ML18199A082
| ML18199A082 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/2018 |
| From: | Mark Miller Division of Inspection and Regional Support |
| To: | Horin W Winston & Strawn, LLP |
| Isom J, 415-1109 | |
| Shared Package | |
| ML18199A072 | List: |
| References | |
| Download: ML18199A082 (3) | |
Text
W. Horin UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 26, 2018 Mr. William A. Horin Winston & Strawn Counsel to the Nuclear Utility Group on Equipment Qualification 1700 K Street, N.W.
Washington, D.C. 20006-3817
SUBJECT:
RECEIPT OF COMMENTS FROM NUCLEAR UTILITY GROUP ON EQUIPMENT QUALIFICATION TO NRC DRAFT QUESTIONS AND ANSWERS REGARDING UNRESOLVED ISSUES RESULTING FROM DESIGN BASES ASSURANCE ENVIRONMENTAL QUALIFICATION PROGRAM INSPECTIONS Mr. Horin:
Thank you for your letter of June 29, 2018, to the U.S. Nuclear Regulatory Commission (NRC) from the Nuclear Utility Group on Equipment Qualification (NUGEQ) titled, Comments of The Nuclear Utility Group on Equipment Qualification on NRC Draft Questions and Answers Regarding Unresolved Issues in DBA EQ Program Inspections (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18199A080). Your letter was in response to the NRCs draft answers to equipment qualification (EQ) questions that were presented during a May 31st public meeting. NRCs document titled, Frequently Asked Questions Regarding Environmental Qualification of Electric Equipment, which was presented at that public meeting is available in ADAMS using Accession No. ML18145A072. I appreciate your comprehensive review of our draft answers.
The NRC has focused a great deal of attention on these important inspections and on the unresolved items (URIs) and questions that have resulted. As is the case in all of our decision-making, we value the perspectives of all affected internal and external stakeholders.
Accordingly, we plan to hold a public meeting with the NUGEQ on July 31, 2018 to continue the dialogue regarding these issues, consistent with the intent of your first recommendation.
Your second recommendation suggested that the Question and Answer (Q&A) list be supplemented to include the URIs that have been identified since the initiation of this effort.
NRC is tracking all URIs in this area and cross-referencing them to specific Q&As. As you may know, any potential performance deficiencies encountered during EQ inspections are referred to a panel of staff with regional, technical, procedural, and legal expertise (which meets bi-weekly),
to ensure consistency in inspection program implementation. The panel has been directed to suggest additional questions to the Q&A list when doubts exist as to the clarity of licensing bases or regulatory requirements for specific issues not covered by existing Q&As.
Your third recommendation suggested that training already conducted for NRC staff on the topics of EQ requirements and backfitting be promptly supplemented to allow for consideration of the material provided in your letter. We plan to fully consider your comments and the material you provided as we work toward finalizing the Q&As and resolving EQ issues. To the extent
W. Horin that NRC concludes that the material you have provided offers necessary or helpful enhancements to the training we have already conducted, the training will be updated and insights will be promulgated, as appropriate.
Your fourth recommendation suggested that the NRC not finalize as violations or performance deficiencies plant findings related to URIs until determinations are made as to the validity and applicability of those findings in light of the overall EQ licensing basis. Additionally, your letter specifically mentioned a recent inspection at Brunswick involving issues that were initially discussed as URIs but were later characterized as non-cited violations (NCVs). As previously discussed, NRC reviews all EQ-related issues by leveraging the expertise of a panel chartered and seated for that purpose. In the interest of meeting our safety responsibility, when NRCs internal reviews indicate that clear performance deficiencies exist, we will finalize these issues and communicate our conclusions to licensees, so that clarity exists on the need for corrective action. During the course of documentation and post-inspection review for Brunswick, which included the participation of the panel discussed above, the Brunswick inspection team determined that there was sufficient information and clarity to characterize the issues as NCVs.
Brunswick management was informed of the change during a subsequent exit meeting on June 21, 2018.
Your fifth recommendation suggested that EQ inspections be held in abeyance until the application of the Q&A process is resolved. The NRC will continue our oversight of this important area, as-planned, in accordance with the Reactor Oversight Process. Foremost in our decision-making on this point is confidence in our ability to identify the information necessary to characterize inspection issues appropriately (e.g., findings, violations, URIs). Additionally, we have seen safety benefits from the corrective actions planned or implemented as a result of our EQ-related findings.
We look forward to meeting with NUGEQ again on July 31 to discuss the Q&A comments contained in your June 29 letter and any comments you may have on our responses to your letters recommendations. We share with you the mutual goal of efficient and effective oversight of environmental qualification.
If you have any questions, please contact Thomas Hipschman by telephone at 301-415-1169 or by e-mail to Thomas.Hipschman@nrc.gov.
Sincerely,
/RA/
Mark S. Miller, Acting Director Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
W. Horin
SUBJECT:
RECEIPT OF COMMENTS FROM NUCLEAR UTILITY GROUP ON EQUIPMENT QUALIFICATION TO NRC DRAFT QUESTIONS AND ANSWERS REGARDING UNRESOLVED ISSUES RESULTING FROM DESIGN BASES ASSURANCE ENVIRONMENTAL QUALIFICATION PROGRAM INSPECTIONS DATED JULY 26, 2018 DISTRIBUTION:
THipschman, NRR JIsom, NRR RidsNrrDirsIrib RidsNrrDirs ADAMS Accession Number:
ML18199A072 (PK)
ML18199A080 (Incoming)
ML18199A082 (Letter)
OFFICE NRR/DIRS/IRIB NRR/DIRS/IRIB NRR/DE NRR/DIRS NAME JIsom THipschman EBenner MMiller DATE 07/ 25 /2018 07/ 25 /2018 07/ 25 /2018 07/ 26 /2018 OFFICIAL RECORD COPY