ML19354D959
| ML19354D959 | |
| Person / Time | |
|---|---|
| Issue date: | 01/18/1990 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Lanning W Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9001250075 | |
| Download: ML19354D959 (3) | |
Text
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MEMORANDUM FOR: Wayne D. Lanning, Chief, Special Inspections Branch Division of Reactor Intpections and Safeguards, Office of Nuclear Reactor Regulation FROM:
Hubert J. Miller, Director, Division of Reactor Safety I
SUBJECT:
COMMENTS ON DRAFT NRC INSPECTION PROCEDURE 93801 - SAFETY l
SYSTEM FUNCTIONAL INSPECTION As requested by Mr. E. J. Butcher's memorandum of December 1,:1989, same-subject, we have reviewed the proposed inspection procedure. Our specific comments are attached.
As a general comment, we feed that the inspection duration can be reduced to six weeks without compromising the effectiveness of this inspection.
4 If you have any questions regarding our comments, please contact l-Mr. M. Phillips of my staff at FTS:
308-5530.
T. O. Martin for j
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Hubert J. Miller, Director.
-1 Division of Reactor Safety-
Attachment:
As stated cc w/ attachment:
T. T. Martin, RI J. L. Milhoan, RII-J J. M. Montgomery, RIV B. H. Faulkenberry, RV i
F. Gillespie, PMAS, NRR F. Miraglia -DRSP, NRR D. M. Crutchfield, DLPQ, NRR i
M. Peranich, ILPB, NRR E. J. Butcher, ILPB, NRR H. Krug ILPB, NRR
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SPECIFIC C0lEENTS ON DRAFT INSPECTION PROCEDURE 93801 1
SAFETY SYSTEM FUNCTIONAL INSPECTION (SSFI) l 1.
Page 5, Section 02-02.3, items 1 and 3: These two items should be-j deleted as specified. We do not feed that a six month review of on-site 1
and off-site review committee meeting minutes will provide useful _
J information to the inspection team.
Similarly, we feel it would be more important to ascertain the knowledge level of personnel conducting the audits on the system rather than general QA personnel background of quality assurance and quality control personnel.
2.
Page 5, Section 02-02.3, item 4: This item should either be expanded to ensure that the information is collected at an early time during the inspection and provided to the appropriate team merbers (for example,
' maintenance work request trends to the maintenance inspector, operational performance trends to the operations inspector, etc.) for their.use, or the item should be deleted, and these important functions specified for each of the operations, maintenance, and surveillance ~and testing sections.
3.
Page 5, Section 02-02.e. item 5: This item should be clarified to clearly indicate that the licensees quality verification program-is to-be evaluated by. comparing the results of audits, surveillances,-or other verification activities performed by the licensee with the'results of the team for the same areas. This could be stated as " Compare the results of the teams assessment of the areas inspected for the selected system with the results of applicable licensee quality verification activities in the same areas (i.e., operations, maintenance, surveillance and testing, engineering design, and design control). :In cases where the same findings exist, determine why they have not been corrected.
In cases where the team found conditions which were missed by the licensee, determine why the licensee's quality verification activities were:not
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capable of finding these issues."
4.
Page 12, Section 93801-04: Based on prior performance, we feel that the inspection schedule can be shortened as noted below without compromising i
the effectiveness of the inspection and thereby freeing up some of the required resources to conduct this inspection:
,p Week 1 - Plant visit by team leader to collect necessary background information and relay expectations to licensee for remainder of inspection. Team leader copias, collates, and distributes background information to all team niembers.
Week 2 - Entrance meeting for design phase of inspection at the best l_
location, either site or corporate, to have access to licensee's i
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knowledgeable engineers and to review modification packages and calculations. The remainder of the inspection team memb2rs begin in-office inspection preparation.
I Week 3 - In-office review of design, inspection work.
Briefings on the preliminary concerns of.the engineering design team are performed this week.
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Week 4 - Entrance meeting at site. On-site inspection for all team nembers,. including design inspectors.
Week 5 - In-office review of inspection documentation and internal NRC management briefings on preliminary inspection findings and-potential operational issues..No on-site or corporate inspection activities.
This: period allows the licensee time to review the outstanding concerns and questions identified during.
the first two weeks of inspection, and allows the team time to develop and refine issues to be inspected during the last week-of.on-site activities.
Week 6 - The entire inspection team, including design inspectors,
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returns on-site.for one week to conplete the inspection and fol. low-up on the cutstanding issues and concerns.- The pre-exit rehearsal is conducted late Thursday afternoon-with the
. participation of.NRC management representatives..The exit-meeting is held on Friday morning..
i 5.
Page 13, Section 93801-01: The title should:be changed to'"Additianal.
Inspection Guidance." In addition, a discussion should be added regarding the use of this inspection activity in lieu.of certa h required core modules (namely, 37700,61726,62703,71707,and.71710).
In those cases where this module is utilized, credit by reference for these core modules should be made into the applicable facilities Mastcr Inspection-Plan (MIP).-
6.
Page 13. Additional, reference guidance caii be provided,by utilizing the i
appropriate owners' group Emergency Response Guidelines tutilized in E0P l
development) to provide information on assumed system response.
7.
-Page 13. Although used throughout the procedure, some definition or guidance should be provided for the term " licensing basis," which may be subject to multiple interpretations.
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