ML18095A900
| ML18095A900 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/15/1991 |
| From: | Eapen P, Lopez A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A898 | List: |
| References | |
| M91-048-01, M91-48-1, NUDOCS 9105020122 | |
| Download: ML18095A900 (64) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
M9 l-048 Docket Nos. As listed in Attachment 1 License Nos. As listed in Attachment 1 Licensee:
As listed in Attachment 1
Participants:
As listed in Attachment 1 Meeting At:
Sheraton Valley Forge. King of Prussia. Pennsylvania
. Meeting Conducted: February 20 - 21. 1991 Prepared by:
A.E.
Approved by: ----=J;._) __
\\./_. _ __.,.--_-:.."--~--i--=\\i..."'-, _*.,._L-'-------
Dr. P. K. Eapen, Chief, S stems Section, Engineering Branch, DRS ate/
j date Meeting Summan*: The Engineering Symposium/Workshop was held to promote an open discussion of various industry topics. The meeting was attended by NRC, licensee, and other industry personnel. The topics discussed were: (1) Elements of a good engineering organization; (2) Licensee's actions with degraded conditions, including operability/reportability determinations; and (3) The modification process including 1 OCFR 50.59 reviews. The symposium conclusions recommended six action items for the NRC and seven action items for the industry.
9105020122 910417 PDR ADOCK 05000272 p
Region I Meeting Report M9 l-048 1.0 Purpo~e 2.0 General Overview 3.0 Summary of Workshop Group Presentations 4.0 Conclusion - List of Attendees - Meeting Agenda Table of Contents - Speakers Slide Presentation - Workshop Group Summaries Page 3
3 4
6
3 1.0 Purpose The Engineering Symposium/Workshop was designed to promote discussion and a better understanding between the utility engineering personnel and the NRC staff regarding the engineering departments role in support. of plant activities.-
- 2. 0 General Overview The Engineering Symposium was conducted on February 20 - 21*, 1991, as published in the Federal Register Notice dated January 24, 1991. Attachment 1 presents the list of persons who attended the symposium. An agenda of the symposium is provided in The Engineering Symposium began with a Call to Assembly, an Introduction, and a Welcome. Mr. J. H. Sniezek, NRC Deputy Executive Director for Operations, and Mr. E. J. Mroczka, Northeast Utilities Senior Vice President of Nuclear Engineering and Operations then addressed the symposium. Both Mr. Sniezek and Mr. Mroczka eloquently discussed the theme of the symposium, "The Engineering Role in Plant Support." They provided an excellent basis for promoting open discussion during the symposium. Attachment 3 contains the slides presented by the keynote speakers.
The afternoon concluded with the attendees participating in the first of two planned workshop sessions. The participants were assigned to one of the workshop groups.
Two groups discussed the elements of a good engineering organization; three groups discussed the licensee's actions with degraded conditions including operability/reportability determinations; and three groups discussed the modification process including 1 OCFR 50.59 reviews. Each workshop group was lead by two facilitators, one each from the NRC and a licensee, and had approximately 15 - 25 participants.
The participants returned the next morning to the same workshop group as the day before for approximately two hours to finalize discussions and to develop recommendations.
At 10:30 a.m. on February 21, 1991, a speaker, Mr. M. R. Tresler, Diablo Canyon Engineering Manager, Pacific Gas and Electric Company, and Chairman of Region V Engi,neering Managers' Forum addressed the symposium. Mr. Tresler discussed the experiences at the Region V Engineering Managers' Forum. The slides from Mr.
Tresler's presentation can be found in Attachment 3.
3.0 4
In the afternoon, the facilitators from each of the eight workshop groups presented a summary of the their groups discussions and conclusions. Attachment 4 contains slides from the facilitators presentations. The facilitators presentations were then followed by two wrap-up speakers and closing remarks by Mr. M.W. Hodges, NRC Director of the Division of Reactor Safety for Region I. The symposium adjourned at 4:20 p.m.
Summary of Workshop Group*Presentations A.
Elements of a good engineering organization The two work groups on this subject concluded the following:
- 1.
There is no single universal engineering organizational structure that is best for all plants.
- 2.
A good engineering organization must:
- a.
prioritize its activities from a safety perspective and establish clear lines of responsibility and accountability
- b.
- c.
be responsive to the needs of its customer (operations, maintenance,... )
maintain a well qualified and trained staff
- d.
maintain a high quality interface with the NRC These working groups did not recommend specific actions for the NRC or the industry groups.
I B.
Licensee's actions with degraded conditions including qperability/reJJortability determinations The three working groups on this subject concluded the following:
- 1.
Concerns
- a.
lack of well defined concepts and terms for operability
- b.
lack of well defined processes for operability determination
- c.
lack of adequate guidance for the use of engineering judgement in operability determinations
- 2.
5 d.
lack of adequate guidance for reportability Recommendations
- a.
NRC establish consistent guidance on operability and reportability (NRC Action Item 1)
- b.
Industry develop design basis standards with NRC endorsement (NRC Action Item 2, Industry Action Item 1)
- c.
Industry establish guidelines for the timeliness for operability determinations with NRC endorsement (NRC Action Item 3, Industry Action Item 2)
- d.
NRC and Industry train their respective personnel in the use of the above guidance (NRC Action Item 4, Industry Action Item 3)
C.
The modification process including 10CFR 50.59 reviews The three working groups on this subject concluded the following:
- 1.
- 2.
the modification process including the 50.59 process has been consistently improving NSAC 105 and NSAC 125 are good industry standards to provide guidance in the design process and the 50.59 review process, respectively
\\Veaknesses
- 1.
design change process is cumbersome
- 2.
temporary modifications may be bypassing the modification process
- 3.
design bases are not adequately defined
- 4.
control of contracted modification work i~ not adequate
- 5.
inadequate prioritization and control of backlog
4.0 6
Recommendations
- 1.
NRC and Industry train their respective personnel in the modification process (NRC Action Item 4, Industry Action Item 3)
- 2.
Licensee establish clearly developed design basis documents for each unit using NRC endorsed standards (Industry Action Item 4)
- 3.
Industry define categories of modification with NRC endorsement (NRC Action Item 5, Industry Action Item 5)
- 4.
Industry improve NSAC 125 to provide examples of good 50.59 reviews (Industry Action Item 6)
- 5.
NRC endorse NSAC 125 for 50.59 review (NRC Action Item 6)
- 6.
Industry establish measures based on safety to prioritize and control backlog of engineering projects (Industry Action Item 7)
Conclusion The symposium had good participation from all its attendees. The majority of the feedback forms received, indic~ted that the symposium achieved its goals, and promoted and stimulated open discussion between the NRC and the industry. The feedback also encouraged future symposiums in the engineering area. A small minority of participants did not fully agree with all the conclusions of the symposium and they provided alternate conclusions.
ATTACHMENT 1
A.
Region I Licensees LICENSEE
- 1.
BG&E
- 2.
Boston Edison
- 3.
Conn. Yankee Atomic Power Company
- 4.
Consolidated Edison Co.
of NY
- 5.
Duquesne Light Company
- 6.
GPU Nuclear
- 7.
Long Island Lighting co.
- 8.
Niagara Mohawk Power Corp.
- 9. Northeast Nuclear Energy Company
- 10. PP&L LIST OF ATTENDEES DOCKET #
LICENSE #
50-317 50-318 50-293 50-213 50-247 50-334 50-412 50-219 50-322 50-220 50-410 50-245 50-336 50-423 50-387 50-388 DPR-53 DPR-69 DPR-35 DPR-61 DPR-26 DPR-66 CPPR-105 DPR-16 NPF-19 DPR-63
- NPF-54 DPR-21 DPR-65 NPF-49 NPF-14 NPF-22 ATTENDEES Charles Cruse Peter Katz Robert Waskey Robert Fairbank Edward Kraft Clint Gladding Joe Bahr John Curr Mike Lee Pete Szabados Kenneth E. Halliday Nelson R. Tenet Jim Byrne Dave Distet Greg Gurican William Heysek James W. Langenbach Max Nelson Ed O'Connor Art Rone Richard Skillman Patrick Walsh Ed Pierpont Michael Carson Gregory Gresack Rob Oleck Bill Yaeger Michael Bigiarelli Brendan J. Duffy G. Leonard Johnson John s. Keenan Edward J. Mroczka R. L. McGuinness
- c. Fred Sears Bob Byram F. G. Butler
- w. H. Gulliver J. M. Kenny George Kuczynski G. D. Miller D. P. Parsons
LICENSEE DOCKET #
LICENS-E #
ATTENDEES
- 11. PECO 50-352 NPF-39 Jim Basilio 50-353 CPPR-107 William Bloomfield Wes Bowers Frank Cook Jack Evans Al Fulvio David Foss Cliff Harm.on Dave Helwig Frank Hunt Marilyn Kray Rod Krich G. Kernahan Dave Meyers Lou Pyrah David Schra Glen Stewart Kevin Walsh
- 12. Power Authority 50-333 DPR-59 Jerry Gullick of State of NY Terry Herrmann Gus Mavrikis Steve Smith Vic Walz
- 13. Public Service 50-443 CPPR-135 Terry Harpster of NH 50-444 CPPR-136 Joe Vargas 14. PSE&G 50-272 DPR-70 Richard Bashall 50-311 DPR-75 Raymond Brown Moises Burzstein Thomas M. Crimmins Scott Gillespie Lee Griff is Bruce Hall Michael Morroni Bruce Preston Martin E. Raps John P. Ronafalvy Frank Thomson
- 16. Yankee Atomic 50-029 DPR-3 Peter Anderson Electric Co.
John Hoffman William Jones Dave King Robert Shone George Tsouberous
B.
Licensees From Other NRC LICENSEE
- 1.
Florida Power and Light
- 2.
Toledo Edison
- c.
Other Participants 2 *
- 3.
- 4.
- 5.
6.
- 7.
OTHER Bechtel Westinghouse Tenera Massachusetts Nuclear Engineer General Electric Nuclear Energy Stone & Webster NCS Corp - Florida Regions ATTENDEES Bill Skelley Vernon Watson ATTENDEES Nancy Chapman Steve Routh David Schmit Rick Eastering John Elliott James McKerheide Lee Lantz Ajay Banerjee Thomas Bates Marc Boothby Alan Chan Tim Chitester Louis Hirst E. J. Hubner Tom Szabo Michael Johnson Peter s. Jordan Eric'R. Smith
D.
The Nuclear Regulatory Commission OFFICE
- 1.
HQ
- 2.
HQ
- 3.
HQ
- 4.
HQ
- 5.
HQ
- 6.
HQ
- 7.
HQ
- 8.
HQ
- 9.
HQ
- 10. HQ
- 11. HQ
- 12. HQ
- 13. HQ
- 14. HQ
- 15. HQ
- 16. HQ
- 17. HQ
- 18. HQ
- 19. HQ
- 20. HQ
- 21. HQ
- 1. RII
- 2. RII
- 3. RIII
- 4. RIV
- 1.
RI
- 2.
RI
- 3.
RI
- 4.
RI
- 5.
RI
- 6.
RI
- 7. *RI
- 8.
RI
- 9.
RI 10 RI
- 11. RI
- 12. RI
- 13. RI
- 14. RI
- 15. RI
- 16. RI
- 17. RI
- 18. RI
- 19. RI
- 20. RI
- 21. RI
- 22. RI
- 23. RI
- 24. RI
- 25. RI
- 26. RI
- 27. RI
- 28. RI ATTENDEES Bob Capra Jin Chung Dick Clark Al DeAgazio Richard L. Emch Mort Fairtile Bagchi Goutam Craig c. Harbuck Gary D. Holahan Chris L. Hoxie Eugene Imbro Jeff Jacobson Wayne Lanning Erasmia Lois Dan McDonald James G. Partlow Uldis Potapovs Mark F. Reinhart Jim Sniezek John Stolz David L. Wiggington Caudle H. Julian Francis Jape Mark Ring Johns Jaudon Scott Barber Walter Baunack Lee Bettenhausen Norman Blumberg Fred Bower Suresh K. Chaudhary Rich Conte Larry Doerf lein Jacque P. Durr P.K. Eapen Harold Eichenholz Pete Eselgroth E. Harold Gray Harold I. Gregg Peter Habighorst Sam Hansell Donald Haverkamp Tom Hiltz M. Wayne Hodges Kerry Ihnen Jon Johnson Herbert Kaplan Paul Kaufman Gene Kelly James c. Linville Al Lohmeier Thomas T. Martin Marie Miller
OFFICE
- 29. RI
- 30. RI
- 31. RI
- 32. RI
- 33. RI
- 34. RI
- 35. RI
- 36. RI
- 37. RI
- 38. RI ATTENDEES Dan Moy George Napuda - retired William Oliveira Steve Pindale Len Prividy John Rogge Glenn Tracy Ed Wenzinger Barry Westreich Peter Wilson
ATTACHMENT 2
Symposium/Workshop Engineering's Role In Support Of Plant Activities AGENDA Wednesday, February 20, 1991 12:00 -
12:50 p.m.
Registration 12:50 -
1:00 p.m.
Call to Assembly 1:00 -
1:05 p.m.
Introduction 1:05 -
1:15 p.m.
Welcome 1:15 -
1:55 p.m.
Keynote Speaker 1:55 -
2:35 p.m.
Keynote Speaker 2:35 -
3:00 p.m.
Break 3:00 -
5:00 p.m.
Breakout Sessions Topic Harold I. Gregg Senior Reactor Engineer Division of Reactor Safety, RI M. Wayne Hodges Director Division of Reactor Safety, RI Thomas T. Martin Regional Administrator, RI James H. Sniezek Deputy Executive Director for Operations, NRC Edward J. Mroczka Sr. Vice President Nuclear Engineering and Operations Northeast Utilities Room Location A.
Elements of a Good Engineering Organization Berwyn Room or Devon Room B.
- c.
Licensee's Actions With Degraded Conditions Including Operability/
Reportability Determinations The Modification Process Including 10CFRS0.59 Reviews Gladwyne Room, Bryn Mawr Room, or Hemlock Room Rad.nor Room, Merion Room, or Quaker Room
Thursday, February 21. 1991 8:00 - 10:00 a.m.
Breakout Sessions - Refinement issues of most significant
'Topic Room Location A.
Elements of a Good Engineering Organization Berwyn Room or Devon Room B.
- c.
Licensee's Actions With Degraded Conditions Including Operability/
Reportability Determinations The Modification Process Including 10CFR50.59 Reviews 10:00 - 10:30 a.m.
Break 10:30 - 11:30 a.m.
Speaker 11:30 - 1:00 p.m.
Lunch Gladwyne Room, Bryn Mawr Room, or Hemlock Room Radnor Room, Merion Room, or Keystone Room Michael R. Tresler Engineering Manager, Diablo Canyon Pacific Gas and Electric Company Chairman of Region V Engineering Managers Forum 1:00 - 2:15 p.m.
First Group summary Feedback Breakout Session Facilitators 2:15 - 2:30 p.m.
2:30 - 3:15 p.m.
3:15 3:35 p.m.
3:35 - 3:55 p.m.
3:55 - 4:15 p.m.
Break Second Group summary Feedback Wrap-up Wrap-up Closing Remarks Breakout Session Facilitators David R. Helwig Vice President Nuclear Engineering and Services Philadelphia Electric Company Jacque P. Durr Chief, Engineering Branch Division of Reactor Safety, RI M. Wayne Hodges Director Division of Reactor Safety, RI
ATTACHMENT 3
/
JAMES H. SNIEZEK DEPUTY EXECUTIVE DffiECTOR FOR OPERATIONS, 1RC PRESENTATION FOR NRC REGION I - UTILITY SYMPOSIUM/WORKSHOP Engineering's Role in Plant Support February 20-21, 1991 Sheraton Valley Forge Hotel King of Prussia, Pennsylvania
r.
SAFE ENOUGH ARGUMENT BACKSLIDE TOWARD INADEQUACY PRINCIPLE OF COST EFFECTIVE SAFETY IMPROVEMENT
RESPQJlS_I_B_I_LIT_L_(Q_ILSA EEJ_~
UTILITY RESPONSIBLE FOR SAFETY NRC IS REGULATOR-NEED FOR NUCLEAR INDUSTRY SAFETY CULTURE TRUST IS FOUNDATION OF NRC/UTILITY RELATIONSHIP
RE.l~JJ_O_RS_H_I_e__\\.!IJH_UilLITI_ES LICENSE BASED ON TECHNICAL/MANAGERIAL COMPETENCE
- NRC HANDS OFF, IF TRUE
- NRC ACTIVE INVOLVEMENT, IF NOT TRUE 1
NRC EMPHASIS ON COMMUNICATION OF EXPECTATIONS 1
UTILITY CERTIFICATION OF PERFORMANCE UTILITY RESPONSIBLE FOR SAFETY EVALUATION 1
NRC RESPONSIBLE TO REGULATE
REGULAJ_OIJLlMfACT S_U_&YEY ESTABLISH MANAGEMENT EXPECTATIONS MEASURE IMPLEMENTATION OF MANAGEMENT EXPECTATIONS ESTABLISH A STABLE PROCESS CONDUCT ACTIVITIES IN A PROFESSIONAL MANNER
REGU_L_AJORY IMPACT SJJ_RVEY
(<;_Q_~LIJtV_E;_pJ_
- ACTIVITIES SHOULD CLEARLY ENHANCE SAFETY ACTIVITIES~SHOULD BE COST-BENEFICIAL RESOURCES SHOULD BE FOCUSED ON AREAS NEEDING IMPROVEMENT CONDUCT A MANAGEMENT SELF-ASSESSMENT
~ -- -----
~-
INSPECTORS NEED TO ALWAYS BE ALERT FOR SAFETY ISSUES -- EVEN THOSE OUTSIDE THEIR AREA OF EXPERTISE PRIMARY EMPHASIS IS ON SAFETY WITH THE RECOGNITION THAT NRC REQUIREMENTS ARE SUPPOSED TO BE MET REGARDLESS OF SAFETY IMPORTANCE DEGREE OF REACTION/RESPONSE BY INSPECTORS DICTATED BY SAFETY IMPORTANCE ACCEPTANCE CRITERIA ARE BASED ON AGENCYWIDE POSITIONS, NOT ON INDIVIDUAL REVIEWER/INSPECTOR DESIRES
lNSPE_CTI_ON_e_R_I_NCIPLES PERFORMANCE INDICATORS ARE USED TO HELP DETERMINE DIRECTION, SCOPE AND DEPTH OF INSPECTION EFFORT AND ARE NOT A DISPOSITIVE MEASURE OF PERFORMANCE BY THEMSELVES ANALYSIS OF MANAGEMENT EFFECTIVENESS IS BASED ON RESULTS OF MANAGEMENT EFFORTS AND NOT ON ANALYSIS OF SKILLS, STYLES OR POPULARITY FOCUS OF INSPECTION IS PRIMARILY ON END PRODUCT; HOWEVER, PROCESS OF ENSURING QUALITY ALSO IMPORTANT IN ORDER TO ENSURE CONSISTENT QUALITY
STANDARDS OF PROFESSIONALISM OF INSPECTORS EXCEED THE STANDARDS EXPECTED OF LICENSEE PERSONNEL APPLICATION OF REGULATORY EXPECTATIONS IS CONSISTENT FROM INSPECTOR TO INSPECTOR AND FROM PLANT TO PLANT INSPECTION APPROACH AND TECHNIQUES ARE SUCH THAT INSPECTOR AND LICENSEE TIME ARE EFFECTIVELY USED INSPECTORS ARE QUALIFIED COMMENSURATE WITH DIFFICULTY OF TASK
INSPECTION FINDINGS ARE ACCURATELY AND PROMPTLY COMMUNICATED TO APPROPRIATE LEVELS OF UTILITY MANAGEMENT BOTH DURING AND AT THE END OF THE INSPECTION INSPECTION ACTIVITIES APPROPRIATELY RECOGNIZE THE EFFORTS OF INDUSTRY SELF-EVALUATION ORGANIZATIONS SUCH AS INPO AND DO NOT INTERFERE WITH THE LICENSEE/SELF-EVALUATION ORGANIZATION INTERFACE NRC MANAGEMENT.IS PROMPTLY INVOLVED WHEN FUNDAMENTAL DIFFERENCES CANNOT BE RESOLVED BETWEEN INSPECTOR AND LICENSEE
_I N_S_f_ E_C_ll_O_N_PRI_ N CJ_~ LES IN PLANT SOURCES OF INFORMATION ARE GUARDED IN ORDER TO PROMOTE FREE EXCHANGE BETWEEN STAFF AND INSPECTORS COMMUNICATIONS ABOUT THE LICENSEE OR LICENSEE PERSONNEL ARE CONTAINED WITHIN THE REGULATORY FRAMEWORK BE RECEPTIVE TO All ALLEGATIONS AND TREAT All PUBLIC INQUIRIES WITH RESPECT AND PROFESSIONAL RESPONSE INSPECTORS MUST GENERATE AN AURA OF INDEPENDENCE IN All DEALINGS WITH THE LICENSEE
MOST NRC/UTILITY INTERFACES ARE POSITIVE INTERFACES MUST BE STRAIGHTFORWARD AND HONEST RESULT IN EFFECTIVE AND EFFICIENT SAFETY PROGRAMS GREATER NRC EMPHASIS ON PROPER INTERFACES IN THE FUTURE
The Engineering Role In Plant Support E. J. Mroczka Senior Vice President Nuclear Engineering and Operations Northeast Utilities NRC Region I Workshop February 20-21, 1991 I
"NRC PRINCIPLES OF GOOD REGULATION" Independence Openness
- Efficiency Clarity Reliability
INDEPENDENCE o "Nothing but the highest possible standards of ethical performance and professionalism should influence regulation.
o However, independence does not imply isolation.
o All available facts and op1n1ons must be sought openly from licensees and other interested members of the public.
o The many and possibly conflicting public interests involved must be considered.
o Final decisions must be based on objective, unbiased assessments of all information, and must be documented with reasons explicitly stated."
OPENNESS o "Nuclear regulation is the public's business, and it must be transacted publicly and candidly.
o The public must be informed about and have the opportunity to,_participate in the regulatory process as required by law.
o Open channels of communication must be maintained with Congress, other government agencies, licensees, and the public, as well as with the international nuclear community."
EFFICIENCY o "The American taxpayer, the rate-paying consumer, and licensees are all entitled to the best possible management and administration of regulatory activities.
o The highest technical and managerial competence is required and must be a constant agency goal.
o NRC must establish means to evaluate and continually upgrade its regulatory capabilities.
o Regulatory activities should be consistent with the degree of risk reduction they achieve.
o Where several effective alternatives are available, the option which minimizes the use of resources should be adopted.
o Regulatory decisions should be made without undue delay."
INTEGRATED REGULATORY REQUIREMENTS IMPLEMENTATION SCHEDULE o "IRRIS provides a simple mechan~sm that will encourage implementation of plant modifications offering the, most safety for resources spent; o help to evaluate and set balanced priorities for an entire set of pending requirements; and *
- o help to avoid duplication of efforts to enhance safety."
CLARITY o "Regulations should be coherent, logical, and practical.
o There should be a clear nexus between regulations and agency goals and objectives whether explicitly or implicitly stated.
o Agency positions should be readily understood and easily applied."
REPORT ABILITY NRC Guidance Should be Consistent Prompt Reports (10CFR 50.72)
Licensee Event Reports (10CFR 50.73)
Inspection and Enforcement Should be Consistent Inspector to Inspector Region to Region Degraded Conditions, Operability Determinations, and JCO's - Terminology and Requirements need to be worked out.
More Rewards for Self Assessment
RELIABILITY o "Regulations shou1d be based on the best availab1e knowledge from research and operational experience.
o Systems interactions, technological uncertainties, and the diversity of licensees and regulatory activities must all be taken into account so that risks are maintained at an acceptably low level.
o Once established, regulation should be perceived to be reliable and not unjustifiably in a state of transition.
o Regulatory actions should always be fully consistent with written regulations and should be promptly, fairly, and decisively administered so as to
- lend stability to the
- nuclear operational and planning processes."
CONCLUSIONS "NRC PRINCIPLES OF GOOD REGULATION" are also Good Principles for Engineering Support Independence Openness Efficiency Clarity Reliability NRC and Licensees Working Together as Professionals
I
.*-*****------*----....... ~--.....
."""'""'9 REGION V ENGINEERING MANAGERS FORUM REGION I UTILITY EllGlllEERlllG SY*P0811116 I.
REGION V ENGINEERING MANAGERS FORUM i
Mike Tresler Diablo Canyon Power Plant - PG&E E11gineering, Manager Roo"' A1409 333 Market Street San Francisco, CA 94106
\\'-------------------------------------------'
REGION V ENGINEliRINQ MANAGERS FORUM REGIOll 5 EllGlllEERlllO
- AllAGERS' FORU*
BACKGROUND
- Membership PllRPOSE
- PGE
- PG&E
- SMUD
- WPPS
-* Meet Quarterly
- Shared Knowledge I Experience
- Unified Position I Working Task Forces
- Improve Communication
/
- ~~*-----------~*~
.._..REGION V ENGINEERING MANAGERS FORUM e Charter e DBD Guide e Proactive Engineering Guide e Design Engineer Training &
Qualification Guide e Management Of Low Priority Engineering Tasks Guide e Procurement Engineering Guide C __. __
*-*... --------*-----* --* ----==--*------
REGION V 1
~~:~!:~~G PROCUREMENT QUIDELl#j e Tech. Eva/. Of Supplier Qua/. I Deficiencie e Spare I Replacement Configuration Contrc e Performance History - CGD e Commercial Grade Survey*
e Location Specific Components e Detection Of Fraudulent Materials*
e Information Exchange
- .. /.
*---4
- Engineering Task Prioritization
- Set Points
.-------.. -R-EG-ION_V _________ -_--_----------------------===i ENGINEERING POTENTIAL MANAGERS FORUM SUBCO**ITTEES
,~..---~~---------------------------~
- Pert ormance Monitoring
- Design Process
- System Walkdowns Operability
- Procedure Review
REGION V ENGINEERING MANAGER~
FORUM BENEFITS TO DAT*
e Budget I Staffing*
- Leak Repair (90-05)
- EDSFI
- Setpoints
- ADV's
- INPO I NRG Support
- Issue Definition I Containment
- Shared Experience At All Levels*
a.. REGION V ENGINEERING MANAGERS FORUM LESSONS LEARllED
- Conflicting Demand On Time
. I
\\
Top Level Participation In Task Forces
- Tension Between "Set Ways" And New Guidance
- Documents Must Be Useful & Used Variability In D.E. Org.,
- Staffing, Capability And Responsibility
.._,.--=----------------=-=--*..
.. ~=*===------****-_*_* _---*----_------_---**--=---=---=---.
REGION V ENGINEERING llANAGER:J FORUM
- Add Plant To Membership
- Excellent Point of Reference
- *rips* On Latest NRG Concerns, Perspectives & Positions
- United Position On Critical Issues
- General Mutual Support Environment I
I I
I i
I
- I.
I I
I i
I
ATTACHMENT 4
ELEME~TTS OF A GOOD ENGINEERING ORGANIZATION Group I:
Facilitators - Ed Wenzinger (NRC), Tom Crimmins (PSE&G)
Industry participants: 16, NRC participants: 5 Four key issues
- a.
priorities (19)
- b.
responsiveness (15)
- c.
people (8)
- d.
NRC interface (7)
Good engineerinr orranizations prioritize plan effective]\\* allocate resources to their work Elements
- a.
- b.
- c.
- d.
e.
- f.
- g.
- h.
long-term planning priorities - setting how and who emergent work forced outage plan orderliness vs chaos communication enhanced show proacti\\'e nature balance long term and short term Good engineering organizations are responsive to the needs of operations, maintenance, and day to day activities Elements
- a.
mission clarity
- b.
physical involvement
- c.
joint planning/priorities
- d.
balance reactive and proactive
- e.
communications, communications, communications
- f.
key to maintaining design quality and configuration
- g.
ops and maint. understanding of basis for and demands of the design
- h.
balance eP.gineering/design perspective and operations perspective Good engineering organizations maintain a high quality interface with the NRC
Group 1 2
Elements
- a.
technical competence
- b.
proactive assertive engineering
- c.
communications - listen
- d.
quality of process/product
- e.
NRC acceptance of acceptable solution
- f.
escalate professional differences
3 Group 2:
Facilitators - Harold Gray (NRC), Fred Sears (Northeast Utilities)
Industry participants: 14, NRC participants: 5 Factors for consideration
- a.
there is no single, universal engineering structure or organization that is best for all plants
- b.
whatever the organization is, it must be clearly defined with respect to responsibilities and accountabilities Attributes
- a.
continual improvement
- b.
economical operation
- c.
common goals
- d.
teamwork
- e.
effective self-assessment
- f.
conformance to requirements
- g.
well defined, available, usable design basis
- h.
configuration management
- 1.
lessons learned application J.
new technology usage
- k.
customer satisfaction Eneineerine concerns - "problems"
- a.
LT A Design Basis - documentation and organization
- b.
Resource Management
- 1.
conflicting goals and priorities both internal and external
- 2.
NRC interface - team inspections
- 3.
off normal support
- c.
Ineffective Processes - internal and external
- d.
Plant Materials - obsolescence, aging, vetip (vendors), OEM demise/dedication Solutions
- a.
mission
- b.
strategies
- c.
responsibilities
- d.
plans, schedules, priorities, resources
- e.
communications, education, sharing
- f.
decision tools
- g.
staff training, development
- h.
cultivate positive NRC/utility relation
Group 2 4
Conclusions
- a.
no single definition of engineering
- b.
consider all with engineering or science background and those performing in technical roles to be part of engineering
- c.
solutions of engineering concerns can be reached by good management practices, including consideration of mission - strategies - responsibilities - accountability, plan, schedule, train, educate
- d.
the functions of good engineering are many, but the intent is safe, reliable, economical plant operation.
/
5 OPERABILITY /REPORT ABILITY DETERMINATIONS AND DEGRADED CONDITIONS Group I:
Facilitators - Jon Johnson (NRC), Wes Bowers (PECO)
Industry participants: 14, NRC participants: 8 Q.
How does licensee know or determine operability and reportability?
A.
When there is sufficient evidence or basis that a component or system meets its design safetv function(s) including operation under prescribed accident conditions. The determination must be made in a timely manner.
W11at is sufficient evidence?
Issue Recommendation/solution
\\\\Tho lack of guidance revise NRC inspection manual NRC on operability to provide improved determinations guidance; transmit manual to licensees lack of guidance finish owners group BWROG on reportability guidance on reportability; transmit manual to NRC develop improved guidance NRC on reportabili ty
\\\\'hat is design bases?
Issue Recommendation/solution Who design bases publish design bases standard utility is unbounded including guidance and and component level NRC endorse refine and clarify WRT safety function clarify functional capabilities clarify \\VRT clarify difference (if any) operability between design bases for or reportability operability (T.S) and reportability (50. 72, 50. 73)
Group 1 6
Timeliness of operability determinations unclear process (accountability priority) refine timeliness guidance lack of knowledge/
utility/Il\\TPO sensitivity to staff timeliness needs Recommendation/solution use a two step process
- 1. screen (operability determination) and
- 2. F/U analysis publish/endorse guidance
- use STS LCO action times
- use IPE/PRA to prioritize train engineering support Sug£estions for improved guidance for operabilitv clarify that the following can be used
- engineering judgement
- test results
- analysis
- compensatory action
- operating experience
- operating parameters
- current physical condition clarify that PRA cannot be used utility/INPO NRC/NUMARC clarify that unavailability of component not required for safety function does not make system unavailable consider NU.MARC guidance on design basis definition and examples
7 Group 2:
Facilitators - Rich Conte (NRC), Bob Byram (PP&L)
Industry participants: 13, NRC participants: -8 Format
- open forum
- aired concerns
- focused on positive aspects
- selected four key concerns
- positive aspects into process objectives
- focused on key concerns Objectives
- assurance of nuclear safety
- clear expectations
- communication/action on generic conditions
- efficient and effective
- mutually agreeable
- eng. involvement in operability/reportability
- clear and consistent
- promote initiative/action
- foster questioning attitude
- training and de\\*elopment
- strengthen design documentation
- work on what's important
- enhance safety cultures that are assumed to satisfy regulatory expectations
- sensitivity to real needs of operator Operabilitv/Reponabilit\\* major concerns
- a.
define concepts and terms on operability
- b.
define the process for operability determinations
- c.
use of engineering judgement Aside Issue - Reportability
- a.
groups discussion focus was on operability issue
- b.
group generally agreed
- 1.
reportability criteria not to be discussed - residual issues exist-but are being dealt with
- 2.
reportability criteria should remain separate and distinct from operability criteria but properly sequenced with operability determinations
Group 2 8
Major concern No. 1 - Define concepts and terms
- a.
operability workability capable of perf qualification timeliness degraded condition JCO/BCO functionality design basis
- b.
distinguish postulated events (how far do you go) versus current configuration events (normal conditions)
- c.
avoid determinations of inoperability because of lack of documentation
- d.
once defined as above, distinguish workability versus functionality and/or operability versus qualification Major concern No. 2 - Define the process
- a.
administrative procedure to address operability determinations (including organization roles and responsibilities) should be left to licensee initiative b.
let (responsibility not defined by group) establish process criteria which focus on:
timeliness, prioritization, quality of documentation, etc. (here again licensee initiative)
- c.
although the NRC says that the pending guidance contains no new requirements (reports/records procedures), the reality is the opposite because of licensee initiative to establish controls J\\fajor concern No. 3 - Use of engineering iudgement
/-
- a.
recognize its use as variable but viable
- b.
document the thought process for the engineering judgement
- c.
encourage people to think
- d.
demonstrate competence in applying engineering judgement
- e.
make engineers responsible and accountable for the above
- f.
initial through final stages of operability determination - how is engineering judgement to be applied
Group 2 9
Summarv
- a.
disseminate information
- 1. pending guidance
- 2. this conference
- b.
industry interaction at working level
- c.
focus on expectation as opposed to prescriptive guidance
10 Group 3 Facilitators - Lee Bettenhausen (NRC), Bruce Preston (PSE&G)
Industry participants: 13, NRC participants: 10 What value/criteria do you use for operability determinations - design/purchase specs - design basis licensing basis (FSAR, SER, LC, etc.), or safety limit basis (2200°F, containment pressure, etc.)?
- 1.
technical specification values must be used if avllilable
- 2.
IOCFR safety limits
- 3.
other -
example:
containment fan coil units BTU capacity being tested - is tech spec operability based on
- 1.
purchase spec - design? IOOK
- 2.
FSAR SOK
- 3.
Ultimate safety limit - i.e., containment pressure 60K can current conditions be used also -i.e., river water temp (heat sink) -
yes Operable - ASME code versus tech spec operability pumps and valves
- 1.
GL 89-04 directs that device is inoperable if test results are in action range -
appropriate tech spec LCO should be entered (basis-degradation cause unknown, device could fail immediately)
- 2.
ASME section XI allows for analysis to change action range value using 50.59, maintaining component operable per tech specs (i.e., enter LCO, do analysis, exit LCO)
I section III, class 3 and B31. l - a thru wall leak of below minimum wall condition does not automatically equate to an inoperable condition (i.e., analysis of flow and structural impact using LCO time as a marker)
Appendix R, EQ, electrical separation discrepancies versus operability:
Group 3 11 Qualification problems such as these generally not operability problems electrical separation problem does not necessarily call for associated equipment to be inoperable Appendix R equipment still operable but compensatory actions to deal with fire need to be taken operability an issue if accident causes failure and loss of emerge:icy function Timeliness of operability calls no new NRC regulations utility develops written policy; elements include:
- a.
prompt initial screen by knowledgeable group
- b.
timeliness commensurate with safety significance and plant conditions; tools:
PRA, LCO action statements
- c.
detailed evaluation to support initial screen decision within time bounds, e.g.,
3 days How should operabilitY £uidance be promulgated?
- 1.
'")
- 3.
- 4.
- 5.
NRC incorporate in inspection manual and by generic letter (in progress) 1\\LJMARC/INPO take initiative for industry guidance, e.g., NSAC (need next month) plant unique program with region buy in NUREG or regulatory guide for utility to construct program do nothing The group favors #2
12 MODIFICATION PROCESS INCLUDING 50.59 REVIEWS Group 1 Facilitators - P. K. Eapen (NRC), Nelson Tonet (DLC)
Utility participants: 6, NRC participants: 6 Discussion topics
- 1.
50.59 reviev.* process
- 2.
temporary modification process
- 3.
design change process
- reviewed strengths and weaknesses
- developed recommendations for improvement
- 1.
50.59 revie\\\\' process strengths NSAC 125 effective resource utilization weaknesses needs standards needs guidelines for results lacks consistent training required recommendations/comments good DBD, reduce potential for inadequate safety reviews impro\\'e NSAC 125 with samples of adequate/good evaluations for short term utility should develop standards individually enhance NRC inspector training
- 2.
temporary modification process strengths timely and effective utilization can help to keep*the plant safe provides more effective utilization of resources
Group 1 13 weaknesses can bypass modification process challenges configuration control reviews may lack detail can become numbers game recommendations/ comments better define maintenance vs mod upfront good DBDs needed to properly manage process
- 3.
design chan£e process strengths controlled process maintains DBDs controls plant configuration weaknesses process perceived as cumbersome potential AE or contractor interface problem daily plant support may detract potentially excessive reviews performed recommendations/comments Conclusions DBDs essential to be successful integrated living schedule provides for effective backlog control regulators/inspectors need better training to understand processes design change process continues to improve further training needed NSAC 125 enhancements could be beneficial effective screening is necessary integrated scheduling can provide more effective resource management
14 Group 2 Facilitators - Jim Linville (NRC), Bill Yaeger (Niagara Mohawk)
Industry participants: 7, NRC participants: 4 Strengths of 50.59 process there has been a significant improvement in safety as a result of the 50.59 process 50.59 process has improved greatly in the last few years. It is more substantial and better documented. Less perfunctory NSAC 125 and design basis reconstitution have contributed significantly to these improvements 50.59 process appears to work well for major modifications Major problem areas difficulty in applying 50.59 process to the modification process commensurate with the nature of the modification major modifications minor modifications temporary modifications (including electrical jumpers and lifted leads) generic modifications design equivalent changes non-safety related systems maximize safety minimize resource impact Recommendations for industrv I
clearly define modification categorie's and which parts of the review process are applicable in order to minimize resource impact develop screening process similar to that suggested in NSAC 125 establish well developed design basis establish generic processes to the extent possible Recommendations for NRC publish a position on the acceptability of NSAC 125 Establish clear staff guidance on application of position train NRC staff on application of guidance manage inspection and enforcement of guidance to provide consistent application with focus on potentially safety significant oversights
15 Group 3 Facilitators - Gene Kelly (NRC), Charles Cruse (BG&E)
- Industry participants: 10, NRC participants: 4 Strengths 50.59 gives flexibility to utility good 50.59 process helps clarify design basis 50.59 process gives engineering a better understanding of design basis 50.59 process fosters well documented and assessable design basis N.SAC 125 fills long standing void_
50.59 enables integrated multi-disciplinary review 50.59 process started early helps provide design framework Concerns/problems (in prioritized order) what is the safety analysis report (scope, detail, referenced documents) does 50.59 apply to as-found, design basis reconstitution "findings" "changes" - where do they end? How far should 50.59 be applied?
distinction between licensing and design bases threshold for "temporary" modifications distinction between safety related and important to safety (and definition of the latter)
NSAC 125 "in progress" change clarity 50.59 review of procedure changes scope/criteria for "screening "processes measures of 50.59/modification effectiveness Problem 1 - what is SAR?
recommendations provide guidance on whether emergency plan, environmental report, and like documents are part of the SAR management meeting between NRC and utilities (NUMARC) incorporate guidance in NSAC 125 delete items not important to safety from SAR add documents clarifying "licensing basis" to next SAR update (SERs, GL responses)
Problem 2 -
does 50.59 process apply to "as found" design problems (design basis reconstitution) 50.59 process does apply to "as found" design problems develop "tiger team" of small dedicated engineering/licensing group to address "as found" design problems - use screening process
Group 3 16 Problem 3 -
how far should 50.59 process be applied?
resolve problem 1 (SAR question) clarify need for 50.59 process procedure changes temporary mods long term equipment outages (silent mods) develop screening process provide training on screening criteria add step at end of mod process to perform self assessment of 50.59 process Conclusions NSAC 125 is a good start but it need additional clarity what is SAR temporary mods procedure changes in progress work definition of important to safety I