ML17312B295

Insp Procedure 40501, Licensee Self Assessments Re Team Insps

ML17312B295
Person / Time
Site:	Palo Verde
Issue date:	02/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
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ML17312B293	List: ML17312B292 ML17312B295
References
40501, NUDOCS 9703170106
Download: ML17312B295 (9)

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yo UN IT E 0 STATE6 UC LEAR R EG ULATORY COMMISSI REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLING TON, T E XAS 76011 8064 ENCLOSURE NRC INSPECTION IVIANUAL INSPECTION PROCEDURE 40501 PSIB LICENSEE SELF-ASSESSMENTS RELATED TO TEAM INSPECTIONS PROGRAM APPL ICABILITv:

2515 SALP FUNCTIONAL AREA:

OTHER (OTHER) 40501-01 INSPECTION OBJECTIVE To provide guidance on evaluating a licensee's self-assessment effort as an alternative to an NRC team inspection.

40501-02 INSPECTION REQUIREMENTS 02.01 Regional management will determine if a licensee's past performance is sufficient to warrant reduced NRC inspection.

Note however

~ inspection procedure (IP) 40500.

"Effectiveness of Licensee Controls in Identifying, Resolving

~

and Preventing Problems" is not a candidate for licensee self-assessment.

02.02 Licensee's Pro osed Self-Assessment g~t.

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manage the self-assessment.

Assessment Team.

Ensure that the licensee's assessment team has the

, necessary credentials and experience to perform a technically creditable self-assessment.

c.

Sco e of Effort.

Ensure that the scope and depth of the licensee's program are at least equivalent to those requirements specified in the temporary instruction (TI) or 'the IP for the issues involved. or that the licensee has provided an acceptable basis for reducing the scope or depth.

d.

~Timin Ensure that the timing of the.licensee's proposal and assessment is such that NRC can adequately adjust its planning so that it has sufficient time to evaluate the licensee's proposal and align its resources to be able to monitor the in-process conduct of the licensee's self-assessment effort.

9703i70i06 9703ii PDR ADOCK 05000528 8

PDR Issue Date:

02/11/97 40501

02.03 Im lementatio f the Licensee's Self-Assessm a.

In-Process Ins ection.

Evaluate the capability of the licensee's team and the depth of its review by monitoring the conduct of the licensee's in-proces-.

assessment.

b.

Final Ins ection.

Perf6rm a technical inspection of the licensee's completed self-assessment using its final repori..

40501-03 INSPECTION GUIDANCE General Guidance This procedure outlines the process for conducting a limited-scope, indepth inspection as an alternative to a full-scope NRC inspection and for monitoring the licensee's self-assessment effort.

Inspection Hanual'Chapter 2515 allows the regional administrator. with concurrence of the Director, Inspection and Support Programs'o delay or not'perform a generic area team inspection at a specific site or facility.

The licensee's formal submittal of its proposed self-assessment effort will be the basis for NRC's review and acceptance of the proposal.

The licensee's proposal should include the schedule.

scope.

level of effort.

and team qualifications to perform.the self-assessment.

The region will formally respond to all licensee requests for reduced inspection.

If reduced NRC inspection is conditionally approved, the letter will include any stipulations (e.g.,

revised self-assessment scope) on which the approval is conditioned.

The letter will

. also state that the option of permitting licensees to conduct a self-assessment in lieu of'n NRC ihspection is an NRC program aimed at minimizing regulatory impact and utilizing NRC resources more efficiently.

Copies of all correspondence to the licensee regarding reduced inspection effort will be sent.

to the Chief. Inspection Program Branch, NRR.

Notwithstanding the. licensee's self-assessment, the region may elect to not reduce its normal inspection scope if there are indications that the licensee's effort was not implemented in accordance with the licensee's approved plan. or was deficient for some'other reason.

Consider any issues identified as a result of a licensee's self-assessment as licensee identified'otwithstanding that licensee effort was initiated as a

result of NRC selecting the area to inspect.

However. refer any enforcement action involving an old design issue to the Office of Enforcement.

When the licensee self-assessment involves a TI. follow.the requirements in the TI pertaining to reporting.requirements, completion schedule, expiration',

and technical'contact.

For HIPS and RITS purposes, the inspection effort involved in performing this IP is to be charged against the TI, and the TI closed with a status code of "C" when NRC inspection activities are completed.

When the licensee sel.f-assessment involves an IP, normal'nspection program reporting requi rements will be followed.

The inspection effort involved is to be charged against the involved IP for HIPS and RITS reporting.

S ecific Guidance 03.01 Regional management may recognize a licensee's good performance and self-assessment capability in a given area by reducing the scope of NRC inspection 40501 Issue'ate:

02/11/97

'ffort in the same a

This reduced inspection ap es to team inspections d fi,". d by Tis and IPs.

NRC's evaluation of a licensee's ability to detect problems early and resolve them before they result in significant performance concerns.

forms the basis for significant NRC decisions.

such as the future level o>> inspection resour e 'allocation at a licensee's site and whether to permit a

?icensee to conduct a selt-assessment in @ther areas.

Licensee self-assessment will not be allowed to be performed for any 'IPs listed in Appendix A to IMC 1245.

Appendix A to IMC 1245 defines the Core inspection program which is the minimum inspection effort that the NRC performs at each operating power reactor to independently confirm licensee performance and identify potential problems in early stages:

thus no part of this effort will be performed by a licensee.

Regional management should consider licensee performance during prior major safety inspections.

relevant NRC inspections'eriodic plant performance reviews.

and SALP ratings.

Regional management should limit the number of occasions where multiple usage of IP 40501 is authorized for core inspections at the same site within one SALP cycle.

Consider licensees recognized by NRC senior management.

for superior performance as automatic candidates.

Requests from other licensees are to be evaluated on a case-by-case basis.

Licensees placed on the "watch list" would not be eligible for reduced NRC inspection.

03.02 Licensee's Pro osed Self-Assessment

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hth thh'kit lll tliti ld preclude management from effectively managing the sel f-asSessment effort.

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Assessment Team.

Review the technical qualifications of the involved licensee personnel.

The design reviewers should have hands-on design experience.

such as that of a supervisory engineer in an architect-engineer organization.

The reviewers in other than design areas should have appropriate technical and plant experience.

c.

Sco e of Effort.

Deviations from the scope of the team 'inspection will be treated on a case basis with appropriate justification., For example, it may be appropriate for. the licensee's assessment not to include areas evaluated during recent NRC inspections.

d

~Timin It is desirable that.licensee proposals be made at least 90'days in advance of both the implementation of the self-assessment and the planned NRC inspection.

This is to ensure that the region has su'fficient time to evaluate the proposal (Section 02.02) and align its resources as appropriate to monitor in-process conduct of the licensee's self-assessment (Section 02.03.a),.

Although the intent is not to penalize a

licensee who does not give the region sufficient lead time before the

,self-assessment.

it is obviously more efficient for the licensee to

. resolve NRC comments on the inspection scope.

depth, and so forth, before.

initiating the self-assessment.

In addition, it is impractical for NRC to be notified of a licensee request for reduced NRC inspection under this IP -after the NRC inspection has proceeded substantially in the planning stage.

In the case of a TI. licensee self-assessments should be completed in'a timeframe that is sufficient to allow the NRC to complete a final inspection of the licensee's effort before the expiration date of the TI..

Issue Date:

02/11/97 40501

C zl

.To ensure tim self-assessment proposals.

pr de advance notification of inspections within the scope of thi.s IP by as much as 9 months.

consistent wi "h the latitude in IMC 0300.

"Announced and Unannounced Inspections."

Also. advise the licensee of the self-assessment option and of the possibility Of obtaining a copy of this inspection procedure if r quested.

03.03 Im lementation of the Licensee's Self-Assessment a.

In-Process Insd3ection.

Generally.

a senior inspector qualified for conducting the specific team inspection will conduct the in-process inspection.

Generally.

this will require more than one individual because of the several disciplines involved. but not as many as requi red for the final inspection of the licensee's effort.

The in-process inspection should last up to 5 days and be implemented when the self-assessmeht is approximately 50 percent complete.

During this inspection.

evaluate the scope and depth of the licensee's self-assessment, including the objectivity and independence of the self-assessment team.

Include a

review of the process for addressing operability. concerns and the process for developing corrective actions and ensuring their appropriateness.

If the licensee's organization primarily responsible for the areas of the self-assessment has demonstrated good performance (e.g.,

SALP Category 1) and the licensee's implementation of its self-assessment appears to be effective.

NRC effort during the final inspection may be reduced.

h b.

Final Ins ection.

Perform this inspection when the licensee has completed its self-assessments specified corrective actions to be implemented'nd issued a final summary report.

The regional technical inspection of the completed self-assessment will-include appropriate multi-discipline expertise.

including contractor specialists.

Wherever

possible, use personnel who participated in the in-process inspection (Section 03.03.a above) on the team.

The team should parallel the disciplines for the normal team inspection, with appropriate reductions made in areas where one inspector can cover.

several disciplines.

Predicate the inspection scope and team size on the TI/IP requirements, findings from other inspections,.

results from the NRC in-process inspection.

site-specific characteristics, and the licensee's past performance.

Include areas covered by the self-assessment to evaluate the completeness of the licensee's reviews.

but expend minimal resources in areas where the. licensee adequately addressed significant findings.

For areas. within the scope of the TI/IP reviewed during the self-assessment on a sampling basis.

include items both reviewed and not reviewed during the licensee's self-assessment..

For example, if the self-assessment did not include a

review of the thermal performance of all service water system heat exchangers.

the NRC inspectors would need to

reach, a

conclusion on whether the self-assessment sample provided a reasonable basis to support a licensee conclusion regarding the performance of the heat exchangers

'ot reviewed.

Also include any significant areas of the TI/IP not addressed by the self-assessment.

During the NRC inspection, evaluate the corrective actions proposed by the licensee for the more significant assessment findings as well as for generic findings and the licensee's handling of any operability con'cerns.

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It may be appropriate for the region to follow up on, the licensee's implementation of the corrective actions for significant.findings.

40501 4

Issue Date:

02/11/97

I/

40501-04 INSPECT REPORT The inspection report will document how the NRC ensured that =its reduced inspection effort. in combination with the licensee self-assessment.

provided at least the equivalent of a full-scope NRC inspection in accordance with the applicable TI or IP.

The inspection report will also include a discussion of the inspection requi rements identi fied in this IP such as evaluating (I) qualifications. objectivity, and independence of the assessment team.

(2) scope and depth of the self-assessment.

and (3) handling of operability issues and corrective actions.

Discuss NRC independent inspection as outlined in section 03.03.b.

and evaluate the licensee's self-assessment final report.

Since the licensee's self-assessment is being performed as an alternative to a full-scope NRC inspection.

the NRC inspection report shall document the licensee's safety significant findings and related corrective actions.

40501-05 RESOURCE ESTIMATE The goal for the total NRC oversight effort should be 25 percent of the normal preparation and inspection effort for the team inspection.

Inspection duration.

scope, and team size and composition will be determin'ed by the regional office on a case-by-case basis.

END Issue Date:

02/11/97 40501