Resolution of Generic Safety Issues: Task II.J: General Implications of TMI for Design and Construction Activities (Rev. 1) ( NUREG-0933, Main Report with Supplements 1–34 )
TASK II.J.1: VENDOR INSPECTION PROGRAM
The objective of this task was to improve vendor-supplied components and services through a modified and more effective vendor inspection program.
ITEM II.J.1.1: ESTABLISH A PRIORITY SYSTEM FOR CONDUCTING VENDOR INSPECTIONS
This TMI Action Plan48 item called for the NRC to develop an integrated information system to establish priorities for selecting vendors for inspection in order to permit optimum utilization of available resources. Priorities were to be based on the relative safety significance of products and services provided by the vendors. The information necessary to establish the priorities was to be collected and integrated from LERs, deficiency reports from holders of construction permits and non-licensees, and other relevant information. This item addressed improvement in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.
A contract study, "Development of the Automated Vendor Selection System," was completed by Gasser Associates, Inc. on June 30, 1980, and was reviewed by OIE. Changes in the vendor selection and inspection procedures that were considered appropriate were incorporated into the OIE Manual, Chapter 2700, in July 1981. Thus, all required action on this item was completed235, 248, 379, 406 and the issue was resolved with changes in NRC procedures that address vendor selection and inspection.
ITEM II.J.1.2: MODIFY EXISTING VENDOR INSPECTION PROGRAM
This TMI Action Plan48 item called for the NRC to improve existing vendor inspection procedures by including more routine technical assessments of products, by expanding the scope to reflect operational and construction feedback experience, and by placing greater emphasis on design control and the use of independent measurements. Full implementation of the expanded scope of this program required an increase in vendor inspection staff. This item addressed improvement in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.
Chapter 2700 of the OIE Manual, which described the overall licensee contractor and vendor inspection program, was revised to incorporate the fundamental changes defined by this item.259, 297 With respect to staffing, additional positions for the vendor inspection program were authorized and, by November 1983, 26 people were performing vendor inspection functions. The program changes required by this item were incorporated into the routine ongoing vendor inspection program. Detailed inspection procedures covering these program activities were prepared as the needs of the program were identified. Thus, all required action on this item was completed297, 379 and the issue was resolved with changes to NRC procedures that address licensee vendor inspection programs.
ITEM II.J.1.3: INCREASE REGULATORY CONTROL OVER PRESENT NON-LICENSEES
This TMI Action Plan48 item required the NRC to study the need to extend its licensing authority over vendors who supply components and services to licensees. Nuclear steam system suppliers, architect/engineers, constructors, and designated vendors were to be included in the study. Upon completion of the study, the staff was to present a paper to the Commission for a decision on the subject. This item addressed improvement in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.
As part of the resolution of Item II.J.4.1, OIE submitted to RES recommended changes to 10 CFR 21 that would revise deficiency reporting requirements for NSSS vendors, A/E firms, and others. These revised deficiency reporting requirements would provide increased information on component failures that affect safety, so that prompt and effective corrective action could be taken. OIE stated235 that further extension of NRC authority over non-licensees with licensing requirements was not warranted and would not be cost-effective. In light of the proposed rule change, all required action was completed379 and the issue was resolved.
ITEM II.J.1.4: ASSIGN RESIDENT INSPECTORS TO REACTOR VENDORS AND ARCHITECT ENGINEERS
This TMI Action Plan48 item required the NRC to evaluate the desirability of assigning resident inspectors to NSSS vendors and A/Es. The staff was to prepare a Commission Paper describing a proposed trial program to be applied to selected NSSS vendors and A/Es. This item addressed improvement in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.
The proposal to assign resident inspectors to NSSS vendors and A/Es as a part of the vendor inspection program was reviewed by the staff who concluded235, 268 that such a program should not be initiated. It was further recommended379 that the item be deleted for the following reasons268: (1) more effective utilization of existing vendor inspection resources could be obtained by retaining inspectors in the regional offices; (2) the absence of new orders resulted in significant changes in NSSS and A/E work activity, in that more sub-contracting to numerous small firms was occurring; (3) to provide inspection coverage of the activities required greater mobility and flexibility from the vendor inspection staff; and (4) the trial program would require resources that were not available. Based on these recommendations, the issue was resolved March 14, 1982.
TASK II.J.2: CONSTRUCTION INSPECTION PROGRAM (REV. 1)
The objective of this task was to provide greater assurance that nuclear plants are properly constructed by improving construction inspection programs.
ITEM II.J.2.1: REORIENT CONSTRUCTION INSPECTION PROGRAM
This TMI Action Plan48 item called for OIE to change its reactor construction inspection program and its Inspection Manual to require increased observation of work activities, more attention to the involvement of licensees in construction activities, independent verification that as-built conditions met design requirements, and followup of reported incident information, as applicable, from operating reactors. This item addressed the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.
Chapter 2512 of the Inspection Manual was revised on August 1, 1980, as part of the OIE program to incorporate increased observation of work activities and to increase inspection of licensees' involvement in the overall construction of plants. In addition, program changes to ensure earlier and continuing inspection of construction QA activities were made. A trial program involving team inspections was also completed. Thus, this issue was resolved with changes in the NRC procedures that address construction inspection.235, 239, 379, 406
II.J.2.2: INCREASE EMPHASIS ON INDEPENDENT MEASUREMENT IN CONSTRUCTION INSPECTION PROGRAM
This TMI Action Plan48 item called for OIE to evaluate trial programs involving independent measurements (non-destructive examination) at construction sites. NRC was to buy a van to be fitted with equipment to conduct ultrasonic, liquid penetrant, and magnetic particle non-destructive examinations. If the evaluations were successfully made from the equipment-fitted van, additional vans were to be purchased for use at each Regional Office. In addition, a contract was awarded to the Franklin Research Center to provide services involving independent assessment (destructive testing) of material samples. Data from these assessments were to supplement the testing to further verify conformance with licensee commitments, specifications and/or codes and standards requirements. Five uniquely qualified inspectors were to be assigned full-time to each van to ensure maximum use of the vans. This item addressed improvement in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.
A contractor for destructive testing was hired and tests were performed on an ongoing basis. An NRC mobile van was purchased, equipped, and staffed with contractor assistance. The original plan called235 for the staff to evaluate a trial program involving independent measurements at construction sites and then, based upon the results of the trial program, equip each region with the capability and equipment necessary to conduct independent measurements on a routine basis. The trial program was a success; however, based on budgetary constraints, a cutback in the effort was necessitated. OIE recommended a modified scope of the item so that the effort was limited to purchasing one van which would be available to all five regions. Personnel to utilize van equipment were supplied by an NRC contractor. This eliminated the need to hire additional full-time personnel and to provide a training program necessary to maintain personnel competency in NDE disciplines.
This issue was resolved when the scope of the action plan was revised and the program of independent measurements was incorporated into routine NRC operations.379 Followup was to be performed via routine programmatic action, and further expansion was to be based on continuing OIE appraisal of the program's effectiveness.
ITEM II.J.2.3: ASSIGN RESIDENT INSPECTORS TO ALL CONSTRUCTION SITES
This TMI Action Plan48 item called for OIE to expand the resident inspector program to include one inspector at each power plant construction site. Previous experience had shown the need for inspection at all stages of construction. This conclusion contradicted earlier criteria that delayed the assignment of resident inspectors to a plant site until 50% of the construction was completed. Schedules and resources for assigning resident inspectors to construction sites were to be developed in connection with routine agency budgetary processes. This item addressed improvement in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.
OIE assigned resident inspectors to all active construction sites that were greater than 15% complete.235 In November 1983, there were 23 resident inspectors at various construction sites. This item was developed as part of the routine program for NRC operators and was resolved when it was decided that future specific allocation of resources in this inspection program would be reevaluated as part of the annual budget process.379
TASK II.J.3: MANAGEMENT FOR DESIGN AND CONSTRUCTION (REV. 1)
The objective of this task was to improve the qualification of licensees for operating nuclear power plants by requiring greater oversight of design, construction, and modification activities.
ITEM II.J.3.1: ORGANIZATION AND STAFFING TO OVERSEE DESIGN AND CONSTRUCTION
The purpose of this TMI Action Plan48 item was to require "license applicants and licensees to improve the oversight of design, construction, and modification activities so that they will gain the critical expertise necessary for the safe operation of the plant."
The criteria and regulatory guidelines for this issue were addressed and developed by DHFS/NRR as a part of Item I.B.1.1. Therefore, this issue was covered in Item I.B.1.1.
ITEM II.J.3.2: ISSUE REGULATORY GUIDE
The purpose of this TMI Action Plan48 item was to issue a Regulatory Guide to codify the criteria relating to organization and staffing to oversee design and construction (Item II.J.3.1).
This item required the utilization of criteria developed from Item II.J.3.1. Therefore, this item was evaluated together with Item II.J.3.1 under Item I.B.1.1.
TASK II.J.4: REVISE DEFICIENCY REPORTING REQUIREMENTS (REV. 3)
The objective of this task was to clarify deficiency report requirements to obtain uniform reporting and earlier identification and correction of problems.
ITEM II.J.4.1: REVISE DEFICIENCY REPORTING REQUIREMENTS
This TMI Action Plan48 item called for the NRC to revise, as necessary, the event-reporting requirements of 10 CFR 21 to assure that all reportable items are reported promptly and that the information submitted is complete. Improvements were to be implemented by rule changes, as appropriate, and coordinated with those made under TMI Action Plan Item I.E.6. The reports received as a result of these rule changes were to provide increased information on component failures that affect safety so that prompt and effective corrective action could be taken. The information was also to be used as input to an augmented role of the NRC's vendor and construction inspection program.
This issue was originally classified as nearly-resolved, based on changes to 10 CFR 21 and 10 CFR 50.55(e) proposed by OIE,291, 292 and was later RESOLVED with new requirements when amendments to 10 CFR 21 and 10 CFR 50.55(e) were issued.1396 The staff's changes were presented to the Commission in SECY-91-150.1397 In an RES evaluation,1564 it was concluded that consideration of a 20-year license renewal period did not affect the resolution.