U-600474, Forwards Results of Overinsp & Records Verification Programs,Including Lessons Learned,Per 851121 Request. Initiation of Programs & Experiences Gained During Implementation Enhanced QA Program
| ML20154K136 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/04/1986 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| U-600474, NUDOCS 8603110195 | |
| Download: ML20154K136 (4) | |
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U-600474 L42-86(03 -04 )-L 1A.120 ILLIN0/8 POWER 00MPANY CLINtON POWEH ST AllON. P.O. 804 678. CLINTON. ILLINOls 6172 7 March 4, 1986 IEIMITY rTITU:$
Docket No. 50-461 fle Y u
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lir. James G. Keppler J-r
' Regional Administrator i "~F'
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Region III fnh U.S. Nuclear Regulatory Ccemission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Subj ect:
Illinois Power Ccopany (IP) Overinspection Program -
Lessons Learned
Reference:
Let ter, J. G. Keppler to Illinois Power Company (ATTN:
W. C. Gerstuer) of November 21, 1985
Dear Mr. Keppler:
The referenced letter requested that IP review the overall results of the Overinspection Program, determine what lessons may be learned from those results, evaluate those lessons for appli-cability to future activities and inform the NRC of the resultant actions IP intends to take.
IP has conducted this review and has also reviewed the results of the Records Verification Program for similar charac-teristics.
The information requested is provided as Enclosure 1 to this letter.
rep yours, S
. un Vice President REC /jsp Enclosure cc:
Director, Office of I&C, US NRC, Washington, DC 20555 B. L. Siegel, NRC Clinton Licensing Project Itanager NRC Resident Office Illinois Department of Nuclear Safety MAR 6 Igag
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ENCLOSURE 1 IP OVERINSPECTION AND RECORDS VERIFICATION PROGRAMS LESSONS LEARNED I.
Introduction In reviewing the results of the IP Overinspection Program and the Records Verification Program, there are areas where the experience gained may be of interest to the nuclear industry.
These aspects of overall management and control have been the subject of numerous discussions and a signif-icant volume of correspondence between the NRC and IP.
This experience is described in the IP Reports entitled "Results of Quality Programs for Construction of Clinton e
Power Station" and " Update to Results of quality Programs for Construction of Clinton Power Station' which were provided to the NRC on February 13, 1985, and April 11, 1985, respectively.
The effectiveness of the IP Quality Assurance program is affirmed in the NRC (NRR - Division of Licensing) letter " Report on Construction and Operational Quality Assurance and Quality" Control Organization for Clinton Power Station, Unit 1 of August 28, 1985.
II.
Lessons Learned A.
The current regulatory system is subject to a signifi-cant degree of interpretation.
Construction qualit regulations are established to meet a " reasonable" y basis, whereas~the review and challenge to construction quality is likely to be adjudicated on a basis ap-proaching " perfection."
The licensee must have the ability to answer any question, although the question may or may not be related to the safe operation of the plant.
The lesson is cicars anyone desiring to e
construct a nuclear facility must be prepared to answer any challenge or question to the quality of construc-tion regardless of the source.
The rate payers, utilities and rate regulators must understand that they will be required to pay for this confirming effort which is undefined in regulation.
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Regulations do not define what course of action is required to establish a standard " acceptable" over-i inspection program.
Therefore, individual preferences and experience will surface on both sides.
The lessons of this are:
the utility should attempt to obtain agreement with the NRC on the following items at the outset of a program.
This effort should be documented.
1.
The overall scope of the program.
2.
The termination criteria for the program, based upon hardware acceptability.
NOTE:
Statistical sampling methods should be approached with caution since reliance on purely numerical pass / fail criteria (e.g., production line statistics (MIL-STD-105-D]) is inappropriate to apply to the construction industry.
An understand-ing of the type, extent and engineering signifi-i cance of the noncompliance needs to be factored 1
into a pass / fail critoria.
3.
Inspection criteria that are well defined, sup-aorted by engineering justification, and understood ay inspection personnel.
C.
An "overinspection" program could create an environment that causes construction personnel to place reliance on such a program rather than maintaining an objective of
" building it right the first time."
The Clinton program stressed that the "overinspection" supplemented the normal quality Assurance Program and was not a substitute for quality.
This message must be clearly understood by construction personnels this is a diffi-cult task and has mixed success unless reemphasized frequently.
D.
"Overinspection" programs are sometimes imposed in order to satisfy the need to demonstrate a positive basis for licensing to a higher standard, and not necessarily as a result of construction quality prob-lems.
The lesson is:
utilities must be 1regared to demonstrate the basis for licensing to a ligier stan-dard, irrespective of hardware quality.
E.
Properly managed "overinspection" programs have the potential to reduce ASLB public hearing delays.
Utilities should consider all aspects of the licensing arena prior to proceeding or rejecting a specific course of action within the "overinspection" concept.
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III.
Summary In conclusion, the conduct of'the Overinspection and Record Verification Programs has been continuously reviewed by IP management.
The initiation of these programs and the experiences gained during the implementation have contrib-uted to an enhanced Quality Assurance Program.
- Further, the lessons learned at CPS can be utilized by both the NRC and other utilities for future "overinspection" programs.
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