ML20237E728

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Forwards Wj Dircks 811119 Testimony Before Subcommittee on Energy & Environ in Washington,Dc Re QA for Nuclear Power Plants Under Const,Per Request
ML20237E728
Person / Time
Site: Diablo Canyon, Midland, 05000000, Zimmer, Marble Hill
Issue date: 10/03/1986
From: Combs F
NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To: Hayes B, Taylor J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF INVESTIGATIONS (OI)
Shared Package
ML082310219 List:
References
FOIA-87-726 NUDOCS 8712290150
Download: ML20237E728 (16)


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UNITED STATES g

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g NUCLEAR REGULATORY COMMISSION E

W ASHINGTON, D. C. 20555 g

8 October 3, 1986 o

NOTE TO: Ben Hayes, Director, 01 s Taylor, Director, IE FROM:

Cecci;, OC?

SUBJECT. ' /19/81 TESTIMONY OF WILLIAM DIRCKS ON QUALITY ASSURANCE At the request of the majority staff of the house Interior Comittee, I have attached a copy of the subject testimony.

Attachment As stated

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4 TESTIMONY OF WILLIAM J. DIRCKS BEF0ftE THE SUBCom!TTEE ON ENEN6Y AND THE EWIRomENT 7 THE Com!TTEE 011 INTER 10lt AND INSULAR AFFAIRS

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QUALITY ASSURANCE FOR NUCLEAR PLANTS UNDER CONSTRUCTION THIS TESTIMONY ADDRESSES THE ADEGUACY OF 00ALITY ASSURANCE AS IT APPLIES TO NUCLEAR POWER PLANTS UNDER CONSTRUCTION, NHY IDENTI-FIED CONSTRUCTION OR QUALITY ASSURANCE DEFICIENCIES HAVE NOT BEEN DETECTED ON A MORE TIMELY EAllS, AND ACTIONS BEING TAEN T0 $0LVE RECOGN!IED PROSLEMS.

THE NRC LOOKS TO THE POWER PLANT OWNERS, THE UTILITIES THEMSELVES, TO TAE THE LEADERSHIP ROLE IN ASSURING THE QUALITY OF THEIR PLANTS AND CPERATIONS.

THIS REQUIRES HEAVY EMPHASIS AND ACTIVE INVOLVE-MENTOFTOPLICENSEEMANAGUIENTINd[ PROGRAMS.

CAAEFUL ATTEN-T10N 13 REQUIRED IN THE SELECTION OF ENGINEERING SPECIFICATIONS AMD QA PROCEDURES AND PRACTICES FOR EACM TASK AND THEIR IM ATION SY THE WORKERS ON THE J0S.

MOST IMPORTANTLY, THERE MUST SE ADEOUATE RESOURCES OF QUALIP!ED PERSONNEL AT MANAGEMENT, CPERAT-ING. AND STAFF LEVELS.

NRC ASSESSES THE PERFORMANCE OF THE UTILITIES AND THE!R MAJ CONTRACTORS DURING THE DESIEN AND CONSTRUCTION PHASES.TNE NRC DOES NOT ATTEMPT TO REDO THIS NCRK OR INSPECT IT COMPLETELY $1 THE NRC RESOURCES ON A PARTICULAR PLANT ARE ONLY A SMALL 0F WHAT WE REQUIRE A UTILITY TO DEY0TE TO INSPECT!0N, OUALITY CONTROL, AND QUALITY ASSURA'NCE.

THE NRC'S REGIONAL OFFICES CARRY OUT A SAMPLING INSPECTION PROGRAM AIMED AT DETERMINING COMPLIA WITH THE PROGRAMMATIC COMMITMENTS.

TNE REGui.ATORY ' REQUIREMENTS PLACE TNE MAJOR INSPECTION RESPONSIBILITIES.FOR QU$LITY ASSURANCE

' 2-ON THE LICENSEE'S CONTRACTOR $, NHICH ARE IN TURN INSPECTED AND AUDIT G SY THE LICENSEE'S STAFF.

THE NRC'8 EFFORT 18 AN AUDIT AND OVERYlEW 0F THE LICENSEE'S AND ITS CONTRACTOR 8' GUALITY ASSURANCE ACT!YITIES.

IN CARRYING OUT THESE INSPECTION ACTlvlTIES, NRC INSPECTION 8 COVER APPROXIMATELY 1-5 PEaCENT OF THE :INSPEE. TION ACT!YlTIES PERF0lMED BY THE LICENSEE AND ITS CONTRACTORS.

1 THE NRC'8 QUALITY AssuaANCE REeu!REMENTS Amt CONTAlus IN APPENDIX 5 TO PART 50 0F TITi.E 10'o# %E CODE OF FEDERAL REPUTATIONS, " QUALITY ASSURANCE CRITERIA FOR NUCLEAR POWER PLANTS AND Futt REPROCESSING PLANTS.*

THEst CRITEntA PROVIDE A SAS!$

UPON WHICH THE NRC JUDGES THE ACCEPTABILITY OF GA PR08 RAMS.

THE CRITERIA 0F APPENDIX 3 APPLY TO ALL ACTIVITIES AFFECTING SAFETY-RELATED FUNCTIONS OF NUCLEAR POWER REACTOR STRUCTURES, SYSTEMS, AND COMPONENTS.

QUALITY ASSURANCE !$ DEFINED IN OUR REGUL,ATIONS AS "ALL THOSE PLANNED AND SYSTEMATIC ACTIONS NECESSARY 70 PROVIDE ADEQUATE CONFIDENCE THAT A STRUCTURE, SYSTEM, OR COMPONENT WILL PERFORM SATISFACTORILY IN SERVICE."

WHAT THIS MEANS IS ' HAT - FOR ITEMS HAVING SAFETY $1GNIFICANCE IN A NUCLEAR POWER ' tA T O

THE DESIGN 15 VERIFIED TO BE CORRECT AND T'O INCLUDE APPROPRIATE REGULATORY REQUIREMENTS;

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PROCUREMENT DOCUMENTS CONTAIN ADEQUATE INFORMATION AND l

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0 INSPECTION OP PARTS, MATERIALS, AND PROCESSES ARE TIMELY AND ADEeuATEJ 06 DEFICIENCIES IN DESISN, CON 87NUCTION AND INSTALLATION ARE IDENTIFID AND APPROPRIATELY REMEDIED 1 THE QA PROCESS IS SUDlTili Ad REPORTED TO AN ORGAN!=

0 ZATIONAL LEVEL CAPABLE OF ASSURING EFFECT!YE CORRECTIVE MEASURESJ 0

RECDRDS ARE KEPT WHICH CLEARLY DEMONSTRATE SUFFICIENCY OF ACTIVITIES AFFECTING GUALITYs AND 0

THE ORGANIZATIONS PERFORMINs QA FUNCTIONS HAVE SUFFICIENT INDEPENDENCE AND AUTHORITY TO IMPLEMENT THESE ACTIVITIES.

TH13 DISCUS $10N WILL FOCUS OM SOME EXPERIENCES THAT HAVE AND CON-TINUE TO GENERATE WIDESPREAD PUBLIC INTEREST.

SPECIFICALLY, THERE MAVE BEEN SOME SERIOUS' QUALITY ASSURANCE BREAKDOWNS WITH BROAD REPERCUS$10NS' AT THE MARBLE HILL, MIDLAwD, ZIMMER, SOUTH TEXAS, AND DIABLO CANYON CONSTRUCTION $1TES.

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$ RRLE RILL IN 1979, DEAKNE88Es WERE IDENTIFID IN THE PROGRAR FOR THE PLACEMENT OF CONCRETE AND RELATO 90ALITY ASSURANCE MEASURES AT THE MARSLE HILL ftm, EAR PLANT CMSTRUCTIM SITE IN SOUTHERN INonANA.

WE INVEST 16ATB THESE PROSLEMS MEN A CONCRETE WORKER RAISO ALLEGATIMS THAT HONEYCOMBIM, VOIDS AND SURFACE SEFECTS NERE BEING IMPROPERLY PATCND.

fME8ENE81TIONS, WICH WERE SUBSEQUENTLY SUBSTANTIATE, LD TO A h40ADER INVESTIGATION THAT ADDRE88D OTHER ARIAS OF NORK AT THE $1TE.' ABOUT THE SAME TIME.

CODE COMPLIANCE PROSLEMS NERE IDENTIFIED BY THE ISIANA BOILER CODE INSPECTOR AND THE NATIONAL BOARD OF BOILER AND PRESSURE VESSEL INSPECTOR 8.

THESE EVENTS LB TO A. HALTING OF ALL SAFETY-RELATB WORK AT THE SITE IN AUGUST 1979 - A MOYE TAKEN SY THE UTILITY AND CONFIRMED BY AN NRC ORDER.

WORK WAS NOT PERMITTED BY THE MC TO RESUME UNTIL DECEMSER 1980, SOME 16 MONTH 8 LATER, WHEN THE UTILITV'S QUALITY ASSURANCE PROGRAM --AND THAT OF ITS CONTRACTORS -- HAD BEEN SUS $7 ANT! ALLY UPGRADED AND THE ADE00ACY OF COMPLETED CONSTRUCTION WORK MAD SEEN VERIFIED.

DELAYS IN C0!!STRUCTION AND EFFORTS TO CORRECT THESE AND OTHER PR08LEMS 'AR'E ESTIhATED To HAVE COST THE UTILITY HUNDREDS OF MILLIONS OF DOLLAR $.

I 5-IN TM CASE OF THE MIDLAND FACILITY IN MICHISAM, EXCESSIVE SETTLEMENT OF THE DIESEL SENERATOR SUILDI N WA8 0888RVED IN 1978.

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THE,UNEXPECTO SETTLING MAS SUB8EOUENTLY ATTR18UTD TO INADEGUATE AND. M Y.COMPACTO 80lk UNDER THE SUILDIM.

FURTMER INVEST!=

SAfl0N.SY THE LICENSEE REVEALES THAT OTHER SAFETY-RELATO SYSTEMS AND STRUCTURES NERE AFFECT D.

ALL OF THESE SYSTEMS AND STRUCTURES WERE NEARIN COMPLET!0N AT THE TIME THE PROBLEM NAS DISCOVERED.-

THE NRC'8 INVESTIGATION DETEIIMINED.NAI MSIM AND CONSTRUCT SPECIFICATIONS MAD NOT BEEN FOLLOWED hWRIM PLACEM FILL MATERIALS AND THAT THERE WAS A LACK 0# CONTROL AND SUPER-VISION OF THE 80!L PLACEMENT ACTIVITIES SY THE UTILITY AND 178 CONTRACTOR 8.

THE COSTS ASSOCIATED NITH AS8URING PROPER SOIL COMPACTION AND DEMONSTRATIM TM ADEGUACY OF THE PLANT DESISN ARE SIGNIFICANT.

THE MATTER HAS STILL NOT BEEN RESOLVED AND THE ISSUES ARE CURRENTLY BEIM LITISATO MFORE AN NRC HEARING 30ARD.

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,, AT THE ZIMMER FACILITY IN SOUTHERN OHIO, THE NRC HAS SEEN INVESTIGATING ALLEGED QUALITY ASSURANCE IRREGULARITIES SINCE JANUARY OF THIS YEAR.

THIS INVESTIGATION EFFORT, WHICH IS STILL ONG0!NG, STARTED N!TH ALLEGATIONS FROM A COUPL'E OF SbuRCES, BUT SOON BROADENED TO HANY WORKERS AND EX-WORKERS.

To DATE WE NAVE

.6-INTENY!EwtB APPROXIMATELY 100 INDIYlDUALS AND EXPENDED OVER 250 MAN-DAYS ON8ITE PUR8UIM THESE ALLEGATIONS.

Tm CURRENT INva87IsATION MAS IDENTIFID A NUMBER OF SUALITY ASSURANCE-RELATO PROBLEMS AT THE llMMR SITE.

THE MAJORITY OF THE ?ROSLEMS IDENTIFI D TO DATE FOCUS ON THE INEFFECTIVENESS OF CONTROLS IMPLEMENTS SY THE LICENSEE AND 178 CONTRACTORS FOR A88URIM THE 80ALITY OF WORK PERFORMED.

IN THAT RESARD, NUMEROUS DEFICIENCit8 HAVE MEN FOUND CONCERNIN TRACEABILITY OF MATERIALS, MANDLINS OF BONCONFORMANCE, fMTEkP E3ETWEENCONSTRUCTIONAND OUALITY CONTROL, GUALITY RECORDS, AND THE LICEN8Et'8 OVERY!EW 0F ON80lM WORK.

THE IMPACT OF THE IDENTIFID 00ALITY ASSURANCE DEFICIENCit8 ON THE ACTUAL CONSTRUCTION HAS Ytf TO 88 DETERM!NES.

AN EXTENSIVE REVIEW 0F THE A8 BUILT PLANT IS CURRENTLY MING PERFORMED.

LIMITED INDEPENDENT MEASUREMENTS WRE PERFORMED SY THE NRC In SELECTO ARIAS OF CONCERN IN AN ATTEMPT TO CHARACTERIZE THE ACTUAL 8AFETY Sl8NIFICANCE OF THEWE DEFICIENCIES. ' ALTHOUGH A FEW PROSLEM8 REQUIRIM CORRICT!YE ACTION WERE IDENTIFitD, THE MAJORITY OF THE TESTS AND EXAMINATIONS DISCLOSED N0 HARDWARE PROSLEMS.

BEFORE THE PLANT CAN M LICENSED A COMPREHENSIVE QUALITY CONFIR-MATION PROGRAM WILL HAVE T0 SE CONDUCTED AND IDENTIF1ED PR08LEM

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7 AREAS RESOLVD.

SY ITSELF, WITHOUT FACTORING IN ANY REw0ng, THE GUALITY CONFIRMATIM PROGRAM WILL BE BOTH COSTLY AND TIME CONSUM-ins.

THE EFFECT OF THIS ON THE CONSTRUCTIM SCHEDULE OF TME PLA REMAINS 70 St MTIMING.

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SOUTK IED3 IN JANUARY 1981, H0usTON LisNTING AND PONER ConPANT (HLSP)

INITIATED A DESIGN REVIEN OF THOSE PORTIONS OF THE ENetNEERING DESIGN WORK PERFORMED BY 355NN AitD NiDT, INC., (84R) FOR TM south TEXAS PROJECT EttCTRIC 6ENERATING STATION (STP). THE PURPOSE OF THIS REVIEW WAS TO ASCERTAIN THE OVERALL ADEGUACY OF THE STP Des!6N.

QUADREX CORPORATION WAS ASKED TO ASSIST IR.aP IN A REY!EW OF THE FOLLOWING BAR TECHNICAL DISCIPLINES:

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C!v!L/ STRUCTURAL COMPUTER PR0sRAMs AnD'C00t8 ELECTRICAL / INSTRUMENTATION AND CONTROL 6t0 TECHNIC HEATING, VENT!' ATING AND AIR CONDITION!NG MECHANICAL NUCLEAR ANALYSIS PlPING AND SUPPORTS / STRESS AND SPECIAL STRESS RADIOLOGICAL CONTROL

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THE LICENSEE MET WITH QUADREX CORPORATION FOR THE FIRST TIME ON JANUARY 16, 1981, AND SEVERAL OTHER TIMES IN JANUARY AND FEBRUARY 1981, TO' PLAN THE REY!Ew.

THE REY!EW BY QUADREX INVOLVED 12 ENGINEERING CONSULTANT PERSONNEL M40 SPENT MORE THAN $!X WEEKS IN AUDITING B4R DE81GN ENGINEERING DOCUMENTS AND INTERY! EWING VA9L1008 34R DISCIPLINE ENelNEERS.

THE REP 04tf ON THE QUADREx EFFORT DATED MAY 1982, WAS SUsMITTED BY THE LICEN8tt TO THE NRC LICENSING HEARING BOARD ON SEPTEMSER 28,1981.

BRE! PLY, THE -

QUADREX REPORT FOUND THAT BRONN 4 ROOT APPARENTLY FAILED TO PROPERLY IMPLEMENT THE QA piiOGREIN htt DESIGN AREA BUT ALSO FAILED 70 PROPERLY IMPLEMENT AN OVERALL DESIGN PROCESS CONSISTENT WITH THE NEEDS OF A NUCLEAR POWER PLANT. ~ As A Rt8vtT WRIFICA-T10N OF DESIGN INFORMATION WAS APPARENTLY NOT PERFORMED IN A TIMELY MANNER, AND RESULATORY COMMITMENT 8 FOR SAFETY D!D NOT APPEAR To SE FULLY OR PROPERLY IMPLEMENTED TO SAT!8FY NRC REQUIRE-MENTS FOR LICENSABILITY.

NRC INSPECTION REPORTS DATING BACK TO 1979 POUND PR0sLEMS AT TH SOUTH TEXA8 PLANT SIMILAR TO THOSE IDENTIFIED IN'THE QUADREX REPORT.

HowEVER, THE AGENCY'8 AUDITS DID NOT SURFACE THE NUMBER OF PRolLEMS SUGGESTED BY THE QUADREX REPORT.

THOUGH WE WERE AWARE OF QA PROBLEMS AT SOUTH TEXA8 AND HAD CITED THE LICENSEE FOR A BREAKDOWN IN THEIR QA PROGRAM IN APR4L 1980, THE MAGNITUDE OF POTENTIAL PROBLEMS WAS NOT FULLY APPRECIATED UNTIL WE FIRST REY!EWED THE REPORT IN AUGUST OF 1981.

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IN LATE SEPTEMSER THE LICENSEE ANN 0UNCED THAT BROWN AND ROOT WAS BEING REPLACG SY BECHTEL POWER CORPORATION AS ARCHITECT-ENGINEER.

WE INTEND 70 CAREFULLY MONITOR HOW BECHTEL INVESTIGATES AND D1SPOSES OF THE PROSLEMS SURFACED SY THE QUADREX REPORT.

DIABLO CANYM AT DIASLO CANYON, THE PACIFIC 6AS & ELECTRIC COMPANY (PGs,E)

PROVIDD INCORRECT INFORMATION TO A EXPERT CONSULTANT,1940 USED THE INFORMATION IN DEVELOPIMS T' E. SE!IMIC RESPONSE SPECTRA FOR H

THE DESIGN OF CERTAIN SEISMIC P!P!NG AND EQUIPMENT RESTRAINTS.

OUR INVEST!SATORS HAVE FOUND THAT THERE WAS A LACK OF RIG 0R AND FORMALITY IN THE PROCEDURES US D FOR VERIFYING THE ACCURACY OF INFORMATIONTRANSFERREDBYPG4ETOITSCONSULTANTS. THESE PROCEDURES DID NOT CCMPLY WITH OUR REQUIREMENTS CALLING FOR 'ER!-

FICATION OF DESIGN INFORMATION AT EACH STAGE OF THE PROCESS SY AN INDEPENDENT PERSON OUALIFIED IN THE PERTINENT DISCIPLINES.

PROPER QUALITY ASSURANCE CONTROLS WERE NOT EMPLOYED IN TECHNICAL AND PROCUREMENT COMPRINICATIONS WITH SERVICE-TYPE' CONTRACTOR $. NOR WERE DOCUMENT CONTROLS ADEGUATE TO ASSURE THAT THOSE INVOLVED IN DEslGN HAD READY ACCESS TO THE MOST RECENT INFORMATION AVAILABLE.

BECAUSE OF THE INADEQUACY OF QA CONTROLS,0VER DES!GN YERIFICA-TJON, PROCUREMENT AND THE TRANSMITTAL OF DOC 0MENTS*TO SERVICE CONTRACTOR $, THE ACCEPTABILITY OF THE DESIGNS BASED ON THEIR ANALYSES IS NOW IN QUESTION.

O A8 A RESULT, THE STAFF HAS DECIDED THAT THERE !$ SUFFICIENT REASON TO REVIEW THE ENTIRE PROCESS FOR SEISMIC DE818NJ 70 REVIEW THE ADEQUACY OF OTHER PLANT DES!SN ASPECTS, PARTICULARLY THOSE THAT NERE SASD ON EMINEERIM INFORMATION DEVELOPED UNDER OTHER SERVICE-TYPE CONTRACT 83 AND TO REYlEW THE IMPLEMENTATION OF THE UTILITY 4A PROGRAM IN THESE AREAS.

IN LOOEING AT THE MARsLE HILL, MIDLAND, ZIMER, SOUTH TEXAS, AG DI ASLO CANYON PROBLEMS, GUESTIONS MAVE MEN RAISD AS TO MfY THE LICEWSEE'S OuALITY ASSURANCI PR'sRAMlue THE imC INSPECTION O

PROGRAM MAD NOT IDENTIFID THE PROBLEMS 80001ER. CLEARLY, IN EACM CASE, THERE MAS AN OVERRELIANCE SY THE UTILITY ON ITS ' CONTRACTORS FOR MAINTAINING A THOROUSM GUALITY ASSURANCE PROSRAM. TM UTILITY'S OWN QA STAFF WAS T00 SMALL TO MAINTAIN SUFFICIENT SURVEILLANCE OVER THE WORK OF CONTRACTORS.

IN TWO 0F THE CASE 8 WE SAW INSTANCES WHERE THE CONSTRUCTION MANAGEMENT DOMINAT O OR CONTROLLG THE 00ALITY ASSURANCE PROSRAM AIS PERSONNEL.

AND, IN EACH OF THE CASE 8 WHERE PROBLEMS MAD SEEN IDENTIFI D, THE CORRECTIVE ACTION TAKEN WAS NOT SUFFICIENTLY 8 ROAD.

TOO FREQUENTLY, THE RESPONSE WAS ONE OF TREATING THE SYMPTOM, RATHER THAN FINDING THE BASIC CAUSE AND CORRECTING 17.

IN ANALYZING THE IDENTIFIED PROBLEMS AREAS,,ONE CAN COME UP WITH A LIST OF IMMEDI ATE CAUSES -- SUCH At UNGUAllFIED WdRKERS OR QC INSPECTOR $, FALS1FIED RECORDS, INTIMIDATION OF QUALITY

'.11 CONTROL INSPECTORS, LACK OF AUTHORITY, LACK OF COMMUNICATION, INADEGUATE STAFF 1H LEVEL 8, INADE00 ATE CORRECT!YE ACTION SYSTEMS, LACK OF SUPERY!8 ION, POOR TO NONEXISTENT PROCEDURE 8, P004 DE8!SN AND CHAME CONTROL, DESI8N ERROR 8, INADE00 ATE ANALYSIS, POOR OUALITY COMPONENTS, AND 80 ON.

MOST OF THE8E CAN M TRACED TO FALLURE OF OUALITY ASSURANCE DUL TO INEFFECTIVE MANAGEMNT CONTROL OF Tus 04 PR0eaAM. THERE ARE A MTRIAD OF EXCUSE 8 AND REASONS WY MANAGEMENT FAILS.

SOME ARE EXPLICIT FAILURES OF PERF0AMANCE OR LACE OF ATTENTION.

OTHER PAILURES ARISIM FROM POOR ATTITUDES AND PERCEPTI' int 3 hRE DIIFICULT TO IDENTIFY. THE

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NRC CANNOT TOLERATE THESE DEFECTS MCAUSE OF THEIR POTENT!AL IMPACT IN TERMS OF PUBLIC RISK.

IT 18 SURPR!8tM THAT SOME LICENSEE 8 ARE INSUFFICIENTLY CONCERNED ABOUT GUALITY ASSURANCE NOT ONLY SECAUSE OF THE SAFETY IMPLICATIONS SUT ALSO BECAUSE OF THE IMMEP88 COST OF MISTAES AND OF THE RESULT!N8 DELAY IN CONSTRUCT 10N.

GIVEN THESE INSTANCES OF BREAKDONN8 IN MANA8EMENT CONTROL OF CONSTRUCTION OUALITY AND THE COMMISSION'8 DISSATISFACTION, THE ISSUE IS 'WHAT ARE E D0!M ABOUT IT7' WITHOUT DOUST, THERE HAYE 8'EEN $H0RTCOMINGS IN THE NRC INSPECT!0N PROGRAM AT CONSTRUCTION SITES.

THERE HAVE,8EEN CASE 8 WHERE WE HAVE FAILED TO SEE THE SAEADTH QR DEPTH OF A )R08 LEA.

WE IDENTIFIED SPECIFIC Y!0LATIONS OF REQUIREMENTS WITH6UT REQUIRING THE CORRECTION OF THE SASIC CAUSE OF THE PR08LEH.

ADDITIONALLY,

WE MAY HAVE 8 PENT T00 LITTLE TIM NITH OUALITY CONTROL INSPECTOR 8 AND CONSTRUCTION WORKERS 70 SET tnt!R VIEWS ON THE IMPLEMENTATICE OF SUALITY ASSURANCE ACTIVITIt8 AT THE $1TE.

HOWavtR, NE ARE TAK!N8 STEPS TO ASSURE ATTENTION TO CONSTRUCTION GA INCLUDINS Dil!8MATION OF 4ESIDENT INSPECTOR 8 AT ALL CONSTRUCTION SITES.

THE COMMISSION MAS MADE OR 18 CONSIDitlNG A NUMBER OF CHANet8 OF ITS INSPECTION AND ENFORCEMNT PROGRAM TO INCREASE THE EMPNA818 ON IMPLEMENTATION OF GA PR0$ HAM 8U.Effit ADDRESS SIX SPECIPl ACT!Y1 TIES:

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A8 INDICATED An0va, NRC RallDENT INSPECTORS NAVE BitM OR WILL BE STATIONED AT ALL CONSTRUCTION 81788 NMERE ACT!YE CON 87NUC-TION IS PRESENTLT UNDER WAT AND THE PROJECT IS AT LEAST 15 PERCENT COMPLETE.

BA$ts OR out EXPERitNCE NITH THE RESIDENT INSPECT!cN PtosRAM.To 8478, NE GELitVE RESIDENT INSPECTOR 8 i

ENHANCE THE NRC'8 ABILITT 70 n0NITOR,eUALITT ASSURANCE ACTIVITIES AND IDENT!FT THE SYMPTCM8 0F BREAkDONN IN MANAGEMENT CONTROL.

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THERE MA8 titN A 7008HEMING OF THE NRC'8 ENFORCEMENT POSTURE OvtR THE PAST COUPLE OF YEARS AND THt NRC'8 REY!8ED ENFORCE-MENT POLICY HAS PLACED EMPHA8IS ON DEALIN'8 N!TH' POOR RESULA-TORY PERFORMANCE IN THE COM8TRUCTION AREA 8.

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WE MAYE COMPLETED.A TRIAL PROGRAM OF TEAM INSPECTIONS

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r, WERE8Y 8tVERAL NRC INSPECTORS S0 TO A CONSTA'UCTid$1TE FOR N,,

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TWO TO THREZ wtr.K3 V0 DO A SRCAD, INTIN8!YE INSPECY!0N 0F l

THE OUAL11T DCM RANCE PROSRAM POR ONGOINS WORK.

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APPROACM EnASLit NRC TO 4AIN A TOTAL PROJECT PERSPECT!YE,TC

'l 1J A GREATER EXTENT THAN PAST PRACTICE.

THE ADVANTA8 OF 78 !]8

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MANAstMENT EFFECTIVEtttSS.

THE USE OF SUCN IN8PECTION TNAMS

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18 EXTREMELY LINITO SY THE AVAILABILITY OF, INSPECTOR $ AND e

PUNDS POR THIS PURPOS$

WIN Ai61TIONAL Rtf 00RCits WE COULD 8END INSPECTION TEA 48 TO EACH CONSTRUCTION Shb TO 00 COMPRENEN81Vft INSPECTIONS r

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THE NRC C0e8TRUCTt0N IN8PECTION PROSRAM Is uwDER Avvilles 70 ACCOMPLI 8N SEVERAL OBJECT!Yts.

WE ARE RECASTING IN8PECTION

,L PROCEDURES TO DELETE INSPECTION ACT!YJT!El 0F LE8SER IMN3R-L j

TANCE AND TO RENCE DUPLICATION OF, EPFORT SY RESIDENT AND'-

RESIONAL-BASED $PECIALIST INSPECT 0H<.lN $1TUAT!0NS WHEREj l

c INSPECTOR ESOURCES LIMITATION 8 PRECLUDE COAPLETINS THE t'

t, i1 ENT!RE INSPECTION PROGRAM, WE ARE ORDER!NG CUR PR10RIT!Es sd

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THAT THE MOST IMPORTANT INSPECTIONS WILL SE COMPLETED.

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FORMAT IZED PERFORMANCE MlPRAISALS OF LICEMEE RE6ULATORY

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PERFCbtAhCE ARE BEING CONDUCTED.- ANNVALLY SYl VME NRC ($YSTEM-

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i ATI( ASSESSMENT OF LICENSEE PERFORMANCE PR0sRAM).

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APPRAISAL 8 WHICH REVIEW THE COLLECT!VYNRC EXPERIENCE WITH j

EACH POWER *EACTORe BRIN 6 THE BROAD IS$UES OF PERFORMANCE I

EFFECTIVEntts TO THE ATTENTHHf 0F SENIOR LICENSEE OFFICIALS.

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WE ' ARE NOW vs!NS OUR OWN MOBILE LABORATOLY POR NONMSTRUC-T!VE EXAMINATION (NDE) AT C0Q'MJCTIM SITES.

THIS LEE VAN' HAS MULTIPLE CAPABILITIES THAT PINCLUM' RADIOGRAPH DEVELOP *>

MENT, METALLURGICAL AhXLY3!S, AND'.' HARDNESS, ULTRASONIC, DYE PENETRANT AMD MAGNETIC PARYlCLE TESTlies. THE EXAMiNAT!MS THAT WE PERFORM ARE INTENDED TO CONFIRM QUALITY BASED ON A

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SELECTIVE SAMPLING APPROACM.

o THE COMMIS$10N 13 COMTINUIN6~ TO REVIEW ITS RESPONSIS!LITIES IN THE NUCLEAR QA AREA IN ORMR TO DEVELOP IMPROVEMENTS IN MFININs

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l REQUIREMENTS, REY! EWING LICENSEE GA PR0sRAMS, AND INSPEC?im l

PRACTICES WHERE THEY ARE CALLED FOR.

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