NRC Perspectives on Quality Assurance - ASQasq.org/ee/2008/06/nrc-perspectives-on-quality-assurance.pdf• Inadequate commercial grade dedication programs (lack of engineering involvement)

NRC Perspectives on Quality Assurance

ASQ 35th Annual Energy & Environmental Training and Education Conference

Raleigh/Durham, North Carolina

Glenn M. Tracy, DirectorDivision of Construction Inspection &

Operational ProgramsSeptember 16, 2008

2

3

NUREG-1055• First published in 1984• Significant quality-related concerns included:

– Inadequate management control– Lack of construction experience and false sense of

security based on prior successes– Failure to encourage problem reporting and

resolution– Failure to appropriately delegate– Lack of clear communication

4

NUREG-1055 (continued)

• Continuing validity of NUREG-1055 concerns:– Olkiluoto 3 in Finland– Lungmen in Taiwan– Flamanville-3 in France– MOX facility

5

Construction and Operational Experience Program

• Updated NRC-INPO MOA to include new builds• Issued a RIS on lessons learned on ITAAC reviews• Issued an IN on counterfeit parts• Drafted an IN on 3 concrete-related ConE events• Drafted an NRO office instruction on ConE process• Facilitated exchange of inspectors with Finland and

Taiwan• Significant interactions with international counterparts• Evaluated 82 operating experience (OpE) events

applicable to the design and construction of new reactors

6

Example 1: Catawba AFW pump inoperability due to potential flooding protection deficiencies

• In January 2008, Catawba discovered that restrictor plates were not welded over floor drain openings (EN 43945)

• Cause: Failure of the licensee QA program and construction oversight

• OpE/ConE process results:

– Event is applicable to all new reactor designs and is safety-significant because of a loss of a “passive” flood barrier

– Identified specific improvements for NRC construction inspectionprocedures (IMC 2503 and IMC2504)

– Similar past experiences were examined and was concluded that a generic communication (information notice) is warranted

7

Example 2: Unidentified Piping Weld Joints at YGN-3

• KINS inspector found an unidentified weld joint in the safety injection system piping during installation inspection (inspection of NDE of adjacent weld joints)

- Requested a radiographic examination of the weld- Verified it was an unidentified weld joint

• The inspector required the licensee to examine all piping of thesafety class and seismic category in YGN # 3 & 4

- 43 unidentified weld zones including those of the non-safety class were additionally discovered

- All of them were cut out, re-welded and documented

8

piping Piping penetration

Head plate

Concrete wall

piping

Head plate type support

Unidentified Piping Weld Joints (cont’d)

– Cause• Misalignment of the final weld joint

of a piping fixed by head plate / piping weld

• Workers cut the original piping and inserted pups

• Weld joint was neither inspected nor documented

– Lesson• Importance of installation order to

avoid difficulty in fabrication

9

Worldwide Construction

Argentina

Canada

France

Finland Russia

Slovakia

Iran

Pakistan

India

China

Taiwan

S. Korea

Japan

10

Global Supply Chain

Canada

US Spain

France

Germany

Italy

China

S. Korea

Japan

UK

11

Vendor Inspection Insights• Inadequate implementation of Part 21

requirements (IN 2007-40)• Inadequate commercial grade

dedication programs (lack of engineering involvement)

• Inappropriate use of commercial supplier surveys

• Unfamiliarity with NRC regulations (new and existing suppliers)

12

International Cooperation• Active member of newly-formed Vendor

Inspection Cooperation Working Group (VICWG)

• Joint activities conducted with Korea, France, Finland, Canada, Germany, United Kingdom, and Japan

13

Quality Assurance Topics

• Licensing Reviews• Design Verification Inspections• Standards Development Activities

14

Future Activities/Initiatives• Anticipate increasing number of vendor

inspections in future fiscal years• Public workshop on NRC QA and

reporting requirements in the planning stages

• Expansion of international cooperation• Focus on programs and training to

identify counterfeit parts

15

Prerequisites to Success

• Effective licensee management oversight of construction

• Detailed designs must be complete prior to construction

• Maintain the integrity of the global supply chain