ML18107A509

Attachment 21 to Procedure 71111, Safety Sys Design & Performance Capability.

ML18107A509
Person / Time
Site:	Salem
Issue date:	08/23/1999
From:	NEW JERSEY, STATE OF
To:
Shared Package
ML18107A507	List: ML18107A506 ML18107A509 ML18107A512
References
71111, NUDOCS 9909070057
Download: ML18107A509 (2)

Text

INSPECTION PROCEDURE COMMENT FORM Inspection. P~cedure No.: 7/ 1, \ I* A achment No.: L i

Title:

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• Inspection Repo No: _ _ _ _ _ _ ___;...._ _ Inspection Type: RE\side11t/DRS!Team .

Plant Name: Scdero Region: I Date(s}: 7/1q-Z3 /9'? * *

'f5'/2 - (o I c; er Address the following statements using the following rating scale: 1= Disagree, 2= Moderately Disagree, 3= Neutral, 4= Moderately Agree, S=Agree. Please identify errors and inconsistencies in the procedure and provide comments and suggestions for improving the procedure,

1. The level of effort required for the inspection was consistent with that _ Disagcj)z 3 4 5 Agree in the IP. If not, what is the appropriate level of effort and basis for IP revision?

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2. The procedure met the inspection objectives. Disagree 1 2@4 SAgree If applicable, describe how the procedure (or how it was implemented) failed to meet the inspection objectives .

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3. The inspection requirements were appropriate based on risk. Disagree 1. 2 f) 5 Agree What inspection requirements should be added, deleted or revised based on risk? Based on implementing the Significance Determination Process for inspection findings, how should the inspection requirements be revised to better identify. risk significant findings?

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4. The inspection procedure was clear and easy to use. If not, how Disagree 1(§) 4 5 Agree should the inspection guidance be revised to better clarify the inspection requirements?

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5. The IP does not result in an unreasonable impact on licensees. Disagree 12 3 4@)gree How should the IP be revised to preclude unreasonable licensee impact?

Figure 4.2 - Inspection Procedure Comment Form 9.

9909070057 990826 PDR ADOCK 05000272 G PDR

INSPECTION PROCEDURE 71111 Attachment 21 COMMENTS

1. Level of effort needed for a two unit plant is more than for a one unit plant. The manpower estimate should reflect this. Utilizing an operations area inspector exceeds the estimate as well. The manpower estimate should be a range of hours because of these variables.

2a The procedure utilizes a sampling of work products. It does not direct the inspector to examine processes or interfaces. As more and more emphasis is placed on cost reduction and efficiency, drastic streamlining of processes seems likely. It would seem appropriate to evaluate, to some extent, engineering and design processes that undergo this type of change rather than wait for deficiencies to show up in installed equipment.

2b In recent years, a point of emphasis in NRC inspections was the accuracy of and compliance with the Updated Final Safety Analysis Report. The pilot inspections seem to not have this same emphasis. It is not specifically addressed in the inspection procedure.

3. The scope of the inspection is predicated on an accurate risk ranking of mitigation systems. It is not clear how support systems are considered, whether they are included in the ranking, and whether they would ever be subject to an Attachment 21 inspection.

4. The interface of Attachment 21 with the Corrective Action Program Inspection Procedure, needs to be strengthened. It is not clear as to what action an inspector takes when the licensee fails to enter identified non-conformances into the Corrective. Action Process, or enters then in an untimely manner.