ML20138L808
| ML20138L808 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1476, NUDOCS 8512200053 | |
| Download: ML20138L808 (149) | |
Text
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c U' UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON QUALITY AND QUALITY ASSURANCE OR G VAL O
LOCATION: WASHINGTON, D. C. PAGES: 1 - 133 DATE: FRIDAY, DECEMBER 13, 1985 Ei 122 3 851213 T-1476 PDR 200Of00[00[@ N 3&7emgve from ACRS00 ice ACE-FEDERAL REPORTERS, INC.
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Offic:/ Pqorters d O 444 No% Capitol Street Washington, D.C. 20001 (202)347-3700 NATIONWIDE COVERAGE
' l O PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS FRIDAY, DECEMBER 13, 1985 The contents of this stenographic transcript.of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at O this meeting accepts any responsibility for erro*rs or inaccuracies of statement or data contained in this transcript.
1 O
CR25284.0 DAV/sjg 1 1 UNITED STATES OF AMERICA
'd 2 NUCLEAR REGULATORY COMMISSION 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON QUALITY AND QUALITY ASSURANCE 5 Nuclear Regulatory Commission Room 1046 6 1717 H Street, N. W.
Washington, D. C.
7 Friday, December 13, 1985 9 The subcot.;mittee meeting convened at 8:30 a.m.,
10 Dr. Forrest Remick presiding.
11 ACRS MEMBERS PRESENT:
l 12 DR. FORREST REMICK i
('l k-13 DR. CHESTER P. SIESS 14 StHR. GLENN A. REED 15 MR. DAVID A. WARD MR. CARLYLE MICHELSON MR. CHARLES J. WYLIE l 17 ll ;
II i 18 ;
l 19 20 l
21 22 23 i i.
Ass-Federal Reporters, Inc.
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40 01 01 2 1 DAvbw 1 PROCEEDINGS 2 DR. REMICK: The meeting will now come to order.
3 This is a meeting of the ACRS Subcommittee on 4 Quality and Quality Assurance in Design and Construction.
5 I'm Forrest Remick, Chairman of the 6 subcommi ttee .
7 other ACRS members present today are David Ward, I 8 Chet Siess, Glenn Siess, Carlyle Michelson and Charlie
- 9 Wylie.
10 Richard Major and E. G. Igne, on my right, are 11 the ' assigned ACRS Staf f members. for this meeting.
()- 12 ,
- The purpose of the me'eting is to discuss with the
! 13 NRC S taf f such programs as CAT, IDVP,-IDI and Readiness
]
'14 Reviews to ensure quality in nuclear power plant design and 15 cons truc tion. Further discussion with the Staf f is planned i
16 to discuss their programs to deal with allegations 17 concerning plo .c quality at the operating license stage.
18 Emphasis will be placed on comparing the 19 resources required by the various programs and the 20 effectiveness of the programs, ensuring quality of plant 21 design construction and readiness for operation.
22 A transcript is being kept of the entire meeting,
, 23 and it is requested that each speaker first identify himself O 24- or herself and speak with sufficient clarity and volume so i
25 that he or she can be readily heard.
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l 0 01 02 3 1 DAVbw 1 We've received no written statements from members 2 of the public. We've received no requests for time to make 3 oral statements from members of the public.
4 Do any members of the subcommittee wish to make 5 any opening comments?
6 (No response.)
7 If not, Ted, perhaps you would want to introduce 8 the S taf f members that you have with us. You have a copy of 9 the agenda. Is tha t sa tisfactory, or do you have suggested 10 changes?
11 MR. ANKRUM: Good morning, Dr. Remick, members of
(- 12 the commi ttee. Thank you for this opportunity. I do w/ .
13 believe we'd like to adjust the order of the presentation 14 this morning. We'll start with a series of overviews of 15 initiatives tha t the Staff has undertaken at the moment tha t 16 the committee has not heard from before. Then we'll shift 17 int 9 some of the findings and the status of both those 18 programs and the programs the committee has heard about in 19 the pas t.
20 We'll start off with a presentation from NRR, 21 represented here by Mark Williams, and Dick Brady here, and 22 Jim Knight is also here to answer questions at a later p'.. int 23 in time.
r' 24 They'll discuss the allegation tracking system, N_/
25 which is new to the subcommittee.
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s, 1 Then Jim Partlow, who is Director of the Division 2 on Programs within I&E, will give you a brief overview of 3 the inspection program initiatives that we've been working 4 on in the recent past and tell you how we're doing those 5 things.
6 You specifically asked for an update on the 7 findings of the CAT program, and Bob Heishman of I&E is here 8 to give you a status report on the kinds of things that CAT 9 has been doing and contributing to this overall process, at 10 which point in time, we'll shif t back and give you a status 11 report of the kinds of things that the IDIs and IDVPs 12 engineering assurance programs and readiness reviews have (5
(/ 13 bene finding.
14 I'll be giving the overview on tha t.
15 Jim M111hoan here, who heads the inspection teams 16 outdo network. He'll answer specific questions, and there 17 are a number of staf f members that are engaged in those 18 kinds of inspections here. We can get into some detail on 19 any of those questions. Once we finish that, that will 20 constitute the formal part of our presentation. We're 21 leaving ample time for you to delve into any area that you 22 find of particular interest.
23 Yes, Dr. Siess?
24 DR. SIESS: Tha t sounds somewhat fragmen ted. If 25 anybody going to give us an overview and tell us why these ACE FEDERAL REPORTERS, INC.
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2840 01 04 5 i JDAVbw 1 things are being done and what contribution they make to 2 public health and safety or reduction of of core melt 3 probability or reduction of person-rems. You know, the 4 various measures that are being used by the Commission to 5 decide what should or shouldn' t be done.
6 The programs as they are, are divided in a number 7 of places. Each of us contributes our piece to the overall 8 picture. We' re here to talk to you about each of our 9 individual pieces, and to the extent that we could 10 in tegra te those, we'll be happy to do so.
11 DR. SIESS: Then each individual person tell us 12 why they' re doing it -- because the EDO ordered it or t%
'J 13 somebody else ordered it?
14 MR. ANKRUM: I think we can all respond as to why 15 we're doing it.
16 DR. SIESS: I have a problem keeping track of 17 these things, in terms of time. There seems to be 18 overlays. Somebody does this. Somebody else comes along 19 and does that. Somebody else goes back and does that.
20 Can somebody give us that picture too?
21 MR. ANKRUM: To the extent we're able to, we'll 22 certainly address tha t poin t.
23 DR. SIESS: Now when you say various people have 24 -- NRR and I&E are the two organizations?
25 MR. ANKRUM: They're the two principal players.
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,.840 01 05 i-)DAVbw 1 I&E being, of course, responsible for the program 2 as it's implemented in the regions.
3 DR. SIESS: Nobody else besides NRR and I&E?
4 MR. ANKRUM: I certainly don' t know of any other 5 major players. OI would certainly be involved, in terms of 6 some of the allegations, but tha t has not, to da te, been an 7 item that I think we're prepared to talk about today.
8 DR. SIESS: Do you think that OI inves tiga tions 9 have any contri'o ution to safety? Why don' t we hear about 10 tha t too.
11 MR. ANKRUM: I would encourage the subcommittee 12 to invite them.
13 DR. REMICK: Yes. Go ahead, Dave.
14 MR. WARD: I have had a similar subject to 15 Dr. Siess'. There are, you know, a number of different 16 programs here. Each of them are similar, I think, in what 17 they' re trying to do. It involves different places or 18 different times. Is there any thrust toward going to one 19 sort of program? Are we going to hear whether you decided 20 that one of these is better than the others, or one is best?
21 MR. ANKRUM: No, you' re not going to hear that, 22 because some other programs we're talking about are wrapping 23 up the IDI and IDVP, and we'r shifting into operating 24 reactor kinds of concerns. other programs that we're going O 25 to talk about are very much in the pilot stage, and that's ACE-FEDERAL REPORTERS, INC.
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2840 01 06 7 DAVbw 1 the readiness review. We're going to talk to the CAT 2 program, as we ge t all the plants to the pipeline. The CAT 3 program is obviously shif ting its emphasis over to operating 4 plants and outages at operating plants.
5 So I think we'd have to say, no, we' re not going 6 to talk about it in any great detail today, because we're 7 not at the stage where we could.
8 The readiness reviews are very much up at this 9 time.
10 DR. SIESS: Once plants are under construction, 11 of course, there's not much you can do about inspecting the
, 12 cons truc tion, but we find construction errors ten years V 13 af ter a plant's been operating. Of course, if there's 14 nobody constructing, you can' t feed that back. I can 15 understand that, but it seems to me we find design errors, 16 again, at all stages, ten years af ter a plant's been 17 operating or 15, and a lot of designers that we see are not 18 rela ted to the original design. These plants are constantly 19 being redesigned, as you well know. Some are redesigned at 20 the initiative of the utility, some at the initiative of 21 NRC, and so forth. So that process continues. And there's 22 at least one theory in my business that design changes never 23 get the attention that original designs do.
24 MR. PARTLOW: I'm Jim Partlow from I&E. I'd O 25 like to address that in my presentation, of where we're ACE-FEDERAL REPORTERS, INC.
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2840 01 07 8 DAVbw I trying to go with our inspection program.
2 MR. REED: Forrest, it seems to me about a year S
3 ago, there were points made in open meetings by me, and I 4 think by Ted that the industry had overreacted with respect 5 to quality control and the degree in which it was handled.
6 In other words, they were putting engineering pipes without 7 any real work experience, welding experience or anything 8 like that, into the oversight and approval of quality 9 control, which should have been done by a craf tsman.
10 Now I believe you said, in two open mee tings, 11 that you're going to produce a letter addressing that 12 industry overreac tion and trying to get quality control back eS
~# 13 into the hands of the skilled people. Subsequen tly, I 14 called your office. You said that the letter had been 15 delayed.
16 C3uld you address, in this meeting, the status of 17 tha t?
18 MR. ANKRUM: Yes. The letter has been prepared 19 and it's in Staf f review at this time.
20 MR. REED: It's been a long time, hasn' t it? It 21 must have been almost a year now.
22 MR. ANKRUM: Yes. It's had to take its place in 23 a long list of priorities. We have prepared the le tter, and 24 it's in Staf f circulation at the moment for comment. It's O 25 moving on a fast track now. It'll get an up or a down ACE FEDERAL REPORTERS, INC.
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1 2840 01 08 9 DAVbw 1 fairly soon.
2 MR. REED: Well, good. I've been waiting with 3 ba ted breath.
4 DR. SIESS: There'a another aspect we discussed 5 once that could be worked in anywhere, and that was, ins tead 6 of looking at paper -- you know, what I mean, that's an 7 exaggera tion , the preoperational tests startup programs are 8 certainly one way in which errors are found in design or 9 construction.
10 I think I asked once whether those tests were 11 planned to detect errors or whether they were just planned 12 to see if things operated under some conditions or 13 scenarios. I mean, we've had instances where systems have 14 never been testod in their required mode, which might be an 15 of fbea t mode, a severe acciden t-type mode. We certainly 16 find things in preop tests.
17 MR. ANKRUM: If I can expand your question into 18 another area, not just preop testing, but testing of sys tems 19 af ter modifications on currently licensed plants.
20 DR. SIESS: That's a little more obvious, 21 though.
22 MR. ANKRUM: Well, Jim Partlow is going to talk 23 to yo about some of our inspection initiatives in that 24 area. We've had a couple of trial inspections, and'we've 25 had design inspectors, people from the IDI and IDVP ef forts, ACE-FEDERAL REPORTERS, INC.
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1 on those temar.. We have found s'ome ra ther interesting 2 r resul ts', interesting in that we' re finding that the same 3 kinds ,of Irrors that we discovered during the construction 4 process are, i'n f ac t, being perpe tuated once the plant is 5 operated and you're looking at design changes.
6 We also are finding -- we're looking very, very 7 carefully in .this these new inspections at safety system t'
~
8 functionality and at the testing associated with those 9 sa f e ty sys tems , to be sure that the tes ting, in fact, 10 reflects all of tne conditions that tha t system may f ace.
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11 7- DR. .SIESS: You mean preopera tive surveillance 12 bes ting? -
\~' '
13 MR. ANKRUM: I mean -- I'm going to talk 14 specificaly "now about operating plant modifications to the 15 ' safe tyysys tems , because that's some inspections that we have 16 recently performed and we're very f amiliar with.
17 DR.'SIESS: My question was a little bit 18 different. It seems to me highly unlikely that one of these 19 things can be designed and built without a mistake
- , 20 somewhere. I mean, perfection is impossible. You can go 21 back and check the design and check the OA program for 22 design. You can do the Dsame on construction, and you'll
~
23 find things that don' t work, when you make certain tests, 24 and I was wondering of pre-op tests have been planned, or if
'# 25 not, could they be planned in such a way as to show up these ACE-FEDERAL REPORTERS, INC.
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i 2840 01 10 11 DAVbw 1 mistakes.
2 MR. ANKRUM: They're supposed.
3 DR. SIESS: Are pre-op plans reviewed by NRC with 4 tha t in mind?
5 MR. ANKRUM: I can' t directly answer that 6 ques tion , because our direct inspection ef forts have not 7 been involved in tha t, but I can say that the pre-op tests 8 are supposed to do that, and I can' t say that our 9 inspections now in the safety system functionality area and 10 the outage area are very definitely inspection the tes t 11 programs to determine whether or not they ' re testing all of
.- x 12 the design features that that plant has to encounter.
l )
v 13 For instance, the valve has to open with a 14 certain delta P across that valve seai', and we want to be 15 sure tha t the te s t , in fact, tests that valve with that 16 delta P across it. We've found some very specific instances 17 in the recen t past.
18 DR. SIESS: That's probably one of the most 19 dif ficult tests. Have there been instances where the wires 20 were connected backwards and it wasn' t discovered until five 21 years later?
22 MR. ANKRUM: Yes.
23 DR. REMICK: Gentlemen, I think we'd be tter ge t
,~ 24 s ta r ted . We can save these questions for later.
O Ted, I suggest you get started. Remember, i t's 25 ACE-FEDERAL REPORTERS, INC.
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.(~h b / DAVbw 1 Friday the 13 th.
2 (Laughter.)
, 3 MR. ANKRUM: In that case, I'd like to pass the 4 baton on to Dick Brady of the NRR Staff, talking about the 5 allegation tracking system that NRR is managing at this 6 time.' l s
7 (Slide.)
8 MR. BRADY: My name is Dick Brady, and I do work 9 at NRR. I'm responsible for the allegation tracking system, 10 or the allegation management system, as it's called. What 11 I'd like to do is just give you a brief presentation on the i
12 NRC policy surrounding the management of allegations.
13 When you talk about allegation management policy 14 in NRC, you' re generally talking about two things. You ' re 15 talking about a manual chapter, a set of rules and 16 procedures, that codifies the policy with regard to 17 treatment of allegations, and you're talking about a 18 computerize tracking system.
19 I'm not going to spend much time talking about a 20 computerized sys tem.- I don' t think it would of terribly 21 great interesi to you.
- g 22 (Sitde.)
23 I will ' spend just a few -moments talking about the 24 manual chapter and what it says and what ws do with regard 25 to allegah, ions. It was put together by the of fice of ACE-FEDERAL REPORTERS, INC.
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b 'DAVbw 1 Inspection and Enforcement, beginning back in the latter 2 part of '82. A small system or set of procedures was put 3 together by that office, to say what the agency's policies 4 would be with regard to the handling of concerns tha t we 5 received for resolution.
6 And in September of '84, Mr. Dircks put out the 7 draf t of that policy guidance. The reason he didn' t put it 8 out in a final was that there were two main issues tha t bore 9 on that. They had not been decided by the Commission. One 10 was the handling of allegations that we received very late 11 in the licensing process, particularly when they came in in 12 grea t numbers , and what the Commission desired to do 13 concerning the issue oT confidentiality. Those people who 14 would come to us with information but desired that their 15 name and other identifying characteristics be kept 16 confidential.
17 Well, the Commission did make those two decisions 18 in March of '85. The issued the policy statement of late 19 filed allegations, and I can talk a moment about tha t, 20 briefly. And they did issue this last month a policy 21 statement on confidentiality.
22 We have in NRR now the responsibility for 23 finalizing tha t chapter, in conjunction with ELD, who is
_ 24 giving us some help. Of course, with I&E and the regions 25 and all the program offices, we get their input. We hope 26 to have that done in the next couple of months.
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2840 02 01 14 u_/DAVbur 1 The major policy areas that are covered in 0517, 2 the manual chapter, are these:
3 (Slide.)
4 It establishes in each major office that 5 generally has to deal with the resolution of concerns an 6 office allegation coordinator. The regions each have such a 7 person, and I&E and NRR and NMSS have them.
8 They are designated for some of the smaller 9 offices, but they don' t get very many allegations for 10 resolution, quite frankly.
11 People like myself are responsible for the 12 receipt, tracking, and the processing of these allegations b
'/ 13 to see that they are addressed by the staf f, that the Shk 14 allegers are contacted, and that they receive feedback as to 15 what we are doing with their concern.
16 Another major area -- and Mr. Dircks put out 17 several memoranda on this -- is our contact with allegers.
18 The EDO has repea tedly stressed the need to treat the 19 allegers with respect, courtesy, and dignity and that we 20 view the concerns we receive in that manner as a vital 21 source of information that can be helpful to us.
22 The contact wi th the licensee, as I said, the 23 confidentiality decision by the Commission was just issued 24 last month, and that will be folded into 0517, the contact 25 with the licensee, and this is where we are talking about ACE-FEDERAL REPORTERS, INC.
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(~s k-)DAVbur 1 if we receive an allegation from an individual and there is 2 no issue of confidentiality at all and there is no problem, 3 say, of a question of wrongdoing on the part of the 4 applicant or licensee, what we will do primarily is turn 5 that concern over to the applicant or the utility for their 6 review. They will make a review. We will ask that they 7 review that concern and get back to us.
8 We will take their report and review it by our 9 staff, and if we agree with it and we think it resolves the 10 concern, we will use it or fold it into a response to the 11 alleger, and we will get back to them.
12 Now, there are two times and two instances here Ol 13 in the contact with the licensee when we don' t go to the 14 applicant or the licensee. If there is a question about the 15 confidentiality of the individual, if confidentiality has 16 been granted, we will not go back to the licensee and ask 17 him for tha t concern.
18 If it is some thing that can be folded in with a 19 number of other concerns that the licensee or the average 20 man would not be able to tell where the concern came from, 21 we could in some instances do it. Normally, we don' t.
22 The other time is that the allegation has about 23 it a concern of wrongdoing on the part of the applicant or 24 the licensee. Obviously, in those cases we can' t go back.
25 So in those two areas, those allegations are ACE-FEDERAL REPORTERS, INC.
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2840 02 03 16 DAVbur 1 covered by the s taf f themselves. In the wrongdoing area, 2 obviously we have the assis tance of the Of fice of 3 Inves tiga tions .
4 The other area that we cover in 0517 is 5 documen ta tion. It is entered into the allegation management 6 sys tem . It is tracked. A hard copy file is kept. There is 7 a hard copy file maintained for each allegation we get.
8 Closecut with the alleger. Here, we are talking 9 about positive feedback to that individual, saying what we 10 did with their concern. We don' t always agree with them 11 obviously, but we do have a requirement to let them know how 12 we view their concern, what we did with it and how we closed
(~)
13 it out.
14 Those closeouts, they are generally by letter.
15 de send them a report. If it is an inspection report we use 16 to close out the concern, we send them a copy of the 17 inspection report and show them where we address their 18 concern. If it is something that has been worked into an 19 SER supplement, they will receive a copy of that.
20 So tha t is one concern. One thing we always do 21 is get back to those people.
22 Now, we get a number of anonymous allegations, 23 and obviously we don' t feed those back.
24 MR. MICHELSON: Is this process the same, whe ther
(
' '-) 25 it is a major or minor allegation?
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'L/DAVbur 1 MR. BRADY: Yes, sir.
2 MR. MICHELSON: No ma tter how minor . you still go 3 through the whole process?
4 MR. BRADY: If we know the individual. Quite 5 frankly, sir, we get a number of allegations that aren' t 6 safe ty significant, but they do fall within something that 7 the NRC would be interested in. We try to get back to these 8 people.
9 Now, it may not take an inspection. It may not 10 take writing an SER. It may just take a phone call, which 11 would be documented in the file. It may just take a letter 12 saying we get someone in industrial health and safety, and O 13 we try to politely tell them that this may not be something 14 that we need to spend a great deal of resources on. We try 15 to get back to those people in every case.
16 And late filed allegations is the other area that 17 is covered in 0517. These are just the main highlights. I 18 will talk about that in just a second.
19 DR. REMICK: Going back to Mr. Michelson's 20 ques tion, is there any screening at all on allegations from 21 the standpoint of putting them aside and either have no 22 bearing upon the activities or interests of the agency or 23 triviality, or must you handle them all in one form or 24 another?
25 MR. BRADY: Certainly, the significance of the ACE-FEDERAL REPORTERS, INC.
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2840 02 05 18 DAVbur 1 allegation, whether it is very general or vague or 2 insignificant, bears a great part of the time we take on 3 it.
4 If it is something that is not clear, that we 5 can' t really discern from a letter or a phone call what it 6 is, we will try to get in touch with that person to 7 understand what their concern is.
8 If it is something that is clearly understandable 9 but is insignificant, you are right, it may not get first 10 priority. We might not work on it first thing Monday 11 morning, but it will be tracked. It will be placed in the 12 system, and as the program manager, I watch those things for (7_)
13 everybody in the agency to see that they don' t hang on too 14 long.
15 MR. WILLIAMS: Excuse me, Dick. I am Mark 16 Williams, from NRR.
17 There is a screening process in Manual Chapter 18 0517, and it is encouraged that you look at whether these
{ 19 need to be resolved for fuel load or full power. There is a 20 prioritization, and there is a review by the staf f for 21 screening of these allegations.
22 MR. BRADY: The specific screen criteria I think 23 we are talking about is in the Commission policy statement 24 on late filed allegations -- I want to talk about that in O 25 just a minute -- where we look at the significance of it, ACE-FEDERAL REPORTERS, INC.
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iJ DAVbur 1 whether it has to be resolved before the licensing. Would 2 it have to be resolved before fuel is on the site? Would it 3 have to be resolved before the low power license? That sort d
4 of thing.
5 There is no screening of allegations, I should 6 tell you, with regard to tracking them. We feel a 7 commi tment to let the people know that we have looked at 8 their concern, so there is no screening of putting them in 9 the system.
10 A number of the regions -- and I think this is a 11 very good idea, but it is not set down in the policy -- use 12 an allegation review board, in which those allegations are
'- 13 reviewed by a number of technical people in the region, 14 possibly the regional counsel, and they can decide ea'rly on 15 that this is not a concern that needs a very high priority
! 16 placed on it because of the nature of the concern or that 17 this is not something that needs to be handled by an 18 inspection. We can simply explain to this individual our 19 position, and that should take care of it.
20 I might just add a note here that a number of 21 allegations that we get turn out to be substantiated, but 22 many of those substantiations are not terribly significant.
! 23 Oftentimes, it is jus t miscommunica tion. An individual at 24 the site just didn' t unders tand some thing, and we thought O^ 25 that somebody ought to look at this, and it might very well ACE-FEDERAL REPORTERS, INC.
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( >DAVbur 1 turn out to be not a major concern at all. But the concern 2 is substantiated because the individual was right, because 3 he didn' t understand what it was he was saying.
4 The next item I want to talk about -- and this is 5 kind of new to me because it was just issued a couple of 6 weeks ago -- is the confidentiality issue.
7 (Slide.)
8 This received a lot of scrutiny by the staff, by 9 lawyers, all of them, and the Office of Investigations and 10 other people had an input into the final confidentiality 11 policy.
12 First off, I would just like to say that it is G '
kl 13 not something that you bring up immediately when you sit 14 down to talk with an alleger. You don' t offer it up front.
15 The Commission views confidentiality, as I 16 believe the Department of Justice does, as a very useful 17 investigatory tool to use when necessary to obtain certain 18 inf orma tion. If you don' t have to grant confidentiality to 19 get tha t information, you are essentially tying your hands 20 to a written commitment of something that isn' t necessary.
21 So we don' t always use it.
22 The new policy statement requires a signed 23 confidentiality agreement with the individual. If we are 24 going to observe confidentiality, there are certain
'- 25 restrictions on the individual as well as on the ACE-FEDERAL REPORTERS, INC.
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,O L /DAVbur 1 Commission.
2 If he has -- to be rather absurd about it -- a 3 press briefing the next day and lays it all on the line, a 4 signgp confidentiality agreement is obviously of not much 5 use.
6 DR. REMICK: Can I have an estimate of the number 7 of people who request confidentiality agreements, the number 8 of allegers? What percentage? Is it half? Three-quarters?
9 A small percentage?
10 MR. BRADY: If I were to tie myself to a number 11 on the ones that we have a signed confidentiality agreement 12 with, Mr. Remick, it would be very small.
13 We treat in the staff, quite frankly, we treat in 14 the staff the name of a citizen, concerned citizen, or an 15 alleger as confidential. We don' t distribute it, say, from 16 my office to the technical staff of the project manager 17 unless it is necessary for them to resolve their concern, 18 even without a grant of confidentiality, and as I said a
19 earlier, we get a lot of anonymous concerns. So it really 20 isn' t an issue there at all.
21 The statement says that the Commission will make 22 its best efforts to protect the identity of a confidential 23 sodrce and that within the NRC, which is what I was talking 24 about, it would only be released on a "need to know" basis.
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25 MR. MICHELSON: Is your tracking system going to ACE-FEDERAL REPORTERS, INC.
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('8' L 'DAVbur 1 be computerized?
2 MR. BRADY: The tracking sys tem, sir, I can talk 3 a few minutes about tha t if you like.
4 MR. MICHELSON: I don' t want all the de tails. I 5 jus t want to know, is it computerized?
6 MR. BRADY: Yes, sir.
7 MR. MICHELSON: Who has access to the tracking 8 sys tem?
9 MR. BRADY: The allegation coordinators in each 10 of the primary offices.
11 MR. MICHELSON: Is this set up by a computer 12 security arrangement so that only certain people can even O 13 get into it?
14 MR. BRADY: There are certain restrictions on 15 getting into it.
16 MR. MICHELSON: Are these the kind of 7
17 restrictions that keep you out of them?
18 MR. BRADY: I do not have in the system the names 19 of allegers, okay?
20 MR. MICHELSON: Where do you find out who the 21 alleger is then?
22 MR. BRADY: There are hard copy files kept on 23 each allegation.
- 24 MR. MICHELSON: If you went through the tracking
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- 25 system, is there a code number of a code name that gets you ACE-FEDERAL REPORTERS, INC.
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(^JDAVbur s- 1 over to the alleger?
2 MR. BRADY: Each allegation has a specific 3 number. I will talk about the documenta tion.
4 MR. MICHELSON: And then it is only kept in hard 5 copy?
6 MR. BRADY: That is right, sir.
7 MR. MICHELSON: And in only one place?
8 MR. BRADY : That is right, sir.
9 The allegations are specifically numbered. When 10 you pick up an allegation file and see a number on it, after 11 you have worked with them for a while you can tell which 12 of fice has the responsibility to resolve that allegation.
\s) 13 MR. MICHELSON: And they are the ones that have 14 the hard copy?
15 MR. BRADY: That is right, sir.
16 The confidentiality statement, as set out by the 17 Commission, does have several provisions in it, obviously:
18 when we would have to release the identity by order of a 19 court and the one here that says there are certain 20 exceptions here that I am not totally f amiliar with, but by 21 order of the Commission.
22 It talks about in this case if an adjudicatory 23 body of the Commission, boards or panels, needed or thought 24 they needed of an alleger to understand a certain concern,
(")
\- 25 the Commission itself would order that that identity be ACE-FEDERAL REPORTERS, INC.
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2840 02 11 24 DAVbur 1 released to the parties. There is another exemption that 2 generally deals with other federal and state agencies that 3 have a public health and safety job to do.
4 Again, there are provisions for contacting the 5 alleger, saying would you permit us to give the individual 6 your name. If he says no, then we have to go up several 7 more levels to get permission. We can sometimes release the 8 name even without his permission. If it is a matter of 9 public health and safety or some other department, the 10 Department of Jus tice, says we mus t have tha t informa tion, 11 then obviously we do.
12 There are times when we have a written request O
13 from Congress for the name of an individual. We advise 14 Congress of our Senfidentiality agreement with this 15 individual. We ask them to honor it. And then we would 16 provide the informa tion.
17 (Slide.)
18 The next thing I would talk about just briefly --
19 I have to apologize a little bit for this slide. I looked 20 at it last night, and it is not exactly what I would like, 21 but it tells you how we got to the policy on late filed 22 allegations rather than what that policy is. But I will try 23 to run through it as best I can. -
24 As I said earlier, the policy on late filed 25 allegations was approved in March '85 by the Commission, ACE FEDERAL REPORTERS, INC.
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.2840 02 12 25 DAVbur 1 published in the Federal Register.
2 We got to that point because on several of the 3 facilities we received very large numbers of allegations 4 just prior to a critical licensing decision, and the staf f 5 and everybody had to have some guidance as to how to deal 6 with these concerns that came in at the eleventh hour.
7 The policy statement in its sort of preamble 8 stresses the responsibility of all people to bring the 9 concerns to the applicant or the licensee or NRC as soon as 10 possible, and it does set up, as Mr. Williams was saying, 11 certain screening criteria.
12 The screening criteria, as I understand, are a 13 carryover from screening criteria that were used from Diablo 14 Canyon. They established certain criteria to deal with tha t 15 situation before the Commission had a policy on it.
16 That was approved in that instance, and then it 17 was carried over in a modified fashion into the present 18 position tha t we have.
19 It says, essentially, look at the allegation, and 20 if it were to be true, is it something that would have to be 21 resolved before the licensing stage you are about to 22 authorize; in other words, something, as I said earlier, 23 that has to be resolved before the fuel can be onsite; that 24 is, is it something that has to be resolved before low O 25 power, full power, et cetera?
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1,_/ DAVbur 1 There are other screening criteria. What is the 2 likelihood the allegation is true? Does the alleger know 3 what he is talking about? Does it appear that he knows what 4 he is talking about?
4 5 If these things all come up with a positive 6 indication, yes, we have to resolve it before this decision, 7 yes, it appears credible on its face, then we are bound to 8 review that allegation and come up with a resolution before 9 that licensing decision is taken.
10 DR. REMICK: I understand then, once again, this 11 does not enable you to throw any out; it just sets the 12 priority of when you would pay attention to it?
f~h kJ 13
- MR. BRADY: Tha t is exactly right, sir. That is 14 exactly right. There are some allegations -- we don' t throw 15 any out, but there are some that come in, and not 16 necessarily any more at the eleventh hour but other times, 17 that are just too general or too vague to be of any 18 signficance to the s taf f. They just can' t do anything with 19 them. We have those, and we can take our best shot at them 20 and do the best we can with them, qui te frankly.
21 If you get an allegation that says, you know, the 22 program stinks, what are you going to do?
23 You can look at your inspection program, and that 24 is all you have done with it. But if that is all you have O
\' 25 and you have no name, you have to push on, quite frankly.
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-(e / DAV/bc 1 (Slide.)
2 I talked earlier about allegation processing, 3 sort of how it works. An allegation is received by any NRC 4 individual. We have, as I say, allegation coordinators, 5 with the primary of fices in the regions.
6 But, anyone can receive an allegation. The NRC 7 employee should get as much information as he can and get it 8 to an allegation employee.
9 The allegation is documented. We en ter i t in to 10 the system. We keep'the hard copy files, as I mentioned.
11 One other point. The Allegation Review Board, most regions 12 are using them now and it gives several dif ferent O 13 perspectives on allegations.
14 They will review it, decide which division or 15 which group in the region, for instance -- I keep sort of 16 picking on the regions. I ought to tell you something up 17 front. Out of a hundred ordinary allegations, probably 18 ninety of them are in the regions, and in the regions for 19 resolution.
20 That's generally because most of the concerns 21 come during the construction phase. They are things that 22 you may have to look at or put your hand on to say this is 23 how i t's resolved.
24 NRR resolves some allegations. They' re the kind O 25 generally where we have to look at the code, or go back and ACE-FEDERAL REPORTERS, INC.
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2840 03 02 28 7-hsDAV/bc 1 look at some commitment that was made by the licensee or 2 s ta f f to see if it was me t or not me t.
3 It's those kind of analyses and evaluation things 4 that the staf f looks at, more so in NRR than in the 5 regions. But, most of the allegations are handled by 6 regional staff.
7 DR. REMICK: If the applicant receives the 8 allegation and handles it, need they notify the NRC? And 9 this then comes under the NRC list? Or can they handle it 10 on their own and you monitor what they do with it? How is 11 that handled?
12 MR. BRADY: The latter. There is a body of G 13 thought that says the allegation system should have 14 everything in it, that you should put all of the concerns 15 out of 2.206 petitions in it, that you should go through the 16 hearing record and you dump all that in it and anything else 17 you can find, you dump in it.
18l If Fermi has a quality first team or safe team 19 program of resolving allegations, you take all those and 20 dump tha t into it. That I think is incorrect; I don' t 21 support that. Right now, tha t's not the policy. Those 22 applicants and licensees that have programs for resolving 23 allegations are being reviewed by the staff.
24 You look a t the processes. Bu t we dont' subsume A
U 25 their allegations into ours. We have an interest in them, ACE FEDERAL REPORTERS, INC.
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2840 03 03 29 DAV/bc 1 certainly. We have an interest in the procedure for 2 resolving them. We look at them. We do not individually 3 take them on ourselves.
4 MR. MICHELSON: Do you have ready access to that 5 informa tion? You see, what I'm getting at is, if you 6 receive a particular allegation, how do you know that it 7 doesn' t fit a pattern of allegations, most of which have 8 ended up with the utility, or whatever?
9 MR. B RADY: To answer your question, we have not 10 had a problem with access to the allegations. Possibly, 11 someone from I&E who knows the inspection business better 12 than I can speak to it. . .but it's been my experience that
\l 13 the senior resident inspectors have complete and open access 14 to the files.
15 MR. MICHELSON: Are the utilities required to 16 maintain files of these allegations in some ctganized 17 fashion?
18 MR. BRADY: I want to answer your question this 19 way. The Commission's posture with regard to applicants' 20 allegations programs is right now in a state of 21 development. The Office of I&E is preparing a paper, I 22 'believe, that will be forwarded down to the Commission for 23 their review as to what we really should do with regard to 24 the quality first programs, the safety programs and those O 25 other programs run by the utilities, to look at allegations ACE-FEDERAL REPORTERS, INC.
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l /DAV/bc 1 tha t come to them.
2 MR. MICHELSON: I guess the inference is it's a 3 mixed bag out there as to how well they have documented and, 4 therefore, how readily you can find out what kind of 5 allegations have been given to the licensee.
6 MR. BRADY : I think it's probably a fair 7 statement to say that probably some licensees do a better 8 job of documenting the results of their allegations than 9 others.
10 MR. MICHELSON: In the case of an anonymous 11 allegation, do you put it into your tracking system at all?
12 MR. BRADY: Yes, sir, we do.
(~h
\ 13 MR. MICHELSON: Even though, of course, you don' t 14 know the source?
15 MR. BRADY: We track the resolution of it even if 16 we don' t or can' t ge t back to the individual to let them 17 know what they do with it.
18 MR. REED: I'm wondering if you aren' t 19 structuring turmoil in the workplace. We all know that in 20 construction activity, 3,000-4,000 constructions workers, 21 and a good number of them are drif ters and bad characters, 22 and we all know that the NRC on the one hand keeps saying to 23 the licensee: tighten up your act. Fire your drugees, 24 discipline this and discipline that. And, yet, when the O 25 licensee, we see these reported every day, when the licensee ACE-FEDERAL REPORTERS, INC.
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2840 03 05 31 DAV/bc 1 disciplines somebody, he has now created a potential 2 alleger. He has created a dissident if he didn' t already 3 have one in the first place, based on the character of the 4 person that was there.
5 Now, the other part of the NRC says: pay 6 attention to all this. How do you separate the drugee, the 7 dissident, the good-for-nothing, and the activist, even an 8 activist, from the genuine?
9 MR. BRADY : I don' t know about the other people 10 who receive allegations and attempt to resolve them, but I 11 personally have no mechanism to determine an individual's 12 motive when he comes to me uith a concern. I try to look a t 13 them all as being forthright and honest and having a concern 14 tha t's deeply felt that they would like to have the agency 15 responsible for the public health and safety look at.
16 I do not attempt, and I don' t think others 17 a ttemp t to look at the source of the allegation and say:
18 These people are drugees or these people are dissidents.
19 MR. REED: You mean, you don' t look back into the 1
20 record and see if this man was terminated or disciplined for 21 marijuana in the workplace?
22 MR. BRADY: Certainly, there are times when we 23 get into those. Those are generally handled by the Office 24 of Investigations, when a person's background may have a O 25 bearing on the voracity of his comments.
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2840 03 06 32 C) k 'DAV/bc 1 But I'm saying we don' t disregard those and do 2 nothing with them.
3 MR. REED: That's the basis of my opening 4 comment. We are creating turmoil in the workplace so, 5 eventually, the workplace will accomplish very little.
6 MR. WARD: Dick, could I in terrup t?
7 It doesn' t look like we' re going to get. .
8 MR. B RADY: I'm just about finished, sir, for my 9 part anyway.
10 MR. WARD: But I'd almost accept by stipulation 11 that you have a very comprehensive and disciplined program 12 for looking at allegations.
O
\' 13 But wha t I'd hope to hear a little bit more about 14 was the need for the program, your assessment of what it's 15 accomplished. Are you going to be able to tell us? I don' t 16 see anything on the last slide. Are you going to tell us 17 anything about the cos t of the program to the NRC? The cost 18 of the program to the applicants? And whether there's been 19 any attempt to make some sort of a cost benefit assessment 20 of the program and, in particular, have there been 21 allegations that have identified significant safety problems 22 to which you could really ascribe some benefit?
23 Or, are all the benefits perhaps public relations
, 24 and political benefits?
(- 25 MR. BRADY: With regard to specific allegations, i
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2840 03 07 33 L / DAV/bc 1 I wouldn' t want to try to give out the kind of specifics 2 that might endanger someone's private interest or names.
3 But there have been a number of instances.
4 We get a great many allegations. Some of those 5 are safe ty-significan t. Some of those are substantiated.
6 And some of those turn out to be something that we didn' t 7 have anything on before as to the cost of the program. And 8 I can give you some examples of those if you'd like.
9 There's some people in jail right now, I can tell 10 you that, because of an allegation that we received, that we
- 1) investigated it and finally turned it over to the Department 12 of Jus tice. It was very true.
O k- 13 So they' re not all, you know, you have to 14 separate the wheat from the chaff. The reason for the 15 expenditure of the funds is because, in there somewhere, 16 there are some valid allegations that we need to know 17 about. I do not have, sir, information on the cost of the 18 program that I'm responsible for.
19 As far as the allegation tracking system, we 20 spend very little money, quite frankly, on the ADP system, I 21 can tell you that. Less than $40,000. But if you' re 22 talking manyears, FTD's, contract dollars for resolving 23 allega tions , I don' t have that kind of information.
24 Quite frankly, it's not within my purview.
O 25 MR. WILLIAMS: Let me just say a few words. Mark ACE FEDERAL REPORTERS, INC.
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k- DAV/bc 1 Williams, NRR.
2 The program has been evolutionary since Diablo 3 Canyon. It's evolved since that time into a manual chapter 4 and formal procedures. The Commission has issued some 5 policy guidance in that evolutionary process. I'm not aware 6 of any real cost benefit analysis that we went through.
7 I think it's clear that there have been safety 8 benefits f rom the program. And, if not, the outgrowth of 9 the program, once you get these concerns back up to the 10 utility or the licensee.
11 The staf f reviewed these for generic 12 implica tions, and the utility has to. review them for generic b'
13 implications. And I think there are examples, whether it be 14 Diablo or Comanche Peak or Waterford, or some of the other, 15 more normal plants , because those really are outliers, real 16 safety improvements that resulted from the treatment of 17 allegations. The exact number of allegations which resulted 18 in some safety improvement, I think would be a very small 19 number.
20 But, again, it's hard to ignore any allegations 21 that you receive.
22 MR. WARD: Why is it hard to ignore them? What 23 would happen if they were ignored? What do you run into?
24 Wha t if you said, for Plant X, we've got a new policy, a A
25 pilot program. We' re going to ignore all allegations. What ACE FEDERAL REPORTERS, INC.
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k DAV/bc 1 would happen to you?
2 MR. WILLIAMS: Let me try to talk in terms of the 3 screening criteria. Rather than ignoring the allegations in 4 the screening process, you do resolve on a schedule 5 consistent with the priority of the allegation, resolve the 6 allegation. Rather than ignore it, we resolve it.
7 But we just have not wholesale put a block of 8 allegations aside or submitted it to the NRC s taf f as 9 concerns.
10 Jim Knight has some experience in resolving 11 allegations on Diablo and other plants, and he can talk a 12 little bit more to our motives for not putting them aside.
13 But we just haven' t wholesale ignored a block of She 14 allegations.
15 MR. WARD: You see, my problem is he gave an 16 example of an allegation that put somebody in jail, which 17 may be in teres ting . I don' t understand if there's any 18 direct relationship to the Commission and the NRC, which is 19 to protect the public health and safety from radiological 20 accidents.
21 The fact that thera is an occasional benefit, and 22 at least occasionally some safety-related problem is 23 identified, that in itself is not enough justification for a 24 program. You know, I could ascribe a safety benefit to a O
V 25 second and third scram system on a reactor. But if it's not ACE-FEDERAL REPORTERS, INC.
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2840 03 10 36 DAV/bc 1 cost beneficial, I wouldn' t be very interes ted in seeing it 2 put on. And I don't think anybody else would, in an era 3 when the budget of the NRC is being reduced; when there's a 4 cap on the total resources, the NRC has to promote the 5 protection of public health and safety.
6 It just seems to me that programs of this sort 7 need to be given the scrutiny of the best cost benefit 8 analysis and I'm disappointed that there apparently doesn' t 9 seem to be any move in that direction.
10 MR. PARTLOW: Excuse me. I'm Jim Partlow, from 11 I&E. You know, the protection of the public health and 12 safety is in the eye of the public health and safety.
A
\'-] ,
13 They're the ones that decide whether they are 14 being protected or not. So this matter of let's just forget 15 all allegations when you say: What would happen if the 16 staf f got guidance and direction from the Commission to do 17 tha t.
18 Well, what would happen is tha t is what would 19 happen. But, Chairman Palladino's draf t policy guidance to 20 the staff for FY-86, calendar year '86, speaks to a shared 21 responsibility for safe construction and operation. And the 22 staf f is held accountable and signs off. NRR signs off.
23 The regional adminis tra tor signs off. The Director of I&E 24 signs off and says that the shadows of doubt have been O- 25 removed and the plant is ready for licensing.
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2840 03 11 37 L /DAV/bc 1 So when you're put in that seat and the 2 allegations come to you, the ability to say there can' t be 3 anything here is a tough job to do.
4 So what the staf f is doing in its responsibility 5 when it gets these allegations is, sure, there's some 6 sif ting that goes on. The resident inspectors are probably 7 the main ones that have to deal with that. I, here in my 8 job, have received two allegations in two years that I had 9 to deal with. The resident inspector probably deals with 10 many, many more than tha t.
11 Somebody has to decide and those people af ter the 12 fact are held accountable. So tha t's the game we're in, n
Yl 13 allegations resulting in safety-related changes in the 14 plant. The yield may be only 5 percent, 10 percent, 15 15 percent. I don' t know what the number is, but it is greater 16 than zero; it represents shadows of doubt.
17 And the responsible staff is going to look into 18 those things before they say tha t they' re going to sign of f, 19 tha t the plant is ready to license.
20 In terms of the resouces, I can only give you a 21 few numbers. In the last few years, we felt the need in our 22 I&E budget to actually budget with a line that says follow 23 up on allegations and support to the Of fice of the OI to 24 give them technical support.
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25 For example, in FY-85, this past fiscal year, for ACE-FEDERAL REPORTERS, INC.
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( 2840 03 12 38 s, ,
DAV/bc 1 following up on allegations, we've budgeted for an extra 17 2 FTE fulltims equivalent people. And we spent something like 3 32.
4 But even that number doesn' t capture how much 5 time was spent on allegations. It captures, to the best we 6 can, regional inspectors saying, well, today, I'm following 7 through on' an allegation, not doing my inspection procedure.
8 But, really, ' resident inspectors were really 9 spending much more time than that on allegations. But 10 tha t's one example of our forethou,qht, what we' re able to 11 . get in the budget. We' re spending almost twice tha t much 12 this past year.
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2840 04 01 39 MlhDAVbur 1 MR. WARD: When I asked what would happen, sort 2 of hypothetically, if you didn't respond to allegations at 3 all, what I was trying to drive at is: this kind of 4 elaborate program, is it a result of the staff 5 interpretation? Is it a result of Commission guidance? Is 6 it a result of pressure from the Congress, or is it a result 7 of what is written in the atomic energy law?-
8 MR. PARTLOWs Yes. My personal view is that the 9 driving force is the feeling of accountability in the staff 10 and management.
11 We don't have any specific direction -- somebody 12 correct me'if I am wrong -- from the Commission to do it the O
\- 13- way we are doing it. The guidance is rather general.
14 That is my view. It is the feeling of what the 15 job is of the staff.
16 DR. REMICK: If the Commission's regulations on 17 construction were such that there were hold points or 18 certification points where somebody signed off at this 19 point -- we have inspected this and we are satisfied, and 20 you sign -- do you think that would help the staff later on 21 if an allegation came in and said we know there are holes in 22 that concrete? But if that had been a hold or certification l 23 point, do you think the staff could have thrown out those 24 allegations, or do you think they would still want to go
() 25 back end look into it?
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i 0 2840 04 02 40 jlgDAVbur 1 Do you know what I mean? Would certification 2 points help the staff not have to go back and reinspect 3 something that was inspected two years ago or three years 4 ago?
5 MR. ANKRUM: There are elements of exactly what 6 you are describing in the readiness review program.
7 Although there is not a formal hold point, there is a 8 presentation of a module of work by the licensee, including 9 their self-assessment of how wel'. they fulfilled their 10 commitments and the regulatory requirements.
11 Then there is a staff review of the licensee's 12 self-assessment in that ana a sign-off by the regional
,s
(,) 13 administrator once that review is complete as to whether or 14 not we agree with the utility's self-assessment.
15 We in fact have several of those under our belt 16 now, and the one that springs most easily to mind, we found 17 a number of deficiencies -- let me correct that -- the 18 utility found a number of deficiencies in their 19 implementation of the Commission's regulations and their own 20 commitments in their self-assessment.;
21 We reviewed all of that work, went back over old 22 inspection reports, made new inspections, and we agreed with 23 the utility's assessment, raised some questions about how 24 the utility chose to resolve some of the issues that they
() 25 generated. We didn't generate any new concerns as a ACE-FEDERAL REPORTERS, INC.
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2840 04 03 41
([j DAVbur 1 result -- concerns, that is, that the utility had not found 2 in their own self-assessment.
3 We did question the way that they resolved some 4 of those concerns. We have a considerable documentation 5 based on that, and the regional administrator accepted the 6 utility's assessment that they had met the Commission's 7 regulations, their own commitments, and the law for that 8 category of work they had assessed, and the regional 9 administrator accepted the assessment and said on behalf of 10 the NRC that the NRC staff accepted that assessment and said 11 we agree with it and we were not going to revisit that 12 particular work unless some new safety concern, about which
() 13 we.had no previous knowledge, were to make itself evident.
14 So we have said in the readiness review that we are not 15 going to go back and look at that work.
16 If an allegation came in at the last minute with 17 questioning records, questioning work in that area, we feel 18 that we would have a very strong basis to assess the 19 validity of that allegation, and it might not be necessary 20 to go back and perform another inspection or another review 21 of records, 22 For instance, if the allegation had something to 23 do with the adequacy of records or if it had anything to do 24 with a particular design that we had dealt with in the
() 25 readiness review, we would be able to resolve that ACE-FEDERAL REPORTERS, INC.
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2840 04 04 42 jlgDAVbur 1 allegation without any additional work.
2 That is one of the purposes of the readiness 3 review, is to be able to deal with last minute allegations.
4 Another purpose is to deal with the things that 5 might be wrong with that block of work as early as possible 6 so they don't become last minute issues.
7 Georgia Power tells me that they feel that the 8 program, as it is progressing right now, is doing that very 9 effectively. They are finding things that would not have 10 been found, but they have accepted the last minute 11 allegations.
12 I shouldn't say would not have been found, but
() 13 have typically turned up at the last minute as last minute 14 allegations.
15 They are resolving those things now, and we are 16 assessing their resolution, and we are also looking to see 17 if any of these things that they are finding have cost 18 cutting implications.
19 What we are finding is that, as Dr. Siess said, 20 there is no such thing as a perfect job. There are errors.
21 But we are finding that they are isolated instances. We 22 have not found anything at that plant yet that would be 23 generic, that would call into question some broad area of
~24 the plant.
() 25 We are finding individual things wrong. We are ACE-FEDERAL REPORTERS, INC.
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l l
2840 04 05 43
$lhDAVbur 1 finding things wrong. They are turning out to be 2 individual things.
3 They are being corrected, and we think we cr-11 4 have a very firm basis for dealing with any last minute 5 allegations should they arise.
6 DR. REMICK: It will be interesting to see.
7 MR. KNIGHT: Jim Knight, from the NRR staff.
8 Having lived through Diablo Canyon and Waterford 9 and parts of Comanche Poak, we find that in a large number 10 of instances you could argue that in fact a number of the 11 allegations from a pure safety standpoint didn't have an 12 impact on the plant, even those which were substantiated,
() 13 even those where we caused the utility or the utility took 14 the initiative to go back and do something physically to the 15 plant.
16 Still, I think if you expose it to a hard-nosed 17 cost / benefit analysis we would find it difficult to say, 18 yes, there was in the final analysis the definite safety 19 improvement here if you define safety as the overall 20 function of the plant.
21 If, however, as we must, we are bound to say 22 there are intricate lists of requirements to build a nuclear 23 plant, down to the last piece of hardware, and safety 24 systems and that our mendate is to see that all of those
() 25 requirements are indeed kept faith with and put into place ACE-FEDERAL REPORTERS, INC.
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r 2840 04 06 44 1 and the last piece of paper is there and the documentation
(()DAVbur 2 of the last cotter pin and self-locking nut is there, then 3 when you went back and looked at the allegations you would 4 say a large number of them were true, a large number of them 5 required someone to do something to complete the regulatory 6 requirements.
7 I guess certainly if we go back and look at the 8 atmosphere which prevailed at the time of the licensing of 9 Diablo Canyon, it was politically and philosophically 10 unacceptable, by any stretch of the imagination, to do other 11 than to take every one of those situations and pursue them.
12 But if there is anything to be gained, we might
() 13 take a hard look at what are the requirements of the place ,
14 and how broadly, how meaningful are some of the quality 15 requirements.
16 DR. REMICK: Thank you.
17 MR. WARD: Okay. I really don't mean to be 18 critical of you gentlemen and your efforts, given the 19 guidance that you have had or the interpretation of the 20 guidance you have made. This is a comprehensive 21 professional program.
22 But, you know, I think there is kind of a 23 philosophical question about the mission of the agency, and 24 it just seems to be most extreme in these programs.
() 25 Is the mission of the agency to protect the l
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$lhDAVbur 1 public health and safety, or is the mission of the agency to 2 satisfy all members of the public that its health and safety 3 is protected?
4 And Mr. Partlow came down very hard on the latter
'S in the statement you made, that your mission is to satisfy 6 the public that its health and safety is protected rather 7 than to protect.
8 So it goes back a ways into the philosophy of 9 regulation, but at other meetings we run across situations 10 where a program that seems to have more direct connection --
11 at least analysis shows it is more directly connected to the 12 protection of public health and safety -- is delayed because
() 13 of lack of resources, caps on manpower, and so forth, within 14 the agency, and I wogger if this program is subjected to the 15 same sort of analysis that, for example, generic issues are 16 subjected to and prioritized as far as staff resources. I 17 wonder how this would come out.
18 DR. REMICK: Are you pretty well finished?
19 MR. BRADY: Gentlemen, I have finished my 20 presentation, and I wanted to talk about --
21 (Slide.)
22 I have one last slide. I really don't have any 23 comments to add. This slide is just a selection of some of 24 the plants that I think are on the management review
() 25 report. I believe that is what it is called. And I have ACE-FEDERAL REPORTERS, INC.
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2840 04 08 46 qllDAVbur 1 pulled off the names of the plants and some of the open 2 allegations that we have in there in our tracking system.
3 It gives you some idea of the range of the 4 numbers of allegations that we have. There is no sorting 7
5 here with regard to what is significant and what isn't.
6 These are the numbers of entries in the allegation system 7 that are still open, have not been closed out, as of about 8 the end of November.
9 So it is just a representative sample.
10 DR. REMICK: Have you observed any relationship 11 between those utilities that have a good program for 12 handling allegations and the numbers of allegations that the
() 13 NRC receives? Is there an inverse relationship?
14 MR. BRADY: I don't have any real good figures on 15 that. I really don't.
16 As I say, the staff is in the posture right now 4
17 of putting together what will be the recommended policy, 18 working with utilities' allegation programs, our own 19 programs.
20 We have not done any correlation to see if there 21 is a good program at Fermi. Is the number of allegations on l
22 Fermi down or up? l l
23 Sometimes we find -- this is almost an aside --
24 but sometimes we find that the allegations that go to the
() 25 applicant or the licensee will come to us as well, and they ACE-FEDERAL REPORTERS, INC.
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2840 04 09 47 MlhDAVbur 1 are duplicated that way.
2 So we wind up resolving on our own some of the 3 same things. But that has not been a big problem.
4 But to answer your specific question, Mr. Remick, 5 no, I don't have that information.
6 DR. REMICK: Do you have any kind of a gutsy 7 feeling?
8 MR. BRADY: I wouldn't hazard a guess on that.
9 Is there anything else that I might be able to 10 answer about the agency?
11 DR. REMICK: Let me ask a question on 12 clarification. What we are hearing now is basically all we Il
\_e 13 are going to hear on the allegation program, am I correct, 14 Ted?
15 MR. ANKRUM: Correct.
16 DR. REMICK: I will alert the subcommittee if 17 ther are questions.
18 Are the NRR people going to be leaving?
19 MR. ANKRUM: I would like to ask them to stay 20 until we get through the formal part and develop the Q&A.
21 DR. REMICK: Any other members of the 22 subcommittee have questions before we leave this subject on 23 the handling of allegations?
24 (No response.)
( 25 DR. REMICK: Seeing none, let's proceed to the ACE FEDERAL REPORTERS, INC.
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2840 04 10 48 gAVbur 1 next topic.
2 Thank you very much, Mr. Brady.
3 MR. ANKRUM: I would like Mr. Partlow, then, who 4 is Director of the Division of Inspection Programs in I&E, 5 to give a brief overview of our initiatives in the 6 inspection programs area.
7 (Slide.)
8 MR. PARTLOW: Thank you.
9 There were some earlier questions about what are 10 the different programs and the difference between them and 11 who started them, and so forth.
12 So I would like to just take a brief walk through
() 13 our general inspection program, and I think I will be able 14 to address a number of these things.
15 Has that handout been handed out, Rich? It is 16 about five pages. It is called "The NRC Inspection 17 Program."
18 First, IE did a reorganization almost a year 19 ago. That is the current chart up there now.
20 So I have the Division of Inspection Programs.
21 Richard Branston handles construction and Branston handles 22 reactor operations, and a third branch that handles the 23 other things we do in the area of materials, fuel 24 facilities, medical administration, and so forth.
() 25 Then in the other division on the other side, it ACE-FEDERAL REPORTERS, INC.
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2840 04 11 49 1 has quality assurance -- that is where Ted comes from -- our
$lhDAVbur 2 vendor inspection program, which you know is now well 3 underway here in Washington, and the technical training 4 center down in Chattanooga.
5 The reorganization did not change Ed Jordan's 6 Division of Emergency Preparedness and Engineering 7 Response. That division is still pretty much the same.
8 So I am going to speak mainly about our 9 inspection program some and how it relates to the division, 10 with quality assurance, vendors, and so forth.
11 The first sheet is just some general objectives 12 of the inspection program. Again, most of this is not new
() 13 to you. We do feel that we are in the business of verifying 14 compliance as well as evaluating utilities' performance in 15 carrying cut the regulatory program.
16 You all know of the acronym SALP, systematic 17 assessment of licensee performance. That is our way of 18 evaluating performance, both in construction, in pre-op, and 19 in operations. That is the SALP program.
20 It seems to be working rather well. Every 12 to 21 18 months a line is drawn on a date, and the staff, which 22 means the regional office as well as NRR and IE, attempt to i
23 bring together an evaluation of the utilities' performance 24 in various functional areas.
l () 25 DR. REMICK: If I could just interrupt you a I
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2 Just recently, I was at a meeting where a member 3 of a utility who had intended to be there, who had planned 4 to be there, had to cancel out because he had been informed 5 that there was going to be a SALP evaluation on a certain 6 date.
7 He indicated, he said, well, can't it be some 8 other date? And he was told, no, this is when the SALP 9 visit is going to be; there must be some kind of a visit.
10 So he had to be involved. Then at the last 11 minute the NRC canceled it.
12 But when you say it is working fine, I think some
() 13 people froa the other side have some complaints on that, and 14 it becomes very important on the staff side, when they set 15 it up, that then they can cancel it after making the 16 arrangements.
17 This just happened within the last week.
18 MR. PARTLOW: I bet I know.
19 DR. REMICK: Maybe I shouldn't have said when it 20 happened.
21 (Laughter.)
22 MR. PARTLOW: Often, after the staff has prepared
- 23. this SALP evaluation, they then meet with utility management 24 to try to make sure they understand it. That is an
/")
(_j 25 important part of it, and that shouldn't happen.
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2 40 05 01 51 F DAV/bc 1 As we allocate the resouces that we can allocate 2 to conduct inspection, of course, we allocate them on the 3 type of facility on where the facility is in its life 4 between construction, preoperational testing, startup and 5 opera tions .
6 Of all the inspection resources tha t we have, 7 about 90 percent of them are dedicated to power reactors.
8 The other 10 percent are involved in the fuel cycle and 9 materials, and so forth.
10 When it gets down to how much inspection is 11 conducted at each of the plants then, it varies according to
- 12 those little round numbers that I gave you there upon what 13 the s tatus of the plant is.
14 These are numbers, round numbers for the current 15 , fiscal year, FY-86. It shows tha t our peak time , by the 16 way, for budgeting purpose, the preoperational testing 17 phase, we just call 18 months prior to the projected 18 licensing date, tha t is the heavies t period of our 19 inspection ef fort.
20 The construction resident is still on board and 21 some final construction activities are taking place. Our 22 people are there reviewing the precperational testing 23 program and our people are there reviewing the development 24 of the operational program prior to licensing.
7-)
[
\J 25 It falls of f a little bit then in what we call t
l dCE FEDERAL REPORTERS, INC.
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(~JDAV/bc k 1 the startup period. But it still remains larger than it was 2 for construction, and larger than it is for routine 3 operations.
4 We consider that period that we call the startup 5 period to be for about two years. So, the first two years 6 of a unit's operation gets some extra inspection emphasis 7 from us.
8 Then, finally, about 4 FTE per year during 9 opera tion. Now, again, to remind you, these numbers do not 10 mean that there are four people at a nuclear power plant all 11 year around. These are fulltime equivalent positions.
12 So, for example, this is a combination of the O- 13 resident inspectors who are on site basically for a 40-hour 14 week, plus a number of dif ferent regional specialists, who 15 each go to a plant to contribute in their area. But these 16 are round numbers tha t we budge t for.
17 Now, we try to temper this based upon our best 18 view of the plant's regulatory performance. That's sort of 19 how this SALP program fits in. Our policy is that these 20 general numbers for plants will be modified based upon 21 pe rformance.
22 So tha t, to the extent we're able to draw the 23 right conclusions about performance, our intent is that a 24 plant with superior performance receives less inspection in
/~)#
25 the future and the plant with not that kind of performance ACE-FEDERAL REPORTERS, INC.
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2840.05 03 53 DAV/bc 1 will get more of that time.
2 So, at the end of a year, when you put toge ther 3 some numbers to show the overall number of inspection hours 4 at various plants in the same status, the numbers are not 5 all the same. In general, they come out. The plants that 6 you might see with the number of SALP ca tegory III's, which, 7 of course, is the lower end of the performance scale, have 8 received more inspection during that year than the plants 9 with categories I through II.
10 DR. REMICK: Jim, these are I&E inspections 11 you're referring to. But NRR conducts an inspection on 12 their own. Is that correct? On certain things. I'm f'\
G 13 thinking of one. There as a recent flap on a 14 post-accreditation inspection that was conducted by NRR.
15 MR. PARTLOW: We try to keep our nomenclature 16 clear. Normally, if it's called an inspection, it's 17 something tha t the region or IE has done. But NRR is in the 18 business.
19 Jim, of course, knows more about this, but they 20 are in the business of audits, on site audits. These take 21 place in the form in conjunction with their review of an 22 acceptance of a piece of paper of some kind. They often 23 feel a legitimate need to go on site and take a look.
24 DR. REMICK: They're not included in your O 25 figures?
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2840 05 04 54 b>DAV/bc a 1 MR. PARTLOW: That's right. So that's going on 2 in the training accreditation area. It goes on on the SPDS 3 systems, control room habitability, those things are going 4 on. But they' re not inspection numbers.
5 The second phase, what I call the three basic 6 segments of inspection again, the resident inspection 7 program -- and by the way, the resident inspection program 8 is generally intending to grow. We now have two resident 9 inspectors, ~ construction resident inspectors at construction 10 sites , where, traditionally, we have had but one from the 11 time that the resident program started in 1978-79.
12 And we are adding to our resident inspectors in 13 the opera tions area. Traditionally, our single unit 14 operating sites have had but one resident inspector. In the 15 current year's budget, there are some 37 or 38 of those 16 sites. FY-86, our budget calls for manning of about half of 17 those sites, with two resident inspectors.
18 Most of the remaining ones would be manned by two 19 resident inspectors in FY-87 subject to how our budget comes 20 out.
21 DR..REMICK: Those 37-38, were those single unit 22 sites?
23 MR. PARTLOW: Single units where the plant is in 24 opera tion.
O 25 MR. WARD: If I look in the NRC phonebook, it ACE-FEDERAL REPORTERS, INC.
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2840 05 05 55 A DAV/bc 1 looks to me like there are two or more residents at each 2 site. Maybe I'm interpreting those data incorrectly.
1 3 MR. PARTLOW: A couple of things on tha t . Of 4 course, the secretaries are listed. Each site has a 5 secretary assigned on at least a part-time basis.
6 So, again, you go by the budget and the plan.
7 Every site would have from one to three resident inspectors 8 by budget, by policy, assigned to it. In a number of 9 regions, there is a general move to put more people on 10 site. IE does not object to that. If the region wants to 11 take one of its budgeted resources for a regional inspector 12 and spend that FTE with an additional resident at some site, O 13 we allow him to do that.
14 A second thing that you're seeing going odhis we 15 are hiring more young, relatively junior people. They are i
16 not full-fledged, qualified resident inspectors, but the 4
17 regional administrators think that when we first bring them 18 aboard, it's a good opportunity to send them out to the site 19 in sort of a training assignment for six months to a year.
20 So they' re ' also probably lis ted.
21 MR. WARD: Thank's. I appreciate the
, 22 information.
23 How long does an operating plant resident 24 inspector stay at a given site? I know it's a relatively O 25 new program. What's your philosophy there?
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,- s
(
L>)DAV/bc 1 MR. PARTLOW: A couple of things.
2 -We have no fixed tour for the resident inspector 3 so that resident inspector stays there as long as he wants 4 to, as long as the agency doesn' t have any other burning 5 position tha t they feel they must have that fellow in. And 6 as long as we remain satisfied through regional management 7 that he is remaining effective in his job.
8 I would hesitate to say what the average tour is 9 these days. I suppose it's at least three or four years.
10 Once a person goes to a site as a resident inspector, we try 11 to encourage them to move. They're a heck of a resource.
12 We want them at headquarters. The regional offices want 13 them. But we have no fixed time limit for how long they can 14 s tay .
15 DR. REMICK:. That's a change, isn' t it, in 16 philosophy? Didn' t at one time you purposely move then 17 af ter a fixed time?
18 MR. PARTLOW: Yes. We worked through having a 19 fixed tour policy, primarily because of the objectivity 20 issue. And they are very much by themselves out there.
21 But that was abandoned. And we decided that as
-22 long as we were confident that he was still objective in 23 that climate, he could stay there if he wanted.
24 DR. SIESS: You had a problem with relocation U 25 expenses, didn' t you? Did that get resolved?
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2840 05 07. 57 (L-,)DAV/bc 1 MR. PARTLOW: There were some new Civil Service 2 rules put through in the last year or two, which, if 3 implemented, would ease the burden of relocation -- moving 4 services, and so forth. So that's law.
5 But, then the second step is that it's very, very 6 expensive to the extent, as I understand it, tha t the agency 7 wants to adopt those provisions, fine, provided they pay for 8 it out of their budget.
9 And I believe that EEO has that in the '87 '88 10 budget. But I don' t have any details. A source of some of 11 the questions, let me get to the bottom half of these three 12 basic segments of inspection.
i O.
k/ Overwhelmingly and routinely, traditionally, our 13 14 inspections are carried out by the regional offices. But, 15 in the past years, there's been a turn towards inspections 16 being conducted directly out of headquarters, out of the _
17 Office of Inspection and Enforcement.
18 So that has grown up with the various acronyms 19 that you have heard of CAT's, PAT's, IDI's, and I've got a 20 couple of new ones to add to it today.
21 There are various reasons, I guess, for each of 22 them. And I have a number of them listed here. First, as 23 you know, several years ago, the Vendor Inspection Program 24 was brought in because the vendor situation is a national O. 25 situation as opposed to a regional situation.
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_ . _ . . - _ . -._ _._. _ ._. _ = __ _ - . - . . - _ _ . - __ -
2840 05 08 58
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1/DAV/bc 1 The licensee is located within the region, so 2 that program has been brought here. It's been reoriented 3 towards utility responsibilities to a large extent, but 4 tha t's the subject of a whole different discussion.
5 Yes, sir?
6 MR. REED: I notice tha t recently, a 7 reaf firmation or rehash of the Vendor Inspection Program 8 came out as a policy paper. I guess it's out for comment at 9 the end of February. It was more or less rewritten the same 10 as it was before.
11 I, of course, believe that the whole structuring 12 is wrong. And I was very interested in the Lloyd hearing f')
13 that just took place, where one of the people brought in in 14 24 front of Congressman Lloyd, I guess, made a strong pitch for 15 the airworthiness certificate type of structuring in 16 nuclear.
17 But the vendor should be made responsible for his 18 design, and some of his key manufactured goods, so on and so 19 forth, as is done in the aircraf t situation.
20 I'm a little disappointed to see that the vendor 21 program is not planned to be changed. In other words, the 22 responsibility of the vendor for this product that he is 23 putting off on the sole licensee remains pretty small; his 24 responsibility is pretty small.
25 Therefore, the encouragement for doing a good Acs-FEDERAL REPORTERS, INC.
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2840 05 09 59 L-)DAV/bc 1 job is not strong.
2 Is there any trend that you' re detecting that 3 we're going to make the vendors at least liable and 4 responsible for everything tha t they ditch off on to the 5 sole licensee?
6 MR. PARTLOW: I can' t speak very specifically to 7 that program. I guess we don' t have anybody here in it. I 8 did just recently read the Commission on Enforcement Policy 9 on Vendors. The Commission, I guess, reaffirmed.
10 MR. REED: Tha t's the one I meant to refer to.
11 MR. PARTLOW: Rea" firmed that we would hold 12 enforcement conferences, that we would issue deviations to 13 vendors. And that if they were not responsible in the Part 14 21 manner of reporting their defects, that we would take 15 civil penalty enforcement action.
16 MR. ANKRUM: To go to your broader question, 17 Mr. Reed, this is something that was examined in the OA 18 report to Congress as to whether or not we should license 19 vendors, and particularly NSSS, whe ther we should change 20 from this policy of holding the licensee responsible for the 21 action to the vendors.
22 And the decision which was approved by the 23 Commission was that we would not change that policy. So 24 there is no move afoot at this time to change the basic A
kl 25 notion that we hold the licensee responsible and, in turn, ACE-FEDERAL REPORTERS, INC.
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)DAV/bc 1 should hold his vendors responsible.
2 We' re not considering licensees.
3 MR. REED: If you haven' t read that Lloyd 4 hearing, you might want to read that.
5 DR. SIESS: Ted, have you followed the gestation?
6 What is the role of a vendor inspection?
7 MR. ANKRUM: The role of a vendor inspection is 8 to confirm whether or not the utility has fulfilled its 9 responsibilities in auditing the vendors. The vendors do 10 still retain. They have a Part 21 legal responsibility and 11 we also verify whether or not the vendor is properly 12 discharging its Part 21 responsibility.
O
\/ 13 DR. SIESS: In terms of whether the utility is
- 14 auditing the vendor, do you find that out by inspecting the 15 vendor?
16 MR. ANKRUM: That's correct.
17 DR. SIESS: All the utility audits are on file 18 with the vendor, everybody he sold something to. I mean, 19 here's a vendor selling valves and the valves are good 20 enough that 20 people have bought them.
21 MR. ANKRUM: We will generally audit both the 22 utility and the vendor. But the focus of our audit has the 23 utility fulfill its responsibilities vis-a-vis that vendor.
24 And we'll look at some vendor-specific items such as:
25 Has a utility implemented the service information ACE-FEDERAL REPORTERS, INC.
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2840 05 11 61 DAV/bc 1 bulletin?
2 DR. SIESS: It seems to me you would get that by 3 inspecting the utility. I just haven' t got the picture of 4 what you find out from the vendor about what the utility 5 did.
6 MR. ANKRUM: We are inspecting both. When we go 7 to the vendor, we will discover whether or not the utility 8 has been there and then what the utility might have done, 9 actions it might have taken vis-a-vis that vendor.
10 We'll get a cross-section of what different 11 utilities may have done at that vendor. But the focus of 12 the inspection is in terms of who is responsible for taking
(
) 13 action to the utility.
14 DR. SIESS: Not when we have an incident like 15 Sale.n or Davis-Besse, or San Onofre. We now have 16 investigation teams going out to find out where the system 17 broke down.
18 Is there anything like that in connection with 19 the vendors? Has there been a similar study of where the OA 20 program broke down on TDI diesels?
21 MR. ANKRUM: Most recently, yes. Our vendor 22 inspections to find something more than an isolated 23 instance. We'll te looking at that particular vendor and 24 trying to determine why that system broke down at that O 25 vendor.
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()DAV/bc 4- 1 I'm not sure if we did it on TDI, and I'm not 2 totally familiar with all of these areas, so I'm giving you 3 a little bit of an ad hoc answer.
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 i
20
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2840 06 01 63 13 L /DAVbw 1 DR. SIESS: That seems to me to be a perfect 2- example of where the system broke down. Obviously poor 3 quality equipment was supplied. I had heard that there had 4 been vendor inspections of TDI over a period of years that 5 showed defects in their QA program, not necessarily defects 6 in their equipment, I ga ther. It seems to me that incident, 7 I'll admit, seems to me as important as what happened at San 8 Onofre, in view of the importance of on-site AC power.
9 There was a big accident. I just wondered if there 's been 10 any reports on it. What happened.
11 MR. ANKRUM: We agree with you that we need to 12 get to the bottom of these vendor-related issues and that n
13 we, in fact, are dealing with those things now. That's one 14 of the things that would happen to the program at 15 headouarters, but I don' t believe that we produced a 16 vendcr-related report related to th'e TDI diesels, but again 17 tha t's not a program I'm directly responsible for.
i 18 MR. REED: Let's go the other halfway where Chet 19 was talking. Let's go beyond equipment design. We now have 20 some incidents up there that point to design 21 vulnerabilities. In my opinion, the utility is being asked 22 to do something beyond their capability as sole licensee, to 23 be able to say tha t a design doesn' t have vulnerabilities 24 and that it's appropriate. It seems to me that in order to 25 get to tha t other half beyond equipment, I think that ACE-FEDERAL REPORTERS, INC.
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)DAVbw 1 perhaps OA audits in these kind of things can work on 2 equipment and achieve something, but when you get to the 3 complexity of design and design frailties, it seems to me 4 that there's a gap in the system. That's where the 5 airworthiness certificate comes in. You've got to begin 6 with design that doesn' t have vulnerabilities. And I don' t 7 see who is addressing design vulnerabilities.
8 U tilities , I don' t think, should ever have been 9 expected to have the total know-how to do tha t.
10 MR. ANKRUM: I certainly agree with several 11 aspects of what you' re saying. In our recent design 12 inspections, of course we have continued to hold that 13 utility responsible for the adequacy of that design. That 14 is the law. That is the regulation, and we have, indeed, 15 found that some utilities didn' t have the ability to provide 16 the kind of technical oversight of what their contractor was 17 doing. And they were dependent on that contractor's OA 18 program or that contractor's technical review program.
19 We've also found some utilities that did have the 20 kinds of technical background to be an informed customer.
21 One recently completed IDVP for a plant, which we believe, 22 if you look at the three participants, the owner, the 23 utility, the AE and the contractor performing the IDVP on 24 behalf of the utility, all three showed that they were 25 really doing a professional job, and we're very pleased ACE-FEDERAL REPORTERS, INC.
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)DAVbw 1 with how well the design had been done, and one of the key 2 reasons that we attribute to the fact that the design was so 3 well done is the cus tomer. The customer utility had 4 significant technical credentials in the area and was a very 5 informed customer and was able to clearly judge what it.was 6 buyinn and what we have in the thrust of these inspections.
7 The lessons learned are that the utilities under 8 the current regime, which would hold the utility 9 responsible, the utilities are going to have to increase 10 their technical capability to become a more informed 11 customer.
12 MR. REED: In other words, to become designers, The designers '
13 so they can then design their own stock.
14 don' t know enough and will never learn enough how to do it, 15 so that the utilities can do their thing? Ouite frankly, I 16 think the structuring is wrong. You know my feelings.
17 MR. ANKRUM: I know your feelings, but as the
, 18 structure currently is, in order to work as best as it can, 19 the utility has to be an informed purchaser, and that means 20 they have to have the technical credentials to assess what 21 they' re ge tting.
22 MR. REED: That's a reversal of all the history-23 of creation and manufacturing and selling, and so forth.
24 You' re going to make nuclear something dif ferent.
25 Do you think that will hold up in the future?
i ACE-FEDERAL REPORTERS, INC.
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MR. ANKRUM: 4 We definitely do think nuclear is s, 3 something different.
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, 4 DR. REMICK: ,
Ted, refresh my memory. The OA
, 5 Report No. 1055, did Miat address the question of whether i, -
6 the Commission could ' license vendors? Does the Act enable 7 them to do tha t?
\
> C8w MP. ANKRUM: The report itself does not deal with b 1\
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10 DR. RENICK: Do you happen to know? I assume
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11 tha t's been looked, 'at. Would the Act enable the Commission 12 to license ' vendors, ,1f it wished,' r does the Act o
V 13
?
specifically say they should license the facilities.
14 MR. 'ANK RUM : I don' t know the answer to that 15 question. ,
16 MR. MICHELSON: Don' t they license vendors in the
? 17 case of the floating barge-mounted plants, and so forth?
18 They'were licensed for manufacture without specific 19 customers. 'q 20 DR- REMICK: You're right. A manufacturing
')~
s 21 lic,enj'e;yes. \;,
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22 ~ MR..MICHELSON: It must permit it in that case 7' : ,
9 23 for that kind sof thing. "N
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? 24 s DR . REMICK: I think we'd better proceed.
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MR. PARTLOW: Let me go ahead quickly with some N' ,s
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LI DAVbw 1 more kind of inspection activities that go on from IE 2 headquarters about the construction appraisal team. Those 3 are continuing. The construction appraisal team will, of 4 course, be phasing out here over the next year. The 5 performance appraisal team will continue. These program, I 6 think, serve us in a number of ways, and I've tried to list 7 some of them there.
8 You know, the regional offices have both NRR and 9 IE resources out there working for them, doing licensing 10 activities and doing inspection activities. The way 11 decentralization is going, is it, primarily those regions 12 are responsible for carrying out IE and NRR programs in
(')
\' 13 accordance with the headquarters programs policies with the 14 resources that we give them. So one of the responsibilities 15 then is for the program offices to be able to assess how 16 well the regions are doing with those resources.
17 So in construction, the construction appraisal 18 team and an operations appraisal team and other kinds of 19 inspections that we do gives us the opportunity to take an 20 independent look at a utility and draw some conclusions, 21 some recommendations about how ef fective our regional 22 inspection program is operating.
23 DR. REMICK: How many of those PATS do you 24 conduct a year now?
f'" \
25 MR. PARTLOW: The performance appraisal team now ACE FEDERAL REPORTERS, INC.
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f) kJ DAVbw 1 is running on the order of three . to four. I might mention 2 that the Commission, in its restart order for TMI Unit 1, 3 ordered two PAT inspections during the next year at TMI Unit 4 1.
5 So tha t's a part of our schedule. The 6 construction appraisal team, Mr. Heisman here is able to 7 stay on the road all the time, and he's running with one 8 team almost at the five per year rate, I guess. Those are 9 major inspections.
10 DR. REMICK: Which one was tha t? I'm sorry.
11 MR. PARTLOW: CAT construction appraisal.
12 DR. REMICK: I notice one of the items you have 13 her.e is monitoring of INPO effectiveness. I have not heard 14 any criticism of I&E interac tion %#dth INPO. Has there been 15 some recently, as there's been recently between NRR and 16 INPO? Has there been any clashing here that I'm just not 17 aware of?
18 MR. PARTLOW: I really don' t know yet. The NRR 19 case has to do with those kinds of situations where the 20 agency decided not to issue a rule. For example, in 21 training or in maintenance, in favor of what INPO was 22 doing. Therefore, NRR has a greater need, perhaps, to draw 23 plant specific information from someone like INPO about how 24 is it going on that area. I&E, the IE situation is not the O 25 same. We made a decision several years ago not to increase ACE-FEDERAL REPORTERS, INC.
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3s,)/ DAVbw 1 the number of performance appraisal team inspections. We 2 had plans to have three teams every three years. In 3 recognition of the somewhat equivalent INPO evaluation 4 program, we decided not to do that. But in order to see how 5 it's going on, how INPO is doing in those things, we don' t 6 necessarily have to get a lot of plant-specific 7 information.
8 DR. REMICK: Do you feel that has worked out 9 where you limit your PAT inspections to three or four per 10 year and monitor wha t INPO is doing in their evaluation 11 assistance business? Has that worked out?
12 MR. PARTLOW: It seems to be; yes.
O N/ 13 Another area, and Jim Milhoan is here to answer 14 any further cuestions later on, that we're in, is the 15 conduct of independent design inspections. I t's an area 16 that's reasonable for centralization within IE, because of, 17 again, it doesn' t have nice, clean regional boundaries like 18 utility licensees do, and we're able here to maintain 19 through our own staf f and through contractuals, a corps of 20 design experience people to conduct those programs.
21 DR. REMICK: Will that continue when new plant 22 construction stops, or will IDIs then be directed towards 23 major plant modifications?
24 MR. PARTLOW: I'll let Jim get into this later 25 on. The conduct of the big IDI, the conduct of the IDVP ACE-FEDERAL REPORTERS, INC.
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40 06 08 70 1 DAVbw 1 utilities conducting independent design verification 2 programs is, of course, going ot end, but the way we're 3 going in IE programs, I think we'll get more into the kinds 4 of ideas that Mr. Reed was talking about.
5 I'm going to talk in a few minutes about design.
6 Headquarters also does direct inspection activities in such 7 things as fire protection and equipment qualification. I 3 guess there in these kinds of things, I would say, that our 9 intent is, when there are issues that are rather 10 complica ted , that recuires some technical help, that are 11 still developing, in how to conduct the right kinds of 12 inspections, that we tend to start them in headquarters with 73 d teams and go to a few plants in each region to get started 13 14 on the right kind of long-term inspection program and then 15 go with plans to sort of farm that out to the field and to 16 get out of that business, once we've developed the kind of 17 inspection program that we want, that's going on now in 18 equipment qualification.
19 MR. MICHELSON: In the case of fire. protection, 20 have you reached the point where it's been regionalized?
21 MR. PARTLOW: No. And I guess until each plant 22 has had its major Appendix R inspection, tha t won' t happen, 23 as long as we continue to want to use NRR resources and our 24 contractors will be running tha t from headquarters.
g-)
V 25 MR. MICHELSON: Are you going to do it on a Acc-FEDERAL REPORTERS, INC.
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2840 06 09 71 f) h'DAVbw 1 plant-by-plan t basis, in teams of turning over the region, 2 or are you just at a certain point in time going to turn 3 over all fire protection over to a given region?
4 MR. PARTLOW: We're basically doing it 5 plan t-by-pla n t. By virtue of participating in this 6 inspection, the region becomes clearer on the issues that 7 are identified, and they pick it up from there.
8 MR. MICHELSON: Have any of them been turned over 9 to the regions yet, any plantrs?
10 MR. PARTLOW: A number of them have had this 11 initial Appendix R inspection.
12 MR. MICHELSON: Has the responsibility been n'
'- 13 turned over to the region in some kind of a formal way?
14 MR. PARTLOW: I guess there's a memorandum that 15 says, here are the potential enforcement findings that 16 developed from this inspection, and we understand tha t 17 you'll be following through on those.
18 MR. MICHELSON: Thank you.
19 MR. PARTLOW: On the next page, general 20 attributes of inspection program. I'm not going to go 21 through all this, but I thought it might be some interesting 22 numbers that you might want to have, things about the 23 general amount of time that a regional inspector is away 24 from home. It runs 40 percent and over on a month-in,
( 25 month-out basis.
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-1 DAVbw 1 Our resident inspectors, we feel good if they can 2 get in about two-thirds of their time in what we call direct 3 inspection activities. We have goals out there for covering 4 off-shift. We have budgeted goals that allow our inspectors 5 to conduct what we call independent inspection efforts to 6 pull the string on areas that they see that are of 7 potential safety significance, that they want to learn more 8 about.
9 DR. REMICK: Are you familiar with some utilities 10 having an indicator of basically nonconformance reports per 11 hour of inspection time? Is that anything that you track, 12 accumulate or anything like that?
13 MR, PARTLOW: Violations?
14 DR. REMICK: Yes.
15 MR. PARTLOW: Yes, we periodically put those 16 together, normalize them on a per-inspection hour basis; 17 yes.
18 DR. REMICK: Apparently, they include in that 19 resident inspector, inspection time, as well as OA people.
20 Apparently, you must publish how much at each site, how much 21 time a resident inspector spends in inspection.
22 MR. PARTLOW: Yes. Every inspection report 23 contains the number of hours that the inspector was on site 24 conducting inspection activities, so they can get it. The O-s -
25 report has their violations in it and how many hours.
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2840 06-11 73 DAVbw- 1 DR. REMICK: Apparently, some track number of 2 violations per hour of inspection.
3 MR. PARTLOW: Yes. Inspection program plans and 4 trends. This is what I wanted to talk a little bit about, 5 where generally we're trying to go with our inspection 6 program.
7 I had mentioned the increased use of resident 8 inspectors, both in construction and at operating sites.
9 The use of a major team inspection as a diagnostic is J
10 gaining more and more popularity.
11 I won' t try to snow you with the talks of 12 synergism, and so forth, that comes from bringing a team O
'/ 13 'together, but that kind of thing does work, when you bring 14 together the right number of people and don' t get too many
'15 people and have a good team leader with them on a two- or 16 three-week inspection. There is synergism that starts to 17 work, if we got the right people toge ther. So more and 18 more, I think you'll see us moving towards the conduct of I
19 team inspections.
20 Bob Martin, in Region 5, has it in his plans.
21 Every plant gets a major team inspection every year.
22 MR. REED: But this is what goes on in SALP 23 inspections. This is what goes on in INPO inspections.
24 Their team inspections, you're saying, you're going to O 25 duplicate, triplicate other team inspections?
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2 40 06 12 74 1 DAVbw 1 MR. PARTLOW: First, the SALP is not an 2 inspection. Nobody goes on site for a SALP. SALP is 3 sitting down at the table and bringing together everything 4 that's- known about the past year's worth of inspections. So 5 SALPs are not inspections.
6 7
8 9
10 11 13 14 15 16 17 18 19 20 21 22 23 O 25 l
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.2840 07 01 75 DAVbur 1 MR. REED: I guess the discussions are team 2 efforts?
3 MR. PARTLOW: Yes.
4 MR. REED: They always seemed like inspections to 5 me because the SALP efforts onsite have always been 6 ex tensive . I guess their minds are already made up; that 7 is, the discussions with management are very extensive.
8 Okay, let's go back and hang my hat on INPO team 9 inspections.
10 You are saying you are going to be doing 11 something like the INPO team inspections?
- 12 MR. PARTLOW: I am saying tha t I think, as
%)
13 opposed to seeing our inspection program being only 14 throughout the year, one guy out this week and two guys out 15 next week and one guy out the week af ter that, we will still 16 see tha t, but we will see more of the periodic team 17 inspections going on as well.
18 MR. REED: I would like to point out something.
19 In my opinion, the HP man, the chemistry man, the expert in 20 this event discipline going out on his scheduled arrangement 21 is much less burdensome to the facility. If you are going 22 to go out in teams , that blocks up everybody right away.
23 The utility is going to say, hey, I can' t have 24 this happen during the refueling cr during a major O 25 s i tua tion. I can' t divert all my key management. Team ACE-FEDERAL REPORTERS, INC.
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s/ DAVbur 1 inspections are very difficult to plan for, and they can be 2 burdensome.
3 MR. PARTLOW: I agree.
4 By the way, when I speak of these kinds of team 5 inspections in general, I am probably not including the 6 health physicis ts , the security inspectors, and so forth.
7 Those will still probably be going out on more of an 8 individual basis.
9 But the kind of places you put together a team is 10 when you go looking at some kind of inspections that we are 11 doing now at headquarters and in some of the regions. It is 12 more of a system functionality look where you are looking at O 13 a system or you are looking at a major program, like the 14 maintenance program associated with the system. We 15 MR. REED: Me thinks thou dost plan to inspect 16 and do inspect too much. It is not in the best interest of 17 sa f e ty , in my opinion, if it sounds like it is just a 18 ballooning activity.
19 DR. REMICK: These team visits are not PAT team 20 visits; that is to evaluate the region, is that correct?
21 MR. PARTLOW: The PAT is again a headquarters 22 activity limited to three or four per year. I am talking 23 about the general method in which we utilize the 400 or so 24 inspectors in the five regional of fices in a year's period 25 of time, how they go about their duties.
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1 0 07 03 77 1 DAVbur 1 So I am telling you not that we are going to keep 2 doing all the regional individual inspections that we have 3 done in the past plus team inspections, Mr. Reed. I am 4 telling you tha t they might be grouped in a different kind 5 of unit.
6 MR. REED: The issue is man-hours of inspectors 7 on the jobsite, and I know most of that is tracked and I 8 know wha t the curve looks like, and quite frankly, I think 9 that activity has gone beyond an optimum or ef ficient 10 point. It is just diluting the attention of those key 11 personnel on the jobsite. INPO contributed a hell of a lot 12 to it.
s /
13 MR. PARTLOW: You mentioned INPO and the team .
14 inspections. We don' t want to go all to team inspections.
15 INPO does a team inspection where their people are onsite 16 for two weeks. It happens once every 16 to 18 months. We 17 don' t run that kind of program.
18 Our program is more of an NRC presence throughout 19 the year.
20 MR. REED: Yes, I think the resident inspector 21 program is very good, and I think certainly some of the 22 resident inspectors are very down to earth, workplace 23 coupled, workplace knowledgeable people.
24 I have heard complaints from some residents that 25 they are not listened to as much as they would like to be ACE-FEDERAL REPORTERS, INC.
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- Ci b /DAVbur 1 on up the line in regional headquarters and in headquarters 2 in Washing ton. I am not sure whether they are listened to 3 on a balanced basis or not.
4 I thought when the resident program started way 5 back that there would be some lessening from the other 6 programs, but along comes INPO with a great big activity, 7 which -- I shouldn' t call them inspections. They are called 8 evaluations -- but they are recognized, certainly by the 9 burdened ones in the plant, as inspections.
10 But I thought there would be a lessening with the 11 listening. They are there with their ears to the keyholes.
12 I would think that rather than increasing inspections you 13 should be looking at what is the optimum and where does 14 motivation and distracting fit in?
15 DR. REMICK: I do think it is fair to say, Glenn, 16 that if it had not been for INPO E&A visits, inspections, 17 there would be more PAT inspections. That was the intent of 18 staff a couple of y' ears ago, but they purposely curtailed 19 the number of those, recognizing the INPO E&A inspections.
20 MR. REED: I realize tha t.
21 MR. PARTLOW: I do want to key back again to our 22 intent by policy from the top that good performance will 23 result in less inspection. That is our intent. And poor 24 performance will result in more inspections.
25 DR. REMICK: Where do we stand on our ACE-FEDERAL REPORTERS, INC.
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l 0 07 05 79 l 1 DAVbur- 1 presentation here?
2 MR. PARTLOW: For the kind of things for the 3 future, down here in the middle of this set of bullets, the 4 development of an outage inspection program aimed at 5 ensuring that modifications and repairs do not degrade 6 safety margins.
7 We are starting, we are in the middle of a pilot 8 program there now at that Fort Calhoun plant, and we are 9 starting at the Dresden plant.
10 The idea there is to look at the modifications 11 that are conducted during an outage period, tie those back gS 12 into the quality of the design work that was conducted in V
13 planning for those modifications, the change in the original 14 design $ Isis, the original design assumptions, then taking 15 next a look into the actual cuality of the conduct of the 16 modi fica tion , the welding, the installation, and so forth, 17 next into the post-modification tes ting of the program. Is 18 there f anctional testing conducted that still demonstrates 19 the operability of the sys tem?
20 So that is another area that we are getting that 21 does not represent our intent that it represent increased 22 inspection but another, a different way of using our 23 inspection resources.
24 MR. REED: This outage inspection program is 25 being generated, and we are going to be asking for a ACE-FEDERAL REPORTERS, INC.
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i' 2840 07 06 80 1 DAVbur 1 presentation on that sometime. Would you be the proper --
2 MR. PARTLOW: Yes, tha t is us.
l 3 MR. REED: We want to find out if this is going 4 to be beneficial or whether it. is going to be just more of a 5 burden? -
6 MR. PARTLOW: We are scheduled on either January i- 7 or. February full committee on the status of the outage 8 inspec tion. .
9 MR. HEISHMAN: February, I think, is the latest 4
10 date.
11 ,R.
M PARTLOW: The last bulle t, development of 12 realistic uses of PRA in the inspection program, that is l'
13 another thing we are working on with several regional 14 offices.
15 Again, the basic thesis, an inspector can look at
- 16 just so much. So what is the general. priority for his time, J 17 this sys tem versus tha t sys tem, this maintenance evolution 1
j 18 versus that maintenance evolution?
j 19 So we are working now to use, to the extent that 20 we have plant specific PRAs, to provide -- to take from 21 those guidance to the resident inspector or the regional
.22 inspector to help him determine the most important things 2
, 23 from a risk point of view for him to look at for the time
'24 that he has available.
() 25 MR. WYLIE: Jus t a question you skipped over --
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40 07 07 81 1 DAVbur 1 or maybe I didn' t recognize it -- but the next to the last 2 bulle t down there, additional emphasis on utility 3 responsibility.
4 MR. PARTLOW: Really, there I just meant sort of 5 the same discussion that we had had on the vendor inspection 6 program. The vendor program, where traditionally was a 7 little bit of QA on the vendor site, is now turning more to 8 the utility and its responsibilities.
9 MR. WYLIE: This is a particularly important area 10 here, as you well know, particularly since a lot of cuality 11 vendors are out of the business and they are having to em 12 procure replacement parts from other sources. Ouite of ten
(_ ' .
13 those sources are not the highest quality vendors because 14 the high quality vendors got out of the business.
15 I know from being on the design side of the house 16 we had to face this problem. You mentioned earlier Part 21, 17 and quite of ten when you talk to people who got out of the 18 business, one of the things that put them out of the 19 business was the fact that their legal people told them the 20 business is going to decline to a level where it is not 21 worth the risk to stay in this business from a legal 22 s ta ndpoin t.
23 That is wha t pu t them out of the business, and r- 24 Part 21 has tha t threa t to the corporate structure. It is a 25 real problem because the committed high cuality vendors have Aca-FEDERAL REPORTERS, INC.
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2840 07 08 82 DAVbur 1 gotten out of the business, and when you go out to look 2 utilities like sort of a package or a guaranteed job that 3 somebody is going to take complete responsibility to qualify 4 the product and have a paper trail along with it.
5 They will do that for a price. Generally, tha t 6 price is four times what it is worth. But in the end you 7 may end up with an inferior product that you could have 8 gotten and still can get from these vendors that are still 9 manufacturing these items but are not willing to take the 10 risk under the present regulations. ,
11 That is a problem, I think, tha t the industry is 12 going to face more and more because they have to face up to 13 dealing with.
14 Now, here I think you are perfectly right under 15 the present regulations that the utility -- it says it is 16 his responsibility and his problem, and he may have to 17 participate more in the qualifying of that equipment. There 18 has got to be some mechanism by which he can get the best 19 piece of equipment, the highest quality piece of equipment, 20 and then take the responsibility to see that it is properly 21 qualified, even if he has to do it himself.
22 MR. PARTLOW: There should be some kind of 23 economies of scale there. Not every utility should have to 7- 24 go through some kind of special acceptance test on a piece b 25 of commercial equipment in order to responsibly dedicate it ACE-FEDERAL REPORTERS, INC.
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2 40 07 09 83 1 DAVbur 1 to a safety-related job.
2 MR. WYLIE: I know many pieces of equipment where 3 the manuf acturer has gotten out of the business. He still 4 produces that sarce item for the commercial market. The only 5 problem is he is not going to do it to get in the business 6 because he has to have the paper trail along with it.
7 MR. PARTLOW: I won' t go into details on the last 8 sheet. It is just a little advertisement for what IE is 9 responsible for.
10 DR. REMICK: Thank you.
11 (Laughter.)
12 There is one thing. The CATS will be phased out, 13 so I think information on the resources that is required is 14 not pertinent. But PATS will continue at three to four per 15 year.
16 Is that right? Is somebody going to give us an 17 idea of the resources tha t requires?
18 MR. PARTLOW: The performance appraisal team will 19 continue. It may not always be the same. It is changing.
20 In fact, the resources, the people who normally 21 conduct performance appraisal team sections are now 22 conducting what we are calling a safety system functional 23 inspection.
24 We did this at Turkey Point. Perhaps you have
( -
25 seen the results of that inspection several months ago.
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( / DAVbur 1 We were at Pilgrim last month, and we will be going of f to 2 another plant next month.
3 So the concept of a performance appraisal team at 4 IE headquarters will continue. The menu, what they do, is 5 going to change.
6 DR. REMICK: But you still see three to four per 7 year?
8 MR. PARTLOW: At least.
9 DR. REMICK: You mean it is growing?
10 MR. PARTLOW: I would say that it might grow, the 11 number of resources at headquarters. Although the budget 12 probably calls for six people, I suspect I am using more 13 like eight people right now. The headquarters' direct 14 inspection effort is going to continue like that.
15 DR. REMICK: When you say " people," that is 16 FTE's?
17 MR. PARTLOW: Yes.
18 I DR. REMICK: Now, my understanding of IDIs, the 19 regular IDIs are going to phase out, but there are going to 20 be operationally oriented IDIs. So somewhere along the line 21- somebody is going to tell us about the resources that we 22 have utilized there because that is a program that we will 23 be continuing in some form?
24 MR. ANKRUM: Instead of performing IDIs, for O 25 which we are responsible and which are a block related to ACE-FEDERAL REPORTERS, INC.
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2840 07 11 85 DAVbur 1 design types of activities all by themselves and inspection 2 reports all by themselves, that effort is being moved into 3 what I will call a subcontract to the saf e ty sys tem 4 functional reviews and to the outage inspections, the design 5 aspects of outage inspections.
6 So the IDIs and IDVPs and engineering assurance 7 programs are winding down, and we are becoming a 8 subcontractor to these major Division of Inspection 9 Programs' inspec tions .
10 Jim, what are we budgeted for that?
11 MR. MILHOAN: For example, we are going to still 12 maintain or try to maintain a contractor capability and a 7_
(> 13 :' design expertise as we go into the new program when we go 14 into a dif ferent contract. So we will be able to do the 15 contract selection process for that with respe.ct to the 16 resources at the present time.
17 As Ted was saying, we are winding down the other 18 programs. We still have to go into the NTOL plants. So we 19 have resources devoted to that in the engineering assurance 20 programs and the IDVPs.
21 Normally, for an IDVP program, from the design 22 inspection capability, normally I would have one team leader 23 plus one designer type person in each of the major 24 disciplines covered by an IDVP, which is normally mechanical O 25 sys tem, mechanical components, struc tural, electrical, ACE-FEDERAL REPORTERS, INC.
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2840 07 12 86 DAVbur 1 ins trumenta tion, and control.
2 The inspection ef fort associated with that is 3 normally visiting for program approval for the IDVP program, 4 scope approval, looking at the checklist review, conducting 5 an implementation inspection about midway through an IDVP, 6 reviewing and inspecting the documentation associated with 7 an IDVP written report, and then inspecting corrective 8 actions associated with the IDVP.
9 Those are inspection efforts, and I normally run 10 a team of people for each one of those phases, normally 11 about three days for a scope checklist review, about a
- 12 one-week inspection of that part of the IDVP program, and 13 about a one-week inspection associated with the 14 documentation associated with the IDVP report and the 15 corrective actions running from the program, the engineering 16 assurance program, which is a self-directed utility-run 17 program, the scope being approximately the same as an IDVP 18 except the utility is running a self-directed program with 19 our overview. I would expend about the same amount of 20 resources, again, on a team basis with those major 21 disciplines covered.
22 Some of the engineering assurance programs have a 23 module approach to it, such as the South Texas engineering 24 assurance program run by Houston Power & Light, which has a 25 number of modules associated with that. My inspection ACE FEDERAL REPORTERS, INC.
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2840 07 13 87 DAVbur 1 resources on that one I would say are about one-half that of 2 an IDI.
3 And these programs are coming to comple tion.
4 ,
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2840 08 01 88 DAV/bc 1 DR. REMICK: How many of them are there out 2 there? I guess some plants have been exempted.
3 MR. MILHOAN: The present plan in the I&E 4 inspection program, we've just completed the Millstone 5 engineering assurance program.
At the present time, under 6 that review, I have the Nine-Mile Point to engineering 7 assurance program, the completion of the Hope Creek IDVP, 8 the South Texas Engineering Assurance Program, the designs 9 aspects of the readiness review. And the design aspects of 10 the readiness program.
11 We have a letter out at the present time asking 12 Beaver Valley what their plans are with respect to 7_s C,)
13 additional assurance on the design of their plants.
14 I am also heavily involved in design teams with 15 the design adequacy program at Comanche Peak. That has 16 taken a lot of my resources. Again, that program will be 17 coming to comple tion.
18 I will be devoting a rather significant amount of 19 resources to that part. And in the coming years, as Ted was 20 saying, we have design teams associated with the average 21 inspection program. That team is normally, again, 22 comprising a person who can assist with the mechanical 23 components, electrical and instrumentation and control, 24 along with a design team leader, one which has normally had O 25 IDI experience as a team leader on that one. <
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2840 08 02 89 (h
i'l DAV/bc 1 We've gone through the Fort Calhoun inspection 2 and we are now in the trial program. I'm spending right now 3 about three direct inspection weeks in the field on that 4 type of a program. I also have design members as part of 5 the safety system functional inspections.
6 And I'm also supplying numbers to the vendor 7 inspection program on certain designs; if there is an 8 inspection going on that requires design expertise, on a 9 case by case basis, I am supplying design members to that 10 kind of program for specific problems.
11 DR. REMICK: How big is your branch?
12 MR. MILHOAN: In the design aspect, my section O
'~#
-13 has approximately six. . .seven FTE's devoted to design, plus 14 myself. fab 15 MR. ANKRUM: Significant contractor support.
~
16 MR. MILHOAM: We're not looking at that increase; 17 we're looking at the trend. It's shif ting the emphasis over 18 to the operating side.
19 DR. REMICK: So am I correct that the various 20 programs you talk about are design-related? You have seven 21 FTE's plus technical assistance under contract.
22 MR. MILHOAN: Tha t's righ t.
23 DR. REMICK: What's roughly the magnitude of that 24 contrac t?
O 25 MR. MILHOAN: I'm hesitant to give you a money ACE-FEDERAL REPORTERS, INC.
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2840 08 03 90 DAV/bc 1 number, but I've got two contracts -- an IDVP contract and 2 an IDI contract. In FTE's, I would say that the two 3 con trac ts from FTE, they will be about eight to 10 FTE's.
4 DR. REMICK: Questions?
5 (No response.)
6 MR. ANKRUM: If I might, that constitutes the 7 fonnal part of what we were prepared to present today.
8 We'll be happy to respond to questions in any of these 9 areas.
10 DR. REMICK: I suggest that we take a break at 11 this time and then come back and ask cuestions. Why don' t 12 we take a 15-minute break, until 11 o' clock.
13 (Recess.) ,
14 DR. REMICK: Could we reconvene, please?
15 Ted, I'm not sure we've gotten what we were 16 hoping to get from the presentation. I think we were hoping 17 that we could find out which of these programs are cost 18 beneficial from the standpoint of improving public health
. 19 and safety, improving safety.
20 And I realize that's a very dif ficult thing to 21 evaluate.
22 MR. ANKRUM: What you have seen is an exercise on 23 the old premise that if you can' t answer the cuestion tha t's 24 being asked, answer a cuestion that you can answer.
25 DR. REMICK: Yes, I understand.
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2840 08o04 91 DAV/bc 1 MR. WARD: Tha t wa s f rank .
'2 (Laughter.)
.3 DR. REMICK: I come out of this feeling that 4 you're saying that all of these programs are good and are 5_ worthy _ of continuation. Some are being phased out because >
6 there's no longer a need. Some are in transition. But I 7 guess we don' t have any feeling on which ones of these, if 8 any, are worth the expenditure of resources.
9 In fact, I don' t think we have a real good 10 . feeling as to what those expenditures are. I personally 11 feel that, in the case of the allegations, I'm not sure how 12 the Commission gets out of having to respond in a manner to
'O
~
13 what you probably are doinb.
14 And if I put myself in your shoes, that I've got 15 to be the one signing off, I certainly want to have some 16 kind of a logical answer documentation that allegations have 17 been handled properly.
18 I don' t know how you get away from that, unless 19 there is some kind of a certification program, individual 20 of fice directors and the Commissioner are. willing to stand 21 up and say once we do that, we'll no longer accept 22 allegations on these points.
23 The other, I guess I personally don' t have a 24 feeling. Maybe other members of the subcommittee got a O 25 feeling out of this, that there are one of the other, or all ACE-FEDERAL REPORTERS, INC.
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2 40 08 05 92 1 DAV/bc 1 of these programs are programs that we should encourage to 2 continue, or some of them should be te rmina ted .
3 I don' t think we've come to tha t bottom line 4 based on the presentation. As you say, it's a very 5 dif ficult cues tion. And one you haven' t tried to answer.
6 MR. ANKRUM: That's because we haven' t come to a 7 bottom line conclusion as a staf f either.
8 DR. REMICK: Can the staff afford to continue all 9 these programs? Has it thought about integration of 10 programs into one or more that are more important than 11 others?
12 MR. ANKRUM: I think that's exactly what is now O 13 happening. We are integrating the design inspection 14 efforts, which would formerly stand alone, into an operating 15 reactor program for outage inspections and for safety system 16 and functionality inspections.
17 So we are integra ting them. The readiness 18 reviews on the construction side of the house are 19 integrating a number of things that were being done 20 individually in an attempt to get out in front of our 21 problems.
22 As I said, in the three modules that we have 23 accepted and, by the way, that represents the first time the 24 NRC has incrementally accepted a complete construction for a 25 project at the Vogel project. We have specifically stated ACE. FEDERAL REPORTERS, INC.
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2840 08 06 93 DAV/bc 1 in our letter of acceptance that absent new information not 2 previously available to the Commission, we will not revisit 3 these areas.
4 So the door is open for an allegation obviously.
- 5 But we feel that our review has been of sufficient depth 6 that if an allegation comes in and says the whole OA 7 documentation program is not functioning properly, well, i
8 we've looked at that. We can answer that right away. We i 9 can say, yes, because of our review of the OA program and 10 the readiness review, it was functioning properly and we 11 don' t need to go back and look at that again.
.. 12 If an allegation comes in and says: the welding
( 13 on the pipe at such and such a location was not done 14 properly and, therefore, the adequacy of the whole welding j 15 program has been called into question, this is what the 16 allegation says, we can go back and say: We're going to 17 inves tiga te tha t weld. . . I shouldn' t say "inves tiga te" .
l 18 We' re going to go look at tha t well, but we' ve already i
19 assessed the adequacy of the entire welding program and we 20 don' t need to do that again.
21 So the readiness review is also an integration 22 and an attempt to get out ahead of these problems and float 23 the allegations to the surface as early as possible as well,
, 24 because the readiness review programs are open to the O 25 public. The utility is exposing a considerably greater I
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%" l, 1 DAV/bc 1 depth of'datail to the publi~c review process than has ever J'
2 been the case in the past. And we are advertising in
' i 3 advance that when we finish our review, our intent is to put 4 this issue behind us.
5 And one would hope then that, if there are any 6 allegations that anybody has in their hip pocket, tha t
+
'they' llc'omkforward,at that point in time; because we're
~
7 8 ' better off not hav4pg to deal with this issue.
. .:~
I,f you get 50 allegations on the 9 s DR. SIESS:
10 welding program, then that would call into question in the
\ ,,
s ..
11 public's mind, since you gentioned public called into
[- 12 cuestion the adequacy of previous review, which said N/ i 13 everything was fine. , ,
14 s. I mean, I could challenge anything you come up
~
15 - 'with with allegations.
16 MR. ANKRUM: If we found we had 50 allegations 17 and we substantiated all 50 allegations, and if all 50
\ ..
18 allegations that were subg_tantiated dealt with the adecuacy
,s.
N 19 of the program we had previously signed off on, then you'd 20 say we, the s'taff, did a lousy job of signing off on the 21 prograa. ,
s, 22
~
DR. SIESS: I wouldn't say it, but somebody else
- s. s 1- 23 migh t n The cuestion there is substantiating. You've still gg _ 24 got:,to investigate everyone.
\_)
25 MR. ANKRUM: If they are specific. If they are ACE-FEDERAL REPORTERS, INC.
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2840 08 08 95 DAV/bc 1 less than specific and talk about a program kind of an 2 issue, if we've looked at tha t program, then we don' t need 3 to reinvestigate tha t.
4 MR. REED: Forest, this is not an allegation.
Well, I have one cuestion on
- 5 DR. REMICK:
6 allegations. That's part of that. Go ahead, Glenn.
7 MR. MICHELSON: If we're still on allegations, 8 we've been of course hearing from time to time about various 9 dif ficulties with the TVA program at Watts Bar and 10 elsewhere. I thought maybe at this meeting we were going to 11 get a little bit of the background tha t might apply. But I 12 didn' t hear Watts Bar mentioned specifically, or Sequoyah.
O 13 Is that going to be covered somewhere else then?
14 DR. REMICK: We did no t ask the s ta f f 15 specifically.
16 MR. MICHE.* SON: Oh, we don' t want to get into 17 that at all here?
18 DR. REMICK: Not necessarily because this is more 19 general. We do not become plant-specific.
20 MR. MICHELSON: That takes care of my question 21 then. Thank you.
22 DR. REMICK: Dave.
23 MR. WARD: Just a quick one I want to ask Jim. I 24 think Jim made a good point. It seemed good to me anyway, O 25 that the allegation program is probably not very fruitful as ACE-FEDERAL REPORTERS, INC.
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2840 08 09 96 9 DAV/bc 1 far as turning up any significant safety issues. But, it 2 is, he said, necessary because of legal recuirements. Just 3 a quick question.
4 Your point was that if someone wants to address 5 the problem, that that's the place to address it. But are 6 these requirements in the regulations, or are they 7 requirements in the law, federal law?
8 Or are they even lesser?
9 MR. KNIGHT: I would categorize a lot of the 10 types of things that we've seen substantiated, if you will, 11 for want of a better terminology, as kind of secondorial 12 recuirements. Certainly, you have Appendix B and it has
( 13 certain requiremenF.s. It says you will have documentation 14 and this type of thing.
15 And, very frequently not taking debate with the 16 recuirements of having such a program. But then there has 17 evolved a number of interpretations, a number of...I guess 18 I'd call i t standard practices. Expectations might be 19 another tenn'you might use. . .when we have very frequently 20 had an allegation that the utility made a commitment to you 21 that they were going to comply with Standard X, Y, 2 and 22 subparagraph 5 on pcge 16 of that standard says maybe some 23 general statement. And they didn' t do that.
_ 24 And there are a lot of these things. You know, 25 it sounds a little manipulative, but there are an awful lot ACE-FEDERAL REPORTERS, INC.
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2840 08 10 97 a/ DAV/bc 1 of these things. The fact of the matter is they did make 2 that commi tment to us. In a matter of practice, we have 3 held people to whatever that requirement was.
4 If it was pointed out to us that they didn' t do 5 it, we' re going to have to go back and say you didn' t do it 6 and start looking into what does that mean. Very 7 frequently, you find it didn' t mean much at all.
8 If you look again at Diablo Canyon, if you look 9 a t Wa terford, if you look at Comanche to a certain extent, 10 you find an awful lot of our time, energy and resources were 11 expended explaining why, this, tha t or the other thing, 12 although it wasn' t exactly what it was supposed to be,
~'
13 didn' t mean anything.
14 The whole point is if that's your experience, 15 i t's time to go back and look at wha t those recuirements 16 really are, and why are they in place in the first 17 instance. It's not an easy question because the reverse of I
18 that is to probably just let a lot of these things go. And 19 then you've lost control.
20 Finding that middle ground is very difficult.
21 MR. WARD: But the type of requirement you're 22 talking about is not something tha t is at a level of law or 23 regula tion , but it's the staf f practices. I mean, i t's p, 24 an ad hoc requirement tha t the staf f has put on.
(- 25 MR. KNIGHT: No. As I say, there is a licensee ACE-FEDERAL REPORTERS, INC.
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I I
2840 08 11 98 DAV/bc 1 commi tmen t. And I started to say there will be a chain.
2 They make the commitment.
3 MR. WARD: Okay, it's a licensee commitment.
4 MR. KNIGHT: The law says you will use the 5 standards appropriate to the purposes.
6l DR. SIESS: When the licensee commits to a 7 standard, that means he's committed to every single word in 8 it. Does it follow that the specificity of what you're 9 testing against. . .I've never seen a standard that didn' t 10 have some things that were soecified precisely and because 11 when you write it down, tha t's the way you have to write it 12 down. And the guy who wrote it knew if it was 10 percent
\# 13 more than that, it didn' t make any dif ference. But you 14 can' t say tha t.
15 Now, you can get an allega tion -- there are 16 thousands of them -- that something didn' t comply strictly 17 wi th the standard.
18 MR. KNIGHT: And a great percentage are exactly 19 tha t.
20 DR. SIESS: An outstanding example, a very simple 21 one, is Waterford, the allegations that the concrete was in 22 the mixture for 31 minutes when the specification says 30.
23 MR. KNIGHT: That's certainly typical of many.
24 I')
25 ACE-FEDERAL REPORTERS, INC.
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2840 09 01 99 DAVbw 1 DR. SIESS: There was a violation of a 2 specification one which had absolutely no bearing on the 3 integrity of the plant or the safety of the public.
4 Now there's a problem with enforcing that kind of 5 prescrip tive , specific type thing. Usually in anything but 6 the nuclear business, the enforcement is tempered with 7 judgment by people who have judgment and by people who can 8 exercise judgment.
9 Now for some reason NRC can' t do that, it seems, 10 without an awful lot of formality in the process.
11 MR. KNIGHT: I can only agree with you.
12 DR. SIESS: Why can' t we do i t?
13 MR. WARD: Why not? The NRC, I believe, has 14 people who aremore capable of exercising that judgment.
15 Wha t's in the way of a simple rational system?
16 MR. KNIGHT: Somehow we f ail to institutionalize 17 that, I guess. I'm not sure how you go about doing tha t.
18 Maybe as something of an aside, but it might be indicative 19 of an atmosphere that persists that makes it difficult to 20 exercise judgment.
21 I couldn' t help but notice in a recent meeting in 22 Bethesda just a couple of days ago that the number of 23 investigators between OI, OIA, Congress, and such, 24 outnumbered the reviewers. I think they had something like U,_
25 G to 3 or something like that.
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2840 09 02 100 DAVbw 1 DR. SIESS: Would you like to comment on a number 2 of lawyers?
3 (Laughter.)
4 MR. KNIGHT: There was parity there, only three 5 of them.
6 HR. ANKRUM: Dr. Siess, let me add, though, that 7 in the design instructions, we exercise exactly that kind of 8 judgment, and we feel we have the flexibility to exercise 9 that judgment. We exercise it in the specific findings. We 10 have a number of observations or findings, and we will 11 disposition those, and we will describe how we disposition 12 them. And we exercise our abilities in doing that.
13 DR. SIESS: I believe tha t's true. I've seen 14 that in a number of cases. The process of getting to the 15 exercise of that judgment seems to be extremely involved and 16 time-consuming and resource consuming. There had been 17 instances where a stress calculation has been challenged, 18 and it seems tha t everybody goes through the stress 19 calculation four times before somebody looks at the bottom 20 line that says the stress is only half the allowable, and it 21 doesn' t make any dif ference anyway, which the designer l 22 probably knew when he did it, if he knew what he was doing.
23 I agree, I think, in the design area, there have 24 been many, many good examples of the judgment being 25 executed, but only af ter such a formal complex procedure and ACE-FEDERAL REPORTERS, INC.
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2840 09 03 101 DAVbw 1 series of ques tions. I look at some of the design reviews 2 on the seismic design and the cuestions are invariably 99 3 percent on the method of analysis, as if somebody believed 4 the method of analysis.
5 You know, people can sit and argue about the 6 analysis for years, yet i t's the design tha t's important, 7 the end product. Maybe the reviewers are all analysists, I 8 don' t know. Sometimes they've called in consultants to help 9 the analysts ask cuestions on the analysis. It's just that 10 the process seems to be more involved and more 11 resource-intensive than the benefits.
12 MR. ANKRUM: We apply a standard to ourselves 13 that we require the utility to follow, and that is, that 14 when engineering judgment is used in the design, we require 15 that the basis for that engineering judgment be documented, 16 that we set down the reasons for having exercised that 17 engineering judgment, so that a t some time in the future, if 18 that decision or that component has to be modified or 19 revisited in some way, there will be a basis in the 20 documentation for that. We apply the same standards to 21 ourselves. If we are going to disposition a particular 22 finding, if we're going to say, when we reanalyze this, we 23 find it within the design margins, we feel it incumbent upon 24 ourselves to set down the reasons why we would be willing to 25 accept it, which is the same standard we expectr to use.
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40 09 04 102 1 DAVbw 1 There's a lot of formality, and there's something 2 to be gained from that, as well.
3 DR. SIESS: But is the gain in safety or is the 4 gain in something else?
5 MR. ANKRUM: The gain is in auditibility of what 6 we have done and what the utility has done in their case.
7 DR. SIESS: I guess what I'm trying to ge t a t, 8 and I'll admit that nobody knows how to do a PRA 9 incorporating design and construction errors, except if they 10 are already incorporated in the data base, whatever that may 11 be, but I often wonder, if I did a PRA on the plant as g- 12 designed and as built, with no IDVP, IDI, CAT, or whatever, V -
13 and a PRA on the design, after it had been reviewed 14 extensively, would I find any significant difference in the 15 risk, as measured by person-rem, at $1000 a person-rem or 16 reduction in core melt probability. You know, the kind of 17 things you're taking now as safety goal type bottom lines.
18 If the answer is, I wouldn' t find any dif ference, 19 I ask why are we doing this, there must be some other reason 20 than the health and safety of the public that I'm doing it.
21 It may be the credibility of the NRC. I don' t 22 know how to put a dollar value on that. This is the kind of 23 ques tion tha t comes up. I went through Diablo Canyon, ps 24 thousands of allegations, not only allegations, but things O 25 that were discovered, hardly a one of which would have ACE-FEDERAL REPORTERS, INC.
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(- DAVbw 1 affected the ability of that plant to withhold an 2 eartrhouake.
3 MR. ANKRUM: We have found errors or changes 4 needed in designs that would definitely affect safety system 5 function. And those changes have been made, and how they 6 would have affected the person-rem or dollars per 7 person-rem, ultimately, in the PRA. I can' t tell you, but I 8 can tell you we have definitely found errors that af fected 9 safe ty sys tem functionality.
10 DR. SIESS: I'd like a couple of examples, if 11 somebody could think of them, but even so, there's an 12 incremental benefit in finding those af ter the plant goes in
\/ 13 operation. There will probably be an equal number found 14 from operating experience. Now that we've learned to look 15 at operating experience to find out what's not best about a 16 plant, and again, I think there has to be a question as to 17 whether that incremental improvement in safety was worth the 18 ef fort or could we jus t as well wait and depend on operating 19 experience to show it up, because obviously, the process .
20 we're going through now does not lead to perfection. It 21 does not find all the mistakes that have been made. We 22 continue to find mistakes of one kind of another, as the 23 plant operates.
24 MR. ANKRUM: Let's use Davis-Besse as an 25 example. Operating experience allowed us to find out tha t ACE-FEDERAL REPORTERS, INC.
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40 09 06 104 1 DAVbw I certain valves couldn' t be operated with a differential 2 pressure across that, that they had, and the unfortunate 3 thing is that operational experience, we got that right in 4 the middle of an accident, an accident on its way to P
5 happening.
~
6 DR. SIESS: But ACRS had been asking that 7 cuestion for about 10 years, as I recall, about valves that 8 open and close under differential pressures, under abnormal 9 conditions. Salem showed us, you know, that shunt trip was 10 a lot better than undervoltage trip on breakers.
11 MR. WYLIE: I'm not sure Salem showed it. It 7- 12 always has been.
(_ '
13 DR. SIESS: It showed NRC that, no, we learn 14 those things, and you say, yes, it's nice to learn them from 15 incidents that don' t have any effect on the safety of the 16 public. There's always the possibility that we'll learn it 17 only from some incident that does, but my point is that the 18 process only reduces that probability, it doesn' t elimina te 19 it. If we want perfection, you' re not going to get it by 20 the process we're going through.
21 MR. WYLIE: I'm not sure you'll ever get it.
22 MR. WARD: Not only will we not get it, you don' t 23 need it.
s 24 DR. SIESS: We shouldn' t need it, and I hope we
\
25 don' t need it. There's nothing I've ever been involved with ACE-FEDERAL REPORTERS, INC.
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.s u /DAVbw 1 in design that we assume is going to be perfect. We alway 2 try to design things, so that they work, even if they' re not 3 perfect, or at least they don' t kill anybody.
4 MR. WYLIE: That's right. You've got the margins 5 built in to take care of it. Just in the electrical area 6 alone, you've got, for a typical plant, at least a half 7 million terminals. Jus t probably tells you you' re not going 8 to get them all right. And you're going to have to pick 9 them out by your testing programs that are designed to pick 10 those out, such as you mentioned earlier, your pre-op 11 tes ts . Pre-op tests turn up a lot of that kind of things, 12 and thank God, we' ve got the pre-op tests to qualify them.
Q
\' 13 DR. REMICK: I think we've gotten of f 14 allegations.
15 Glenn, you've been waiting very patiently.
16 Please.
17 MR. REED: Inspections. I think I've probably 18 run the total gamut of almost no inspections to lots of 19 them, having been involved in Yankee Rowe. I'm trying to 20 draw a picture, and seeif it may answer some of Chet's 21 ques tions . See if we can' t, from the picture, try to figure 22 out wha t we' re doing wrong.
23 Yankee Rowe, I think, we'll have to agree, I 24 think is one of the most successful nuclear power plants in
( 25 the _ United States. It probably has had, for its lifetime, ACE-FEDERAL REPORTERS, INC.
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840 09 08 106 1 DAVbw 1 the fewest trips, the fewest plucked steam generator tubes.
2 Among the best performance, 25 years of operating history.
1 3 And I can just keep on naming it, and yet was a pioneer 4 plant. That should have given it a disadvantage right away, 5 because the state of the art wasn' t there.
6 Now wha t caused Yankee Rowe to be such a success?
7 Was it inspections? No. I was there. There never was NRC 8 inspection, construction by anybody whatsoever, at all, of 9 Yankee Rowe. Was it operating inspection in the early days?
10 Heck, no. There were never any to speak of. In fact, I 11 remember the first inspector that ever came there, probably 12 af ter one or two years. His name was Reilly. One of the O 13 tough guys. And we had a lot of discussions.
14 So how come Yankee Rowe, and if we get down to 15 audits and paper, you can' t go to Yankee Rowe and find all 16 the paper you want. You're not going to find any paper 17 trail. All you'll find is success.
18 Now I'm going to say that Yankee Rowe was done by 19 stand-up people of quality for the state of the art at the 20 time, movita ted, inspired, to do their work without being 21 clubbed every day.
22 Okay. Now what have we got as a picture? .What 23 we have is -- and I might point out tha t Yankee Rowe was 24 built in the construction phase with a max number of people 25 of 500 or less. Okay. Now wha t do we have? We have ten ACE-FEDERAL REPORTERS, INC.
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1 2840 09 09 107 l DAVbw 1 times as many people on the job site, 5000. And there you l 2 lose control right away, and you have ten times as much 3 paper. I was going to say 100 times as much paper trails, 4 and all these kinds of things. Maybe 100 times or at least 5 ten times as many convincers, floggers carrying whips, 6 diverters, and all these kind of people at hte job site, 7 clubbing away and diverting.
8 Now I'm not going to say that in the NRC, 9 enforcement and inspections for honesty and trend are not 10 necessary. Those are very necessary to establish the 11 integrity of the organization, their ethics, their honor, to
,, 12 do a job, but when we continue to proliferate inspections 13 and proliferate inspections, are we achieving the purpose?
14 I don' t think the record's going to tell you that. The 15 record will tell you that Yankee Rowe achieved the purpose, 16 and these other plants coming along now have got all kinds 17 of allegers, inspectors, windmiller and people running l
18 around in circles like with their head cut off, diluting the 19 effort. And decoupling is the scene of the day. Tha t's the 20 picture of today.
21 Attention is so diverted, and those good inspired 22 ethical, motivated, good old days are no longer in evidence 23 a t the job site.
24 All right. What have we got? Somebody was just O 25 mentioning the number of people that were at some meeting ACE FEDERAL REPORTERS, INC.
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- DAVbw 1 or something. We'll say they were the diverters rather than 2 the contributors.
3 I think that's what's happened in the nuclear 4 workplace. The diverters are now outnumbering the 5 contributors, and the contributors have lost their 6 motivation. So how do we do tha t?
7 You've worried me this morning by talking about 8 more inspections. I'd like to think about less inspections 9 by wise people, who understand the workplace.
10 Now I want to give credit to one program of 11 inspection. That was the resident inspector program. That 12 was good. I didn' t think it was going to be when it was O 13 hatched, and I think the plant I was at was the first plant, 14 one of the first plants that had a resident inspector. It 15 so happened that they picked a wise person who knew about 16 the workplace. He didn' t go hysterical when he saw his 17 first wrench or screwdriver dropped on the floor. I really 18 think the resident inspector program is more the key to 19 success.
20 In fact, if you go back to inspectors at Yankee 21 Rowe, the only inspectors we had were the old-time 22 inspectors like Hartford Steam Boiler, and those kind of l 23 basic insurance inspectors. Those kind of things that have 24 been going on for years with stand-up people who knew their
') 25 jobs in the workplace without a sheet of paper and without ACE FEDERAL REPORTERS, INC.
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'L- DAVbw 1 a check-off list. They had judgment. The thing that was
'2 just mentioned. I don' t know. I think that we desperately 3 need the inspection activity in NRC, because I know that 4 there are management people out there and leaders of 5 industry out there which circumvent and do all kinds of 6 things, but I think we've gone amok. We'va just 7 proliferated the whole thing with noncontributors and the 8 inspectors.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 O 25 ACE-FEDERAL REPORTERS, INC.
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l 2840 10 01 110 ry hr DAVbur 1 MR. PARTLOW: Mr. Reed, I can' t speak to how well 2 Yankee Rowe came out in construction without inspectors, but 3 let me mention a few things.
4 We are adding additional resident inspectors to 5 single unit operating sites. They are at about half of them 6 this year and hopefully a t mos t of them next year. One 7 plant that is not going to get an additional resident 8 inspector is Yankee Rowe.
9 I am perhaps speaking when I shouldn' t, but the 10 NRC management meeting with regional nanagers, and so forth, 11 was held in Philadelphia last week. They were speaking
,_ 12 about how to use the people and the resources that we have
\~) 13 to address problems. What they discussed was the top 14 performers in each region, and wks there a way to really do 15 what I said, reduce inspection at the top performers and use 16 those people where our problems are?
17 As I understand it, one regional administrator in 18 Region 1 said he had one plant where he believed he could 19 take the inspection program down to one resident inspector 20 and that the regional inspection program could consist of 21 that resident inspector, when he sensed something wrong in 22 some area like security or health physics, calling the 23 region for a special inspec tion. It was Yankee Rowe.
24 MR. REED: Let me interrupt and say I believe in '
U,_
25 the resident inspector program. I have said before I don' t ACE-FEDERAL REPORTERS, INC.
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2840 10 02 111 DAVbur 1 think the headquarters and regional headquarters are 2 listening enough to resident inspectors.
3 I also believe -- I know how unfortunate and how 4 much of a problem it is -- that resident inspectors should 5 be rotated. I believe that you have got to learn how to 6 walk in the trenches before you should tell the trenches how 4
7 they should function.
8 I believe that you have the key in the resident 9 inspector program because you -- let's say you assign a man 10 for five years. I wouldn' t assign him less than five years 11 before I said you come to headquarters because we need your t
12 judgment to temper all these wild things that are going on O 13 here in the front office.
! 14 Now, this problem is not unique to NRC. Big 15 companies have the same problem. They have lots of good 16 plant personnel out in the steam plants, but they never 17 promote them out of the plants to where all the windmilling 18 is going on in the front office.
19 I really think the resident inspector program is
- 20 the key to something, but you ought to always be thinking 21 about how many periodic inspectors and headquarters people 22 are running in and out of this facility, and can we cut them 23 down?
24 Now, you said you are going to cut down the 25 periodics and specialty inspectors at Yankee Rowe?
l ACE-FEDERAL REPORbRS, INC.
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2840 10 03 112 DAVbur 1 MR. PARTLOW: Again, I want to make sure it is 2 clear what I said. At a management meeting, the regional 3 adminis tra tors , the EDO, Harold Denton, and so forth, Jim 4 Taylor, they discussed the use of the inspection resources 5 we had and how to address them to what our most serious 6 problems are.
7 What came back again was the theme that I 8 mentioned before of taking inspection resources of f of the 9 top performers as best we are able to identify the top 10 performers, and I am only telling you that Yankee Rowe was 11 apparently mentioned as a place where that could happen.
- 12 MR. REED: I used Yankee Rowe as an example. I U
13 don' t know whether it is .any good any more af ter I lef t 14 there or what. IN*
15 (Laughter.)
16 DR. REMICK: Chet, you had a commnt.
17 DR. SIESS: I keep seeing ratings of plants. I 18 know the regional administrators have come in and given the 19 Commissioners a lis t of trouble plants. I read this in the 20 newspaper, I think, and I read the daily reports from the 21 regions, and I read the PNOs, which tend to indicate who is 22 having problems.
23 There are certain plants that I never see on
- 24 those lists. I almos t forget they exist. Monticello, 25 Kewanee, and Point Beach I hear about every once in a ACE-FEDERAL REPORTERS, INC.
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'a 'DAVbur 1 while. Fort Calhoun, Duane Arnold, they never show up on 2 these lists.
3 Is there some reason?
4 I have never seen ratings that put those plants 5 in a different category, but there are obviously some plants 6 out there that are running along pretty smoothly.
7 Has anybody looked into why they are doing so 8 well?
9 I think one reason is they are small. They have 10 probably got a tenth as many valves as some of the newer 11 plants do. I don' t know.
12 I mean, SALP, I don' t think -- I think it is a
)
\#
13 good enough measure of how much your inspection effort
, 14 should be, considering the objective of the inspection 15 program, but SALP doesn' t measure these other things.
16 Am I wrong about those plants? Do you know 17 something bad about them that doesn' t get into the paper I 18 see?
19 MR. PARTLOW: Thank God, most of them are in that 20 ca tegory .
21 Our job, as we view it, is the problems.
22 DR. SIESS: But isn' t it somebody's job -- maybe 23 it is INPO's job -- to find out why they are doing well and l 24 why other people aren' t and get the people who aren' t doing 1 O
V 25 well to do better?
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2840 10 05 114 hr'DAVbur 1 MR. ANKRUM: Obviously, it is a hard question.
2 One aspect is, as you say, the plants are 3 smaller, less complex.
4 Another reason is --
5 DR. SIESS: But the modern plants are more 6 complex because they are supposed to be safer?
7 MR. ANKRUM: Yes. They may be safer in terms of 8 a hands-off. If you walked away and did nothing, they are 9 safer.
10 The older plants require a lot more operator 11 action, more highly trained operators. There is less 12 hands-of f safe ty.
13 DR. SIESS: You used the word " required. " I 14 don' t think you meant that because " required" a t NRC is a 15 stronger word than you meant.
16 MR. ANKRUM: Please. We looked at these things 17 in the 2-A report, the complexity of the plant, the 18 stability of the workforce. Also, there may well be not 19 that much difference between some plants because a plant may 20 not have had its weakness challenged, as it were.
21 One of those plants that you mentioned that you 22 never read about, we just did a recent inspection on and 23 looked at some of the design aspects. We found tha t tha t 24 plant had not maintained its design basis. In fact, they
( 25 couldn' t even find what the original design bases were, and ACE-FEDERAL REPORTERS, INC.
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,iq h# DAVbur 1 we found a lot of problems with the designs associated with 2 the outage. We found things that would af fect the safety 3 sys tem' a functionality of those sys tems. We found they 4 didn' t know why they were doing some things. They had no 5 adequate design basis for doing things. They didn' t even 6 know what they had in their plant, why the plant was 7 designed the way it was.
8 So it is difficult to see how they would know if 9 they were to effect the design margins by a subsequent 10 modification.
11 Now, we never looked at that before, and now we 12 go in and we look and we find out there are some problems b
13 here.
14 %4 So sometimas you don' t have problems that will 15 cause the area -- it jus t hasn' t been challenged.
16 DR. SIESS: That is a good po.' . But on the 17 i NSEP plants that sort of thing was looked at, and there were l
18 lots of places where those plants did not meet current 19 design criteria, and I admit you were talking about initial 20 design criteria, and an awful lot of places where they 21 didn' t meet current design criteria were considered not too 22 important when you looked at risk rather than regulations.
23 Now, you know, when you look at a deficiency in a 24 plant, you define it in two ways. It is deficient in that ;
() 25 it doesn' t meet the requirements laid down by the .
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\c DAVbur 1 regulations, like GDC-55, -56, -57 on isolation valves. You 2 look 'at it from the standpoint of risk. It doesn' t make any 3 difference.
4 So just the fact that they don' t meet the 5 requirements doesn' t necessarily mean that they are unsafe.
6 I know that is heresy from your side of the 7 table, but not on this side of the table.
8 But you have mentioned other things in terms of 9 ignorance.
10 MR. ANKRUM: One specific finding, accumulator 11 sizing calculations were not performed at this plant. Where 12 modifications af fecting the accumulator, the engineers
(,
~
13 reli.ed on engineering judgment in sizing that accumulator.
14 Previous calculations done, which didn' t go back to the 15 original design bases, overestimated available air by over 16 300 percent, and the modifications did not tes t the ability 17 of the accumulators and valving to perform its design 18 function in the situation that we were faced with.
19 DR. SIESS: What would a modern RELAP calculation 20 show for a large break LOCA?
21 MR. WARD: He is talking about the air system.
22 DR. SIESS: I am sorry.
23 So that would affect the loss of power were you 24 depending on air?
25 MR. ANKRUM: Exactly, and in fact in many plants, ACE-FEDERAL REPORTERS, INC.
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2840 10 08 117 LJ DAVbur 1 LOCA, you automatically strip the air system from the 2 emergency buses. So you are guaranteeing that you will have 3 a loss of power.
4 DR. SIESS: Was this looked at from a risk point 5 of view, a PRA type thing?
6 MR. ANKRUM: No, we don' t do PRAs. We look at 7 safety system functionality. Will it do what it is supposed 8 to do?
9 DR. SIESS: The thing is the risk analysis 10 assumes that sometimes it won' t do it. The requirement 11 assumes it will always do it. You see, it was designed to 12 do it, it will do it. But when you start doing the PRA, you
^ f~)
13 notice some things tha t it won' t do.
14 So I still think the bottom line is risk.
15 MR. REED: You bring up the issue of design. I 16 always bring up the issue of operations.
17 We talked about the Rowe picture and the 18 proliferation of inspections on operating plants, and I have 19 said I think there is a key somehow in the resident 20 inspector program if it was used, perhaps proliferated, 21 while other inspections were downgraded in the operating 22 scene.
23 I would like to say the other half of the 24 equation -- I mean, forget construction this time -- the O 25 other half of the equation that bothers me has always been ACE-FEDERAL REPORTERS, INC.
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2840 10 09 118 DAVbur 1 the vendor scene and the design scene.
2 If you go and talk design -- if you can use this 3 Yankee Rowe example -- Yankee Rowe was created when the 4 state of the art wasn' t too well-known. It was crea ted 5 wi thou t , let's say, steam driven auxiliary feed pumps. That 6 was put in, however, and became the first one ever put in, 7 and the industry followed along. So there was a 8 s ta te-o f- the-ar t si tua tion.
9 It seems to me tha t the headquarters people of 10 I&E and other headquarters people ought to concentrate on 11 the inspections related to design or concentrate more on
,_ 12 vendors and design vulnerabilities being created by 13 vendors.
14 Eventually, you may even get to this licensed 15 vendor scene, but it seems to me there are two halves to 16 quality assurance -- the outbreak plant where you want to 17 have standup experience, people who have had a field life, 18 walking the trenches, and then go to the designer side of 19 your activity. You certainly ought to split these personnel 20 up and have them concentrated where they are most capable to 21 do the job.
22 MR. PARTLOW: That is an integral part of what 23 our safety system's functional inspection is, this somewha t
,_ 24 modern version of the PAT team. It is heavily part of the l
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2840 10 10 119 DAvbur 1 modifications have been made, and design experienced people 2 'are a part of tha t.
3 They do what is called the outage inspection 4 program. It keys to the work packages being conducted 5 during that outage and has people on it from the design end 6 of it.
7 MR. REED: Well, if I had been a member of one of 8 your teams or your organization and I never looked at the 9 drawings on Davis-Besse, all I would have to do is look at 10 the drawings. I wouldn' t even have to make an inspection at 11 Davis-Besse.
12 I would have looked at the fact that they had O 13 four steam driven pumps to provide auxiliary feed; in other 14 words, two mains and two o thers , and I would have said that 15 design is no good and right there said put a stop to it.
16 I don' t understand why that was not. If in 1957, 17 when we created Yankee Rowe, and in the subsequent few years 18 we could have seen the fact tha t you had to make certain 19 electric and steam availabilities for aux feed, I don' t 20 understand why a plant created in the 1970s had this design 21 vulnerabili ty.
22 DR. REMICK: Dave, did you want to comment?
23 MR. WARD: Yes. I would like to go back to the 24 point Dr. Siess raised about the older plants versus the O 25 newer plants, seeing some of the agonies the newer plants ACE-FEDERAL REPORTERS, INC.
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us/DAVbur 1 seem to have, which was partly revealed by experience, 2 partly by your inspections.
3 The older plants don' t seem to have them, and I 4 gather part of that is the older plants were simpler, did 5 not have as many valves, were simpler in hardware but they 6 are also simpler in the tech specs.
7 For the modern plants, the tech specs are more 8 complica ted. Both the hardware and the tech specs were made 9 more complicated because it was perceived that these were 10 improvements in safety.
11 And I guess, are the older plants -- so that this 12 gives more things that can go wrong and your inspections are 13 identifying them, but are your inspections tuned properly --
14 are these older plants kind of living in a fool's paradise 15 here?
16 You are inspecting them against old-fashioned 17 standards, which are no longer valid, and if you inspected 18 and challenged them against a more modern set of standards, 19 which hopefully, we think, are more protective of the public 20 health and safety, would you get a seemingly different 21 performance on old versus new?
22 MR. PARTLOW: I think in general there is 23 something to that, which I had said in my little 24 advertisement.
25 We inspect for compliance, and we try to evaluate
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)DAVbur 1 performance. But when it comes to inspecting for 2 compliance, today's plants, being licensed today, have much 3 more detailed and expansive commitments than the plants that 4 were licensed in the sixties and early seventies, that is 5 right.
6 What is an example?
7 The standard on quality assurance programs, the 8 NS-3.1, which has versions of 1971, '76, '81, '83. There is 9 a difference in what it takes to be in compliance for a 10 quality assurance program, depending upon which of those 11 s tandards you are licensed to.
12 Yes, that is there.
O)
-k/ 13 MR. ANKRUM: There is a conscious Commission 14 policy that plants will be held to the standard in effect at 15 the time their license or permit was granted, absent 16 specific backfitting action. So that is the rules we 17 follow.
18 DR. REMICK: Ted, I sense from your comments 19 about readiness review that you are a believer and think 20 tha t is the way to go.
21 Of course, that is just a pilot program. I don' t 22 think the Commission has made a decision.
23 If somebody were to come a'long and build a plant 24 next week, do they know wha t they might be subject to from
\ 25 the s tandpoint of are they going to have CATS, IDIs, IDVPs, ACE-FEDERAL REPORTERS, INC.
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122 DAVbur 1 readiness reviews?
2 Do they have any idea in the area we have been 3 talking abou wha t. to expec t?
4 I sense -- you say that you are integrating, and 5 that seems like you are impressed with the readiness review; 6 therefore, maybe that would be. the recommendation the staff 7 would be making to the Commission.
8 But it, seems to me that the future licensee is 9 still subject to a whole lot of these programs, plus many 10 more.
11 Am I correct?
12 O
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- DAV/bc 1 MR. ANKRUM: Subject to things like when it comes 2 to direct inspection like an IDI or CAT or safety system 3 functional inspection, all these things are direct 4 inspections by the staff. They're not established by rule.
5 So if the staff finds cause to do those kinds of 6 direct inspections, the staf f will do those kinds of direct 7 inspections, if it has the assets to do them and finds 8 cause.
9 Readiness reviews, on the other hand, tha t's a 10 program tha t the utility voluntarily, in the case of Vogel 11 and the Washington Public Power System has voluntarily 12 agreed to undertake. And we agreed to participate in that.
13 There are duties and benefits to both parts. For 14 , ins tance , the utility is getting incremental acceptance of 15 its work and the NRC is getting a much greater depth of 16 review. And, frankly, it's getting a detailed look at 17 programs earlier than it would have gotten to look at them.
18 So everybody is gaining from that. Now , wha t 19 would happen if someone knew comes across the threshold and 20 .saying, I'm starting in a green field. I'm taking one of 21 these plants that had been previously suspended. I'm going 22 to put it bac? on the agenda. And it was only sitting at 23 20-25 percent uhen it got suspended, basically, a fresh 24 job.
25 We've learned a lot. There are a lot of things ACE-FEDERAL REPORTERS, INC.
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i)DAV/bc 1 that we think could be done better with the construction 2 process. Those things are not being prosecuted through a 3 rule change at this time because the Commission added up its 4 assets versus the needs it saw and decided that it couldn' t 5 afford to put staff time in to rule changes for the future 6 at this point in time.
7 So I think that it would be a process of 8 negotiating between the applicant and the staff, and a 9 seeking of voluntary commitments on the part of the utility 10 and agreement to participate on the part of the staf f in 11 some of these new things that we' re going to.
12 Now, once the utility committed -- and I say O' 13 commi tments in excess of current regulatory requirements --
14 what the utility has committed, it is required to follow 15 tha t commi tment.
16 So your question was: Does a utility know what 17 it can be faced with?
18 The answer is no, because we have not proceeded 19 to rulemaking what a utility is required to do. It knows 20 what it's required to do, and that's no more than it's 21 required to do today.
22 However, I think we've all learned something.
23 And, for instance, the staf f has committed to the Commission 24 that if anyone should voluntarily commit to a designated O- 25 representative program or construction, that we would ACE-FEDERAL REPORTERS, INC.
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'h 'DAV/bc 1 entertain and deal with that, that we weren' t going to 2 require one by rule at this time but if somebody walked 3 across the threshold and said: We want to do this. . .we have 4 instructions from the Commission to work that out.
5 So no utility would not know what they're dealing 6 with right now unless they wanted to say, Hey, I'm going to 7 do what the minimum requirements are in the regulations.
8 DR. REMICK: The point I was trying to ge t a t, 9 one cou'.d interpret all the programs that we're talking 10 about are attempts basically by the staff to find the best 11 way. And to find the bes t way, they're going to narrow it 12 down to tha t.
13 The other could be that the staff has a certain 14 number of resources and they're t$$ing to find a way to keep 15 everybody busy.
16 Therefore, if you want to narrow it down, you've 17 got to cut the resouces. There are two different ways of 18 looking at it. I'm trying to find where the staff is 19 heading.
20 MR. ANKRUM: It's the former, not the latter. We 21 have more jobs than we have rescuces. So it's very 22 definitely the fonaer.
23 DR. REMICK: Chet.
24 DR. SIESS: I have two questions. Both of them,
'-~'
25 I think, have relatively short answers and if they don' t, we ACE-FEDERAL REPORTERS, INC.
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2840 11 04 126 b'DAV/bc u/ 1 can defer them.
2 First, in relation to design review, what is your 3 thinking or your practice for standard designs?
4 MR. ANKRUM: Well, the Commissioners are on 5 record that standardized designs are the way to go. The 6 only question that seems to be on the table is how much 7 design is a, quote, " completed design" before you come to 8 the CP?
9 I don' t believe there's any agreement at this 10 point in time on how much of a design are we talking about 11 should be in place prior to the CP application coming.
12 I think, in practical effect, it will be a rather b
N/ 13 substantially advanced state of design.
14 DR. SIESS: Let's take the specific GESSAR II as 15 a standard design. Has there been IDI, IDVP, any 16 independent review of that design?
17 MR. ANKRUM: No.
18 DR. SIESS: Nothing planned?
19 MR. ANKRUM: Nothing other than the NRR design 20 review and nothing planned because we don' t have a specific 21 application.
22 DR. SIESS: And you' re going to separate. You 23 make a distinction then between a standard plant design and 24 one that's been referenced in an application. It won' t be 25 reviewed until it's referenced in an application?
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\ DAV/bc 1 MR. ANKRUM: We're not going to inspect a design
.2 unless we've got an applicant.
3 DR. SIESS: If you ge t one applicant, you'll 4 inspect it and that will hold for the second one?
5 MR. ANKRUM: Well, we have a precedent for that 6 in the current design inspection activities. We've 7 inspected a first unit and the second unit tends to 8 replicate it. And sometimes more than the second unit. And 9 I'll use the case of Byron I.
10 At Byron I, the design was looked at with an IDI 11 in considerable depth. There was an IDVP that followed as a 12 result of that IDI to follow up some loose threads. We have D)
(- 13 accepted the validity of that inspection for Byron II, 14 Braidwood I and II and Marble Hills. It would have been 15 accepted for Marble Hills.
16 DR. SIESS: It's the safest of the four.
17 MR. ANKRUM: Safe for the peculiarities of each 18 of those individual plants. Braidwocd had some 19 pecualiarities that Byron I did not have.
20 DR. SIESS: My second question. Have you made 21 any progress on establishing a relationship between quality 22 assurance, quality and safety?
23 MR. ANKRUM: Tha t's a loaded question. That 24 doesn' t have a short answer?
25 DR. SIESS: We've asked it before and you said ACE-FEDERAL REPORTERS, INC.
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1 l
2 MR. WARD: They did.
l 3 MR. ANKRUM: We tried and we said we couldn' t l
4 quantify it.
5 MR. WARD: I always felt we got a little bit of a l 6 token ef fort there.
I 7 (Laughter.)
8 MR. ANKRUM: Le t's try it this way. We have more 9 jobs than we have people to do them. And we didn' t put a 10 lot of people on that question.
11 DR. REMICK: Dave.
12 MR. WARD: If it's appropriate, I would like to A 13 address a proposition to the subcommittee. I'll try to make 14 it brief. The NRR has a branch that has developed methods 15 and continually applies these methods, making a sort of 16 accrued cost benefit analyses of generic issues to decide 17 whe ther it's appropriate for the staf f to. spend the 18 resources on addressing the issue.
19 I guess we've had some discussion here of whether 20 some of these programs within the sort of work that we' re 21 talking about here could survive the sort of scrutiny that 22 that kind of cost benefit analysis entails.
23 I suspect there are a number of other programs 24 throughout the agency that similarly have questionable' cot t 25 benefit standing. There's a lot of scof fing about the ACE-FEDERAL REPORTERS, INC.
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' 2840.11 07 129 DAV/bc 1 ability of that cost benefit analysis to approach the true 2 relationships and cost benefits.
3 But it is a reasonably disciplined and sincere 4 effort to do as best as can be done. What you either do in 4
5 that method or you do by pulling numbers completely out of 6 the air.
7 Now I understand the agency is going to be faced 8 with probably some pretty dramatic budgetary cutbacks in the 9 next year. And a lot of programs are going to have to be 10 cut out.
11 I guess I'm asking the subcommittee to consider 12 whether they think that existing programs of the agency as 13 well as proposed new programs on generic issues shouldn' t be 14 subjected to this sort of analysis, that the Generic Issues 15 Branch has given as a basis for prioritizing what's going to 16 be lef t of the agency.
17 DR. REMICK: I guess one of the problems I would 18 have with that, I don' t know if he could do a cost benefit 19 on the idea of the problem you might find by inspection.
20 You might be able to do it by case histories, of taking 21 maybe an IDI or an IDVP that has been conducted and say:
22 What did you find and what was the safety significance of 23 that finding from the standpoint of public risk, and what 24 did it cos t? And make some maybe decisions based on O 25 experience.
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k )DAV/bc m 1 I guess I can' t quite see how you'd do tha t into 2 the future, where you don' t know where a future IDI or IDVP 3 or future readiness review, what safety improvement it might 4 result in.
5 That's my initial reaction. I'm not opposed to 6 it but it seems to me we might almost have to do it by case 7 s tudy .
8 MR. ANKRUM: Let me point out you also have 9 another side to that coin. And 'that is you might have a 10 plant in which questions about the safety of that plant had 11 been raised that were design-related. And in the 12 prosecution of the inspection, you find that those questions
-J 13 have no validity, or are particularly significant. And it 14 allows the licensee to go forward.
15 Now we have two specific instances of that. I 16 should say three specific instances. In the case of Byron 17 I, the IDI found a number of problems. And we required the 18 utility to do further work to prove to us that the problems 19 we found didn' t have cross-cutting implications throughout 20 the remainder of the design.
21 They undertook that work and came in with the 22 answer. We looked over their shoulder the whole time. In 23 the meanwhile, the intervenor for the Byron I plant 24 petitioned to reopen the hearing on the basis of our 25 original inspection findings.
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u DAV/bc 1 We were able, through both the IDI and the 2 followup work to tha t, to satisfy the Board tha t we in f ac t 3 knew what the status of the safety consequences of those 4 findings were.
5 The Board declined to reopen the hearing. And 6 the case of the Clinton Station and the Hope Creek Station, 7 as a result of the IDVP's, the joint intervenor in each case 8 agreed to drop their design OA contentions, which were the 9 major contentions before the hearing.
10 And, in both of those cases, the plant went 11 forward with an uncontested hearing. In fact, no hearing.
12 So, to say that you want to measure the
13 effectiveness of some of these inspections by the safety gl4 significance of the findings only looks at one side of the 15 coin.
16 Finding that there are no deficiencies of safety 17 significance is equally as important.
4 18 DR. SIESS: Well, it has a cost aspect, too. I 19 think that's part of it but I think that not only I&E and QA 20 activities, but in other areas of NRC, it's not going to be 21 merely as simple to do a cost benefit like we do on generic 22 issues, where it's a clear-cut, technical type issue.
23 I think many other areas are driven by public 24 rela tions , Congressional relations, things of that sort.
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is/ DAV/bc 1 intervenors. Things are being done because Congress said to 2 do them. Over and above the mandate from Congress to make 3 them safe, Congress says do this, do that.
4 So it really complicates it and nobody's going to 5 do it until the budget gets cut. And then they don' t do it 6 in some cases.
7 MR. WARD: But I think, even in most cases, the 8 fact that things are being done, that nonsense is being 9 carried out because the Congress says to, ought to be pinned 10 on Congress. Not sort of disguised as some sort of safety 11 beneficial activity.
12 OR. SIESS: I've got a real long list of those.
\- 13 DR. REMICK: Any other discussion or cuestions?
14 (No response.)
15 DR. REMICK: If not, I think we've gone on long 16 enough. I don' t want to cut it short because we certainly 17 have time.
18 (No response.)
19 DR. REMICK: If not, I want to thank the staf f
. 20 for participating in our seminar today and, occasionally, in 21 our lecture. We do appreciate your coming down. We had 22 hoped that your answers could have been a little bit more l 23 specific on the cost benefit.
24 I necessarily understand the dif ficulty in that 25 but we appreciate your coming down and expressing your ACE-FEDERAL REPORTERS, INC.
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L- DAV/bc 1 views and making comments on the effort that has been made.
2 Thank you.
3 (Whereupon, a t 12:05 p.m. , the meeting 4 adjourned.)
5 6
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l l
CERTIFICATE OF OFFICIAL REPORTER I
.kp].
This is to certify that the attached. proceedings before
-the UNITED STATES NUCLEAR REGULATORY COMMISSION in the
- matter of:
NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON QUALITY AND QUALITY ASSURANCE DOCKET NO.:
PLACE: WASHINGTON, D. C.
DATE: FRIDAY, DECEMBER 13, 1985 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
s (sigt) e (TYPED)
DAVID L. HOFFMAN Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation C)
L 0
O O O NRC INSPECTION PROGRAM i
o INSPECTION PROGRAM CBJECTIVE: TO ENSURE QUALITY CONSTRUCTION AND SAFE OPERATION OF LICENSED FACILITIES THROUGH:
- VERIFICATION THAT ACTIVITIES ARE IN COMPLIANCE WITH NRC REQUIREMENTS AND !
- EVALUATION OF LICENSEE PERFORMANCE IN DISCHARGING PRIMARY RESPONSIBILITY FOR NUCLEAR SAFETY o INSPECTION PROGRAM RESOURCES ARE ALLOCATED DEPENDING UPON TYPE OF FACILITY, STATUS OF CONSTRUCTION /0PERATION, AND REGULATORY PERFORMANCE:
- 90% OF DIRECT INSPECTION RESOURCES DEDICATED TO COPNERCIAL REACTORS; 10% DEDICATED TO FUEL CYCLE FACILITIES, MATERIALS AND RESEARCH REACTORS.
l - LEVEL OF GENERAL REACTOR INSPECTION EMPHASIS IS BASED UPON PLANT STATUS. FOR EXAMPLE, A SINGLE UNIT ,
SITE IS ALLOCATED ABOUT:
- 4 INSPECTOR FTE/YR DURING CONSTRUCTION
- 6 FTE/YR DURING PRE-0P TESTING (18 MONTHS PRIOR TO OL)
- 4.7 FTE/YR DURING START-UP (2 YEARS AFTER OL)
- 4 FTE/YR DURING OPERATION (AFTER FIRST 2 YEARS)
- ONE OBJECTIVE OF SALP PROGRAM IS TO DEV0TE INSPECTION ATTENTION TO SPECIFIC PLANTS BASED UPON PERFORMANCE.
SALP CATEGORY ONE INDICATES A CANDIDATE FOR REDUCED INSPECTION; INCREASED INSPECTION IS CONSIDERED FOR CATEGORY THREE. REGIONS DEVELOP PLANT SPECIFIC INSPECTION PLANS.
l j
O O O THREE BASIC SEGMENTS OF INSPECTION o RESIDENT INSPECTION: THE AGENCY'S CONTINUING ONSITE PRESENCE. RESIDENT PROCEDURES ORIENTED TOWARD DIRECT OBSERVATION OF ROUTINE AND SPECIAL ACTIVITIES: DAILY VISITS TO CONTROL ROOM, SYSTEM WALKDOWNS, OBSERVATION OF MAINTENANCE, SURVEILLANCE AND CONTROL ROOM OPERATIONS, " PULLING THE STRING" ON MATTERS WHICH APPEAR QUESTIONABLE.
o REGION BASED INSPECTION: COMPLEMENTS THE RESIDENT PROGRAM THROUGH PROGRAPNATIC INSPECTIONS (QA, TRAINING, ETC.) AND SPECIFIC TECHNICAL EXPERTISE (HP, EP, SAFEGUARDS, ELECTRICAL / MECHANICAL ETC.). REGIONAL INSPECTORS PROVIDE PERSPECTIVE IN EVALUATING REGULATORY PERFORMANCE SINCE THEY ROUTINELY INSPECT MANY SITES WITHIN THE REGION.
'o IE HEADQUARTERS INSPECTION: IE CONDUCTS PROGRAMS WHICH ARE MOST EFFECTIVELY MANAGED ON A NATIONAL BASIS:
- VENDOR INSPECTION PROVIDES A CENTRAL ORGANIZATION FOR WORKING WITH REGIONS TO FOCUS VENDOR PERFORMANCE PROBLEMS WHICH AFFECT PLANTS IN EACH REGION.
- CAT / PAT INSPECTIONS PROVIDE MECHANISM FOR ASSESSMENT OF REGIONAL PERFORMANCE, MONITORING 0F INPO EFFECTIVENESS, GATHERING OF INFORMATION ON PERFORMANCE FROM A NATIONAL PERSPECTIVE, AND INPUT TO INSPFCTION PROGRAM DEVELOPMENT.
- INDEPENDENT DESIGN INSPECTIONS (IDI) PROVIDE FOR A CORE OF DESIGN EXPERTISE IN HEADQUARTERS.
SINCE IDI CONCENTRATES SIGNIFICANTLY ON AE ACTIVITIES, CENTRALIZATION OF INSPECTIONS IS MORE EFFECTIVE.
- IN SUCH AREAS AS FIRE PROTECTION AND EQUIPMENT QUALIFICATION, IE DIRECTLY MANAGES ONSITE INSPECTION PROGRAM ONLY UNTIL SUCH TIME AS POLICY HAS BEEN DETERMINED, INSPECTION PROCEDURES ARE FULLY DEVELOPED, AND REGIONS HAVE GAINED EXPERIENCE. PROGRAM IS THEN REGIONALIZED.
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- GENERAL ATTRIBUTES OF INSPECTION PROGRAM 2
o INSPECTION PROGRAM FOR OPERATING REACTORS IS GENERALLY DIVIDED INTO THREE LEVELS:
- MINIMUM PROGRAM: CONSISTS PRIMARILY OF RESIDENT INSPECTION ACTIVITIES PLUS MINIMAL CHECKS BY REGION BASED INSPECTORS. REPRESENTS A " LOWER LIMIT" GUIDELINE FOR REGIONAL USE IN SALP CATEGORY ONE CASES OR WHEN
, RESOURCES ARE TEMPORARILY STRAINED DUE TO PROBLEMS AT OTHER PLANTS.
- BASIC PROGRAM: THE LEVEL WHICH IS NORMALLY EXECUTED AT MOST PLANTS. ROUGHLY EQUATES TO CATEGORY TWO PERFORMANCE.
- SUPPLEMENTARY PROGRAM: ADDITIONAL INSPECTION PROCEDURES TO BE USED IN CONJUNCTION WITH CATEGORY THREE PERFORMANCE, MAJOR PLANT EVENTS OR UNUSUAL CONDITIONS.
o RESIDENT INSPECTORS PERFORM DIRECT INSPECTION ACTIVITIES ABOUT TWO-THIRDS OF WORK TIME.
o REGIONAL INSPECTORS ARE ONSITE PERFORMING DIRECT INSPECTION ACTIVITIES ABOUT ONE-THIRD OF WORK TIME. TRAVEL -
4 T0/FROM SITE, TRAINING, AND OTHER ACTIVITIES RESULTS IN TYPICAL INSPECTOR BEING IN TRAVEL STATUS FOR OVER 40%
OF TIME.
I o ABOUT TWO-THIRDS OF AN INSPECTOR'S DIRECT INSPECTION TIME IS DEVOTED TO PLANNED (" PREVENTIVE") INSPECTION ACTIVITIES. ABOUT ONE-THIRD IS " REACTIVE" INSPECTION RESULTING FROM EVENTS, REPORTS, ETC.
o ON AN ANNUAL BASIS, ABOUT 20% OF RESIDENT INSPECTOR'S ON-SITE TIME IS DEVOTED TO BACKSHIFT ACTIVITIES.
o SEPARATE FROM ASSIGNMENTS MADE BY SUPERVISORS, ALL INSPECTORS ARE AFFORDED OPPORTUNITY TO SPEND 20% OF ONSITE TIME I IN INDEPENDENILY REVIEWING AREAS OF CONCERN / INTEREST WHICH ARE SAFETY RELATED.
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b INSPECTION PROGRAM PLANS / TRENDS
! o IE PLANS FOR NEXT SEVERAL YEARS INCLUDE:
i i j - INCREASE TO TWO RESIDENTS AT MOST SINGLE UNIT OPERATING SITES l - INCREASED USE OF REGIONAL TEAM INSPECTIONS TO DIAGNOSE PROBLEMS '
j 2
- MORE EMPHASIS ON DEVELOPMENT OF SITE SPECIFIC INSPECTION-PLANS WHICH REFLECT LICENSEE PERFORMANCE
- EMPHASIS ON " PERFORMANCE MEASURES" FOR EVALUATING PROGRAM ADEQUACY (TRAINING, i QA, MAINTENANCE) i j - DEVELOPMENT OF OUTAGE INSPECTION PROGRAM AIMED AT ENSURING THAT MODIFICATIONS / REPAIRS l DO NOT DEGRADE SAFETY MARGINS *
! - PHASE 0UT OF REGULAR CAT AND IDI INSPECTIONS IN FY-87 i
! - INSPECTION EMPHASIS DURING FIRST TWO YEARS OF REACTOR OPERATION l - ADDITIONAL EMPHASIS ON UTILITY RESPONSIBILITY TO PROCURE QUALITY PARTS / SERVICES FROM ,
j VENDORS l - DEVELOPMENT OF REALISTIC USES OF PRA IN INSPECTION PROGRAM 4 ;
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IE PROGRAM RESPONSIBILITIES o IE DEVELOPS AND PROMULGATES INSPECTION PROGRAM POLICY AND PROCEDURES FOR IMPLEMENTATION BY REGIONAL OFFICES o REGIONAL ADMINISTRATORS ARE RESPONSIBLE TO IE FOR IMPLEMENTATION OF IE PROGRAMS WITHIN THE B0UNDS OF POLICY GUIDANCE o IE IS RESPONSIBLE TO THE ED0 FOR ASSESSING THE ONG0ING EFFECTIVENESS AND UNIFORMITY OF REGIONAL IMPLEMENTATION OF INSPECTION PROGRAMS. IE ASSESSES PERFORMANCE OF EACH REGION THROUGH:
- THE CONDUCT OF PAT, CAT AND OTHER INDEPENDENT INSPECTIONS BY IE
- ACCOMPANIMENT ON REGIONAL INSPECTIONS
- ASSESSMENT VISITS TO REGIONAL OFFICES
- REVIEW 0F INSPECTION REPORTS ANC DATA SYSTEMS ,
- REVIEW AND OBSERVATION OF SALP ACTIVITIES
- ROUTINE STAFF AND MANAGEMENT INTERFACE IN SUCH MATTERS AS INSPECTION PROGRAM DEVELOPMENT, AND RESOLUTION OF INTERNAL POLICY ISSUES AND LICENSEE PROBLEMS
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l NRC MANUAL CHAPTER 0517 ALLEGATION MANAGEMENT SYSTEM o DRAFTED BY IE o ISSUED BY EDO SEPTEMBER 198tl IN DRAFT AS POLICY GUIDANCE. -
o COMMISSION DECISION ON LATE-FILED ALLEGATIONS ISSUED MARCH 1985.
O COMMISSION DECISION ON CONFIDENTIALITY ISSUED NOVEMBER 1985, o
o 0517 BEING REVISED. TO BE FINALIZED FEBRUARY 1986, f
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MAJOR POLICY AREAS-0517 o ESTABLISHMENT OF 0FFICE C0ORDINATORS o CONTACT WITH ALLEGERS CONFIDENTIALITY O
o CONTACT WITH LICENSEE N0 BREACH OF CONFIDENTIALITY NO COMPROMISE OF INSPECTION / INVESTIGATION o DOCUMENTATION l
l 0 CLOSE-0VT WITH ALLEGER i-0 LATE-FILED ALLEGATIONS l
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CONFIDENTIALITY o NOT OFFERED TO ALL 13 USE AS TOOL, WHEN NECESSARY, TO ELICIT INFORMATION, 4
o SIGNED CONFIDENTIALITY AGREEMENT o NRC WILL MAKE ITS BEST EFFORTS TO PROTECT IDENTITY OF A CONFIDENTIAL SOURCE i
o IDENTITY RELEASED WITHIN NRC ONLY ON NEED-TO-KNOW BASIS,
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o IDENTITY RELEASED OUTSIDE NRC ONLY:
BY ORDER OF A COURT BY ORDER OF THE COMMISSION TO FEDERAL OR STATE AGENCY TO CONGRESS i
i (SEE SRM 0F NOVEMBER 1, 1985)
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o POLICY APPROVED BY COMMISSION MARCH 1985 o RESULTED FROM RECEIPT OF LARGE NUMBER OF. ALLEGATIONS .
JUST PRIOR TO LICENSING, 4
o STRESSES RESPONSIBILITY OF ALL TO BRING CONCERNS T0 APPLICANT OR NRC AS S00N AS POSSIBLE
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o ESTABLISHES SCREENING CRITERIA FOR THOSE ALLEGATIONS THAT
, ARE NEW AND MATERIAL TO LICENSING DECISION LIKELIHOOD THAT THE ALLEGATION IS TRUE SAFETY SIGNIFICANCE I ()
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I ALLEGATION PROCESSING
- ALLEGATION j RECEIVED BY NRC i
' ALLEGATION DOCUMENTED 4 .
4 ALLEGATION REVIEW BOARD MEETING
! ALLEGER I CONTACTED
- O i RESOLUTION ACTIVITY -
i INSPECTION / INVESTIGATION
! EVALUATION p
PREPARATION OF
- RESOLUTION DOCUMENT i
I ALLEGER CONTACTED CLOSE-00T i
ALLEGATION CLOSED
, IN AMS O
OPEN ALLEGATIONS O AS OF 11/29/85 BRAIDWOOD 1 18 BYRON 2 2 CATAWBA 2 1 CLINTON 35 COMANCHE PEAK 1 200 HOPE CREEK 3 MILLSTONE 3 18 . .
NINE MILE 2 7 PALO VERDE 2 11 PERRY I 8 SEABROOK 1 5
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