ML20134B200

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Comments on SECY-84-124, Rept to Congress on Improving Quality & Assurance of Quality in Design & Const of Commercial Nuclear Power Plants (Ford Amend Study). Recommends Approval & Strengthened Transmittal Ltr
ML20134B200
Person / Time
Site: 05000000
Issue date: 04/02/1984
From: Zerbe J
NRC OFFICE OF POLICY EVALUATIONS (OPE)
To: Gilinsky, Palladino, Roberts
NRC COMMISSION (OCM)
Shared Package
ML17198A269 List: ... further results
References
FOIA-84-293, RTR-NUREG-1055 NUDOCS 8508150545
Download: ML20134B200 (9)
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Text

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1 UNITED STATES

'8" NUCLEAR REGULATORY COMMISSION

.y WASHINGTON, D C. 20555

.....f April 2,1984 MEMORANDUM FOR:

Chairman Palladino Comissioner Gilinsky Ccmissioner Roberts Comissioner Asselstine Co7minnar B rnthal FROM:

hn erbe, Director Office of Policy Evaluation

SUBJECT:

OPE'C0fEENTS ON SECY-84-124

" REPORT TO CONGRESS ON I!! PROVING QUALITY AND THE ASSURANCE OF QUALITY IN THE DESIGN AND CONSTRUCTION OF C0fHERCIAL NUCLEAR POWER PLANTS" (FORD AMENDMENT STUDY)

INTRODUCTION:

Based on our review of the report, we generally agree with the report's conclusions, recommendations and suggestions and recommend its approval.

We concur with staff recomendations for action, but suggest some further steps that the Commission might have the EDO take, both in the QA program plan development and in interim inspections of plants under construction.

Finally, if, as the staff suggests, the transmittal letter to Congress is to serve as the report's Executive Summary, we believe it should be expanded and to that end we offer several suggestions.

THE REPORT The report'is comprehensive in identifying factors associated with NRC and i'ndustry QA program failures and successes. The recommendations, commitments and actions derived from the study are summarized by the staff in Tables 2.1, 2.2 and 2.3 of the report.

However, many suggestions, conclusions and reccomendations presented in the report do not appear to be adequately reflected in those tables.

Thus, we have extracted from the report and provide.in the Attachment what we believe are the more important lessons to be learned from the study.

The primary focus of the report's conclusiens, Q Bi g s 0507o3

Contact:

LEIGHTOB4-293 PDR fleill Thomasson, OFE F0/A-N493 Gene Gallagher, OPE X-432c5 L t%

The Comission 2

recomendations, and suggestions is NRC programs and initiatives.

As a candid and frank self-evaluation of NRC QA and regulatory programs, the report can be valuable to NRC senior management in areas beyond the QA program itself.

The report contains three recomendations for industry to revise its approa'ch to nonnal conduct of business:

(1) view NRC requirements as minimum levels of performance; (2) treat QA as a management tool, not a substitute for management oversight or as just a regulatory requirement; and (3) place additional emphasis on licensee QA programs to icentify problems and trends. Although only these three recommendations are directed specifi-cally to industry, the report as.a whole does provide valuable insights that l

could as,sist in industry self-evaluation.

STAFF RECOMENDATIONS We have grouped our analysis under four topics related to staff recommenda-tions:

Comission actions, program plan, interim actions, and transmittal ietter.

Comission Actions.

The staff recomends Comission approval to initiate the regulatory processes leading to rulemaking to require (1) third-party audits and (2) periodic demonstration of licensee tapability and effectiveness in implementing a QA program and managing a project.

The staff also recommends the Comission approve a regulatory analysis of the concept of establishing an independent advisory panel to advise the Comission on utility management capabilities.

We believe that these staff recomendations are well supported by the report and we recomend your approval.

In addition to the actions for Comission approval that relate to possible future rulemaking, the staff indicated that other identified administrative actions will be taken by the EDO under his existing authority.

Primarily these consist of developing and implementing the QA program plan and of taking certain interim actions.

We believe the Comission should consider and provide guidance on the total package of NRC actions to be undertaken.

Procram Plan.

The staff has comitted in SECY-84-124 to prepare by September 30, 1984 a QA program plan, which will fulfill the Cormission's 1984 PPG direction.

The plan would specify goals and object,1ves. resources, priori-ties and a task-oriented structure for program implementation.

We believe that the plan is critical to comprehensive and timely correction of deficiencies in NRC's QA program, as well as related inspection and its enforcement activities and should be the foundation for all necessary QA and related regulatori initiatives to increase assurance of nuclear plant quality.

Given the urgency of the need, we believe the Cornission should determine whether it is feasible to have the plan completed for Commission consideration earlier than September 30.

In the following, we make several suggestions regarding program plan development.

The Comission 3

With respect to the concept of the designated representative the staff reccmmends only that it be studied further and does not reflect information in or reference a December 5,1983 Information Paper, SECY-83-499, in which the staff presented alternatives on how a designated representative. program might be used by NRC to assure quality through increased inspection oversight.

We believe an appropriate course of action would be to seek a prompt Commission decision whether to adopt the designated representative concept and, if so, to select one of the SECY-83-499 alternatives'.

The program plan would then address the implementation of the designated representative pr' gram.

Unless prompt action is taken, we believe the o

benefits of such a program to improved inspection are unlikely to be real,ized in the current generation of plants.

The report is silent on the potential application to operating plants of the

. insights gained from the study.

In our view, such plants could derive insights on possible im'provements in operational QA and in management of and QA for plant modification construction.

We suggest that, in developing the program plan, the staff address the implications of the study for operating pl ants.

We note that the report contains some recor.cendations -- e.g., those related to training of inspectors and development of QA inspection priorities based on safety significance -- that have not been sumarized in Chapter 2 or l

i indicated by Tables 2.1, 2.2 and 2.3 to be included in the program plan. We l

believe the program plan should ensure consideration of all applicable lessons learned and reasonable suggestions for improvements in the regulatory oversight process.

In Chapter 2 of the report the staff rec 6 mends considering establishment of l

a QA program limited to NRC's QA activities.

The main body of the report, however, takes a much broader perspective -- that of the entire fiRC regulatory program.

We note that in a March 21, 1984 letter on the staff QA l

report the ACRS recommended "that i;RC establish a program to assure quality of its activities," although they do not believe a fomal QA program is "necessary or desirable." We note also that, while not identified in the report, the Department of Energy (DOE) has an independent QA audit group responsible for overview of its program and field office implementation of DOE QA requirements. This could provide of insights for fiRC in considering how to implement this recomendation were it adopted.

We believe the program i

plan should include regulatory analysis of alternatives for assuring quality in all liRC regulatory programs.

i The report to Congress does not contain any specific recomendations for initiatives b~v industry but, as noted above, we believe there are valuable lessons to be 1 earned and actions to be taken by industry.

We suggest the procran plan identify l'RC steps to encourage collective action en the part of industry to implement QA and manager:ent system improvements.

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l The Cc= mission 4

The requirement to develop a program plan should not hinder initiation of FY-1984/FY-1985 procurement actions on follow-on studies and contractor i

suppcrt of the QA developmental. program.

However, each of the follow-on studies should clearly relate to resolution of questions regarding possible QA programs or other related regulatory initiatives.

The staff has indicated that the actions recommended by the study are compre-hensive and that any one of several of the actions could " consume all NRC's current budget and manpower allocated to development of the quality assurance a

program" and, thus, it will be necessary "... to prioritize the quality assurance issues within the other issues faced by the NRC and make resource allecations." While the caveat is important, we assume it is not an indica-tion that the staff would limit the program plan to only those actions attainable with existing QA program resources.

We believe that it is impor-tant to identify the resources necessary to implement the changes and program expansion justified by the study and then to set the priorities and mile-stones accordingly.

To assure adequate resources for initiatives to improve NRC oversight of nuclear plant quality, the EDO should be requested to provide an analysis of resource needs -- personnel and program support -- as soon as possible, since the FY-85 and FY-86/87 budgetary processes are already upon us.

That analysis would address reallocation of FY-84/85 resources, need for supplemental FY-85 resources, and a possible planning wedge for FY-86'87.

/

Tables 2.1, 2.2 and 2.3 of the report to Congress provide an indication of need sufficient for such early planning.

Interim Actions.

Because it will take one to two years to implement many of the suggested regulatory changes and studies, such actions are likely to be of benefit only for future generation plants and not for those of the 42 plants under constructicn expected to be completed during the next three years.

For those plants some actions should be implemented while the plan is under development.

In the report to Congress the staff has indicated that efforts have been initiated to apply the lessons learned to the development of screening criteria for evaluating CP plants for potential QA program deficiencies.

We view this effort to be critical in answering the question "Will the quality of the plants now under construction be found acceptable for future operation?" The staff also indicated that intensive team inspections, e.g., CAT inspection, will be carried out for those plants that fail the initial screening. We endorse these efforts and urge that they be given priority.

However, the staff has recommended that the concepts of team inspections and expanded resident inspections receive additional evaluation through pilot prograns in one region.

As these programs would not be completed for up to twc years, most of the plants under construction will have already been completed and would not have had the benefit of such upgraded inspections.

The Comission 5

We believe that team inspections have been given ample trial in the regions and headquarters and that the benefits of an expanded resident inspector program have been established. Thus, we believe there is sufficient basis for deciding now whether these efforts should be expanded to all regions, instead of embarking on another pilot program.

Similarly, the staff has recommended that licensees be encouraged to conduct

" voluntary" third-party IDVP or IDCVP programs until rulemaking can be completed to requ. ire third-party audits.

The report to Congress provides a sufficient basis for more assertive interim action than this, since it is, generall.y clear that insufficient regulatory attention has been directed at design QA on this generation of plants.

We support the staff effort to develop guidelines and criteria for third-party audits of the design and design implementation process, but we suggest that the applicants for plants that have heretofore no.t completed such audits be directed to arrange for them on a timely basis.

We believe that, if only four CAT and three IDI inspections can be done per year,.it is important to direct all such OL applicants to sponsor independent design audits, if they have not already done so.

As indicated above, we believe there are va-luable suggestions for industry in the report and, thus, we recommend that copies of the report be sent to industry, particularly CP holders and licensees, requesting that they initi-I ate self-evaluations and quality improvement programs based on lessons learned.

While we concur in the text of the transmit-Transmittal Letter to,i, Con,gress.t goes, we believe the letter should be strengthen

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tal letter as far as place the NRC in a more affirmative posi^ ion by reflecting the Corrrnission's t

decisions on the report.

In particular, we believe the letter should indi-cate NRC intent (1) to develop a detailed program plan as the foundation for NRC action to improve nuclear plant quality and the NRC oversight role; (2) to develop as soon as practicable budget and manpower requirements to imple-ment the necessary improvements; (3) to reprogram existing resources as necessary and possible within priorities or to request supplemental budget requests; (4) to institute an interim program to apply lessons learned by screening and reviewing all plants under OL review; and (5) to send each plant owner a copy of the report as a basis for self-evaluation and, as justified, a quality improvement program.

OPE RECOM, MEND,ATIONS In summary, based on the above analysis', we recommend the Cemission:

Approve the report to Congress, but strengthen the transmittal letter as suggested.

1

The Commission 6

Endorse preparation of a QA program plan by Septem.ber 30, 1984 (or earlier, if possible), but request the EDO to assess resou ces necessary so that revisions in budget an.d manpower allocations may be considered as early as possible.

Endorse immediate implementation, as far as current resources permit, of team inspections and an expanded resident inspector program.

Consider issuing orders to require that all plants under construction sponsor third-party audits of design and engineering practices.

Havi the QA report sent to plant owners to consider the insights pre-sented and undertake quality improvement programs as appropriate.

Decide promptly, as a separate matter, whether a designated representative program is to be implemented and, if so, select the alternative to be implemented.

Attachment:

As stated cc:

H. Plaine S. Chilk W. Dircks R..DeYoung V. Stello 4

O O

ATTACHMEN,T OPE

SUMMARY

OF QA REPORT L ES50f(5,,L, EARNED The lessons learned from the study can be separated into, generic, those for industry and those applicable to the NRC as follows:

Generi_c Neither the degree of prescription of design cri,teria nor enforcement were contributing factors to major quality problems.

Quality problems were directly attributable to changes in design and inadequate change management.

INP0's current mission of assisting utilities in raising their levels of performance and standards of excellence will do more to correct, problems 5

than transposition of INPQ activities to a quasi-regulatory role.

Comprehensive third party audits can provide significant additional preventive and detection capability'.

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State Public Utility Commissions provide a major source of regulatory oversight that has unknown implications on quality and safety.

QA implementation should be the focus of regulatory oversight, not indices of implementation or a good program such as shown by paper reviews.

The regulatory basis for QA in the nuclear industry, i.e.,10 CFR Part 50, Appendix B, is sound.

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2 Licensee More complete design early in ' construction would enhance quality.

Deficiencies in utility and project management were root causes of major quality problems.

There is a strong correlation between QA program effectiveness and effectiseness of overall project management.

Prior nuclear design and construction experience in the project team greatly increases the likelihood of success if each team member plays a role appropriate to his experience.

tlanagement understanding and appreciation of the complexities of nuclear project construction is essential.

There is a direct correlation between a project's success and the licensee's view that NRC requirements are minimum standards and that higher standards are to be met.

Important factors for successful high quality projects include strong management commitment, involvement and support for quality.

Centracting arrangements can affect achievement of quality.

QA must be a, tool used by management to achieve quality, not as a substitute for management.

i e

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3 NRC NRC has clearly contributed to the magnitude of major quality problems.

NRC has not adequately assessed management capability to implement a sound QA program on pre-or post-CP reviews and inspections.

Team inspections are an effective way to address the problem of synthe-sizing and analyzing inspection findings into the big picture of the project as a whole.

Resident inspector program should be expanded and assignments to sites should be implemented as early as possible in the life of a project.

Inability to detect and react to quality problems was due to a high threshold established due to (1) the lack of an immediate threat; (2) belief the serious problems would be detected in pre-operational in-spections;(3)focusonpaperversusactualwork;(4)focusondetail rather than QA process and the implementation; and (5) reluctance to address utility management capa.bility.

Third party management audits would be an acceptable means of post-CP demonstration of management effectiveness.

Incorporation of PSAR commitments as conditions of cps would provide inproved bases for enforcement.

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