ML18351A118
| ML18351A118 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2019 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18351A118 (3) | |
Text
1 Inspection Procedure Assessment Summary and Outline of Proposed Changes Inspection Procedure (IP):
71111.21M, Design Bases Assurance (Team) 71111.21N, Design Bases Assurance (Program)
Inspection Procedure Lead: Jim Isom Estimated Hours to Complete Review: 12 Date Review Completed: 11/27/2018
- 1. Results and assessment of review of IMC 308, ROP basis document review The basis for performing these (IP 71111.21M and -.21N) inspections, that is to verify that structures, systems, and components (SSCs) can still perform its design function, remain unchanged. However, based on the recent recommendations to improve the ROP suite of engineering inspections (see SECY-18-0113 (ML18144A567)), which includes IPs 71111.21M and -.21N, the emphasis of IP 71111.21M will be on changes (hardware, procedural and maintenance) which have been made to the SSCs since the last inspection.
Additionally, IP 71111.21N will introduce new engineering areas for inspection and these inspections associated with IP 71111.21N will be referred to as focused engineering inspections.
Therefore, the basis section associated with IP 71111.21M in Inspection Manual Chapter (IMC) 0308, Attachment 2, should be revised to reflect the change in inspection scope emphasis for IP 71111.21M and also to recognize implementation of IP 71111.21N, which allowed inspection of engineering areas previously not inspected in the ROP baseline inspections.
- 2. Results and assessment of review of any applicable changes to PIs There are no PIs associated with these two engineering inspections.
- 3. Results and assessment of review of any applicable changes to Rules or STSs There were no new regulations or applicable changes to STSs which impacted either IP 71111.21M or 71111.21N.
- 4. Results and assessment of review of recent Operating Experience Commercial grade dedication and emergency diesel generator problems were identified as having a potential impact on SSC operability through review of recent (past three to five years) Operating Experience data completed by DIRS Operating Experience Branch.
- 5. Results and assessment of review based on RRPS data (see separate IP 71130.11 Assessment Data file for details of RRPS data)
Adverse trends or outliers noted: No
2 RRPS data show a constant range (average of 87) of inspection findings being identified by inspectors during CYs 2014, 2015 and 2016. All findings are inspector identified.
CY 2014 Findings CY 2015 Findings CY 2016 Findings CY 2017 Findings IP 71111.21/
- 79
- 97
- 82
- 48 IP 71111.21N N/A N/A 5
27 Number of findings were obtained by summing the number of Green and No Color findings for each year. CY 2015 and CY 2016 data includes findings from pilot CDBI (IP 71111.21M) and EQ (IP 71111.21N) inspections. IP 7111.21 was bifurcated into IP 71111.21M and 71111.21N starting in CY 2017. Additionally, the level of effort (DIE inspection hours) for IP 71111.21M was reduced from three weeks to two weeks onsite starting in CY 2017.
There is a reduction in the number of inspection findings for IP 71111.21M starting in CY 2017 due to the reduction in inspection resources being applied to this IP. The resources removed from IP 71111.21M was applied to a new inspection procedure, IP 71111.21N starting in CY 2017. There was a slight reduction in the number of inspection findings from an average of 87 inspection findings per year (average of CY 2014 through 2016 years) for IP 71111.21 to 75 inspection findings in CY 2017 resulting from IPs 71111.21M and 71111.21N.
- 6. Feedback Forms There are currently six feedback forms open (two with IP 71111.21, one with IP 71111.21M and three with IP 71111.21N).
- 7. Other Considerations NRR DIRS management and staff forwarded their recommendations to improve the effectiveness and efficiency of engineering inspections within the ROP in SECY-18-0133.
Recommendations to improve IPs 71111.21M and 71111.21N are described in this SECY.
- 8. Results of discussions with regions All Regions have concurred on SECY-18-0113.
Recommendations NRR DIRS management and staff made recommendations to improve the structure, scope and periodicity of IP 71111.21M and 71111.21N. These specific recommendations and the basis for these recommended changes are described in SECY-18-0013. Specifically, the SECY recommends creation of a new engineering inspection titled Comprehensive Engineering Team Inspection (CETI) to replace the current Design Bases Assurance (DBA) inspection - Team.
3 The new CETI inspection will retain the inspection procedure number, 71111.21M, associated with DBA inspection. Additionally, DIRS staff plans to develop new focused engineering inspections to replace the current environmental qualification inspection being conducted using IP 71111.21N.