ML20138J072
| ML20138J072 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/14/1985 |
| From: | Dircks W, Palladino N NRC, NRC COMMISSION (OCM) |
| To: | Dircks W |
| References | |
| OL-I-CCANP-147, NUDOCS 8510290237 | |
| Download: ML20138J072 (12) | |
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NUNZIO J. PALLADINO UNITED STATES NUCLEAR REGULATORY CGMMISSION BEFORE THE SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT OE.THE. _ -
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COMMITTEE ON INTERIOR AND INSULAR AFFAIRS UNITED STATES HOUSE OF REPRESENTATIVES t
WASHINGTON, D C, 4
NOVEMBER 19, 1981 i
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MR. CHAIRMAN AND MEMBERS OF THE COMMITTEE, 1 AM PLEASED TO APPEAR BEFORE YOU THIS MORNING TO DISCUS'S QUALITY AS5URA l
POWER PLANT-S.
I BELIEVE THAT AN EFFECTIVE QUALITY ASSURANCE (QA) PROGRAM VITAL ELEMENT IN THE MANAGEMENT OF ACTIVITIES THAT MUST BE ACCOMPLISHED DURING THE DESIGN AND CONSTRUCTION OF EACH QUALITY ASSURANCE -SHOUl;E BE USED AS A FORMAL POWER PLANT.
MANAGEMENT TOOL TO ATTAIN THE MUTUAL Y COMPLEMENTARY GOAL
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ASSURING THAT THE DESIGN IS CORRECT AND THAT THE PLANT IS 1
CONSTRUCTED IN FULL ACCORD WITH THE DESIGN.
TO BE EFFECTIVE, A s
QA PROGRAM MUST HAVE THE FULL SUPPORT AND ATTENTION OF THE NUCLEAR INDUSTRY MANAGERS RESPONSIBLE FOR DESIGN AND CONSTRUCTION.
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THE NRC LICENSING AND INSPECTION AND ENFORCEMENT PROCESS t
AIMED AT ASSURING THAT AN EFFECTIVE QA PROGRAM IS ESTA IMPLEMENTED TO PROVIDE THE NGCESSARY CONFIDENCE THAT POWER PLANT FULLY SATISFIES NRC REQUIREMENTS.
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9 AFTER REVIEWING BOTH INDUSTRY AND NRC PAST PERFORMANCE IN QA, I READILY ACKNOWLEDGE THAT NEITHER HAVE BEEN AS EFFECTIVE A SHOULD HAVE BEEN IN VIEW OF THE RELATIVELY LARGE NUMBER OF CONSTRUCTION-RELATED DEFICIENCIES THAT HAVE COME TO LIGHT.
HOWEVER, RECOGNIZING THAT THERE IS A PROBLEM IS THE FIRST STEP TO I HOPE THAT OUR TESTIMONY TODAY WILL DEMONSTRATE FIXING IT.
NRC'S RESOLVE TO DEAL FORCEEULLY._WLTH. CONSTRUCTION RELAT DEFICIENCIES AND THE QA PROBLEMS THEY' REVEAL.
J' MR. CHAIRMAN, ACCOMPANYING ME TODAY IS MR. WILLIAM DIRCKS, i
EXECUTIVE DIRECTOR FOR OPERATIONS, MR. HAROLD R. DENTON, DIRECTOR OF THE OFFICE OF NUCLEAR REACTOR REGULATION, MR. RICHARD DEYOUNG, DIRECTOR OF THE OFFICE OF INSPECTION AND ENFORCEMENT, MR. JAMES l
G. KEPPLER, REGIONAL ADMINISTRATOR OF NRC REGION III, AND MR. JOHN COLLINS, REGIONAL ADMINISTRATOR OF NRC REGION IV.
MR. DIRCKS WILL PRESENT THE REST OF NRC'S WRITTEN TESTIMONY, AFTER WHICH WE WILL BE PREPARED TO ANSWER ANY QUESTIONS YOU MAY HAVE.
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1 TESTIMONYOFWILLiAM'J.DIRCKs BEFORE THE SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT 0F THE COMMITTEE ON INTERIOR AND INSULAR AFFAIRS
..n = n UNITED STATES HOUSE OF REPRESENTATIVES x
WASHINGTON, D.C.'
. NOV 191981 O
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QUALITY ASSURANCE FOR NUCI EkR PLANTS UNDER CONSTRUCTION THIS TESTIMONY ADDRESSES THE ADEQUACY OF QUALITY ASSURANCE AS IT APPLIES TO NUCLEAR POWER PLANTS dNDER CONSTRUCTION, WHY IDENTI-FIED CONSTRUCTION OR QUALITY ASSURANCE DEFICIENCIES HAVE NOT BEEN l
DETECTED ON A MORE TIMELY BASIS, AND ACTIONS BEING TAKEN TO SOLVE RECOGNIZED PROBLEMS.
NRC LOOKS TO THE POWER PLANT.0WNERS, THE UTILITIES THEMSELVES, TO TAKE THE. LEADERSHIP ROLE IN ASSURING THE QUALITY OF THEIR PLA'NTS AND OPERATIONS.
THIS REQUIRES HIGH EMPHASIS AND ACTIVE INVOLVE-1 MENTOFTOPLICENSEEMANAGEMlNTTNQkPROGRAMS.CAREFUL ATTEN-TION iS REQUIRED IN THE SELECTION OF ENGINEERING SP$CIFICAJIONS 5
ANDQAPROCEDURESANDPRACTICESFOREACHfASKANDTHEIRIMPLEMENT-ATIONBiTHEWORKERSONTHEJOB.
MOST IM,.PORTANTLY, THERE MUST BE ADEQUATE RESOURCES OF QU,ALIFIED PERSONNEL AT MANAGEMENT, OPERAT-s ING, AND STAFF LEVELS.
NRC ASSESSES THE PERFORMANCE OF THE UTILITIES AND ITS MAJOR CONTRACTORS DURING THE DESIGN AND CONSTRUCTION PHASES.
THE NRC I
DOES NOT ATTEMPT TO REDO THIS WORK OR INSPECT IT COMPLETELY.SINCE THE NRC RESOURCES ON A PARTICULAR PLANT ARE 0NLY A SMALL FRACTION OF WHAT WE REQUIRE THE UTILITY TO DEVOTE TO INSPECTION, QUALITY CONTROL, AND QUALITY ASSUR,ANCE.
THdNRC'SREGIONALOFFICESCARRY OUT A SAMPLING INSPEC, TION PROGRAM AIMED AT DETERMINING COMPLIANCE WITH THE PROGRAMMATIC COMMITMENTS.
THE REGULATORY' REQUIREMENTS PLACE THE MAJOR INSPECTION RESPONSIBILITIES FOR QUALITY ASSURANCE h,
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ON THE LICENSEE'S CONTRACTORS, WHICH ARE IN TURN INSPECTED AND AUDITED BY THE LICENSEE'S STAFF.
THE NRC'S EFFORT IS AN AUDIT AND OVERVIEW OF THE LICENSEE AND ITS CONTRACTORS QUALITY ASSURANCE ACTIVITIES.
IN CARRYING OUT THESE INSPECTION ACTIVITIES, NRC INSPECTIONS COVER APPROXIMATELY l-5 PERCENT OF THEINSPECTIONACTIVITIESPERF0IMEDBYTHELICENSEANDITS CONTRACTORS.
THE NRC'S QUALITY ASSURANCE REQUIREMENTS ARE CONTAINED IN APPENDIX B TO PART 50 0F TITIE 1D"6F T'HE CODE OF FEDERAL REGULATIONS, " QUALITY ASSURANCE CRITE IA FOR NUCLEAR POWER PLANTS AND FUEL REPROCESSING PLANTS."
THESE CRI-T'ERI A PROVIDE A BASIS UPO'N WHICH THE NRC JUDGES THE ACCEPTABILITY OF QA PROGRAMS.
THE CRITERIA 0F APPENDIX 3 APPLY TO ALL ACTIVITIES AFFECTING SAFETY-RELATED FUNCTIONS OF NUr. LEAR POWER REACTOR STRUCTURES, SYSTEMS, AND COMPONENTS.
i QUALITY ASSURANCE IS DEFINED IN OUR REGULATIONS AS "ALL THOSE PLANNED AND SYSTEMATIC fCTIONS NECESSARY TO PROVIDE ADEQUATE l
CONFIDENCE THAT A STRUCTURE, SYSTEM, OR COMPONENT WILL PERFORM
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SATISFACTORILY IN SERVICE."
WHAT THIS MEANS IS THAT - FOR ITEMS HAVINGSAFETYSIGNIFICANCkINANUCLEARPOWERPLANT:
0 THE DESIGN IS VERIF,IED TO BE CORRECT AND TO INCLUDE APPROPRIATE REGULATORY REQUIREMENTS) s 44
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O PROCUREMENT DOCUMENTS CONTAIN ADEQUATE INFORMATION AND ARE VERIFIEDi 0
INSPECTION OF PARTS, MATERIALS, AND PROCESSES ARE TIMELY AND ADEQUATE;
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O DEFICIENCIES IN DESIGN CONSTRUCTION AND INSTALLATION ARE IDENTIFIED AND APPROPkIATELY REMEDIED; 2
O THE QA PROCESS IS'4UDifE'D ARD REPORTED TO AN ORGANI-s ZATIONAL LEVEL CAPABLE OF ASSURING EFFECTIVE CORRECTIVE 3
MEASURES;
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O RECORDS ARE KEPT WHICH CLEARLY DEMONSTRATE SUFFICIENCY
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OF ACTIVITIES AFFECTING QUALITY; AND O
THE ORGANIZATIONS PERFORMING QA FUNCTIONS HAVE SUFFICIENT I
i INDEPENDENCE AND AUTHORITY TO IMPLEMENT THESE ACTIVITIES.
THIS DISCUSSION WILL FOCUS ON SOME EXPERIENCES THAT HAVE AND CON-TINUE TO GENERATE WIDESPREAD PUBLIC INTEREST.
SPECIFICALLY, z
THERE HAVE BEEN SOME SERIO.US QUALITY ASSURANCE BREAKDOWNS WITH i
BROAD REPERCUSSIONS AT THE MARBLE HILL, MIDLAND, ZIMMER, SOUTH TEXAS', AND DIABLO. CANYON CONSTRUCTION SITES.
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BY ITSELF, WITHOUT FACTORING IN ANY REWORK, THE QUALITY CONFIRMATION PROGRAM WILL BE BOTH COSTLY AND TIME CONSUM-ING.
WHETHER OR NOT THIS DELAYS OPERATIONS REMAINS TO BE DETERMINED.
SOUTH TtX4S i
IN JANUARY 1981, HOUSTON LIGHTING AND POWER COMPANY (HL&P)
INITIATED A DESIGN REVIEW OF THOSE PORTIONS OF THE ENGINEERING
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I DESIGN WORK PERFORMED BY BR6WN ' ND"R06T, INC., (B&R) FOR THE SOUTH TEXAS PROJECT ELECTRIC GENERATING. STATION (STP).
THE-PURPOSEOFTHISREVIEWWASTOASCERTAIN'ihEOVERALLADEQUACYOF THE STP DESIGN.
QUADREX CORPORATION WAS, ASKED TO ASSIST HL&P IN j
A REVIEW OF THE FOLLOWING B&R TECHNICAL DISCIPLINES.
i CIVIL / STRUCTURAL COMPUTER PROGRAMS AND CODES ELECTRICAL / INSTRUMENTATION AND CONTROL
. GE0 TECHNIC HEATI'NG,VENTfLATINGANDAIRCONDITI0NING
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MECHANICAL ~
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l NuCLEARANALYSISk PIPING AND SU,PPORTS/ STRESS AND SPECIAL STRESS RADIOLOGICAL CONTROL, J
.m THE LICENSEE MET WITH QUADREX CORPORATION FOR THE FIRST TIME ON JANUAR,Y 16, 1981, AND SEVERAL OTHER TIMES IN JANUARY AND FEBRUARY 1981, TO PLAN THE REVIEW.
THE REVIEW BY QUADREX INVOLVED 12 ENGINEERING CONSULTANT PERSONNEL WHO SPENT MORE THAN SIX WEEKS IN AUDITING BaR DESIGN ENGINEERING DOCUMENTS AND INTERVIEWING VARIOUS B&R DISCIPLINE ENGINEERS.
THE REPORT ON THE QUADREX EFFORT WAS ISSUED MAY 7,1981.
BREIFLY, THE QUADREX REPORT FOUND THAT BROWN & ROOT APPARENTLY FAILED'TO PROPERLY IMPLEMENT THE QA PROGRAM IN THE DESIGN AREA BUT ALSO FAILED TO PROPERLY IMPLEMENT 4
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AN,0VERALL DESIGN PROCESS CONSISTENT WITH THE NEEDS OF A NUCLEAR l
POWER PLANT.
AS A RESULT VERIFICATION OF DESIGN INFORMATION WAS
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APPARENTLY NOT PERFORMED IN A TIMELY MANNsR, AND REGULATORY COMMIT-MENTS FOR SAFETY DID NOT APPEAR TO BE FUL;LY OR PROPERLY
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IMPLEMENTED TO SATISFY N.RC REQUIREMENTS FOR LICENSABILITY.
NRC INSPECTION REPORTS DATING BACK TO 1979 FOUND PROBLEMS AT THE i
SOUTH TEXAS PLANT SIMILAR TO THOSE IDENTIFIED.IN THE QUADREX REPORT.
HOWEVER, THE AGENCY $S AUDITS DID NOT SURFACE THE NUMBER OF PROBLEMS SUGGESTED BY THE QUADREX REPORT. - THOUGH WE' WERE AWARE OF QA' PROBLEMS T SOUTH TEXAS AND HAD CITED THE~ LICENSEE FOR A BREAKDOWN IN THEIR QA PROGRAM' IN APRIL 1980, 'THE MAGNITUDE t
0F PROBLEMS WERE NOT FULLY, APPRECIATED UNTIL WE FIRST REVIEWED THE REPORT IN AUGUST,0F 1981.
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IN LATE SEPTEMBER THE LICENSEE ANNOUNCED THAT BROWN AND ROOT WAS BEING.P.EPLACED BY BECHTEL POWER CORPORATION AS ARCHITECT-ENGINEER.
WE INTEND TO CAREFULLY MONITOR HOW BECHTEL INVESTIGATES AND
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DISPOSES OF THE PROBLEMS SURFACED BY THE QUADREX REPORT.
DIABLO CANYON AT DIABLO CANYON, THE PACIFIC GAS 8: ELECTRIC COMPANY (PG&E)
PROVIDED INCORRECT INFORMATION TO A EXPERT CONSULTANT, WHO USED TH,E INFORMATION WRONGLY IN' DEVELOPING ~THE SEISMIC RESPONSE SPECTRA FOR THE DESIGN OF CERTAIN SEISMIC PIPING AND EQUIPMENT RESTRAINTS.
OURINVESTIGATORS.HAVEFOUNb'THATTHEREWASALACK OF" RIG 04 AND FORMALITY IN THE PROCEDURES.USED FOR VERIFYING ThE ACCURACY OF INFORMATION, TRANSFERRED BY PGaE TO ITS CONSULTANTS.
THESE PROCEDURES DID NOT COMPLY WITH OUR REQUIREMENTS CALLING FOR l
YERIFICATION OF DESIGN INFORMATION AT EACH STAGE OF THE PROCESS BY AN INDEPENDENT PERSON QUALIFIED IN THE PERTINENT DISCIPLINES.
PROPER QUALITY ASSURANCE CONTROLS WERE NOT EMPLOYED IN TECHNICAL i
AND PROCUREMENT COMMUNICATIONS' WITH SERVICE-TYPE CONTRACTORS. NOR WERE DOCUMENT CONTROLS ADEQUATE TO ASSURE THAT THOSE INVOLVED IN DESIGN HAD READY ACCESS TO THE MOST RECENT INFORMATION AVAILABLE.
l BECAUSE OF THE INADEQUACY OF QA CONTROLS OVER* DESIGN VERIFICATION, l
PROCUREMENT AND THE TRANSMITTAL OF DOCUMENTS TO SERVICE CONTRACTORS, THE ACCEPTABILITY OF THE DESIGNS BASED ON THEIR
' ANALYSES IS NOW IN QUESTION.
AS A RESULT, THE STAFF HAS DECIDED THAT THERE IS SUFFICIENT REASON TO REVIEW THE ENTIRE PROCNSS FOR SEISMIC DESIGN, TO REVIEW THE ADEQUACY OF OTHER PLANT DESIGN ASPECTS PARTICULARLY THOSE THAT WERE BASED ON ENGINEERING INFORMATION DEVELOPED UNDER OTHER SERVICE-TYPE CONTRACTS, AND TO REVIEW THE IMPLEMENTATION OF THE UTILITY @APROGRAMINTHESEAREkS.
IN LOOKING AT THE MARBLE HILL, MIDLAND, ZIMMER; SOUTH TEXAS, AND DIABLO CANYON PROBLEMS, QUESTIONS HAVE BEEN RAISED AS TO WHY THE
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LICENSEE'S QUALITY ASSURANCPPROGR M AND THE NRC INSPECTION PROGRAM HAD NOT IDENTIFIED THE PROBLEMS SOONER. CLEARLY, IN,EACH
, CASE, THERE WAS AN OVERRELIANCE BY THE UYfLITY ON ITS CONTRACTORS FOR' MAINiAINING A THOROUGH QUALITY ASSURA,NCE PROGRAM.
THE UTILITV'S OWN QA STAFF WAS TOO SMALL TO MAINTAIN SUFFICIENT SURVEILLANCE OVER THE WORK OF CONTRACTORS.
IN TWO OF THE CASES WE SAW INSTANCES WHERE THE CONSTRUCTION MANAGEMENT DOMINATED OR CONTROLLED THE QUALITY ASSURANCE PROGRAM AND PERSONNEL.
AND, IN
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EACH OF THE CASES WHERE PROBLEMS HAD BEEN IDENTIFIED, THE CORRECTIVE ACTION TAKEN WAS.NOT SUFFICIENTLY SROAD.
TOO FREQUENTLY,'THE RESPONSE WAS ONE OF TREATING THE SYMPTOM, RATHER THAN FINDING.THE BASIC CAUSE AND CORRECTING IT.
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IN ANALYZING THE IDEN,TIFIED PROBLEMS AREAS, ONE CAN COME UP WITH A LIST OF IMMEDIATE CAUSES -- ISSUES SUCH AS UNQUA'LIFIED WORKERS OR QC INSPECTORS, FALSIFIED RECORDS, INTIMIDATION OF QUAllTY
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CONTROL INSPECTORS, LACK OF AUTHORITY, LACK OF COMMUNICATION, IN ADEQUATE STAFFING LEVELS, INADEQUATE CORRECTIVE ACTION SYSTEM, LACK OF SUPERVISION, POOR TO NONEXISTENT PROCEDURES, POOR DESIGN AND CHANGE CONTROL, DESIGN ERRORS, INADEQUATE ANALYSIS, POOR QUALITY COMPONENTS, AND SO ON.
MOST OF THESE CAN BE TRACED TO FAILURE DE. QUALITY ASSURANCE DUE TO INEFFECTIVE MANAGEMENT CONTROL OF THE QA PROGRAM. THERE ARE A MYRIAD OF EXCUSES AND hEASONS WHY MANAGEMENT FAILS.
SOME:ARE EXPLICIT FAILURES OF '
PERFORMANCE OR LACK OF ATTENTION.
OTHER FAILURES ARISING FROM POOR ATTITUDES AND PERCEPTIONS,ARE DTFFICULT TO IDENTIFY. THE NRC CANNOT. TOLERATE THESE DEFECTS BECAUSE OF THEIR POTENTIAL IMPACT IN TERMS OF PUBLIC RISK.
IN ADDITION, LICENSEES SHOULD BE MOP [E CONDERNED ABOUT QUALITY ASSURANCE NO,T ONLY FOR SAFETY REASONS BUT ALSO BECAUSE 0F THE COMMENSE COST OF MISTAKES AND THE RES.ULTING DELAY.IN CONSTRUCTION.
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GIVEN THESE INSTANCES OF BREAKDOWNS IN MANAGEMENT CONTROL OF
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CONSTRUCTION QUALITY AND THE COMMISSION'S DISSATISFACTION, THE ISSUE IS "WHAT ARE WE DOING ABdVT IT7" WITHOUT DOUBT, THERE HAVE BEEN SHORTCOMINGS IN THE NRC INSPECTION PROGRAM AT CONSTRUCTION SfTES.
THE[EHAVEBEENCASESWHEREWE HAVE FAILED TO SEE THE BREADTH OR DEPTH OF A PROBLEM.
WE IDENTIFIED SPECIFIC VIOLATIONS OF REQUIREMENTS WITROUT REQUIRING
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THE CORRECTION OF THE BASIC CAUSE OF THE PROBLEM.
ADDITIONALLY,
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