Information Notice 2007-04, Construction Experience Related to the Assurance of Quality in the Construction of Nuclear Power Plants

Construction Experience Related to the Assurance of Quality in the Construction of Nuclear Power Plants

ML063040426
Person / Time
Issue date:	02/05/2007
From:	Tracy G Division of Construction Inspection and Operational Programs
To:
References
IN-07-004
Download: ML063040426 (5)

UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, DC 20555-0001February 5, 2007NRC INFORMATION NOTICE 2007-04:CONSTRUCTION EXPERIENCE RELATED TOTHE ASSURANCE OF QUALITY IN THE

ADDRESSEES

All current and potential applicants for an early site permit (ESP), combined operating license(COL), or standard design certification (DC) for a nuclear power plant under the provisions of

Title 10 Code of Federal Regulations (10 CFR) Part 52, all current holders of and potential

applicants for construction permits under 10 CFR Part 50, and all licensees and potential

applicants for new fuel cycle facilities under 10 CFR Part 70.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this Information Notice (IN) to alertaddressees to the importance of considering lessons learned from construction experience

when planning for and constructing new nuclear power plants or fuel cycle facilities. Recipientsare expected to review the information for applicability to their planned activities and to consider

actions, as appropriate, to avoid similar problems. However, the suggestions contained in this

IN are not NRC requirements; therefore, no specific action or written response is required.

DESCRIPTION OF CIRCUMSTANCES

Interest in constructing new nuclear power plants is increasing in the United States. Fifteenutilities have officially notified the NRC of their intent to submit applications to construct more

than 24 new nuclear power plants. One major fuel cycle facility is currently under construction

in the United States with more expected. These events follow a hiatus of more than 20 years in

the construction of new reactors in the United States. Lessons learned during the last period of

plant construction in the United States and during recent international construction offer the

industry the opportunity to understand the causal factors that have led to construction problems.

Developing an appreciation for these factors will decrease the likelihood of repeating past

mistakes and will promote quality in nuclear power plant design and construction. While the

experiences referred to in this IN come from the construction of a new nuclear power plant, the

NRC believes it is also appropriate for consideration in the construction of new fuel cycle

fabrication facilities.

BACKGROUND

In the late 1970s and early 1980s, several nuclear power plant construction projectsexperienced major problems related to design and construction quality. The Congress directed

the NRC to conduct a study to improve quality in the construction of future nuclear power

IN 2007- 04 plants. The NRC published the results of the 1984 study as NUREG-1055, "Improving Qualityand the Assurance of Quality in the Design and Construction of Nuclear Power Plants"

(ADAMS Accession No. ML063000293). NUREG-1055 focused on what had happened in the past to derive lessons to apply in thefuture. The report stated:"The increased industry and NRC experience and the lessons learned, if appliedproperly, should decrease the probability of major quality problems in future

generations of nuclear plants. However, there are several conditions under

which major quality problems might recur. These include the following:*A first-time utility with staffs or an architect/engineer, constructionmanager, or constructors (vendors and fabricators) that have inadequate

nuclear design or construction experience;*A very large growth in the number of nuclear power plants beingconstructed that can overwhelm the industry's and NRC's capabilities; *A long delay before nuclear plant construction activities start again,resulting in a dearth of experience in the industry;*Regulatory actions at federal and state levels that undercut quality.

The NRC and the nuclear industry need to be aware of the implications forquality that these possibilities hold."Several of the conditions identified in NUREG-1055 under which major quality problems mightrecur currently exist in the U.S. This fact emphasizes the importance of understanding the

causal factors associated with historical construction problems in order to chart a future course

for assuring quality in new nuclear power plant construction.

DISCUSSION

The nuclear industry is responsible for designing, constructing, and operating reactors and fuelcycle facilities in a manner consistent with NRC regulations and other applicable federal laws.

Each licensee is responsible for achieving and assuring the quality of a nuclear power plant, beginning with its design and construction. NUREG-1055 identified several causes of

significant quality-related problems that have occurred during the construction of nuclear power

plants:*An inability of utility management to adequately control all aspects of the constructionproject, including planning, scheduling, procurement, and oversight of contractors;*Inexperience with nuclear plant construction, resulting in utilities and their contractorsnot fully appreciating the complexity and difficulty associated with building a nuclear

power plant and therefore the importance of nuclear-related standards;

IN 2007- 04 *A false sense of security growing out of prior successes;*A failure to establish an atmosphere that encourages problem reporting and resolutionat all levels of the organization;*A failure to delegate authority commensurate with responsibility; and

• A failure to have clear communication pathways across all project interfaces.

NUREG-1055 noted that "quality craftsmanship is an absolute necessity" for achieving quality innuclear construction. Further, it also noted that the failure of management to control certain

conditions, such as the amount of rework because of excessive design changes, the failure to

complete designs sufficiently ahead of construction, uninformed supervision, and a project

environment that emphasizes production to the detriment of quality, can defeat quality

craftsmanship.Improvements in the performance of operating reactors over the last decade may suggest thatthese historical issues will no longer pose a problem. However, recent construction

experiences in Finland indicate that the causal factors identified in 1984 continue to exist in thecurrent international construction arena. In Investigation Report 1/06, "Management of Safety

Requirements in Subcontracting During the Olkiluoto 3 Nuclear Power Plant Construction

Phase," dated July 10, 2006, the Finnish Radiation and Nuclear Safety Authority (STUK)

identified the following causal factors related to construction problems at the Olkiluoto 3 construction site:*Poor communication between design and construction organizations and withinorganizations participating in construction;*Overconfidence in personnel with little nuclear industry experience and inadequateoversight and training;*Ineffective problem identification, reporting, and inadequate corrective actions;

• Unrealistic and aggressive schedules to complete designs sufficiently ahead ofconstruction;*Inadequate assignment of responsibilities and authority to control assigned work,

• Inadequate communication of nuclear power plant specific requirements on quality andquality control from the plant vendor to subcontractors in the tendering stage and in

purchase agreements;*Inadequate understanding by vendors and contractors of the special work practicesrequired for performing work in the nuclear field, IN 2007- 04 *Inadequate training of the subcontractors at the site and the staff of the manufacturersabout the importance to safety of the work and about the special requirements of

constructing for nuclear power plants; and*Over reliance on subcontractors by the owner.

STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en GB/news 419/.In both Finland and the United States, interest in new reactor and fuel cycle facility constructionis resuming after many years. However, the problems currently being identified in Finland are

very similar to those that occurred in the United States more than 20 years ago. Regardless of

the licensing process and the type of construction, a commitment to quality, instilled early in a

nuclear construction project, is important to ensure that the facility is constructed and willoperate in conformance with its license and the NRC's regulations.

CONTACT

This IN requires no specific action or written response. Please direct any questions about thismatter to the Office of New Reactors contact listed below./RA/Glenn M. Tracy, DirectorDivision of Construction Inspection

and Operational Programs

Office of New ReactorsContacts: Mary Ann Ashley, Office of New Reactors 301-415-1073email: MAB@nrc.govNote: NRC generic communications may be found on the NRC public Web site,http://www.nrc.gov, under Electronic Reading Room/Document Collections.

IN 2007- 04 *Inadequate training of the subcontractors at the site and the staff of the manufacturersabout the importance to safety of the work and about the special requirements of

constructing for nuclear power plants; and*Over reliance on subcontractors by the owner.

STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en_GB/news_419/.In both Finland and the United States, interest in new reactor and fuel cycle facility constructionis resuming after many years. However, the problems currently being identified in Finland are

very similar to those that occurred in the United States more than 20 years ago. Regardless of

the licensing process and the type of construction, a commitment to quality, instilled early in a

nuclear construction project, is important to ensure that the facility is constructed and willoperate in conformance with its license and the NRC's regulations.

CONTACT

This IN requires no specific action or written response. Please direct any questions about thismatter to the Office of New Reactors contact listed below./RA/Glenn M. Tracy, DirectorDivision of Construction Inspection

and Operational Programs

Office of New ReactorsContacts: Mary Ann Ashley, Office of New Reactors 301-415-1073email: MAB@nrc.govNote: NRC generic communications may be found on the NRC public Web site,http://www.nrc.gov, under Electronic Reading Room/Document Collections.Accession Number: ML063040426

• via-email

OFFICEDCIP/NROTech EditorDPR/NRRReg II/DRACDNRL/NRONAMEMAshley* CBladeyCJackson*LPliscoDMatthewsDATE01/09/07 10/24/0602/ /0701/11/0701/17/07 OFFICEOGCDCIP/NROFCSS/NMSSOIP/ICA

NAMETCampbellGTracyR PiersonJRamsey for CAbramsDATE01/11/0702/5/200702/5/200702/05/07 OFFICIAL RECORD COPY