ML19183A063
| ML19183A063 | |
| Person / Time | |
|---|---|
| Issue date: | 08/09/2019 |
| From: | Chris Miller Division of Inspection and Regional Support |
| To: | Ho Nieh Office of Nuclear Reactor Regulation |
| Bollock D, 415-6609, NRR/DIRS | |
| References | |
| Download: ML19183A063 (4) | |
Text
August 9, 2019 MEMORANDUM TO:
Ho K. Nieh, Director Office of Nuclear Reactor Regulation THRU:
Eric J. Benner, Director /RA Brian Smith for/
Division of Engineering Office of Nuclear Reactor Regulation FROM:
Christopher G. Miller, Director /RA Shakur Walker for/
Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
SUBJECT:
PROGRAMMATIC LESSONS LEARNED FROM ENVIRONMENTAL QUALIFICATION INSPECTIONS The Nuclear Regulatory Commission (NRC) staff has developed lessons learned from its implementation of Inspection Procedure (IP) 71111.21N, Design Bases Assurance Inspection (Programs). Attachment 1 to IP 71111.21N, Environmental Qualification (EQ) under 10 CFR 50.49 Programs, Processes, and Procedures, was implemented in the current inspection cycle that began in January 2017. The lessons learned and actions discussed below were developed based on input received from licensees, Office of Nuclear Reactor Regulation (NRR) staff, and staff in all four regions. The staff will use this information in the development and implementation of future attachments to IP 71111.21N which will replace EQ inspections in future inspection cycles. Additional lessons learned specific to the topic of EQ itself, including changes to the standard review plan, regulatory guides and vendor inspection activities are being developed separately by the Division of Engineering, NRR.
Overall, the EQ inspections have improved safety by identifying current deficiencies in licensee programs. Nevertheless, stakeholders in this process, including NRC inspectors, NRC management, and licensees, discovered several inconsistencies regarding how Attachment 1 to IP 71111.21N was implemented. These inconsistencies were caused by several factors including the following:
The inspection procedure did not provide inspectors with sufficient background guidance regarding the complicated regulatory basis for the EQ programs at licensee sites.
Inspectors had difficulty interpreting each plants unique EQ licensing basis. As a result, inspectors were at times unable to confirm whether certain aspects of licensee EQ programs were acceptable.
Communication between inspectors and the technical program office during inspection activities at times was insufficient and/or untimely. This shortcoming prevented timely CONTACT: Douglas R. Bollock, NRR/DIRS (301) 415-6609
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resolution of some issues during the inspection process. There were no definitive points of contact identified with whom inspectors could discuss technical and implementation issues regarding the EQ inspections.
The minor, more-than-minor screening criteria contained in current NRC guidance were not adequate to assess EQ-related issues in all cases.
Lack of external communication of the inspection procedure basis and scope led to some licensee confusion during inspections. Several licensees also had concerns that inspectors were examining EQ program areas that had previously been accepted by the NRC and were outside of the planned inspection effort.
Not all inspectors were afforded the opportunity to take EQ technical training prior to inspection implementation.
The staff did not develop training on EQ inspection procedure implementation.
Some of these inconsistencies led to several unresolved items being identified during the EQ inspection process. As a result, the NRC established the EQ working group. The working group consisted of representatives from each NRC Region, the Office of New Reactors (NRO)
Quality and Vendor Inspection Branch, the NRR Division of Engineering, the Office of Nuclear Regulatory Research, and the NRR Division of Inspection and Regional Support. The working group met routinely to address findings identified by the inspectors Finding Review Panels.
The NRC staff routinely met with industry representatives (e.g., the Nuclear Utility Group on Equipment Qualification (NUGEQ)) to address the inconsistencies and ensure a more consistent, repeatable, and transparent implementation of EQ inspections and resolution of issues. As a result of these collaborative efforts, the NRC staff updated the EQ inspection procedure and technical training material and developed guidance for the EQ engineering inspections.
Future 71111.21N inspection procedure attachments will focus on additional engineering topics.
These attachments will incorporate the lessons learned from the EQ inspections, such as:
- 1) Inspection procedures directly align with applicable regulations and accepted industry standards and incorporate risk-informed decision-making considerations. The inspection procedures will recognize that individual plants may have different licensing bases for implementing engineering programs.
- 2) Identification of technical and programmatic points-of-contact. Consider a senior executive service (SES) champion for the overall inspection and training effort, depending on its scope.
- 3) Consider adding minor/more-than-minor examples to the inspection procedures/inspection manual chapter.
- 4) Training for the inspectors and inspection team leaders for future IP71111.21N attachments should include:
- a. Technical training on the specific area,
- b. General history of licensing basis and regulations of the inspection area,
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- c. Implementation of inspections,
- d. Consider providing examples of minor and more-than-minor findings and violations, and guidance on how to properly and consistently process inspection findings using the SDP; particularly in a complicated or new inspection area.
- 5) Use the knowledge management website to include relevant historical documentation and any applicable reference material.
- 6) Prior to implementation of new inspections, staff will consider holding tabletop exercises with regional inspectors and managers to run through scenarios that could occur during inspections and uncover those which could lead to inconsistencies in implementation.
- 7) Use Findings Review Panels for the first few months of the procedure implementation to ensure consistent and accurate disposition of findings across the regions. Any lessons learned through the review panels will allow for adjustments to the inspection procedure and training materials (i.e., minor/more-than-minor examples). The need to continue the review panels will be evaluated periodically.
The staff will also consider the following when developing any new inspection procedures:
- 1) Develop a communication strategy for internal and external communications of the inspection bases and scope to address any questions that may arise. Consider holding meetings with industry prior to and during inspection procedure development.
- 2) Develop standardized, procedure-specific lists for use in requests for information.
Emphasize two-way communication with the licensee to efficiently obtain the information needed to implement the inspection. Focus on the pertinent information needed to decrease time spent by inspectors in determining inspection samples and avoid overly burdening the licensee staff.
- 3) Consider measures to increase consistency across the Regions and agency through activities such as:
- a. Coordination with the technical lead to provide support for each inspection.
- b. Provide greater technical and programmatic support for the initial inspections in each Region.
- c. Increase cross-regional inspection participation to enhance dissemination of best practices and to help with consistency in inspection implementation.
- d. Conduct an initial assessment of implementation following the first few inspections.
- 4) Development of a lessons-learned document should be considered following each inspection cycle.
- 5) Consider the engineering inspections as a focused ROP assessment topic for the annual assessments.
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SUBJECT:
PROGRAMMATIC LESSONS LEARNED FROM ENVIRONMENTAL QUALIFICATION INSPECTIONS DISTRIBUTION:
RidsNrrDirs RidsNrrDe RidsNrrOd ADAMS Accession Number: ML19183A063 OFFICE DIRS/IRIB*
DIRS/IRIB NRR/DIRS NRR/DE NAME DBollock THipschman CMiller (SWalker for)
EBenner (BSmith for)
DATE 6/27/19 7/9/19 8/6/19 8/9/19 OFFICIAL RECORD COPY