valley Authority ; = f. l l e 5i
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p,,o u"/ vn Jaled ECLOSL'RE I Qualifications of Companies Proposed to Conduct Independent Revieses e G a d
? 39
QUALIFICATION
SUMMARY
OF ROBERT L. CLCCL ASSCCIATES, I!;C. Robert L. Cloud Associates, Inc. (RLCA) was formed in 1979 to provide emergency consulting services to a broad spectrum of clients having a need for engineering design assistance. So=e of the major areas of expertise provided by RLCA include:
- 1) Static and Dynamic Stress Analysis, 2) Earthquake Engineering and Structural Dynamics, 3) Analysis of Systems Subjected to High Temperatures and 4) Frogram Management and Engineering. In the area of Program Management and Engineering RLCA has performed independent third party design reviews and has provided management services related to the perforr.ance of a va lety of projects and programs.
RLCA has provided service to a number of clients which include architect / engineering firms, electric utilities, nuclear component design firms, private and governmental research organizations. ..
, Since the founding of RLCA, the firm has earned a reputation for ,
engineering' competence and the ability to provide solutions to difficult and . complex problems. In many instances the methods used te provide these ' solutions have been both innovative and unique and have resulted in techniques that have become industry standards. e - p
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y , . ., ELCA has p en previously retained by PGandE for work related to Diablo Canyon. This work included a minor project on whip restraints in 1979, and a major project on Seismic System Interaction that began in October 1979. More detailed information on'the accomplishments and capabilities of RLCA are provided in the attached brochure. t k 4
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QUALIFICATION OF R. F. REEDY INC. TO CONDUCT INDEPENDENT DESIGN VERIFICATION R. F. Reedy. Inc. (RFR) was formed to provide engineering management ; and quality assurance consulting services to electric utilities, architect / engineers, manufacturers and suppliers. The firm provides management with. independent reviews of work performed by RFR clients or organizations which
~
have provided work to RFR clients. RFR personnel have many years of diversified practical nuclear experience and, therefore, are able to assist clients in a number of areas such as materials, fabrication, design and quality related' requirements for nuclear systems. Some of the typical work RFR has been involved includes management - assistance, consulting and third party independent review in the areas of: Quality Assurance and Quality Control .. Audits . . ASME Code App 1'ication ; Program Review and Development . N45.2 (NQA-1) Design Document Reviews Design Specification Design Reports i L 1 e
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l Fabrication and Installation. Reviews kepairs . Modific tions k'elding Qualifications Nondestructive'Exacinat' ion Prograc Reviews Construction Preservice Inservice . Seminars and Training Programs Design Construction j Inservice Inspection Operatiens . Quality Assurance l L Licensing Activities
. NRC i
ASME Accreditation , State Jurisdiction and National Board , Codes and Standard Consulting. Boiler and Pressure Vessel Piping Structures }
Nuclear Components ISI Programs Materials Applications Selection Specifications Investigations O
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. QUALIFICATIONS OF TELEDYNE ENGINEERING SERVICES Teledyne Engineering Services (TES) is an operacing division of _
Teledyne Industries, Inc. , which is a subsidiary of Teledyne, Inc. -TES , _provides a wide range of engineering, management, and technical support . services for the design, analysis, construction, and testing of mechanical
~
systems and structures. TES employs over 200 persons with approxicately 85% of these being. technical. ' The majority of TES work relates to nuclear power. In the nuclear area, TES has serv'ed the following organizations: Nuclear Regulatory Commission, Department of Ene rgy, various National Laboratories, the Electric Power Research Institute, approximately 30 electric power utilities, all of ' the NSSS suppliers, most of the major architect-engineers, and component suppliers. Services provided by TES in the nuclear area include the following: Piping and Pressure Vessel Services, Analytical Engineering, ~ Experimental Engineering, Material Testing, Meta 11ography and Ncn-Destructive Examination, Seismic and Dynamic Analyses, among other analytical expertise, and Fracture Mechanics Evaluations. In addition,'TES offers Design Review Services to the nuclear industry. , TES has been previously retained by PGandE for work related to Diablo Canyon. This work included a minor project involving two days' consulting by the Senior Vice President of TES, and a major project in-response to NRC IE Bulletin 79-02.
i 9 <. Detailed background information describing the technical' qualifications of TES has been compiled and is contained in the attached package. The information included in the attached package inciudes the following:
- l. A general TES company brochure.
- 2. Resumes of the proposed TES Project Manager, Dr. William E.
Cooper, and other TES senior personnel whose support may be required. J
- 3. A series of TES capability and experienze summaries.
4 A TES company brochure on Piping Analysis. l Resumes for TES personnel who may be involved with this project are
, also included in the attached package. For convenience, a summary of the resume for William E. Cooper has been extracted and is included in this section.
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d , g it I}')k , sj p~ ENCLOSURE 3 Overall Management Plan For Independent Desigt. Verification Progra: Of The Diablo Canyon Power Plant 6 e G 4 l , .- _-- . .. . . . -~ .. I
OVERALL MANAGEMENT PLAN FOR INDEPENDENT DESIGN VERIFICATION PROGRAM 0F THE DIABLO CANYON POWER PLANT Introduction This enclosure describes the Management Plan PGandE proposes to - follow to obtain the information required by the NRC in its Order CLI-81-30 dated November 19, 1981 (" Order") and in the NRC letter to PGandE (H. R. Denton to.M. H. Furbush) of' November 19,1981(" Letter"). . Program Scope As a result of errors identified by Pacific Gas and Electric Co. in the design of Diablo Canyon Power Plant (DCPP), PGandE implemented an independent design verification program. This program has been in progress'since early October 1981. In response to the Order and Letter, PGandE has expanded the ongoing effort into a two-phase Program * (" Program"), which is described below. Phase I of the Program encompasses those actions required to be completed prior to fuel load as specified by Paragraph 1 of Attachment 1 - to the Orde'r. The work consists _of a design verification of all , ia, ..'.w-~. ..w - + p m. ~ ~- >-e --
safety-related activities, performed prior to June 1,1978, associated with seismic-related service contracts from which information was utilized-in the design process for safety-related structures; systems and components. Specific details of Phase I of the Program are described in Enclosure 2. Phase II of the Program encompasses those actions' required to be completed prior to issuance of a license authorizing operation above 5% power. The requirements of Phase II are described in detail in the NRC Letter. The work for Phase II consists of three parts: 1) independent
~
design verification of non-seismic safety-related work, performed by service contractors prier to June 1978; 2) a design verification of PGandE internal safety-related design activities, and 3) a design verification of safety-related work by service contractors performing work after January 1, 1978. We plan to submit a detailed program pertaining to Phase II work in approximately two weeks. . Program Management In order to effectively' implement the P'rogram and to assure the independent nature of the review, the Program will be administered by Mr. G. A. Maneatis, PGandE's Senior Vice President for Facilities Development (see Figure 1). Reporting to Mr. Maneatis will be R. L. Cloud Associates, Inc., who will act as the program manager and will direct the independent design verification effort. R. F. Reedy, Inc., as subcontractor to R. L. Cloud Associates, Inc., will perform the review of Quality Assurance activities. Additional contractors will be retained in Phase II of the Program.
Also reporting to Mr. Maneatis will be Dr. William E. Cooper of Teledyne Engineering Services, who will independently review the activities performed by R. L. Cloud Associates, Inc. and its subcontractors. Findings and recommendations from both R. L. Cloud Associates, Inc. and Teledyne Engineering Services will be reported directly to Mr; Maneatis. Program Implementation ' R. L. Cloud Associ'ates, Inc., and its subcontractors will perform the following tasks:
- 1) Develop a network for the design chain for safety-related .
structures, systems and components.
- 2) Develop criteria for selection of a suitable numt.er and type of sample calculations related to the design of safety-related structures, systems and components and for expansion of the sample size when problems in verification are encountered. ,
- 3) Perform a suitable number of sample calculations to verify the adequacy and accuracy of- the design process for affected safety-related structures, systems and components.
- 4) Review Quality Assurance procedures and controls used by safety-related service contractors.
- 5) Review Quality Assurance procedures and controls used by PGandE with regard to safety-related service contractors.
...----.-3 ,
- 6) Review Quality Assurance procedures and controls used by PGandE associated with safety-related structures, systems, and components.
- 7) ReviewtheimpiccantationbyP92ndEanditsrifety-raiated contractors of Quality Assurance procedures and controls identified above.
- 8) Compare the procedures and controls identified above with the criteria of Appendix B to 10 CFR 50.
- 9) Identify deficiencies or weaknesses in the Quality Assurance
. procedures and controls in either the identified contractors or PGandE. -
- 10) Provide a report of their findings and recommendations.
Proars: Review Teledyne Engineering Services, under the direction of Dr. W. E. _ Cooper, will independently review and evaluate.the implementation of the Program. Any deviations or inadequacies in the Program implementation will be reported. - In performing its independent review, Teledyne Engineering . Services will not be limited to auditing the Program but will also have {;51'. , the freedom to separately verify the work being performed by R. L. Cloud - Associates, Inc. and its subcontractors. This may include such activities as making independent calculations or developing separate criteria for sample selection. e O 2
. i Qualifications The qualifications of the three major organizations performing tasks in this Program, and the lead individual for each organizat' ion are furnished in Enclosure 1.
- Conclusion Since implementation of the Program is of the utmost importance
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to PGandE, we have selected independent reviewers w'ith impeccable credentials for.the design verification effort. This program is being , administered by Mr. G. A. Maneatis, PGandE's Senior Vice President for
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Facilities Development, to whom the Departments of Planning and Research, Engineering, Nuclear Power Generation and General Construction report. This organizational arrangement ensures that'the Program will be carried out properly and objectively. PGandE is totally committed to conducting a design verification program and associated review ef' fort which is independent, thorough and of the highest possible quality.
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G. A. MANEATIS Senior Vice President For Facilities Development 1 Pacific Gas and Electric Company 1
- j. .
t I Teledyne Engineering Services
, W. E. Cooper Independent Review Robert L. Cloud Associates, Inc.
Program Management I .. f . R. F. Reedy, Inc. RLCf Oth'ers
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Q. A. Activities Design Chain & As Required Independent Calculations l l FIGURE 1 MANAGEMENT ORGANIZATION W^^ w- wma ,o m -w s e e- op ,
w cCd-cc} Public Comments Sumary by Subject 13.b.1 More Pres &iptive ' Criteria
- 1. NRC should establish detailed QA/QC procedures for all phases of nuclear plant construction. (Jerry Girton) '
- 2. NRC should standardize all paperwork used in nuclear power plant construc-tion. (Jerry Girton)
- 3. New regulations would not do anything to' eliminate construction QA de.fi-ciencies. (Marvin Lewis)
- 4. Establish formal reliability engineering program and require use of scale models. (SDG&E) ~.
' 5. Don't allow construction to start until 50". of the engineering is done and models are built and reviewed. '(SDG&E) ..
- 6. .Large numbers of material false statements illustrate lack of respect of industry for current regulatory framework. (SNSG) -
- 7. The more prescriptive the criteria the better. (OCFRE)
- 8. More prescriptive criteria increases manpower require'ments' without a cor-responding increase in quality. .(PSE&G).
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- 9. Existing regulatory framework should not be encumbered by additional layers of requirements. The NRC should establish a single NRC QA _
document. (PSE&G) 4
- 10. One step licensing and more prescriptive criteria is a logical com-bination. (HL&P)
- 11. More prescrptive A/E criteria will not solve problem. More prescriptive inspection, control, process control,, records requirements would be he-l pful . (FP&L)
.. 12. Need more detailed preplanning of all aspects of construction. (FP&L)
- 13. Use physical modeling and computer assisted drawing. (FP&L) 14.
More prescriptive design criteria would negate designers flexibility
~
and creativity. (NPEC).
-15.
QA/QC begins at design, should have more pres,criptive A/E criteria. (UCS)
'16. Study should investigate ' range of engineering and design review which could be performed by NRC, minimum should be safety-related and important to
, safety designs. (UCS)~
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- 17. More prescriptive criteria stifles creativity and initiative in the design. (Duke Power) -
- 18. More prescriptive criteria won't' solve the problem. (BG&E)
- 19. Use less prescriptive regulations, but stronger performance requirements.
More prescriptive criteria may lead to less rigorous design and more reliance on NRC. (AIF)
- 20. Don't encumber existing regulatory framework by mandating prescriptive criteria (EEI).
- 21. Any prescriptive approach will not succeed until everyone involved believes in and implements the requirements. (ASME) e
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r 13.b.2 Demonstration of Managenent Capability
- 1. Corporate character (attitude) is important, NRC should interview top management. (OCFRE) _
- 2. ~ NRC should assure CE0's and contractors have a thorough understanding of QA/QC requirements. (D. Garland)
- 3. Licensee should demonstrate capability to nanage project and ~QA prior to granting CP, (NB)
- 4. Perform cost / benefit on requiring demonstration. (HL&P) 0
- 5. Need demonstration of capability in areas of personnel, control systems and acceptance of-required QA actions. (FP&L) 1 T
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- 6. There are. adequate , provisions already in place to evaluate management's
~
capability. (NPEC)~ 'l
- 7. NRC should emphasize management of quality.
(INPO)
- 8. Current conditioning of Cp on NRC approval of QA programs meets this requirement, don't need any more. (Duke Power)
~'~ 9. This unnecessarily restricts the owner / licensee ~ to managing the project themselves. (BG8E) e
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- 10. Capability to independently manage QA/QC is essential. (CEI)
- 11. Evaluation criteria should be flexible enough to permit.INPO to perform this function. ,
(EEI) . 4-8 O e a 6 m e D #9 4 A 40 9 D
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- 5. . <.. .
-13.b.3 Evaluations by Organizations of Professionals
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- 1. An additional layer of inspection will not solve the problem. (SDG&E)
- 2. Too many yearly audits already (40). Ratio of product costs vs. audit costs is way out of line. Audit frequency should be related to material type and complexity. (ASC)
- 3. Establish a requirement similar to ASME "N" stamp for electrical equipment '
j with no requirement f'or utility audit. . (ASC) t
- 4. Limit audits to suppliers with-X number of contracts of X dollar value. (ASC)
- 5. Must write standards clear enough so that different auditors don't review two different interpretations of them. (ASC)
- 6. QA programs should ,have independent review groups, would constitute ~
independent design review. (L. Wilkie)
~
- 7. '
NRC should make use of current ASME and National Board' audits. Third party
, audits should be required. (NB )' ,
8. Independent audits should be conducted at set stages of ~ construction, 25%,
, 50%, 70%. (NB) ' ~) .
v. _- me -e- -
. 2- -
- 9. Independent auditing group should be selected by jurisdictional authority or NRC, not utility. (NB)
- 10. Introduction of new organizations would dilute INP0 and NRC efforts. (PSE&G)
- 11. NRC should recognize INP0's contribution in this area. (HL&P) i i
- 12. INP0 and ASME already perform independent audits by qualified personnel.
(NPEC) 1
- 13. Should have independent audits / inspections based on SAR commitments. ~ (USC)
)
~
14 '. INPO requirements satisfy this provision. (Duke Power) 1
- 15. INP0 efforts satisfy this provison. (BG&E) ..
- 16. INPO's efforts provide this function. (NIF)
- 17. INP0's efforts provide this function. (CEI)
- 18. INPO's CEP and NRC CAT inspections perform this function. (EEI)
- 19. INPO's programs' can provide this function. (ASME)
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f 18.b.4. Improvements in NRC
- 1. The NRC should provide an inspection staff of 25-30 inspectors for each plant under construction. (Jerry Girton) '
- 2. - Coninon thread in several (Zimmer, Midland, Salem, TMI-2, Crystal River) deficient plants; all were allowed Ly the NRC staff. (Marvin Lewis)
- 3. NRC must avoid backfits which are not' cost effective. -
(SOG&E)
- 4. Rather than assume current NRC practices have failed, strengthen current framework. NRC need only insist on proper performance based on an approved plan sincerely consnitted to. (SDG&E)
- 5. Large NRC imposed fines for (A violations are hidden in future rate in-creases, and therfore are not an incentive for improved performance. (SNSG)
~~
- 6. Legal mandate of NRC is solely to assure safety, doesn't permit NRC to consider financial or public relations impact on licensees. NRC does consider these things and this is the main roadblock to achieving desired -
quality. (SNSG) , '.
- 7. Have been serious breakdowns but no reason agencies' existing programs cannot be effective. (SNSG) m J -
j
~
- 8. NRC has not exercised sufficient control to prevent danger to public health and safety. (OCFRE)
- 9. Licen$ees have a very narrow definition of safety-related equipment and the NRC doesn't enforce QA requirements on non-safety-related equipment' -
which causes problems. (OCFRE)
- 10. Check implementation of QA programs and number of and qualifications of QA personnel. (OCFRE)
- 11. NRC must improve inspection / audit / enforcement efforts. (OCFRE) $)
- 12. NRC pro-nuclear mindset causes them to wear blinders. -(OCFRE)
- 13. ~
prevent revolving d.cor between industry and NRC, it increa.ses the. pro-nuclear mindset. (OCFRE)
- 14. NRC does not fully investigate allegations and complaints. '
' (OCFRE)
- 15. NRC should approve suppliers of nuclear components.
(ASC) 1
- 16. NRC should investigate use of " audit committees" similar to SEC Board of Directors of Audit' Committees. Audit committees would be preferable to more regulations. (D. ' Garland) .
17. NRC grants CPS and OLs based on-good intent, implementation is not checked. (NB) 18. NRC inspectors;are technical specialists with little QA knowledge and have problems relating findings to root causes. (FP&L) 19 Review current regulations, R.G.s, and national standards for current day applicability. '(FP&L) 20. NRC should improve analysis and consistency of inspections. (FP&L) O
- 21. ,
NRC puts too much emphasis on documentation and not enough on implementa-tion /protuct quality. (FP&L) 22. NRC puts.too much emphasis on procedures rather than on a quality productI (NPEC) 23. NRC should emphasize quality work and deemphasize paperwork. '(INP0) 24. Should improve NRC's modus operandi by using statistically valid sampling plans in inspections. (UCS) _ __ . w,m e. mm. e- ro** -Y
- 1
,_ . _ ~ .-- - . - -
t L h i I v
- 25. NRC should eli.3*nate exemption of commercial grade items from regulatory j requirements. NRC shouldn't restrict QA efforts to safety-related items.
[ (UCS) .
'26. ThestandardreviewplanfailstoprovidedefinitiveQhguidance. (UCS) !
P h
- 27. The NRC should perform independent audits of QA programs. (UCS)
I
- 28. NRC~ places too much emph'asi's on improving QA/QC and not enough on I l
product quality. (L. Gustafson) 2% V!
- 29. The NRC's after the fact actions reinforce the negative side of QA/QC.
The NRC has looked at programs, not , implementation. The NRC should con-I centrate on physical verification. ! The CAT program should be effective. ! (ANI) -
~* !
. l
- 30. Why was it the electrical contractor's inspector ' who discovered faulty
~
[ work, not the NRC's Resident Inspector? (ISAS)
- 31. Resident Inspectors should be responsible for assuring quality of con- l structio . (ISAS). !
- 32. Region III has'a p~oor enforcement history.
T (ISAS) .f *
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= - - ~ - -
- 34. Allegations are not properly investigated by the NRC. (SAFE)
~
- 35. NRC is part of the problem, look at cover ups at Zimmer and South
' Texas. (W. Eddleman)
- 36. Plans should provide for spot checks of implementation. (W. Eddleman) ,
- 37. NRC inspections of ol' der plants are necessary, especially during modifi-cations. (W.'Eddleman) .
() 38. NRC should assure design meets or exceeds NRC criteria, NRC should inspect to assure plants are built according to asign. (W. Eddleman)
- 39. NRC issued cps to utilities with deficient QA/QC programs. The NRC is not w'illing to deny cps or OLs. (W. Eddleman)
~
- 40. NRC should use ' statistically based sampling techniqur- (W. Eddleman)
~
- 41. NRC should inspect both safety-related and non-safety-related work.
(W. Eddleman)
- 42. If penalties are passed through to'the ratepayers they'have no impact.
3 (W. Eddleman) i s_2 *
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- 43. CAT inspections would be more useful if the NRC established and published _. ,
inspection and evaluation criteria. (EEI) e
- 44. NRC should perform more frequent and comprehensive audits. (S. Bullock) l
- 45. All quality personnel should report to NRC in some fashion. (S. Bullock) I
+
- 46. NRC inspectors seem to have trouble relating specific findings to QA [
program weaknesses. i NRC inspectors should have more QA training. (ASME). :
, . .. t
- I
- 47. NRC should provide more uniformity among its inspection personnel in the compilation of Codes, Standards, and QA requirements.
(ASME) f I # r s ** I 6 I I l e e
, , - , . . , .- , -, e r n - - , ,- ,-
~
13.b.5 Independent Inspectors 1. Conflict of interest exists because " independent inspectors" are paid by the utility. Some are guilty themselves of [commiting the] same defi-ciencies in the past that they are inspecting for. For the same reason the ACRS has conflict of interest. (MarvinLewis)
- 2. - Eliminate conflict of interest by using environmentalists as independent auditors and ACRS members. (Marvin Lewis) '
\ .
- 3. Use of " independent inspectors" must be viewed cautiously, as well as defining " independent." (SNSG) 4.
Independent auditor programs could provide additional assurance, but they ~ must not become an end in themselves with the NRC essentially reviewing the reviewers. (SNSG) 5. Independent auditors should be independent of the nuclear industry, not just the utility. (OCFRE) -
- 6. .
Independent auditors should be contracted to ,the NRC rather than the utility. (OCFRE)
,7. Utility should be required to contract for independent QA organization but it should be controlled by the NRC resident inspector. (L. Wilkie) o .
l' l 14
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- 8. There should be increased use of independent auditors and design reviewers. (D. Garland) i p
- 9. Conditioning CP.on independent audits would provide little improvement. !
(PSE&G) r
- 10. Improvements in audits should be through INPO, CATS, and utilities. '
(PSE&G) . L
- 11. Avoid unnecessary duplication when considering more independent inspec-tions. (HL&P) -
i
..J;
- 12. Don't need more independent inspectors.
(NPEC)
- 13. ~
With INPO, ASME, and NRC audits there are enough independent inspectors. (Duke Power) - ,
- 14. With INPO programs in place, don't need another layer of QA/QC. (BG&E)
- 15. INP0 provides independent i.1spector function. (AIF)
- 16. . As long as the licensee can fire QA auditors they are not independent. Should set up citizens panel to hire and fire QA personnel. (Marvin Lewis)-
Ltj 17. Inspection by independent inspectors is desirable. (ISAS) ~ w
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- 18. INPO provides this function. (CEI)
- 19. INPO provides this function. (EEI)
- 20. Because of current reporting chain - construction management - independence of QA function is often compromised. All quality personnel should report to NRC in some fashion.- (S. Bullock) e q
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l 1 13.c Pilot Program -s 1. Pilot programs are of questionable value because (a) people provide quality,
~
not programs and (b) each site is unique because of its people. (Townsend _ and Bottum)
- 2. Each project should be considered on its merits and not be compared to other projects. (TownsendandBottum) 3.
A few revoked cps would do more to emphasize need for better QA than any of the proposed pilot programs. (SNSG)
- 4. Should select more thar three plints, for pilot program. -(S&W)
) -_
- 5. 'NRC should perform a cost / benefit analysis prior to beginning pilot program. (Duke) 6.
Include Midland, Zimmer, South Texas, and Diablo Canyon in pilot program. (John O'Neill) >
- 7. Marble Hill should be part of the pilot program. (ISAS) 8.
Emphasis during pilot programs should be on quality control including training and qualification of' people. (EEI) 9 m
- v General Coments - QA/QC Related
- 1. Alarmed at abuse of drugs and alcohol on site. (Christine Simmers)
- 2. Three interrelated parties are responsible for assuring quality and reliabil--
ity:(a) ownsr/ licensee, (b) A/E, constructor, contractors, vendors, labor unions, and (c) NRC. (SDG&E)
- 3. Can achieve quality through:
, (a) formal commitment by top management, *
(b) training and indoctrination of all level management and craftsmen, (c) establish formal reliability engineering program, requiring use of scale models (see 13.b.1 also), (d) construction should not start until 50% of the engineering done and models are built and reviewed (see 13.b.1 also). (SDG&E) -
- 4. Quality consciousness dulled by needless complexity, rework and make work.
(SDG&E) ~
- 5. Congressional language borders on punative and adversarial, will prove e burdensome, counterproductive and of illusory benefit. (SDG&E) .
- 6. Quality not bad at all nuclear. plants. Excessive emphasis has been placed on a few bad examples. (SDG&E) l J
. . -. . .- . .. - .~ . ._ .
} ~
- 7. Problems in construction are too often called,QA/QC problems when they are really problems with designers, field engineers, craftsmen and craft super- -
vision. (Townsend and Bottum)
- 8. Basic cause of construction problem is people not QA program. (Townsend and Bottum)
- 9. Quality-would be better served by assuring competence of doers rather than over emphasis on competence of verifier.
Should require certification of management, designers, field engineers and crafts. (Townsend and
- Bottum) 4 4
i . -.
- 10. Should implement all five alternatives.
(OCFRE) J
- 11.. Financial health is importent and has an impact on QA.
, NRC should reinstate' its requirements for demonstration .of financial capabil.ity. (OCFRE) ,
- 12. FRN did not contain-specific proposals. These should be commented on, not '
l jest the Congressional Amendment. Studies should include a cost / benefit analysis. (HL&P) l 4
- 13.
Should publish preliminary res'ults of studies after 9-12 months for public , comment'. (Pl.) !
. 0 l
I ,
. r
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- 14. 'NRC should icok at recent NRC, INP0, and utility actions as a'whole, not just each small piece by itself. (HL&P)
- 15. ' NRC should state potential benefits of the study. (Hi.&P)
- 16. Provide incentive programs for craft workers to improve quality. (FP&L)
- 17. Base milestones on co~mpleted and accepted. work.
(FP&L)
- c. ,
- 18. Should have fewer equipment suppliers with better capabilities. (FP&L)
, 19. NRC should require more mandatory personnel qualification and requali- ~
fication. (FP&L)
. 2 0. Increases. in constructio'n costs are due to changes in requirements and --
inflexible, rigorous controls. (NPEC)
- 21. Provide tutorials on existing requirements, not new/more requirements. '
. (NPEC) ,
- 22. INPO's Construction Projects Evaluation (CPE) Program satisfies the Congressional mandate. (NPEC)
- 23. Increased QA requirements increase cost. (NPEC)
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- 24. Part 21 and Part 55(e) reporting requirements should be simplified and i . clarified, get rid of redundancy. (NPEC) _
- 25. All personnel from management down to craft workers shculd receive training in quality. (INPO) 26.
First line supervisors should be respons.ible for quality of work. (INP0)
- 27. ~QA organizations should have sufficient qualified personnel. (INPO) f Strongly support studies.
28. NRC should have given public draft of plan to accomplish studies'for comment.
.)
(UCS)
- 29. Improve QA by improving industry attitude. (AIF)
- 30. QA/QC programs adequate, implementation faulty (AIF)~. .
~
- 31. Requirements should be simplified, clarified and made consistent with each other. (AIF)
- 32. QA/QC is not always effectively utilized as a tool'by management. (ANI)
- 33. Managers other than.QA manager should be concerned about quality. (MAC)
.))
4 t
5-34 Qualifications of inspectors and quality engineers needs improvement. (MAC)
. 35. Management is not aware of what constitutes a good quality program. Quali-fications of management needs improvement. (MAC)
- 36. Financial burden causes hurried construction and resultant poor quality.
(SAFE) 37.. NRC should publish plan for satisfying Congressional Amendment for public - comment. (SAFE) 38. Not surprised NRC did n'ot publish plan for complying with CA, but they s,houl d. (W. Eddleman)
"39. P^ressures from proj.ect management and licensee management to reduce visibility of problem ,is overwhelming. (ScottBullock) 40.
The proposed studies fail to acknowledge that QA also depends on peoples . actions. There should be' stronger emphasis on indoctrination and training of personnel performing and managing activities affecting quality. Should improve motivation of workers to do quality work the first time. (ASME)
- L,/ .
1
. e
- ' ~
- 41. Reconnend stronger emphasis on moving more quality effort to the planning _ .
and performing function of attaining quality rather than to verification. (ASME)
- 42. Could improve quality by taking " human factor" into account. (Nancy Compton)-
~
- 43. Hard to trust quality of construction because of worker apathy and lack of motivation. (Nancy Compton)
. 44~. Need good role models in managers. (Nancy Compton)
- 45. Congressional Amendment doesn't provide enough guidance. Studies are being undertaken wi.thout identifying the problem they are. supposed to study. (S&W) i i
e h 0 l J
;> s Public Comments , ,
13.b.2 Demonstration of Management Capability Pros CapabHity to independently manage QA/QC should 2 utility be demonstrated C - 2 auditor 2 P.C. Cons-Perform.a cost / benefit analysis on requiring 1 utility a demonstration There are adequa'te provisions already in place 1 utility to evaluate management's capability 1 other Evaluation criteria should be flexible enough 1 utility to permit INPO to perform this function , The demonstration would unnecessarily res'trict . I utility the owner / licensee to managing the project O - themselves S 0 + O
+
-~y -a . . . .
'Public Comments , , ..
13.b.3 Evaluations by Organizations of Professionals - Pros
. Establish a requirement similar to ASME "N" Stamp 1 supplier for electrical equipment and eliminate utility audits- -
QA'prograns sho'uld have independent review groups, .. 1 P.C. would constitute independent design review ' Independent audits should be conducted at set stages 1 auditor of construction, 25%, 50%, 70% Independent auditing group should be selected by 1 auditor jurisdictional authority or NRC, not the utility . Should have independent audits based on PSAR 1 C.G. Cons INPO's programs already provide this function 4 utilities - 1 other I auditor -) INPO, ASME, National Board, and NRC programs 1 auditor. already provide this-function 1 other 2 utilities Additional layer of inspection will not solve the 1 utility problem -- Too many yearly audits already. Ratio of product costs I supplier to audit costs is way out of line. Audit frequency ' should be a function of product complexity - i 1 i
.- - e ..,y. -
y .- Public Comments Q - 18.b.4 Improvements in NRC r.
~
NRC puts too much emphasis on procedures and docu- 3 P.C., 2 C.G. mentation and not enough on implementation and 2 audit product quality 2 other
' ~
1 utility Although there have been serious problems overlooked 1 utility under current NRC programs, there is no reason 1 C.G. existing programs cannot be effective. NRC should concentrate on enforcing existing programs NRC should inspect both safety-relate'd and non- 1 P.C. safety-related work 2 C.G. NRC has not exercised sufficient control to. prevent 3 P.C. danger to public health and safety by assuring 5 C.G. quality of plant design and construction, should increase the number of resident inspectors to , 20-30 per site and should be responsible for plant quali ty
/~
. NRC fines are hidden in future rate increases and 1 P. C' .
not an. incentive for improved performance 1 C.G. NRC does not properly investigate or evaluate 2 C.G. allegations NRC should use statistically based sampling 1 P.C., 1 C.G. techniques The NRC has a pronuclear mindset which is sustained 2 C.G. by the constant flow of people between the industry and the NRC NRC inspectors are technical specialists with little 1 utility QA knowledge and have problems relating findings to 1 auditor QA program weaknesses - 1 % _Y 9 e
'Public Comments 13 b.5 Independent Inspectors ~_)
Independent inst ectors should be independent of 3 P.C. the nuclear industry, not just the utility, to 1 C.G.
, avoid <onflict of interest Ir. dependent ua~ ditors and Q personnel should report 2 P.C.
to the NRC/NRC Resident Inspector 1 C.G. Should increase the use of independent inspectors 2 C.G. 1 P.C. More independent inspectors won't solve the 1 other 4 problem 1 utility INP0 programs provide sufficient independent 3 utilities inspectors INPO, ASME, and NRC currently provide sufficient 3 utilities independent inspectors o Of O d __ A.
Classification of Comments Received on the Congressional' Amendment n .
- A. Private Citizens Christine Simmers,'MD Jerry Girton, IN
, f4rvin Lewis, PA L. H. Wilkie, Jr. , AZe - Daniel Garland, WA Nancy Compton, TN L. D. Gustafson, WA John' 0'Neill , MI Marvin Lewis, PA Wells Eddleman, NC Scott Bullock, NY S. Citizen Organizations Suffolk Nuclear Study Group (SNSG), NY Union of Concerned Scientists (UCS), DC Audobon Society, The Indiana Sassafras (ISAS). IN Sinnissippi Alliance for the Environment (SAFE), IL Ohio Citizens for Responsible Energy (OCFRE), OH
~
C. Utilities San Diego Gas and Electric (SDG&E), CA
~
Public Service Electric and Gas (PSG&E), f?J Houston Lighting and Power (HL&P) TX Florida Power and Light (FP&L), FL Duke Power Company, NC Baltimore Gas and Electric (BG&E), MD Cleveland Electric Illuminating Co. (CEI), OH -- Edison Electric Institute (EEI), DC
- D. 0A Auditors The National Board of Boiler and PV -Inspectors (NB), OH-Management Analysis Co (MAC) , CA INPO, GA _
American Nuclear Insurers (ANI), CN American S.ociety of Mechanical Engineers ( ASME), NY E. A/Es, Suppliers and Others Townsend & Bottum, Mi Automatic Switch Co (ASC), NY Stone and Webster (S&W), MA a
, . . Power Engineering Society of the IEEE (flPEC), PA AIF, DC e e
- g. S 6 w
4 DRAFT WORKING PAPER I Bibliography of Material Reviewed in Conjunction with Diablo Canyon Assessment-
- 1. Memorandum dtd 4-30-70, J. B. Denderson, Senior Construction Engineer (AEC) to J. P. O'Reilly, Chief Reactor Inspection and Enforcement Branch, "PG&E Company (Diablo Canyon) - Docket No. 50-323."
- 2. Memorandum dtd 5-13-70, A. D. Johnson, Reactor Inspector (AEC) to G. S. Spencer, Senior Reactor Inspector, "Diablo Canyon Unit No.
2, PG&E Company Docket No. 50-323."
- 3. Memorandum dtd 11-12-70, A. D. Johnson, Reactor Inspector (AEC) to G. S. Spencer, Senior Reactor Inspector, "Diablo Canyon Unit. No. 2, PG&E - Docket No. 50-323."
- 4. Memorandum dtd 6-5-73, W. G. Albert, Reactor Inspector (NRC) to G. S. Spencer, Chief, Reactor Construction and Operations Branch, "PG&E Company Report No. 050-0275/73-03."
- 5. Ltr dtd 11-19-81, Harold R. Denton, Director, Office of Nuclear Reactor Regulation, NRC, to Malcolm H. Furbush, Vice President and General Courisel, PG&E, "Diablo Canyon Unit No.1 - Independent Design Verification Programs."
( 6. Ltr dtd 4-22-82, Philip A. Crane, PG&E, to Harold R. Denton, Director, NRR-NRC, " Docket No. 50-275, and Docket No. 50-323. . ."
- 7. Memorandum dtd 10-13-82, W. J. Dircks to the Commissioners, "Diablo Canyon Design Verification Program - Phase II Recomendations," SECY-82-414.
~
- 8. Newsletter dtd 1-21-83, Diablo Canyon Project, PG&E Company /
Bechtel Power Corporation, to all Diablo Canyon Project Workers, "Get the Plant Ready for Fuel Loading by March 31..."
- 9. News Release dtd 3-25-83, NRC Office of Public Affairs, Washington, DC., No. 83-51, "NRC Considers License Application for Indiana Nuclear Plants: Provides Opportunity for Hearing."
- 10. Quality Assurance Manual Policy Rev. 7 dtd 12-03-79, " Quality Assurance Program Authorization."
- 11. Quality Assurance Manual Pc 'cy Rev. O dtd 02-09-81, " Quality Assurance Program Authorizr. tion."
;0/A-f4 @
W ITW0st!G M PAFER f l6
x DRAFT WQRKmG PAPER
- 12. Inspection Report NUREG-0862, Issue 1, ". Inspection Report of Seismic Related Errors ati Diablo Canyon Nuclear Power Plant, Units 1 and 2 Docket Nos. 50-275 and 50-323, License No.
CPPR-39, PG&E."
- 13. Inspection Report NUREG-0862, Issue 2, " Inspection Report of
' Preliminary Report, Seismic Reverification. Program' at Diablo Canyon Nuclear Power Plant, Units 1 and 2, Docket Nos. 50-275 and 50-323, License No. CPPR-39, PG&E."
- 14. Inspection Report NUREG-0862, Issue 3 "InspectiCn Report of
' Preliminary Report, Seismic Reverification Program' at Diablo Canyon Nuclear Power Plant, Units 1 and 2, Docket Nos. 50-275 and 50-323, License No. CPPR-39, PG&E."
- 15. Order Suspending License, CLI-81-30, In the Matter of PG&E Company Diablo Canyon Nuclear Power Plant, Unit 1, Docket No.
50-275.
- 16. Ltr dtd 03-01-82, Roger F. Reedy to Robert L. Cloud and Associates, Inc.. " Report of R. F. Reedy, Inc., Review of Cygna Energy Services (EES)." . . . " Quality Assurance Program Review Report Phase I, Seismic Safety-Related Design Services Performed for PG&E by Cygna Energy Services (EES) prior to June 1978, R. F. Reedy, Inc., Audit"
- 17. Ltr dtd 03-05-82, Roger F. Reedy to Robert L. Cloud and Associates, Inc. " Report of R. F. Reedy, Inc., Review of URS/
J. A. Blume and Associates Engineers, Quality Assurance Review and Audit Report Phase I By R. F. Reedy, Inc., on URS/J. A. Blume and Associates, Engineers, Seismic Safety-Related Design Services Performed for PG&E Prior to June 1,1978."
- 18. Ltr dtd 03-01-82, Roger L. Reedy to Robert L. Cloud and Associates, Inc. ," Report of R. F. Reedy, Inc., Review of Anco Engineers (formerly Applied Mechanics, Inc.) Quality Assurance Review Report Phase I Seismic Safety-Related Design Services Performed for PG&E by Anco Engineers prior to June 1978."
- 19. Nuclear Regulatory Connission Docket No. 50-275, Low Power Proceeding) in the Matter of PG&E Company (Diablo Canyon Nuclear Power Plant, Unit No.1) - Affadavit of Warren A. Raymond, Charles W. Dicks, and Michael J. Jacobson."
- 20. Ltr dtd 12-04-81, Malcolm H. Furbush to Harold R. Denton, Docket No. 50-275 License No. DPR-76, Diablo Canyon Unit No.1.
[ includes enclosure 1, " Qualification of Companies Proposed to Conduct Independent Reviews," and enclosure 2. " Design */erifica-tion Program Seismic Service Related Contracts prior to June 1978"] SRAFT WORKWG PAPER
DRAR WORKINS PAPER
- 21. Report dtd 10-21-81, R. L. C1'oud to J. Rocca, Chief Mechanical Engineer, PG&E, "A Preliminary Report on the Design Interface Review of the Seismic Reverification Program."
- 22. Ltr dtd 03-08-82, Roger F. Reedy to R. L. Cloud and Associates, Inc., Report of R. F. Reedy, Inc., " Quality Assurance Audit and Review Report of PG&E Company."
- 23. Ltr dtd 11-10-82, P. A. Crane, Jr., to S. S. Chilk, Secretary of the Comission, i'RC, Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1. "Coments by PG&E on October 20, 1982, NRC Staff Briefing to the Comissioners," and SECY 414.
- 24. Ltr dtd 04-06-83, M. H. Furbush to H. R. Denton, NRR-NRC, "Overal_1 Management Plan for Design Verification Program of the Diablo Canyon Power Plant, Rev.1," dtd 4/6/82.
- 25. PG&E Company's coments on the R. F. Reeay, Inc. Quality Assurance Audit Report on Safety-Related Activities performed by PG&E prior to June 1978.
- 26. Ltr dtd 08/24/82, R. L. Cloud to Dr. Nunzio Palladino, Chairman, U. S. Nuclear Regulatory Comission, concerning allegations that PG&E edited the " Preliminary Report, Seismic Verification Program,"
prepared by R. L. Cloud and Associates, Inc., to make the report ( more favorable to them.
- 27. NRC Docket No. 50-275 (Low Power Proceeding) in the Matter of PG&E Company Diablo Canyon Nuclear Power Plant, Unit No. 1, Before the Atomic Safety and Licensing Board, " Response of PG&E Company to Joint Intervenors' Motion to Reopen the Record." .
- 28. Ltr dtd 08-13-82, P. A. Crane to F. J. Miraglia, Jr., Chief, Licensing Branch No. 3., Division of Licensing, NRC, " Docket No.
50-275, OLD-PR-76 and Docket No. 50-323, Diablo Canyon Units 1 and 2 Project Quality Assurance Program."
- 29. Memorandum dtd 08-24-82, W. J. Dircks to Chairman Palladino and the Comissioners, "Diablo Canyon Design Verification Program."
- 30. Ltr dtd 02-10-92, S. J. Chilk to the Comissioners, " Docket No.
50-275 and 50-323 0. L., In the Matter of PG&E Company, Statement of the Comission." DRMT WORKiEG PAPER
DRAFT WORKING PAPER'
- 31. Memorandum, K..S. Herring, Systematic Evaluation Program Bruch, Division of Licensing NRR to Frank Miraglia, Chief Licensing Branch 3. Divisica, of Licensing, NRR, " Trip Report Review of URS/Blume Hosgri Analyses of:
the Diablo Canyon Auxiliary Butiding, Intake Structure Containment Polar Crane and Containment Annulus."
- 32. Nuclear Regulatory Commission, Docket No. 50-275 (Low Power Proceeding) before the Atomic Safety and Licensing Appeal Board in the matter of PG&E Company, affidavitt of Richard S. Bain responding to allegations of an inferred " breakdown" of quality assurance and quality control in construction at Diablo Canyon.
- 33. Nuclear Regualtory Commission, Docket No. 50-275 (Low Power Proceding) in the Matter of PG&E Company Affidavitt of R. C. Anderson, J. B. Hock, G. H. Moore, M. R. Tresler, W. H. White - Related to PG&E Notification of NRC on Seismic Problems.
- 34. Memorandum dated 9-10-1982, P. J. Morrill, Reactor Inspector to J. L.
Crews, Director, Division of Resident Reactor Projects and Engineering Programs, " Region V Inspection Activities Open Issues Related to the Diablo Canyon Reverification Program." (.
- 35. Memorandum dated September 24, 1982 T. W. Bishop, Chief, Rapetor Projects Branch No. 2 to D. G. Eisenhut, Director, Division of Licensing,
" Summary States of Region V Diablo Canyon Action Items."
- 36. Memorandum dated September 9,1982, D. F. Kirsch, Chief, Reactor Project Section No. 3 to J. L. Crews, Director, Division of Resident; Reactor Projects and Engineering Programs, " Region V Inspection Activities Related to the Diablo Canyon Reverification Program."
- 37. Letter, Richard C. DeYoung Director Office of Inspection and Enforcement to Pacific Gas and Electric Company, Docket No. 50-275, License No.
DPR-76 EA 81-13, "Special Inspection by NRC Region V Office on October 14-23, 1381."
- 38. Letter dated 11-5-1982, T. W. Bishop, Chief Reactor Project Branch No.
2 to P. A. Crane Jr. PG&E Assistant General Counsel, " Inspector Report."
- 39. Memorandum dated November 9,1982, R. H. Engelken, Regional Administrator Region V from Harold R. Denton, Director OPPfee eP Mueleer Reae>
Regulation, "Diablo Canyon Design Verification Program." l ! DRMT WestHG PAPER l
drift WORKING papgg i
- 40. Memorandum dtd 11-17-82, D. G. Eisenhut, Director, Division of Licensing, to H. R. Denton, Director, NRR-NRC, "IDVP Potential Conf?ict of Interest."
- 41. Memorandum from W. J. Dircks, Executive Director for Operationsg" Diab.lg Canyon Design Verification Program - Phase II Recomendations," $Ecr 22414,
- 42. Memorandum dated 8-31-1982, T. W. Bishop to J. L. Crews, " Independent Verification of Diablo Canyon Construction Quality Assurance Programs."
- 43. Letter dated 8-2-1982 Darrell G. Eisenhut to P. A. Crane of PG8E Company, "QA Program for Diablo Canyon Project."
- 44. Memorandum dated 1C 28-1981 T. W. Bishop to J. L. Crews " Review of NRC: IE Programmatic Inspections for Design During the Period of Diablo Canyon Unit 1 Construction."
- 45. Letter dated 12-6-1982 W. E. Cooper Teledyne Engineering Services, "IDVP Concurrence with PG&E Request for Restoration of Low Power License and Stepwise Licensing Schedule to Full Power."
(
- 46. Letter dated 2-1-1982, Nunzio J. Palladino to J. D. Dingell, Chainnan Ccamittee on Energy and Coimarce United States House of Representatives,
" Order Suspending License."
- 47. Ltr dtd 2-12-82, Paul H. Anderson and Edward T. Deni:;on to U. S.
NRC Region V, ATTN: Mr. Faulkenberry. 6I i
g lich > th .#uf o Document Name: , .gj NOTES FROM DIABLO CANYON ,, ,f ul6..f " DitAFT Requestor's ID: 90iDupo nprit KAREN Author's Name: Bill Altman Document Comments: 1/28/83 NOTES FROM DIABLO CANYON CASE STUDY m WN2 Fo/A - r1.- 293 am maannra Ffe t- \
DRAFT
' WORKD8G PAPET Draft Working Paper 1/28/83 Notes on Diablo Canyon Case Study (Notes Preliminary and Not Complete)
(Str sm of Consciousness on Airplane) I I. Problem A. General Sloppy control of design changes, design documents, drawings B. Mirror Image Problem Informal manner in which certain data were developed by PG&E and l transmitted to URS/Blume i Lack of independent review of these data within PG&E pri,or to sub-mittal to URS/Blume II. Causes A. Lack of Procedures / Control in the Engr./ Design Process Informal working arrangement with Blume - did not have very tight controls over documents transmitted to Blume Why - Lack of formal quality program on'the engr / design activities associated with D.C. project.~
- Didn't seem to have this problem with construction - on construction had tighter control On construction a quality program was instituted in early 70's - 10 CFR Appendix B came out in 1968 - became effective in 1970.
- The region applied Appendix B type criteria to D. C.
construction activities, including contractors starting
- before Appendix B became effective.
- However the region did not apply the same set of quality standards to engr / design -
Why Not? ,
" Didn't really think they needed
- - We " trusted" the engrs.
same level of scrutiny.
~
l DP.A77 E M M PAPZt _ - _ _ _ _ _ _ _ _ _ _ _ _ = _ - _ _ _ .
DitAFT WOP. KING PAPi:R
- Appendix B interpretations varied widely. No good guidance -
on it from AEC. While Appendix B had criteria covering design control, Appendix B was generally regarded as applying to construction activities, not design engr activities.
- Constr an easier activity to impose procedure controls (quality requirments) on. Easier to . inspect a weld, placement of concrete, etc. - doesn't take too much training. Howe'ver, quality control / assurance applied to engr / design is not an easy trick. Taken to extreme, it essentially requires skilled work to be done twice (to overcheck an engineering calculation may require it to be redone - takes another engineer of comparable quali-fications). [ Fundamental difference in QA/QC for manual type work and professional work - to inspect manual often requries only a look; to inspect professional may involve separate performance of the same task.]
- This a problem f'or several reasons: (1) Engineer considers himself a, professional, resents being overchecked. Leads to a less his. work./ning of degree (2) Theory X workofrule responsibility on Theory Yengr feels for person.
(3)-Second engr finds overcheck work boring. (4)Not cost effective. Point is not that there should be no overcheck or controls over engr./ design. Howeve g problem is less straight fomard, more difficult thyn with crafts and requires more thinking to set up a system that works.
- Also requires more of a push from the top. Craftsmen have less clout than engrs., less power in organization than engrs. So harder for them to resist.
- Also engrs. are professionals. Resent imposition of controls -
feel it is a little degrading. Theory Y person in Theory X setting.
- Also at PG&E very strong engr. group. Company proud of it.
Did much of their own engeering. Powerful politically in company. . Prima donna group. A new quality group such as was set up in early 70's would be no match for engineers.
- 'PG&E had to impose Appendix B somewhere. Constr. the
~
obvi'ou's71 ace to do it (and ops at Humboldt).
- QA for Design / engr. fell through the cracks.
DRAFT WOTJCING PAPj;g .
f DRA7T
~
WORKING P/?It
- Engr. and engr. contractors used " good engr practices" in lieu of documented quality program at least through 1978 time frame (and then it appears that PG&E engr. contractors had a better program than PG&E did)..
III. Other Causes A. AEC AEC worked on QA criteria .in 1968-70 time frame. Public comments, etc. Became effective in 1970. Criteria very general . Everyone
~
(in-and out of AEC) had different interpretation of what they meant. No good clear guidance on what they meant or what an acceptable program was. Pressure from AEC HQ was that everyone would have a program. Emphasis on getting a manual written. Sort of as if having a manual meant you had a program. AEC forced QA on licensees. Was not sold, was jauned .down their throats. Was not presented as management tool that would help, that could be tailored to suit needs of individual licensees. Rather presented an ultimatum. AEC failed to demonstrate or convince or try to convince that it could be useful as a management tool. Rather AEC, and consequently the licenses, treated it as another requirement. Emphasis of AEC on establishment of QA organization and failure to sell it as management tool, led licensees (and AEC to some extent) to believe that having an organization (and a manual) satisfied the requirement. Both AEC (especiall seemed to lose sight of the overall objective (y HQ) and understandable licensee since AEC doesn't seem to have clearly communicated it) and focused on the image of a program. Tended to view establishment of organization and manual as the end, rather than the means Management (of anything) naturally reluctant to embrace a quality program, under best of circumstances. Takes time, selling, good people (see Crosby's book). AEC approach exacerbated this problem. Good example of exactly the wrong way to do it. This led to even deeper mistrust of quality program than would /4 nomally be the case. Led to assignment of " slugs" to QA. Mg U didn't believe in it and they were not going to assign stars'to work in it. This creates self fulfilling prophecy - you don't think much of QA, don't think it can do much for you. So you put slugs in QA, and they deliver exactly what you expected - nothing useful. H ! wm n:uuamm i ~ _
~
DRAFT WORKING PAPER B. PG&E QA Program In case of PG&E, efforts were made to comply with QA rqmts in constr. Programs'were set up for Humboldt and Diablo. Utility picked as QA mgr someone who would not rock boat. Regional insp reports indicate he found some problens, would not elevate them. Wanted AEC to do. that for him. Described as one who had to be dragged to 32nd floor (mahagony row) Original QA manager replaced by real burner in 71 or 72. Real burner lasted 1-li years (promoted ?) out to head Geothermal group. Not clear why he left so soon. Possibly rocked boat, offended people, )/ possibly pursued quality too agressively (to be checked out) Next QA mgr appointed in 72 or so. Out of ops at Humboldt. Fits stereotype of QA manager still head of PG&E QA. Insp reports show no real problems 'with constr QA over years. Region pretty high on. quality of work done there. Good quality seems to have been achieved in constr. Attainment of this quality seems to go deeper than QA program, that is, PG&E had the other things in place needed to achieve quality. . Indeed QA program seems to have not been very agressive program over the years. C. Long Period of Construction (Issued raised by PG&E as contributor to their troubles. Below reflects licensee input) CP in 68 First concrete in 68-69 Hot functional completed December 75 - January 76 Plant ready to go January 76. Plant same generation as Trojan (constr started before Trojan) Plant has had one set back after another, causing startup to be delayed and constr retrofits to be extended Long period 68-83 (15) greatly increases exposure time to changing rqmts and changing state of art
.Very difficult for plant designed with assumptions and technology valid in 68 to. stared up tc rigorous scrutiny when looked at through
- - 83 glasses eei,,
WORXING PAPER
. . .=.
IE E PT WORKING PAPER Many different rqmts now. Many changes taken place over 15 year period of constr Appendix B in 70 Hosgri in 76 Browns Ferry retrofits TMI (were ready to load fuel in April 79, caugt by TMI moratorium) Mirror image 81 - IDVP 82-83
~
Plant generally close enough to license (felt themselves close enough) that they agreed to whatever new thing or ratchet the AEC wanted - figured it would be shorter in long run th.an fighting AEC/NRC. Bend over an'd assume your position syndrome. In.~several. cases this rolling over has been, in retrospect, very costly. The Hosgri issue in 76 cost 7 years and $1 billion. From a technical viewpoint, they probably could have beat Hosgri - they arugue the max credible earthquake is 6.5, not 7.5. - Vic stuck them with 2 man rule in vital areas-when he was still with NRR. They committed to more than is necessary. Still paying for'it - security access controls in place now major hindrance to efficient construction work. Since they were always not quite to their license, AEC/NRC could ask for more in the rachets. Little easier to lay som' thing e on plant "still in constr" than on one in operation. As indicated above, licensee always willing to jump through that one last hoop, indeed to do anything, to get the license. Improved state of art in seismic hurt tremendously. Seismic state of art still very iffy, depends on model, assumptions, etc. However, sophistication of postulation of problem, analysis, etc., is now much advanced over 1966-68, when PG&E got into wit 'ith Diabl6. They used the best expert available, and did analysis at state of art the . State of art changed, they still didn't have license, so they had olt design and assumptions reanalysed under new set of rules. No way they can win in such a situation. Problem caused in part by long exposure time (15 years now). ~ Moreover, the longer the exposure the greater the chance something else will come along. For example, Hosgri, Browns Ferry, THI, annulus drawings. Moral: if you can't get a plant built and licensed in 6 years or less, you expose yourself to more and more events and changes in rqmts and ~ technology. The . longer you take, the greater the chance you will be tripped by something unforeseen (rules of game change) and the longer you will have to take. Going beyond a certain point on the licensing time line, .the time till licensing function seems to grow rather than shrink. [Above reflects licensee position.]
~-
. f?v:,,,,
~
W P.V.K U C PfJ T g
? wryg
- 170RXING PAPER IV. Thoughts / Hypothesis to be Explored A. Experienced Personnel Stretched Thin Proliferation of plant orders in late 60's -early 70's had to have sapped available pool of qualified people to set up and manage these projects. May be contributing factor to spate of problem plants (along with and exacerbating problem of inexper util getting in over their heads). Harold to look into availability.of data on this issue (how many qualified people, etc.).
B. Utility Mentality and High Technology Utilities very conservative businesses by nature. Executives rise up thru the ranks, take over when they have 25 years of utility mentality under their belt. Not going to rock the boat. Basically monopolies, fall-somewhere between govt agencies and real world in terms of making profit, taking risk. Great deal of inertia to stay the course. Probably one of the worst industries to take up a new technology which by its nature has inherent risks. Utilities naturally brought fossil mentality (" utility mentality") to nuclear power - just as they bring it to everything they do. s C. Corporate Senility in General Factor in idea of corporate senility. Five percent. innovate at bottom, five percent vested interest at top, thirty percent don't care, rest of elephant just moves along. Dick to develop idea. D. Utility Mentality and Quality 1 Given that utilities brought utility mentality to nuclear power, they certainly brought utility mentality to quality and formalized AEC mandated (see section on AEC) QA program. Not an environment conducive to the growth and prospering of quality in nuclear power, of quality programs or of the quality idea as a management tool. E. Long Period of Time Followup stumble (Coach Harold says:an ideascore if you can't that long period ofinconstr a touchdown 14 makes on or 15 plays you probably won't - you will fumble, be intercepted, etc.). Another aspect of this (in addition to long exposure making you vulnerable to mor.e events, changing rqmts, and changing state '
,- ofart)is: the longer it takes, the harder it is to hold a unified project team together - people get promoted, move on, etc. This exacerbates the design and design control problem - no one is around who remembers all the original assumptions or the way they approached things then. Changes 'get made, checked back only so far, and something falls thru cracks. Dick to followup on this point.
MMNiiBitWtitte-war 170P;trNG PArzg
. - - , . ~ ,. . _ , m. - - - - -
- DPJLFT WORKINGFJGU2t F. Short Period of Time We also should look at it from other direction: How does short period of time from start to on line help? Have pretty much the same project team, fewer changes in technology and rqmts. PG&E Chairman very interested in our looking at this as part of LTR (esp in foreign countries). Bechtel is building plants in Japan in 4 years now.
Japan has one step licensing. How well is that working? Seems retaining the right to refuse the OL gives NRC leverage it may need in some cases. Given that the pros of 2 step licensing (CP & OL) may out-weigh the ' cons, how about some modification that lessons the time impact. Maybe only have hearings routinely for CP and cut them out of OL licenisng process except in extraordinary circumstances. Dick to look at this i.n conjunction with E. G. IDVP a Two Edged Sword The rules under which the Diablo Canyon IDVPs are being conducted are not very conducive to'the efficient or effective identifying and resolving of technical issues. The rules permit no contact between the PG&E or contractor engrs responsible for some piece of design work and the IDVP reviewer except in.public, in front 'of NRC and the intervenors. Many minor questions which could be resolved thru more informal staff contact are raised, through this process, to a level of importance not justified by their technical merits. Moreover, the rules of intercourse, which put engineers on the stand across from each other, lead to a confrontational, not a scientific, exchange. This is grist for the mills of intervenors and the press. A senior Bechtel engineer told us that if this (IDVP played under these rules) was to be a requirement for the future, no - one, regardless of other problems with nuclear power, would build one (another reactor) in the future. / O e em a we 1. 9 DFJJr WO.".XIRG PAPA
Document Name: ,, NOTES FROM DIABLO CANYON ZEAF1'
. Requestor's ID: foaxIpo nyta KAREN Author's Name:
Bill Altman Document Comments: 1/28/83 NOTES FROM DIABLO CANYON CASE STUDY f i 1 b l h W d Y p--
. .. .. .... m .. . , , ,
i wannsanra ,
- . .. . _m
.~ WORKD3G PAPE Draft Working Paper 1/28/83 !!otes on Diablo Canyon Case Study (flotes Preliminary and Not Complete)
(Stream of Consciousness on Airplane) I. Problem A. General x~ W 4h rY" Sicppy control of design changes, design documents, drawings a B. Mirror Image Problem , Infonnal manner in which certain data were developed 'by PG&E and transmitted to'URS/Blume Lack of independent review of these data within PG&E prior to.sub.- mittal to URS/Blume
,y wpM,Aevi%a a M WgsB"% b N- hO "' 'W II. Causes .
A. . Lack of Procedures / Control in the Engr./ Design Process Informal working arrangement with Blume - did not have very tight controls over documents transmitted to Blume Why - Lack of formal quality program on 'the engr / design activities associated with D.C. project.-
- Didn't seem to have this problem with construction - on construction had tighter control On construction a quality program was instituted in early 70's - 10 CFR Appendix B came out in 1968 - became effective in 1970.
- The region applied Appendix B type criteria to D. C.
construction activities, including contractors starting before App Aee. (endix Hob B became effective. However th]e region did not apply the same set of quality ~ standards to engr / design - Why Not? ,
#- - - We " trusted" the engrs. Didn't really think they needed same level of scrutiny.
.g u ccm pc.u.nu
,- na, am u -.nh urigir++:p
~
DP.A7T .
@ & G NG PLP13 -
IRAFT WORKING PArza
- Appendix B interpretations varied widely. No good guidance -
on it from AEC. While Appendix B had criteria covering M . design control, Appendic =B=was gencr;'y reganded-as M e <~- applying to construction activities, not design engr activities. .
- Constr an easier activity to impose procedure controls (quality requirments) on. Easier to inspect a weld, placement of concrete, etc. - doesn't take too much training. However, quality control / assurance applied to engr / design is not an easy trick. Taken to extreme, it essentially requi_r es skilled work to be done twice (to overcheck an engineering calculation may require it to be redone - takes another engineer of comparable quali-fications). [ Fundamental difference in QA/QC for manual type work and professional work - to inspect manual often requries only a look; to inspect professional may involve separate performance of the same task.]
- This a problem 'for several reasons: (1) Engineer considers himself a professional, resents being overchecked. Leads
- to a lessyning of degree of responsibility engr feels for his. work. (2) Theory X work rule on Theory Y person.
(3)-Second engr finds overcheck work boring. (4) Not cost effective.
- Point is not that there shouldg no overcheck or controls over engr./ design. However,Arablem is less straight forward, more difficult thph with crafts and requires more thinking to set up a system that works.
- Also requires more of a push from the top. Craftsmen have less clout than engrs., less power in organization than engrs. So harder for them to resist.
- Also engrs, are professionals. Resent imposition of controls -
feel it is a little degrading. Theory Y person in Theory X setting.
- Also at PG&E very strong engr. group. Company proud of'it.
Did much of their own engeering. Powerful politically in' .' company. Prima donna group. A new quality group such as was set up in early 70's would be no match for engineers.
- PG&E had to. impose App 5ndix B somewhere. Constr. the obviws Place to do it (and ops at Humboldt).
- - QA for Design / engr. fell through the cracks.
, _in
%wpn nrmimf airnnN$h$
vn DRAFT WORKINGPArgg
- EAFT WORKniGP;2 2
- Engr. and engr. contractors used " good. engr practices" in lieu of documented quality program at least through 1978 time frame (and then it appears that PG&E engr. contractors had a better program than PG&E did).
III. Other Causes A. AEC AEC worked on QA criteria in 1968-70 time frame. Public comments, etc. Became effective in 1970. Criteria very general . Everyone (in and out of AEC) had different interpretation of what they meant. No good clear guidance on what they meant or what an acceptable program was. Pressure from AEC HQ was that everyone would have a program. Emphasis on getting a manual written. Sort of as if having a manual meant you had a program. AEC forced QA on licensees. Was not sold, was jamed ,down their ~ throats. Was not presented as management tool that would help, that
~
could be tailored to suit needs of individual licensees. Rather presented an ultimatum. AEC failed to demonstrate or convince or try to convince that it could be useful as a management tool. Rather AEC, and consequently the licenses, treated it as.another requirement. Emphasis of AEC on establishment of QA organization and failure to sell it as management tool, led licensees (and AEC to some extent) to believe that having an organization (and a manual) satisfied the requirement. Both AEC (especially HQ) and licensee seemed to lose sight of the overall objective (ur.derstandable since AEC doesn't seem to have clearly communicated it) and focused on the image of a program. Tended to view establishment of organization and manual as the end, rather than the means Management (of anything) naturally reluctant to embrace a quality program, under best of circumstances. Takes time, selling, good people (see Crosby's book). AEC approach exacerbated this problem. Good example of exactly the wrong way to do it. . This led to even deeper mistrust of quality program than would nonnally be the case. Led to assignment of " slugs" to QA. Mgmt
- didn't believe in it and they were not going to assign stars to work in it. This creates self fulfilling prophecy - you don't think much of QA, don't think it can do much for you. So you put slugs in QA, and they deliver exactly what you expected - nothing useful.
E.kN
- 170 C E.U !C- Fl y .
~
f:.. , . - ? DRAFT WORKING PAPE B. PG&E QA Program In case of PG&E, efforts were made to comply with QA rqmts in constr. Programs were set up for Humboldt and Diablo. Utility picked as QA mgr someone who would not rock boat. Regional insp reports indicate he found some problems, would not elevate them. Wanted AEC to do.that for him. Described as one who had to be dragged to 32nd floor (mahagony row) , Original QA manager replaced by real burner in 71 or 72. Real burner lasted 1-11 years (promoted ?) out to head Geothermal grono. Not , clear why he left so soon. Possibly rocked boat, offend (3 leople, possibly pursued quality too agressively (to be checked on j Next QA mgr appointed in 72 or so. Out of ops at Humboldt. Fits ' stereotype of QA manager still head of PG&E QA. . Insp reports show no real problems 'with constr QA over years. Region pretty high on quality of work done there. Good quality seems to have been. achieved in constr. Attainment of this quality seems to
~
go deeper than QA program, that is, PG&E had the other things in place needed to achieve quality. . Indee'd QA program seems to have : not been very agressive program over the years. C. Long Period of Construction (Issuediaised by PG&E as contributor to their troubles. Below reflects licensee input) CP in 68 First concrete in 68-69 . Hot functional completed December 75 - January 76 Plant ready to go January 76. Plant same generation as Trojan (constr started before Trojan) Plant has had one set back after another, causing startup to be , delayed and constr retrofits to be extended Long period 68-83 (15) greatly increases exposure time to changing rqmts and changing state of art Very difficult for plant designed with assumptions and technology valid in 68 to- s-tared up to rigorous scrutiny when looked at through
= 83 glasses mm WORKING PAPS
IP. AFT d CORKINGPt2Dt Many different rqmts now. Many changes taken place over 15 year
. period of constr Appendix B in 70 Hosgri in 76 Browns Ferry retrofits TMI (were ready to load fuel in April 79, .caugt by TMI moratorium) ~
Mirror.. image 81 - IDVP 82-83 Plant generally close enough to license (felt themselves close enough) that they agreed- to whatever new thing or ratchet the AEC wanted - figured 1.t would be shorter in long run th.an fighting AEC/NRC. Bend over an'd assume your position syndrome. In several cases this rolling over has been, in retrospect, very costly. The Hosgri issue in 76 cost 7 years and $1 billion. From a technical viewpoint, they probably could have beat _Hosgri - they arugue the max credible earthquake is 6.5, not 7.5. Vic stuck them with 2 man rule in vital areas when he was still with NRR. They committed to more than is necessary. Still paying for it - security access controls in place now major hindrance to efficient construction work. Since they were always not quite to their license, AEC/NRC could ask for more in the rachets. Little easier to lay something on plant "still in constr" than on one in operation. As indicated above,
' licensee always willing to jump through that.one last hoop, indeed to do anything, to get the license.
Improved state of art in seismic hurt tremendously. Seismic state of art still very iffy, depends on model, assumpt. ions, etc. However, sophistication of postulation of problem, analysis, etc., is now much advanced over 1966-68, when PG&E got into itw ' ith Diablo. They-used the best expert available, and did analysis at state of art then. State of art changed, they still didn't have license, so they had old design and assumptions reanalysed under new set of rules. No way they can win in such a situation. Problem caused in part by long exposure time (15yearsnow). Moreover, the longer the exposure the greater the chance something else will come along. For example, Hosgri, Browns Ferry, TMI, annulus drawings. - Moral: if you can't get a plant built and licensed in 6 years or less, you expose yourself to more and more events and changes in rqmts and technology. The_ longer you take, the greater the chance you will be tripped by something unforeseen (rules of game change) and the longer you will have to take. Going beyond a certain point on the licensing time line, the time till licensing function seems to grow rather than shrihk. , [Above reflects licensee position.] W n$ 5!.$$ IF.Gr C3E:CHG ?f1zg
}- *
. ' IEAFr *
. WORXING PAP 3 IV. Thoughts / Hypothesis to be Explored A. Experienced Personnel Stretched Thin Proliferation of plant orders in late 60's -early 70's had to have '
sapped available pool of qualified people to set up and manage these-projects. May be contributing factor to spate of problen plants (along with and exacerbating problem of inexper util getting in over theirheads). Harold to look into availability of data on this issue (how many qualified people, etc.). B. Utility Mentality and High Technology Utilities very conservative businesses by nature. Executives rise
~
up thru the ranks, take over when they hava 25 years of utility mentality under their belt. Not going to rock the boat. Basically monopolies, fall somewhere between govt agencies and real world in terms of making profit, taking risk. Great deal of inertia to stay the course. Probably one of the worst industries to take up a new technology which by its nature has inherent risks. Utilities naturally brought fossil mentality (" utility mentality") to nuclear power - just as they bring it to everything they do. C. Corporate Senility in General Factor in idea of corporate senility. Five percent innovate at- bottom, five percent vested interest at top, thirty percent don't care, rest of elephant just moves along. Dick to develop idea, t D. Utility Mentality and Quality Given that utilities brought utility mentality to nuclear power, they certainly brought utility mentality to quality and formalized AEC mandated (see section on AEC) QA program. .Not an environment conducive to the growth and prospering of quality in nuclear power, of quality programs or of the quality idea as a management tool. E. Long Period of Time Followup (an idea stumble Coach that Harold longifperiod says: ~ ofscore you can't constr makes oneinmore a touchdown 14 likely to or 15 plays you probably won't - you will fumble, be intercepted, etc.). Another aspect of this (in addition to long exposure making you vulnerable to mor.e events, changing rqmts, and changing state ofart)is: the longer it takes, the harder it is to hold a unified project team together - people ~get promoted, move on, etc. This
- exacerbates the design and design ~ control problem - no one is around who remembers all the ori.ginal assumptions or the way they approached things then. Changes'get made, checked back only so'far, and something falls thru cracks. Dick to followup on this point.
l WOP,x:nr3 PAPIit
c__r. ,._ _ - _ . . , .,,,_.-m,. -
. 3 ,.
,m . DRAFT WORKING FAPE
~ .
F. Short Period of Time We also should look at it from other direction: How does short period of time from. start to on line help? Have pretty much the same project team, fewer changes in technology and rqmts. PG&E Chairman very interested in our looking at this as part of LTR (esp in foreign countries). Bechtel is buildingHow plants in Japan in 4 years now. well is that working? Seems Japan has one step licensing. retaining the right to refuse the OL gives NRC leverage it may need in some cases. Given.that the pros of 2-step licensing (CP & OL) may out-weigh the cons, how about some modification that lessons the time impact. Maybe only have hearings routinely for CP and cut them out of OL licenisng process except in extraordinary circumstances. Dick to look at this in conjunction with E. G. IDVP a Two Edged Sword The rules under which the Diablo Canyon IDVPs are being conducted are not very conducive to the efficient or effective identifying . and resolving of technical issues. The rules permit no contact between the PG&E or contractor engrs responsible for some piece of design work and the IDVP reviewer except in public, in front of HRC and the intervenors. Many minor questions which could be resolved thru more informal staff contact are, raised, through this
' process, to a level of importance not justified by their technical merits. Moreover, the rules of intercourse, which put engineers on the stand across from each other, lead to a confrontational, not a scientific, exchange. This is grist for the mills of intervenors and the press. -A senior Bechtel engineer told us that if this (IDVP played under these rules) was to be a requirement for the future, no one, regardless of other problems with nuclear pow e~ r, would build one (another reactor) in the future.
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PACIFIC GAS AND ELECTRIC COMPANY 1 BECHTEL POWER CORPORATION n:p** 8
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L- . f.~ k ^ S_ T0: ALL DIABLO CANYON PROJECT WORKERS ~ Nggg7 GET THE PLANT READY FOR FUEL LOADING BY MARCH 31. THAT MEANS PHYSICAL WORK REQUIRED FOR FUEL LOAD "G0 AHEAD" MUST COMPLETE MID-MARCH S0 THE PAPER WORK HAS 2 WEEKS TO WRAP UP. Most work in the containment,_some pipe supports outside containment, and all electrical support modifications, are required for fuel load. We estimate the craft manpower will reach about 1300 to do it. There will be more infor-mation soon about our other Unit I milestone goals and Unit II work schedule. So we have embarked on the most ambitious and exciting construction period to date at Diablo Canyon, it is clear that we are going to have to all pull to-gether. We know that rumors have been abundant and things have been changing so fast that keeping up with it all is very difficult. You know that things are changing fast, when rumors last four hours not four days. We may have to start.a contest to see who has the best rumor. However, things are at a point where we can . finally see the work ahead of us, and I would like to take this opportunity to brief and enlighten and update everyone on this most ambitious ~ and exciting of undertakings. Here is a look into the future at what we see for the next two to eight months. It is work that involves all craftsman, inspectors, draftsman, engineers, - security, clerical assistants, operators, trainers, supervisors, ie all of us. The major types of remaining Unit I work involve large and small Pipe Support changes, approximately 2,500 all together, Structural Steel mods to connections in the Fuel Handling Building, and in the Containment Annulus Structure. We will also have platfom modification work, minor structural changes on the polar crane and perhaps structural steel mods in the Turbine Building. There will be approximately 900 electrical raceway support modifi-cations and about 400 ventilation duct support mods. In addition to those four categories of work (pipe supports, structural steel connections, electrical supports, and ventilation duct supports), we have minor pipe changes in the Containment and several hundred feet of pipe to run for the Moisture Separator Reheater drain lines. We have on-going electrical Fe / A - N- 293 p gT I i t
]- and' instrumentation' work associated with the Safety Paramenter Display System (SPDS)
.and the Emergency Response Facility Data System (ERFDS). This involves providing
] the plant vital signs to a special display console in the Control Room and on into the Technical Support Room and also all the way over the Emergency Operation j Facility by the county Sheri.ff's office. , There will also be finish-up work relating to pipe rupture restraints which wili continue out to full power operation. .We will have some pipe insulation
" work associated ~~with pipe and rupture restraint work. As you know, we have work
' on the Breakwater, which will get back underway in April. There is also work , going on at the Intake Structure with added concrete and the added snorkle j ventilation stacks, which by the way are designed to withstand the impact of ~
- a car hurdled from the parking lot.
i Completion work for Unit II will be essentially the same as for Unit I, except there will be additional pipe support work, rupture restraint work and
- l. more electrical raceway and circuit work, i
' .You should see an ever increasing amount of work in Unit II by the first of-February. We are starting to get Unit II pipe' support designs now and we already have the Fuel Handling Building structural steel design changes. We
- l will also be getting some significant Startup testing underway in February.
- As always one o.f our primary concerns is Safety. However, it will be 4
most critical that we also continue to maintain our high standard of crafts- ) i manship and quality. Because of our very difficult schedule, it is necessary
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- that I go beyond the ~ call for safety.and craftsmanship and urgently request ' another call and that is a call for productivity. As I mentioned earlier, we have a_ very ambitious program and to maintain our. schedule we have an enonnous
' amount of work to do in a very short time. Things have not been pressing for the most part until recently, because Engineering was busy doing reviews, but they are now nearly complete and design changes have started coming down i to us. We have had an avalanche of designs arrive onsite over the last six L weeks and we expect a heavy snow-fall to continue until engineering work for j both Units.is complete.
i It. is my sincere hope that we can all perform like never before because -- the designat perienced changes Diablo. areForarriving much faster than we have ever previously ex-example, we had expected pipe supports to come four times faster than ever before, but over the last six weeks they have arrivad j ten times faster.
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There 'are those who feel construction can not accomplish the amount of - work before us in the time allotted. However, on other occasions when the . necessity has arisen we. have been able to make our schedule. We have seen the workers put forth the effort to meet schedules in the past and we are betting you are capable of meeting this schedule, while maintaining our high standard i 4 of safety and craftsmanship. To help in this we are looking for.any ideas people have to help achieve j ' safety, quality, and productivity. If there is anyone who has an idea that could help us in any of these areas,- let us hear from you. For instance, we i feel there are a number of things that can be done with Security to streamline } our operation and still live within the legal and connitted requirements. For example, many Unit I areas have been_devital hed to make your access easier and ' the Fuel Handling Building no longer requires " carding", and you can go in and out of the Containment by yourself instead of two st a time. 1 1 I .. --,mho.=m---- = - - -~ - * ~
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o !... We are burning the midnight oil to find ways to speed up clearance processing and " visitor" worker processing. Our goal is to have new hires cleared for unescorted Unit I access in one week or less. It's already im-proved from eight weeks to four weeks. Do you have enough tools? Do you have the right tools? Any suggestions for equipment, tools, and methods will be appreciated. We know that many craftsman on this job have been doing this type of work for many years and have gained a knowledge that may well help us in our endeavor. Tell your foreman, supervisor or General Construction inJpector/ engineer your ideas. We propose a bi-weekly update letter to let you all know how progress - is measuring up to our schedules, and it will bring you in on the project plans, and latest events and an award for the best rumor. We have been giver. a challenge of work and time, let's show them
-)E CAN N IT! Get your button and join the team.
R. D. Etzler Project Superintendent _m. m 09 F 4 9
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AGENDA FOR PG&E VISIT January 24-27, 1983 Monday, January 24 - 9:30 a.m. - Meet with Fred Miekle, Chairman of the Board and 10:30 a.m. Chief Executive Officer, and George Maneatis, Executive
, Vice President for Facilities and Electrical Resources
- Development
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10:30 a.m. - Noon Meet with Don A. Brand, Vice Presic'ent Engineering,
. and Discipline Chiefs:
-, R. Bettinger, Civil ;E E J. Rocca, Mechanical and Nuclear
, J. 'Herrera. Electrical 1:00 p.m. - 4:00.p.m. . Meet with above and 'others, as appropriate
'J Tuesday, January 25 - '
8:30 a.m. - Noon Meet with Diablo Canyon Project: ' H. Friend, Project Manager - R. Anderson, Er.gineering Manager S. Skidmore, Assistant Project Manager G. Moore, Project Engineer (Unit 1) M. Tressler, Piping Leader W. White. Seismic Assistant Project Manager C. Dick, Project Quality Assurance 1 :00 p.m. - 4':00 p.m.- Meet with PG&E Operations and Quality Assurance Staff: J. Schuyler, Vice President, Nuclear ' Operations ,, J. Shiffer, Manager, Operations W. Raymond, Quality Assurance Director 4:00 p.m. Exit Interview / Summary - Corporate Office Thursday, January 27 - 8:00 a.m. Site Tour - Diablo Canyon. John Carlson/Marvin Mendonca, Resident Inspectors,-to escort. - ' F A '8 Y 413 l N ' l s P[3' l x, ~~~ [
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r NRC'S QUALITY ASSURANCE INITIATIVES CUc(da6 ,/ y pal 9' W SPECIAL STUDY OF NUCLEAR QUALITY ASSURANCE (LONG-TERM REVIEW) BRIEFING SLIDES FOR PRESENTATION JANUARY 24, 1983 AT 4
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PACIFIC GAS AND ELECTRIC HEADQUARTERS , SAN FRANCISCO, CALIFORNIA - i DR. W. D. ALTMAN, PROJECT MANAGER Fo/ A 293 ff31. . L rj
TEAM MEMBERS DIA'BLO CANYON CASE STUDY NRC WILLARD D. ALTMAN NRC PROJECT MANAGER, SPECIAL STUDY OF NUCLEAR QUALITY ASSURANCE BATTELLE PNL HAROLD HARTY SENIOR STAFF ENGINEER fk,/h/% ENERGY SYSTEMS DEPARTMENT ryy %x.% Q k -e9 ball. xv ""r ;2" yyH g- W"Mh a BATTELLE COLUMBUS mMe+. W uW% e*$< Ys*^H P'-y"~ W 0 e d'5 . %y w kr ~ MILES PATRICK MANAGER, PROJECT MANAGEMENT PROCEDURES AND TRAINING . ap p mp w.e ip p s-1 2 &~'~" '
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w f. .- L - KfNNETH CARROLL -MANAGER, QUALITY PROCUREMENT, PROGRAMS AND CONSTRUCTION BRANCH .
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. .. . y an m w w h u---o h G EARL BRADFORD -QUALITYENGINEERINGSUPERVIbRl',%','M,/'k -f -
am* -in% QUALITY DEPARTMENT *", . p ,, n a & l J' ,n >
,4 ,, u, % pSAf a 1 <ho ,l q ua ~! bt ,w L+ y a d KIST'AND' ASSOCIATES RICHARD KLECKNER VICE PRESIDENT, N.C.
. KIST & ASSOCIATES pm ut.ad, ~j ;"7v , t% 'J: !"' ,
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DFFICL"DF INSPECTION AND ENFDHCEMENT ' 4 e i - R. C. DeYoung. Director J. II. Snlezek, Deputy Director i
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f i Technical Training Center
, C. W. Thayer, Director Program Support Branch '
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J. L. Bleha Chief , I Enforcement Staff
. J. A. Axelrad, Acting Director Division of Quality Assurance. _
--- Sa feguards, and Inspection Programs Division of Emergency Preparednes -
J. H. Taylor, Director .
~~~ and Engineering Response B. K. Grimes, Deputy Director E. L. Jordan, Director S. A. Schwartz, Deputy Direct Quality Assurance Branch Engineering and Generic T. L. liarps ter, Chie,f ----
Communications Branch R. L. Baer, Chief Reactor Construction Programs Branch R. F. lleishman, Chief Events. Analysis Branch .n W. R. Hills, Chief
'c l Dperating Reactor Programs Branch t
- J. G. Partlow, Chief .
Incident Response,.Dranch I 1 K. E. Perkins, Chief l Sa feguards..and Ha terla]s Programs Dranch L.1. Cobb, Chief _ Emergency
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l'reparedness tiranch
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BACKGROUND OVER T5E PAST.' SEVERAL YEARS THERE HAS BE PUBL'ICIZED PR,0BLEMS REGARDING THE QUALITY OF CONSTRUCTION'AT SEVERAL NUCLEAR POWER PLANT PROJECTS i ' j _ PLANTSRECEIVINGWIdESPREADATTENTIONINCLUDE: MARBLE HILL MICLAND '
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ZINMER - SOUTH TEXAS DIABLO CANYON -
'THE PERCEIVED SEVERITY OF THE QUALITY PROBLEMS AND THE ATTENDANT PUBLICITY AND PUBLIC INTEREST HAVE CAUSED THE CONGRESS AND THE NRC
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COMMISSIONERS TO QUESTION _ g - - T.NE ABILITY OF INDUSTRY TO CONSTRUCT NUCLEAR PLANTS -
- ) J IN A MANNER CONSISTENT WITH PUBLIC SAFETY ~
THE ABILITY OF THE NRC STAFF TO PROVIDE ASSURANCE THAT
' INDUSTRY HAS CONSTRUCTED PLANTS IN A MANNER CONSISTENT
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WITH PUBLIC SAFETY
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AS A RESULT, THE INDUSTRY AND THE NRC ARE JOINTLY FACING AN EROSION IN THE PUBLIC'S CONFIDENCE IN OUR ABILITY TO BUILD, LICENSE, AND l OPERATE NUCLEAR POWER PLANTS IN A MANNER CONSISTENT WITH PUBLIC SAFETY l _ e , , __ _ ,_ _ * , . .- . . - _}}