NUREG 1055 NUREG 1055 –– Then and Then and NowNow

Overview of NUREG 1055Overview of NUREG 1055

BackgroundBackground

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Application of NRC Lessons LearnedApplication of NRC Lessons Learned

BackgroundBackground

Nuclear Construction at Zimmer ended in Nuclear Construction at Zimmer ended in 19821982

The scope of necessary corrective actionsThe scope of necessary corrective actions

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The scope of necessary corrective actions The scope of necessary corrective actions became so extensive, the project was became so extensive, the project was abandoned after 10 years of construction abandoned after 10 years of construction and nearly $2 Billion in investment.and nearly $2 Billion in investment.

What Were The Deficiencies?What Were The Deficiencies?Per NUREGPer NUREG--1055, quality of structures, systems, and 1055, quality of structures, systems, and components was indeterminate due to:components was indeterminate due to:

Inadequate quality Inadequate quality inspection documentationinspection documentation

Inadeq ate reporting ofInadeq ate reporting of

Inadequate procedures Inadequate procedures and instructionsand instructions

Proced re iolationsProced re iolations

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Inadequate reporting of Inadequate reporting of nonconformancesnonconformances

Drawing deficienciesDrawing deficiencies

Inadequate specificationsInadequate specifications

Materials control Materials control deficienciesdeficiencies

Procedure violationsProcedure violations

Inadequate licensee Inadequate licensee auditsaudits

Inadequate corrective Inadequate corrective action programaction program

New Construction New Construction -- Deficiencies NowDeficiencies NowWhat is being observed in current construction efforts:What is being observed in current construction efforts:

Inadequate QC Inadequate QC DocumentationDocumentation

Inadeq ate reporting ofInadeq ate reporting of

Inadequate procedures Inadequate procedures and instructionsand instructions

Proced re iolationsProced re iolations

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Inadequate reporting of Inadequate reporting of nonconformancesnonconformances

Drawing deficienciesDrawing deficiencies

Inadequate specificationsInadequate specifications

Materials control Materials control deficienciesdeficiencies

Procedure violationsProcedure violations

Inadequate licensee Inadequate licensee auditsaudits

Inadequate corrective Inadequate corrective action programaction program

New Construction New Construction –– NRC ObservationsNRC Observations

Vendors inexperienced in nuclear environmentsVendors inexperienced in nuclear environmentsIndustry challenges with Vendor oversightIndustry challenges with Vendor oversightConstruction craft and contractors inexperienced in Construction craft and contractors inexperienced in nuclear environmentsnuclear environmentsDifficulty managing multiple design control processesDifficulty managing multiple design control processesDifficulty managing multiple problem identification and Difficulty managing multiple problem identification and

l ti (PI&R)l ti (PI&R)

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resolution (PI&R) programsresolution (PI&R) programsProcurement specification issues Procurement specification issues –– beyond code but not beyond code but not enforcingenforcingInsufficient QA personnel for oversight activitiesInsufficient QA personnel for oversight activitiesInconsistent understanding and implementation of NRC Inconsistent understanding and implementation of NRC requirementsrequirements

Commercial Grade Dedication Commercial Grade Dedication 10 CFR Part 2110 CFR Part 21

Zimmer Contributing Factors:Zimmer Contributing Factors:

Nuclear ExperienceNuclear ExperienceCincinnati Gas & Electric was a firstCincinnati Gas & Electric was a first--time nuclear time nuclear plant owner.plant owner.Kaiser Company had no nuclear construction project Kaiser Company had no nuclear construction project experience.experience.

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Evolving Regulatory FrameworkEvolving Regulatory Framework

Informal and undisciplined approach to Informal and undisciplined approach to construction oversightconstruction oversight

Lessons Learned for the NRCLessons Learned for the NRCA mindset existed that there was no immediate A mindset existed that there was no immediate threat to the health and safety of the public until threat to the health and safety of the public until a planta plant became operational. became operational.

P t d d t lt i t i ti fP t d d t lt i t i ti f

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Programs tended to result in categorization of Programs tended to result in categorization of nonconformances to the lowest action levels. nonconformances to the lowest action levels. There was an inability to categorize observed There was an inability to categorize observed issues to the correct thresholds for stronger issues to the correct thresholds for stronger enforcement action.enforcement action.

Lessons Learned for the NRCLessons Learned for the NRC

Inspection procedures Inspection procedures GuidanceGuidanceRelied on inspector’s engineering judgment Relied on inspector’s engineering judgment

Program ImplementationProgram ImplementationVaried across RegionsVaried across Regions

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Varied across RegionsVaried across RegionsDependent on Regional management approachDependent on Regional management approachIndividuals’ knowledgeIndividuals’ knowledge

Inspector knowledge of quality assurance and Inspector knowledge of quality assurance and inspection performance skill was insufficient.inspection performance skill was insufficient.Inspector focus on activities other than Inspector focus on activities other than constructionconstruction

Lessons Learned for the NRC Lessons Learned for the NRC

The legal base for direct NRC inspection of vendors The legal base for direct NRC inspection of vendors and any resultant enforcement action was not clearly and any resultant enforcement action was not clearly addressed in regulations. addressed in regulations.

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The vendor inspection program did not include The vendor inspection program did not include material manufacturers or material suppliers, sources material manufacturers or material suppliers, sources of many material related problems during construction.of many material related problems during construction.

NRC Response to Identified Lessons NRC Response to Identified Lessons LearnedLearned

Establish a nearEstablish a near--constant onsite presenceconstant onsite presenceApply more attention to design activitiesApply more attention to design activitiesMinimize diversions of inspectors for the Minimize diversions of inspectors for the purpose of investigating allegationspurpose of investigating allegations

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Enforcement needs to encourage conformance Enforcement needs to encourage conformance to commitmentsto commitmentsEnhanced capability to detect Quality Assurance Enhanced capability to detect Quality Assurance Program breakdownsProgram breakdownsInIn--process QC inspections and NRC’s ability to process QC inspections and NRC’s ability to inspect oninspect on--going construction activitiesgoing construction activities

NRC Response to Identified Lessons NRC Response to Identified Lessons

LearnedLearned

Today’s construction inspection strategy Today’s construction inspection strategy includes placement of qualified inspectors on includes placement of qualified inspectors on site to conduct direct observations of site to conduct direct observations of construction activities (SECYconstruction activities (SECY--0606--0114)0114)

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construction activities (SECYconstruction activities (SECY 0606 0114)0114)

The formal inspection planning process is The formal inspection planning process is ensuring direct inspections are scheduled for ensuring direct inspections are scheduled for Resident, Regional, and Headquarters Resident, Regional, and Headquarters inspections staff.inspections staff.

NRC Response to Identified Lessons NRC Response to Identified Lessons LearnedLearned

PresentPresent--day inspections of the MOX Fuel Fabrication day inspections of the MOX Fuel Fabrication Facility and the LES National Enrichment Facility have Facility and the LES National Enrichment Facility have included specific inspections of design development.included specific inspections of design development.

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Per SECYPer SECY--0606--0114, the use of certified designs for 0114, the use of certified designs for reactors requires NRC staff to inspect and review the reactors requires NRC staff to inspect and review the adequacy of design early, possibly beginning soon after adequacy of design early, possibly beginning soon after receipt of the licensing application.receipt of the licensing application.

NRC Response to Identified Lessons NRC Response to Identified Lessons LearnedLearned

ITAAC strategies identify minimum resource ITAAC strategies identify minimum resource requirements for accomplishing scheduled inspections.requirements for accomplishing scheduled inspections.

U h d l d i ti t dd t iU h d l d i ti t dd t i

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Unscheduled inspections to address emergent issues Unscheduled inspections to address emergent issues such as allegations are scheduled separately or with such as allegations are scheduled separately or with supplemental personnel.supplemental personnel.

NRC Response to Identified Lessons NRC Response to Identified Lessons

LearnedLearned

Focusing on a cooperative scheduling interface Focusing on a cooperative scheduling interface to enable timely field inspections. to enable timely field inspections.

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NRC is developing an inspection schedule NRC is developing an inspection schedule management tool that will address this area. The management tool that will address this area. The system will facilitate inspector observations of system will facilitate inspector observations of critical activities.critical activities.

NRC Response to Identified Lessons NRC Response to Identified Lessons LearnedLearned

Guidance for evaluating the significance of Guidance for evaluating the significance of findings and apparent violations in respect to findings and apparent violations in respect to minor / more than minor is currently being minor / more than minor is currently being

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evaluated for revision to ensure clear and evaluated for revision to ensure clear and consistent conclusions. consistent conclusions.

NRO has developed an assessment process NRO has developed an assessment process complete with a Construction Response Table complete with a Construction Response Table for assessing NRC response to findings.for assessing NRC response to findings.

NRC Response to Identified Lessons NRC Response to Identified Lessons

LearnedLearned

The NRC willThe NRC will inspect different aspects of the licensee’s QA program over the entire project. Inspections include verifications of program implementation during the performance of construction-related work.

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QA measures exercised in the development of the application for an early site permit are addressed.

Early verifications of the licensee’s QA manual and quality procedures are being implemented by appropriately trained and qualified staff.

ReferencesReferencesNUREGNUREG--0969, 0969, Report of the NRC Evaluation Team on Report of the NRC Evaluation Team on the Quality of Construction at the Zimmer Nuclear Power the Quality of Construction at the Zimmer Nuclear Power StationStation, published April 1983, published April 1983NUREGNUREG--1055, 1055, Improving Quality and the Assurance of Improving Quality and the Assurance of Quality in the Design and Construction of Nuclear Power Quality in the Design and Construction of Nuclear Power Plants A Report to CongressPlants A Report to Congress published May 1984published May 1984

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Plants, A Report to CongressPlants, A Report to Congress, published May, 1984, published May, 1984Article by Robert T. Grieves, TIME magazine, dated Article by Robert T. Grieves, TIME magazine, dated 10/31/198310/31/1983Article, New York Times newspaper, dated 01/24/1984Article, New York Times newspaper, dated 01/24/1984IMC 2503, Construction Inspection Program: Inspections IMC 2503, Construction Inspection Program: Inspections of ITAAC Related Workof ITAAC Related Work

References (cont’d)References (cont’d)IMC 2504, Construction Inspection Program: NonIMC 2504, Construction Inspection Program: Non--ITAAC ITAAC InspectionsInspections

IMC 2517, Watts Bar Unit 2 Construction Inspection IMC 2517, Watts Bar Unit 2 Construction Inspection ProgramProgram

IMC 0616, Fuel Cycle Safety And Safeguards Inspection IMC 0616, Fuel Cycle Safety And Safeguards Inspection ReportsReports

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IP 88107, Quality Assurance: Design And Documentation IP 88107, Quality Assurance: Design And Documentation Control (PreControl (Pre--licensing And Construction)licensing And Construction)

SECYSECY--0606--0114, “Description Of The Construction 0114, “Description Of The Construction Inspection Program For Plants Licensed Under 10 CFR Inspection Program For Plants Licensed Under 10 CFR PART 52,” Enclosure 1PART 52,” Enclosure 1

ADAMS NUMBERS FOR LES NEF INSPECTION ADAMS NUMBERS FOR LES NEF INSPECTION REPORTSREPORTS DOCKET: 70DOCKET: 70--3103 (FY 08 3103 (FY 08 –– 09)09)

IR 2008IR 2008--001, ML081160345001, ML081160345IR 2008IR 2008--002, ML081930118002, ML081930118In Office Review, ML080670488In Office Review, ML080670488IR 2008IR 2008--003, ML083040618003, ML083040618

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IR 2008IR 2008--004, ML083540709004, ML083540709IR 2008IR 2008--005, ML090610203005, ML090610203IR 2008IR 2008--006, ML090790642006, ML090790642IR 2009IR 2009--001, ML090850669001, ML090850669IR 2009IR 2009--002, ML091770643002, ML091770643

ADAMS NUMBERS FOR MOX INSPECTION REPORTSADAMS NUMBERS FOR MOX INSPECTION REPORTS

DOCKET: 70DOCKET: 70--30983098 (FY08(FY08--09)09)

IR 2008IR 2008--001, ML081210717001, ML081210717IR 2008IR 2008--002, ML082120091002, ML082120091IR 2008IR 2008--003, ML083050388003, ML083050388IR 2008IR 2008--004, ML090300246004, ML090300246IR 2008IR 2008 005 ML081340672005 ML081340672

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IR 2008IR 2008--005, ML081340672005, ML081340672IR 2009IR 2009--001, ML091200733001, ML091200733IR 2009IR 2009--002, ML092110728002, ML092110728IR 2009IR 2009--005, ML091000358005, ML091000358IR 2009IR 2009--006, ML091550287006, ML091550287IR 2009IR 2009--007&008, ML091310674007&008, ML091310674

ADAMS NUMBERS FOR VENDOR INSPECTION ADAMS NUMBERS FOR VENDOR INSPECTION REPORTSREPORTS

Consolidated Power Supply Consolidated Power Supply --ML081160345ML081160345

Energy and Process Energy and Process -- ML081410040ML081410040

BF Sh / J h O t C tiBF Sh / J h O t C ti

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BF Shaw / Joseph Oat Corporation BF Shaw / Joseph Oat Corporation --ML091310674ML091310674