ML18107A506

Provides First Feedback from Observation of NRC Insp Under Pilot Nuclear Power Plant Insp Program.Attached Are Completed Insp Feedback Forms for Procedure 71111, Attachment 21 & Procedure 71151

ML18107A506
Person / Time
Site:	Salem
Issue date:	08/26/1999
From:	Tosch K NEW JERSEY, STATE OF
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18107A507	List: ML18107A506 ML18107A509 ML18107A512
References
NUDOCS 9909070053
Download: ML18107A506 (3)

Text

~hdc of ~cfn WcrSClJ Christine Todd Whitman Department of Environmental Protection Robert C. Shinn, Jr.

Governor Division of Environmental Safety, Health, Commissioner and Analytical Programs Radiation Protection Programs Bureau of Nuclear Engineering PO Box415 Trenton, New Jersey 08625-0415 Tel (609) 984-7700 August 26, 1999 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Ladies and Gentlemen:

Subject:

Pilot Plant Program Feedback

_ .* .. This letter

pt6vides. our first feedback!ioin observation of ari NRC inspection under the pilot nudear;po\ver;plarlt inspection program: We will*continue*tO provide you our feedback

• froni dthe~ in8pectid1i'6bsefVatlons as-:they*;ai-'e'developed."It is our intention to participate in 23 resident-and regional based N inspedfo'ns* at Artificial Island-prior to ovembet J 0, 1999. In -

addition, we will in~ependently review all Performance Indicators (PI) for Hope Creek and Salem, review and comment on Nuclear Energy Institute' s 99-02 PI guidance document, and review and comment on the Significance Determination Process.

Inspection Observed The New Jersey Department of Environmental Protection:r~cently observed an NRC at Region 1 team inspection the Salem Nucleaf Generating Station. The inspectio:c. follm.ved Attachment 21 of Pilot Procedure :71111, Safety** system Design and Performance Capability.

The same inspection team also performed a Performance Indicator Verification (Procedure 71151) of several indicators which we also observed. The inspection team was onsite from July 19 through 23, 1999 and from August 2 through 6, 1999.

Overall Assessment

_- * * -:The pi_iot process,: as ~~il as the-NRCeiifotcerrient 'r>rocess; relies heavily on a lice~see

~ainta'!nihg '~"effective" corrective actio~ prOgram (CAP);* It would seem appropriate that-the:

NRC: 1nsp~ct- the CAP* early:li:i the' pifot* program.* This is orie bf the :oniy inspections of a: li_censee process: ,It woiild lay the groun-d'\korkfor 'future iri'spectio'ns sirice;inost,if:not all, inspection-

procedures require some interface with the CAP. The NRC' s risk based inspection philosophy

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relies heavily on an effective CAP. In addition, iflicensees modify their CAP, it would seem appropriate that the NRC re-inspect this area since it may adversely impact the resolution of previously NRC-jdentified nonconformances.

Overall, we believe the level of effort utilized in these inspections was appropriate but it clearly was in excess of the man-hour estimates contained in the inspection procedures. These estimates appear unrealistic and do not take into account inspection options that are identified within the procedure. For example, the use of an inspector to review the operations area is an option in the engineering and design inspection but the man-hours for this individual are not included in the estimate within in the procedure. In addition, a two unit plant should take more resources than a one unit plant because the units may be similar but not 100% identical and it will take more time to perform system walkdowns, review differences in design bases, differences in modifications, differences in equipment performance etc. For two units, there are more opportunities to review modifications, tests and maintenance on a real time basis which we feel is a key component of the inspection.

The safety system inspection is focussed on plant systems in the mitigating cornerstone.

Supporting systems such as instrument and control air and ventilation systems are included on a limited basis in the inspection scope. Where in the inspection program would a thorough inspection of one of these support systems take place? Additionally, a system like Control Room ventilation supports mitigating systems in an indirect way, but it appears to be unlikely that it would be included in the scope of an Attachment 21 inspection.

Specific Comments Attached are our completed inspection feedback forms for Procedure 71111 Attachment 21 and Procedure 71151.

We appreciate the opportunity to provide our input and look forward to a continuing dialogue on the pilot process. If you have any questions, please contact Dennis Zannoni at (609) 984-7440. .

Sincerely, Kent Tosch, Manager Bureau of Nuclear Engineering

Distribution:

Jill Lipoti, Ph. D.

N.J.DEP Dennis Zannoni N.J.DEP R. Bores, Ph.D.

NRC Region I State Liaison Officer P. Milano NRC Project Manager D. Garchow PSE&G

. Gary Wright, Illinois Department of Nuclear Safety