ML20154G702

Summary of ACRS Subcommittee on Quality & QA in Design & Const 851213 Meeting W/Nrc in Washington,Dc Re NRC Insp Programs & Readiness Reviews to Ensure Quality in Plant Design & Const.Agenda & Attendee List Encl

ML20154G702
Person / Time
Issue date:	02/18/1986
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
References
ACRS-2382, NUDOCS 8603100079
Download: ML20154G702 (13)

Text

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SUMMARY

/dINUTES OF THE ACRS SUBCOMMITTEE ON QUALITY AND QUALITY ASSURANCE IN DESIGN AND CONSTRUCTION DECEMBER 13, 1985 WASHINGTON, D.C.

The ACRS Subcommittee on Quality and Quality Assurance in Design and Construction met in Washington, D.C. on December 13, 1985 to discuss with the NRC Staff inspection programs and readiness reviews to ensure i quality in nuclear power plant design and construction. In addition, their programs to deal with allegations concerning plant quality at the operating license stage was discussed.

Notice of the meeting was published in the Federal Register on November 22, 1985 (Attachment A). The schedule of items covered in the meeting is in Attachment B. A list of handouts kept with the office copy of the minutes is included in Attachment C. The entire meeting was open to the public. There were no written or oral statements received or presented from members of the public at the meeting.

R. Major and E. Igne were the cognizant ACRS staff members for the meeting.

Principal Attendees ACRS NRC F. Remick, Chairman J. Partlow D. Ward, Member G. Ankrum C. Siess, Member R. Heishman G. Reed, Member J. Milhoan C. Michelson, Member R. Brady C. Wylie, Member J. Knight M. Williams R. Brady, NRR, briefly discussed the allegation management system, as defined in NRC Manual Chapter 0517. This chapter was drafted by I&E in 1984 and issued by the ED0 in September 1984, in draft form, as policy L:^ . . , .

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o QUALITY & QUALITY ASSURANCE 2 December 13, 1985 Meeting guidance. This chapter is presently being revised to account for the Commission decisions on late-filed allegations and confidentiality, and 0517 should be finalized in February 1986. Regarding confidentiality, R. Brady stated that this is used as a tool when necessary to obtain information not otherwise obtainable. Confidentiality is not offered to all allegers; although if offered a written confidentiality agreement is signed. Identity of the alleger is released outside NRC only by a court order, by order of the Commission or released to congress and federal or state agencies.

The late-filed allegation policy resulted from receipt of a large number of allegations just prior to licensing. The policy stresses the respon-sibility of all to bring concerns to the applicant or NRC as soon as possible. It establishes a screening criteria for those allegations that are new and material to a licensing decision based on the likelihood that the allegation is true and of possible safety significance. All allegations are tracked via a computer system.

In reply to a committee question regarding a cost-benefit analysis on the NRC Staff's allegation program, the Staff stated that no cost-benefit analysis has been performed and indicated that some signif-icant safety findings have been found, although only a very limited number. The NRC Staff feels that all allegations must be " looked at" and not disregarded because of their feeling of accountability. It was stated that about 17 FTEs process allegations.

J. Partlow, I&E, discussed the NRC inspection programs. He stated that the objective of the inspection program is to ensure quality con-struction 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. Inspection program resources are allocated depending

QUALITY & QUALITY ASSURANCE 3 December 13, 1985 Meeting upon type of facility, status of construction / operation and regulatory performance. For example, a single unit site is allocated about:

. 4 inspector FTE/yr during construction

. 6 FTE/yr during pre-op testing

. 4.7 FTE/yr during startup (2 years after OL)

. 4 FTE/yr during operation (after first 2 years)

Safety assessment of licensee performance (SALP) is one of the primary tools used by I&E. One objective of the SALP program is to devote inspection attention to specific plants based upon performance. SALP Category 1 performance indicates a candidate for reduced inspection and Category 3 for increased inspection. The SALP program is generally performed every 12-18 months to determine in a qualitative manner the plant and utility performance. It was mentioned that SALP is not a detail inspection program (it is a records review) but a qualitative judgment of plant performance.

The three basic segments of the NRC inspection program are as listed:

. Resident inspection - the agency's continuing onsite presence toward direct observation and special activities Region-based inspection - complements the resident program through programmatic inspections which provide perspective in evaluating regulatory performance since they routinely inspect many sites within the region.

. IE headquarters inspection - conducts programs which are most effectively managed on a national basis, for example

1) vendor inspection which focuses on vendor performance problems; i

2) construction appraisal team (CAT)/ performance appraisal team (PAT) inspections which provide a mechanism for assessment of

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QUALITY & QUALITY ASSURANCE 4 December 13, 1985 Meeting regional performance, monitoring INPO effectiveness and developing new inspection programs;

3) independent design inspections (IDI) which provide for a core of design expertise in headquarters and concentrates on AE e

activities.

It was stated that CAT inspections are being performed at a rate of about five plants per year, and PAT inspections about 3-4 per year.

J. Partlow briefly discussed IE plans for the next several years. They include the following:

increase to two residents at most single unit operating sites, increased use of regional team inspections to diagnose problems, emphasis on performance measures for evaluating program adequacy, developtrent of outage inspection program aimed at ensuring that modifications and repairs do not degrade safety margins,

. inspection emphasis during first two years of reactor operation, additional emphasis on utility responsibility to procure quality parts / services from vendors, and

. development of realistic uses of PRA in inspection program.

Some highlights of the discussions between the NRC Staff and the Commit-tee are as follows:

. It was noted that inspection programs that are related to con-struction activities, such as, CAT, IDI and IDVP are winding down, as the agency shifts emphasis away from plant construction and towards plant operations.

It was suggested that some sort of cost / benefit analysis be applied to the inspection programs and the way NRR handles alleg'tions.

a In view of the reduction of agency resources, it would appear useful to ensure funds spent on addressing allegations were contributing

,o QUALITY & QUALITY ASSURANCE 5 December 13, 1985 Meeting an appropriate amount of reduction in risk to the public health and safety. A concern raised was that expeditures on allegations could be draining resources from programs which could make a larger contribution to safety.

. Another comment indicated that cost / benefit analyses could be made on items discovered in past allegation investigations. The safety significance of potential future allegations can not be predicted.

The Staff noted that only a few allegations result in a finding that has safety implications. Presently the Staff is not able to give an indication of the cost / benefit from the various programs.

The Staff appeared to perceive it as their duty to investigate allegations that are referred to them.

. The Staff noted that there is value in inspections which discover no safety problems. A finding that things are in good order can have benefit to the Staff and Applicant. For example, ASLB hear-ings have been avoided by the results of favorable inspections.

. The Staff felt that as the agency shifts toward a more plant operations orientation, the inspection programs, over time, will become more integrated.

. In response to questions from Mr. Reed, the Staff indicated that plant safety is ultimately the responsibility of the utility. This does include the utility being responsible for the vendor's prod-ucts. The Staff expects the utility to be informed customers.

,, QUALITY & QUALITY ASSURANCE 6 December 13, 1985 Meeting future Actions A subcommittee report to the full ACRS will be presented at the January 1986 meeting.

NOTE: A complete transcript of the meeting is on file at the NRC Public Document Room at 1717 H St., N.W., Washington, D.C. or can be obtained at cost from Ace Federal Reporters, Inc., 444 North Capitol St.,

Washington, D.C. 20001 [ Telephone (202) 347-3700]

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that the systematic evaluation program

%e Subcommittee will then hear has been completed. By letter dated .

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presentations by and hold discussions March 16.1983, the staff informed ~.

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with representatives of the NRC Staff. NNECo that the systematic evaluation

.g Safeguards; Subcommittee on Quality its consultants. and other interested program had been completed for and Quality Assurance in Design and

.. persons regarding this subject.' Mllstone Unit 1 and that. pursuant to 10..

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Construction; Meeting -

Further information regarding topics - CFR 50.71(e)(3), the licensee was

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to be discussed. whether the meeti '

required to file an updated NAR. By ' (' ,

.d  : . He ACRS Subcommittee on Quality has been cancelled or rescheduled, e letter dated February 4.1965 the -

and Quahty Assurance in Design and , - Chairman's ruling on requests for the licensee requested an exemption to j{ Construction will hold a meeting on -

December 13.1985. Room 1040,171711 opportunity to present oral statements defer submittal of the updated FSAR for

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and the time allotted therefor can be Millstone Unit 1. By letter dated April g Street. N1. Washington. DC. , obtained by a prepaid telephone call to 11.1985, the staffissued an exemption to p The entire meet ng will be open to ,,

public attendance.

the cognizant ACRS staff member.Mr.

10 CFR 50.71(e)(3) for %!! stone Unit 1

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.. ., . Richard Major (telephone 202/634-1414) phtmitting a 6 month extension from tha

• He agenda far LE subject meeting. . between 815 a.m. and 5.00 p.m. Persona date ofissuance of the exemption for . " -

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planning to attend this meeting are evbmittal of the updated FSAR. Any . .

Friday. December 13.19as--d:300.m. . . . urged to contact the above named '

additional exempilons to 10 CFR 50.71 S-(a; untilthe conclusion of business , individual one or two days before the . would be granted by the Director of

,., . ' The Subcornmittee will discuss with

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IJcensing. ONRR. only upon redew and

} . gi s d1 e lhm approval of a program plan for the the NRC Staff such programs as CAT. h*** '*" " d* . .

. . IDVP.IDI. and readiness review to * '*

submittal of an updated FSAR. By letter,

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• ensure quality in nuclear plant design . ' Dated November 1s.tess. 3 l.. . dated September 13.1985, the licensee I

and construction. Further. a discussion Moriou W IAarkia. .

requesteo an additional exemption to .

will be held with the Staff on their - Assistant Euevtive Directorfor Project defer submittal of the updatel FSAR for

~ [' program to deal with al!egations -

Renew. Millstone Unit 1. However by letter .,

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concerning quality at the OL stage (e g.,

Comanche Peak) Emphasis should be

[nt Dec. as-tro:a nled 11-21-as; a 45 a nj aumo coca rm as .

dated October 2.1965 the sta!Inotified NNECo that its request for en additional i or comparing the resources required by exemption was being denied because,;

p i '. the earious programs and the * ' - .

.- the l.icensee's request was not

.; effectiseners of the programs in assuring (Docaem m2ul , , ,,,ponsive to the terms identified In'the '

,a quality of plant design. construction and Northeast Nuclear Energy Co. et at; exemption lasued on April 11.1965. By ,

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Environmental Assessment and letter dated October 11.1965. NNECo Oral statements may be presented by . Finding of No Significant impact resubmitted a request for an exemption

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< of the public with the - *

. r ". from the schedular requirements of 10 concurrence of the Subcommittee no U.S. Nuclear Regulatory . ., , CFR 10.71(e)(3)(ii) that contained the .

• 1 Chairman; written statements will be , Commission (the Commission)is schedular information required. He E'0 accepted and made available to the consideringissuance of an exemption e deferralof the submittalof th: updated.

Committee. Recordings will be permitted from the schedular requirement of to a FSAR is the proposed action being

['. S only during those portions of the CFR 50 71(e)(3)(li) to the Northeast considered by the staff.

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meeting when a transcript is being kept. Nuclear Energy Company (NNECo)(the

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\? and questions may be asked only by . licensee) for the Millstone Nuclear

} 'y members of the Subcommittee.its Power Station. Unit No.1. located at tho' For most plants covered by to CHL ~

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consultants, and Staff. Persons desirfng

~ to make oral statements should notify .. Connecticut..

licensee's site in New tendon County. . 50.71(c)(3)(ii). ample time was available for updatmg the FSAR within the 24-'

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the ACRS staff member named below as Environmental Am- rt far in advance as is practicable so that / -

month interv al a!! awed in ths

• regulations. However. Millstone Unit l '

iV appropriate arrangements can be made. Identificotion o/ProposedNetion " . a requested participation in an expanded-

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ne proposed action would grant en assessment of outstanding regulatory '

i 0 meeting the Subcommittee.along with 3 exemption from the requirements of to - requirements' with the idea of . .

i f y any of its consultants who may be CFR 50.71(e)(3)(ii) to submit an updated establishing an integrated sche'duls for

! prescrit. may exchange preliminaryi Final Safety Analysis Report (FSAR) for the completion of these issues in a

• l views regarding matters to be " the Millstone Unit 1 within 24 months of resource efficient manner, . .-

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TENTATIVE SCHEDULE DECEMBER 13, 1985 MEETING OF ACRS SUBCOMMITTEE ON QUALITY AND QUALITY ASSURANCE IN DESIGN AND CONSTRUCTION ROOM 1046, 1717 H STREET, N.W.

WASHINGTON, D.C.

v8:30 A.M. Opening Remarks - F. Remick (10 min) a) ob,1ective b) schedule

/ :40 8 A.M. Introduction - IE (20 min)

Overview of Division of Quality Assurance, Safeguards and Inspection Programs 9:00 A.M. Construction Appraisal Team (CAT)

Inspection - IE (30 min) a) description of program b) scope, size, resources involved c) benefits perceived by Staff 9:30 A.M. Integrated Design Verification Program (IDVP) - IE (30 min) a) description of program b) scope, size, resources involved c) benefits perceived by Staff 10:00 A.M. Integrated Design Inspection (IDI) - IE (30 min) a) description of program b) scope, size, resources involved c) benefits perceived by Staff M A.M. Break (10 m n) 10:40 A.M. Readiness Review - IE (30 min) a) description of program b) scope, size, resources involved c) benefits perceived by Staff l

O > V 11:10 A.M. Response Team Program (Handling Allegations) at OL Stage - NRR (30 min) a) description of program b) scope, number, size, resources involved c) benefits perceived by Staff 11:40 A.M. Conclusions (20 min) a) Summary of strengths and weaknesses of current system b future plans e1degreeofdifficultyinmakingchanges/

constraints 12:00 noon Adjourn

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