ML20024G924

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Meeting Summary of Region I Engineering Symposium/Workshop M91-048 on 910220-21 in King of Prussia,Pa.Topics Discussed: Elements of Good Engineering Organization & Mod Process, Including 10CFR50.59 Reviews.List of Attendees Encl
ML20024G924
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 04/15/1991
From: Eapen P, Lopez A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20024G922 List:
References
M91-048-05, M91-48-5, NUDOCS 9105020133
Download: ML20024G924 (64)
v • d • e


Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No.

M91-048 Docket Nos. As listed in Attachment 1 License Nos. As listed in Attachment 1 Licensee:

As listed in Attachment 1

Participants:

As listed in Attachment 1 Meeting At: Sheraton Vallev Forge. King of Prussia. Pennsylvania Meeting Conducted: February 20 - 21.1991

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Prepared by:

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A A. E Lopez, Reactor Engineer,' Systems Section, date' m

Engineering Branch, DRS Approved by:

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Dr. P. K. Eapen, Chief, Systems Section,

'dse Engineering Branch, DRS Meeting Summary: The Engineering Symposium / Workshop was held to promote an open discussion of various industry topics. The meeting was attended by NRC, licensee, and other industry personnel. The topics discussed were: (1) Elements of a good engineering organization; (2) Licensee's actions with degraded conditions, including operability /reportability determinations and (3) The modification process including 10CFR 50.59 reviews. The symposium conclusions recommended six action items for the NRC and seven action items for the industry.

9105020133 910417 PDR ADOCK 05000213

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Region 1 Meetine Report M91-048 Table of Contents PlEt 1.0 Purpose 3

2.0 General Overview 3

3.0 Summary of Workshop Group 4

Presentations 4.0 Conclusion 6 - List of Attendees - Meeting Agenda - Speakers Slide Presentation

t. - Workshop Group Summaries i

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1.0 Purpose The Engineering Symposium / Workshop was designed to promote discussion and a better understanding between the utility engineering personnel and the NRC staff regarding the engineering departments role in support of plant activities.

2.0 General Overview The Engineering Symposium was conducted on February 20 - 21,1991, as published in the Federal Register Notice dated January 24,1991. Attachment 1 presents the list of persons who attended the symposium. An agenda of the symposium is provided in.

The Engineering Symposium began with a Call to Assembly, an Introduction, and a Welcome. Mr. J. H. Sniczek, NRC Deputy Executive Director for Operations, and 1

Mr. E. J. Mroczka, Northeast Utilities Senior Vice President of Nuclear Engineering and Operations then addressed the symposium. Both hir. Sniczek and Mr. Mroczka eloquently discussed the theme of the symposium, "The Engineering Role in Plant Support." They provided an excellent basis for promoting open discussion during the symposium. Attachment 3 contains the slides presented by the keynote speakers.

The afternoon concluded with the attendees participating in the first of two planned workshop sessions. The participants were assigned to one of the workshop groups.

Two groups discussed the elements of a good engineering organization; three groups discussed the licensee's actions with degraded conditions including operability /reportability determinations; and three groups discussed the modification process including 10CFR 50.59 reviews. Each workshop group was lead by two facilitators, one each from the NRC and a licensee, and had approximately 15 - 25 participants.

The participants returned the next morning to the same workshop group as the day before for approximately two hours to fmalize discussions and to develop recommendations.

At 10:30 a.m. on February 21,1991, a speaker, Mr. M. R. Trester, Diablo Canyon Engineering Manager, Pacific Gas and Electric Company, and Chairman of Region V Engineering Managers' Forum addressed the symposium. Mr. Trester discussed the experiences at the Region V Engineering Managers' Forum. The slides from Mr.

Trester's presentation can be found in Attachment 3.

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4 In the afternoon, the facilitators from each of the eight workshop groups presented a summary of the their groups discussions and co.wlusions. Attachment 4 contains slides from the facilitators presentations. The facilitators presentations were then followed by two wrap-up speakers and closing remarks by Mr. M.W. Hodges, NRC Director of the Division of Reactor Safety for Region 1. The symposium adjourned at 4:20 p.m.

3.0 Summary of Workshor Groun Presentations A.

Elements of a nood engineering organization i

The two work groups on this subject concluded the following:

1.

There is no single universal engineering organizational structure that is best for all plants.

2.

A good engineering organization must:

a.

prioritize its activiti:s from a safety perspective and establish clear lines of responsibility and accountability b.

be responsive to the needs of its customer (operations, maintenance.....)

c.

maintain a well qualified and trained staff d.

maintain a high quality interface with the NRC These working groups did not recommend specific actions for the NRC or the industry groups.

B.

Licensee's actions with degraded conditions including onerabilitv/renortability determinations The three working groups on this subject concluded the following:

1.

Concerns lack of well defined concepts and terms for operability a.

b.

lack of well defined processes for operability determination lack of adequate guidance for the use of engineering judgement c.

in operability determinations

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5 d.

lack of adequate guidance for reportability 2.

Recommendations a.

NRC establish consistent guidance on operability and reportability (NRC Action item 1) b.

Industry develop design basis standards with NRC endorsement (NRC Action Item 2, Industry Action Item 1) c.

Industry establish guidelines for the timeliness for operability determinations with NRC endorsement (NRC Action item 3, Industry Action Item 2) d.

NRC and Industry train their respective personnel in the use of the above guidance (NRC Action Itrm 4, Industry Action Item 3)

C.

The modi 6 cation process including 10CFR 50.59 reviews The three working groups on this subject concluded the following:

1.

the modification process including the 50.59 process has been consistently improving 2.

NSAC 105 and NSAC 125 are good industry standards to provide guidance in the design process and the 50.59 review process, respectively Weaknesses 1.

design change process is cumbersome 2.

temporary modifications may be bypassing the modification process 3.

design bases are not adequately defined 4.

control of contracted modification work is not adequate l

5, inadequate prioritization and control of backlog I

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6 Recomalendvions 1.

NRC and Industry train their respective personnel in the modincation process (NRC Action item 4, Industry Action item 3) 2.

Licensee establish clearly developed design basis docements for each unit using NRC endorsed standards (industry Action item 4) 3.

Industry define categories of modification with NRC cndorsement (NRC Action item 5, Industry Action item 5) 4.

Industry improve NSAC 125 to provide examples of good 50.59 reviews (Industry Action item 6) 5.

NRC endorse NSAC 125 for 50.59 review (NRC Action ! tem 6) 6.

Industry establish measures based on safety to prioritize and control backlog of engineering projects (Industry Action item 7) 4.0 Conclusion The symposium had good participation from all its attendees. The majority of the feedback forms received, indicated that the symposium achieved its goals, and promoted and stimulated open discussion between the NRC and the industry. The feedback also encouraged future symposiums in.the engineering area. A small minority of participants did not fully agree with all the conclusions of the symposium and they provided alternate conclusions.

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9 ATTACHMENT 1 l

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l LIST OF ATTENDEES l

A.

Englon I Licensees klQEDJE D_QQEET__f L191NER_f ATTJNDEES 1.

BG&E S0-317 DPR-53 Charles Cruso 50-318 DPR-69 Peter Katz Robert Waskoy 2.

Boston Edison 50-293 DPR-35 Robert Fairbank Edward Kraft 3.

Conn. Yankee 50-213 DPR-61 Clint Gladding Atomic Power Company 4.

Consolidated 50-247 DPR-26 Joe Bahr Edison Co.

John Curr of NY Mike Lee Peto Szabados 5.

Duquesne Light 50-334 DFR-66 Kenneth E.

Halliday company 50-412 CPPR-105 Helson R.

Tonet 6.

GPU Nuclear 50-219 DPR-16 Jim Byrne Dave Distet Greg Gurican William Heysek James W. Langonbach Max Nelson Ed O'Connor I.rt Rono Richard Skillman Patrick Walsh 7.

Long Island 50-322 NPF-19 Ed Pierpont Lighting Co.

8.

Niagara Mohawk 50-220 DPR-63 Michael Carson Power Corp.

50-410 NPF-S4 Gregory Gresack Rob Oleck Bill Yaeger 9.

Northeast Nuclear 50-245 DPR-21 Michael Bigiarelli Er. orgy Company 50-336 DPR-65 Brendan J. Duffy 50-423 NPF-49 G. Leonard Johnoon John S. Keenan Edward J. Mroczka R. L. McGuinness C.

Fred Seara

10. PP&L 50-387 NPF-14 Bob Byram 50-388 NPF-22 F. G. Butler W.

H. Gulliver J.

M. Kenny George Kuczynski G.

D. Miller D.

P.

Parsens i

L.IEENDJJ EQEf&T l LICENSE 1 ATTJEDEER

11. PECO 50-352 NPF-39 Jim Basilio 50-353 CPPR-107 William Bloomfield Wes Bowers Frank Cook Jack Evans Al Fulvio David Foss Cliff Harmon Dave Helwig Frank Hunt Marilyn Kray Rod Krich G.

Kernahan Dave Meyers Lou Pyrah David Schra Glen Stewart Kevin Walsh

12. Power Authority 50-333 DPR-59 Jerry Gullick of State of NY Terry Herrmann Gus Mavrikis Steve Smith Vic Walz
13. Public Service 90-443 CPPR-135 Terry Harpster of Nil 50-444 CPPR-136 Joe Vargas
14. PSE&G 50-272 DPR-70 Richard Dashall 50-311 DPR-75 Raymond Brown Moises Burzstein Thomas M. Crimmins Scott Gillespie Lee Griffis Bruce Hall Michael Morroni I

Bruce Preston l

Martin E.

Raps i

John P.

Ronafalvy Frank Thomson

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). 5. Vermont Yankee 30-271 DDR-28 Mark Palionis Nuclear Power Corp Dean Porter

16. Yankee Atomic 50-029 DPR-3 Peter Anderson Electric Co.

John Hoffman l

William Jones Dave King Robert Shone George Tsouberous

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Licensees From other NRC Recions LICENSEE bTTENpf48 L

Florida' Power Bill Skelley and Light 2.

Toledo Edison Vernon Watson l

C.

Other Participants OTHEB ATIENDEES 1.

Bechtel Nancy Chapman Steve Routh David Schmit 2.

Westinghouse Rick Eastering 3.

Tenera John Elliott 4.

Massachusetts James McKerheide Nuclear Engineer 5.

General Electric Lee Lantz Nuclear Energy 6.

Stone & Webster Ajoy Banerjee Thomas Bates l

Marc Boothby i

Alan Chan Tim Chitester Louis Hirst l

E.

J. Hubner Tom Szabo 7.

NUS Corp - Florida Michael 'ohnson Peter S.

Jordan l

Eric R. Smith

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Thn,Juclear -Recrulatory commissioD

.o OJFICE AT_T_ENDEEE 1.

HQ Bob Capra 2.

HQ Jin Chung 3.

HQ Dick Clark 4.

HQ Al DeAgazlo 5.

HQ Richard L.

Emch 6.

HQ Mort Fairtile 7.

HQ Bagchi Goutam 8.

HQ Craig C. Harbuck 9.

HQ Gary D. Holahan

10. HQ Chris L. Hoxie
11. HQ Eugene Imbro
12. HQ Jeff Jacobson
13. HQ Wayne Lanning
14. HQ Erasmia Lois
15. HQ Dan Mcdonald
16. HQ James G.

Partlow

17. HQ Uldis Potapovs
18. HQ Mark F.

Reinhart

19. HQ Jim Sniezek
20. HQ John Stolz
21. HQ David L.

Wiggington 1.

RII Caudle H. Julian 2.

RII Francis Jape 3.

RIII Mark Ring

4. RIV Johns Jaudon 1.

RI Scott Barber 2.

RI Walter Baunack i

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RI Lee Bettenhausen 4.

RI Norman Blumberg 5.

RI Fred Bower 6.

RI Suresh K. Chaudhary 7.

RI Rich Conte t

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RI Larry Doerflein 9.

RI Jacque P.

Durr 10 RI P.K.

Eapen

11. RI Harold Eichenholz
12. RI Pete Esclgroth
13. RI E.

Harold Gray i

14. RI Harold I. Gregg
15. RI Peter Habighorst
16. RI Sam Hansell
17. RI Donald Haverkamp
18. RI Tom Hiltz
19. RI M.

Wayne Hodges

20. RI Kerry Ihnen
21. RI Jon Johnson
22. RI Herbert Kaplan
23. RI Paul Kaufman
24. RI Gene Kelly
25. RI James C.

Linville

26. RI Al Lohmeier
27. RI Thomas T.

Martin

28. RI Marie Miller

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29. RI Dan Moy
30. RI George Napuda-- retired
31. RI William Oliveira
32. RI Steve Pindale
33. RI Len Prividy
34. RI John Pogge
35. RI Glenn Tracy
36. RI Ed Wenzinger
37. RI Barry Westreich
38. RI Peter Wilson l

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ATTACHMENT 2 l

Symposium / Workshop Engineering's Role In Support of Plant Activities AGENDA Wednesday. February 20. 1991 12:00 - 12:50 p.m.

Registration 12:50 - 1:00 p.m.

Call to Assembly Harold I. Gregg Senior Reactor Engineer Division of Reactor Safety, RI 1:00 - 1:05 p.m.

Introduction M. Wayne Hodges Director Division of Reactor Safety, RI 1:05 - 1:15 p.m.

Welcome Thomas T. Martin Regional Administrator, RI 1:15 - 1:55 p.m.

Keynote Speaker James H. Sniezek 4

Deputy Executive Director for Operations, NRC 1:55 - 2:35 p.m.

Keynote Speaker Edward J. Mroczka Sr. Vice President Nuclear Engineering and Operations Northeast Utilities 2:35 - 3:00 p.m.

Break 3:00 - 5:00 p.m.

Breakout Sessions Toolc Room Locatio.n A.

Elements of a Good Engineering Berwyn Room or Organization Devon Room B.

Licensee's Actions With GladWyne Room, Degraded Conditions Bryn Mawr Room, or Including Operability /

Hemlock Room Reportability Determinations C.

The Modification Process Radnor Room, Including 10CFR50.59 Reviews Merion Room, or Quaker Room

Thursday, Febrtiary 21, 1991 8:00 - 10:00 a.m.

Breakout Sessions - Refinement of most significant issues Topiq Rocm Location A.

Elements of a Good Engineering Berwyn Room or Organization Devon Room B.

Licensee's Actions With Gladwyne Room, Degraded Conditions Bryn Mawr Room, or Including operability /

Hemlock Room-Reportability Determinations C.

The Modification Process Radnor Room, Including 1GCFR50.59 Revie'is Merion Room, or Keystone Room 10:00 - 10:30 a.m.

Break 10:30 - 11:30 a.m.

Speaker Michael R. Tresler Engineering Manager, Diablo Canyon Pacific Gas and Electric Company Chairman of Region V Engineering Managers Forum 11:30 - 1:00 p.m.

Lunch 1:00 - 2:15 p.m.

First Group Breakout Session Facilitators Summery Feedback 2:15 - 2:30 p.m.

Break 2:30 - 3:15 p.m.

Sr.cond Group Breakout Session Facilitators Sammary Feedback 3:15 - 3:35 p.m.

Wrap-up David R. Helwig Vice President Nuclear Engineering and Services Philadelphia Electric Company 3:35 - 3:55 p.m.

Wrap-up Jacque P.

Durr Chief, Engineering Branch Division of Reactor Safety, RI 3:55 - 4:15 p.m.

Closing Remarks M. Wayne Hodges Director Division of Reactor Safety, RI

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ATTACHMENT 3

JAMES H. SNIEZEK DEPUTY EXECUTIVE DIRECTOR FOR OPERATIONS, NRC i

PRESENTATION FOR NRC REGION I - UTILITY SYMPOSIUM / WORKSHOP Engineering's Role in Plant Support February 20-21,1991 Sheraton Valley Forge Ilotel King of Prussia, Pennsylvania i

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IMPROVEMENT OF OPERATIONAL SAFC'!

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INSPECTION PRINCIPLES l

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INSPECTORS NEED TO ALWAYS BE ALERT FOR SAFETY ISSUES -- EVEN THOSE i

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DEGREE OF REACTION / RESPONSE BY INSPECTORS DICTATED BY SAFETY IMPORTANCE ACCEPTANCE CRITERIA ARE BASED ON AGENCYWIDE POSITIONS, NOT ON s

INDIVIDUAL REVIEWER / INSPECTOR DESIRES l

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i INSPECTION PRINCIPLES PERFORMANCE INDICATORS ARE USED TO HELP DETERMINE DIRECTION, SCOPE

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AND DEPTH OF INSPECTION EFFORT AND ARE NOT A DISPOSITIVE MEASURE OF PERFORMANCE BY THEMSELVES ANALYSIS OF MANAGEMENT EFFECTIVENESS IS BASED ON RESUl.TS OF a

MANAGEMENT EFFORTS AND NOT ON ANALYSIS OF

SKILLS, STYLES OR POPULARITY FOCUS OF INSPECTION IS PRIMARILY ON END PRODUCT; HOWEVER, PROCESS a

OF ENSURING QUALITY ALSO IMPORTANT IN ORDER TO ENSURE CONSISTENT QUALITY

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STANDARDS OF PROFESSIONALISM OF INSPECTORS EXCEED THE STANDARDS l

EXPECTED OF LICENSEE PERSONNEL i

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s APPLICATION OF REGULATORY EXPECTATIONS IS CONSISTENT FROM INSPECTOR E

TO INSPECTOR AND FROM PLANT TO PLANT i

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INSPECTION APPROACH AND TECHNIQUES ARE SUCH THAT INSPECTOR AND LICENSEE TIME ARE EFFECTIVELY USED 1

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INSPECTORS ARE QUALIFIED C0l#fENSURATE WITH DIFFICULTY OF TASK L

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INSPECTION FINDINGS ARE ACCURATELY AND PROMPTLY C0l#4UNICATED TO i

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INSPECTION ACTIVITIES APPROPRIATELY RECOGNIZE THE EFFORTS OF f

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INTERFERE WITH THE LICENSEE /SELF-EVALUATION ORGANIZATION INTERFACE i

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a NRC MANAGEMENT IS PROMPTLY INVOLVED WHEN FUNDAMENTAL DIFFERENCES CANNOT BE RESOL ED BETWEEN INSPECTOR AND LICENSEE i

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a COMUNICATIONS ABOUT THE LICENSEE OR LICENSEE PERSONNEL ARE CONTAINED WITHIN THE REGULATORY FRAMEWORK l

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a BE RECEPTIVE TO ALL ALLEGATIONS AND TREAT ALL PUBLIC INQUIRIES WITH l

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u INSPECTORS MUST GENERATE AN AURA 0F INDEPENDENCE IN ALL DEALINGS I

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MOST NRC/ UTILITY INTERFACES ARE POSITIVE i

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INTERFACES MUST BE STRAIGHTFORWARD AND HONEST l

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RESULT IN EFFECTIVE AND EFFICIENT SAFETY PROGRAMS l

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GREATER NRC EMPHASIS ON PROPER INTERFACES IN THE FUTURE

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The Engineering Role In Plant Support i

E. J. Mroczka 4

Senior Vice President Nuclear Engineering and Operations j

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Reliability 1

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INDEPENDENCE c

o "Nothing but the highest possible standards of ethical performance and professionalism should influence j

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However, independence does not imply isolation.

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o All available facts and opinions must be sought openly from licensees and other interested members of the public.

The many and possibly conflicting public interests o

involved must be considered.

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Final decisions must be based on objective, unbiased assessments of all information, and must be documented l

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L OPENNESS l

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" Nuclear regulation is the public's

business, and it must be transacted publicly and candidly.

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Open ; channels.of communication must be mamtamed with Congress, other government agencies, licensees, and the public, as well as with the international nuclear i

community."

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EFFICIENCY o

"The American

taxpayer, the rate-paying consumer.

and licensees are all entitled to the best possible management and administration of regulatory activities.

The highest technical and managerial competence is o

required and must be a constant agency goal.

NRC must establish means to evaluate and continually o

upgrade its l regulatory capabilities.

l Regulatory activities should be consistent with the degree o

of risk reduction Lthey achieve.

Where several effective alternatives are.available, the o

option which minimizes the use of resources should be adopted.

Regulatory decisions should be made without undue delay."

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Ib TEGRATED REGULATORY REQUIREMENTS I

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1 IMPLEMENTATION SCHEDULE i

t "IRRIS provides a simple mechanism that will i

o encourage implementation of plant modifications offering the most safety for resources spent; help to evaluate and set balanced priorities for an o

entire set of pending requirements; and j

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" Regulations should be coherent, logical, and practical.

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There should be a clear nexus between regulations and j

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Agency positions should be readily understood and easily l

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REPORTABILITY NRC Guidance Should be Consistent Prompt Reports (10CFR 50.72) 4 Licensee Event Reports (10CFR 50.73) l Inspection and Enforcement Should be Consistent Inspector to Inspector j

Region to Region s

l Degraded Conditions, Operability Determinations, i

and JCO's

- Terminology and Requirements 1

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i More Rewards for Self Assessment i

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W RELIABILITY

" Regulations should be based on the best available o

knowledge from research and operational experience.

Systems interactions, technological uncertainties, and the o

diversity of licensees and regulatory activities must all be taken into account so that risks are maintained at an acceptably low level.

Once established, regulation should be perceived to

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reliable and not unjustifiably in a state of transition.

Regulatory actions should always be fully consistent with o

written regulations and should be promptly, fairly, and decisively administered so as to lend stability to the nuclear operational and planning processes."

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CONCLUSIONS 0

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MANAGERS

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l Mike Tresler Diablo Canyon Power Plant - PG&E Engineering, Manager i

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Environment

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ATTACHMENT 4

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l ELEMENTS OF A GOOD ENGINEERING ORGANIZATION Group 1:

Facilitators - Ed Wenzinger (NRC), Tom Crimmins (PSE&G)

Industry participants: 16, NRC participants: 5-Four key issues a.

priorities (19) b.

responsiveness (15) c.

peoplc (8) d.

NRC interface (7)

Good engineerine organizations prioritize plan effectively allocate resources to their work Ejements a.

long-term planning b.

priorities - setting how and who c.

emergent work d.

forced outage plan e.

orderliness vs chaos f.

communication enhanced g.

show proactive nature h.

balance long term and short term Good engineering organizations are responsive to the needs of operations, maintenance, and day to day activities Elements a.

mission clarity b.

physical involvement c.

joint planning / priorities d.

balance reactive and proactive c.

communications, communications, communications

' f.

key to maintaining design quality and configuration g.

ops and maint, understanding of basis for and demands of the design h.

balance engineering / design perspective and operations perspective Good engineering organizations maintain a high quality interface with the NRC

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Group 1

.2 Elements a.

technical com;x:tence b,

proactive assertive engineering c.

communications - listen d.

quality of process / product e.

.NRC acceptance of acceptable solution f.

escalate professional differences l

l

3-Group 2:

Facilitators - Harold Gray (NRC), Fred Sears (Northeast Utilities)

Industry participants: 14, NRC participants: 5 Factors for consideration a,

there is no single, universal engineering structure or organization that is best for all plants b.

whatever the organization is, it must be clearly defined with respect to responsibilities and accountabilities Attributes a.

suntinual improvement b.

economical operation c.

common goals d.

teamwork e.

effective self-assessment f.

conformance to requirements g.

well defined, available, usable design basis h.

configuration management i.

lessons learned application j.

new technology usage k.

customer satisfaction Engineering concerns "nroblems" a.

LTA Design Basis - documentation and organization b.

Resource Management 1.

conflicting goals and priorities both internal and external 2.

NRC interface - team inspections 3.

off normal support c.

Ineffective Processes - internal and external d.

Plant Materials - obsolescence, aging, vetip (vendors), OEM demise / dedication Solutions a.

mission b,

strategies c.

responsibilities d.

plans, schedules, priorities, resources e.

- communications, education, sharing f.

decision tools g.

staff training, development h.

cultivate positive NRC/ utility relation

Group 2 4

Conclusions a,

no single definition of engineering b,

consider all with engineering or science background and those performing in technical roles to be part of engineering c.

solutions of engineering concerns can be reached by good management practices, including consideration of mission - strategies responsibilities - accountability, plan,-

schedule, train, educate d.

the functions of good engineering are many, but the intent is safe, reliable,-

economical plant operation.

9 x.-

5 OPERABILITY /REPORTABILITY DETERMINATIONS AND DEGRADED CONDITIONS Group 1:

Facilitators - Jon Johnson (NRC), Wes Bowers (PECO)

Industry participants: 14, NRC participants: 8 Q.

How does licensee know or determine operability and reportability?

A.

When there is sufficient evidence or basis that a component or system meets its deign safety function (s) including operation under prescribed accident conditions. The determination must be made in a timely manner.

What is sufficient evidence?

lune Recommendation / solution

. ito W

lack of guidance revise NRC inspection manual NRC on operability to provide improved determinations guidance; transmit manual to licensees lack of guidance finish owners group BWROG on reportability guidance on reportability; transmit manual to NRC develop improved guidance NRC on reportability What is design bases?

Iss!c Recommendation / solution Who design bases publish design bases standard utility is unbounded including guidance and and component level NRC endorse refine and clarify WRT safety function clarify functional j

capabilities clarify WRT clarify difference (if any) operability between design bases for or reportability operabihty (T.S) and reportability (50.72, 50.73) 4

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Timeliness of operability determinations lisne Recommendation / solution li'ho unclear process use a two step process utility /INPO (accountability

1. screen (operability priority) determination) and
2. F/U analysis refine timeliness publish / endorse guidance NRC/NUMARC guidance

- use STS LCO action times

- use IPE/PRA to prioritize lack of knowledge /

train engineering support utility /INPO sensitivity to staff timeliness needs Suggestions for improved guidance for operability clarify that the following can be used

- engineering judgement

- test results

- analysis

- compensatory action

- operating experience

- operating parameters j

- current physical condition clarify that PRA cannot be used clarify that unavailability of component not required for safety function does not make system unavailable consider NUAIARC guidance on design basis definition and examples L

l 1

O 7

Group 2:

Facilitators - Rich Conte (NRC), Bob Byram (pF&L)

Industry participants: 13, NRC participant;: 8 Formal

- open forum

- aired concerns

- focused on positive aspects

- selected four key concerns

- positive aspects into process objectives

- focused on key-concerns Qbjectives

- assurance of nuclear safety

- clear expectations

- communication / action on generic conditions

- efficient and effective

- mutually agreeable

- eng. involvemeat in operability /reportability

- clear and consistent

- promote.aitiative/ action

- foster questioning attitude

- training and development

- strengthen design documentation

- work on what's important

- enhance safety cultures that are assumed to satisfy regulatory expectations

- sensitivity to real needs of operator Operabilitv/Reportability major concerns a.

define concepts and terms on operability b,

define the process for operability determinations c.

use of engineering judgement Aside issue - Reportability groups discussion focus was on operability issue a.

b.

group generally agreed 1.

reportability criteria not to be discussed - residual issues exist but are being dealt with 2.

reportability criteria should remain separate and distinct from operability criteria but properly sequenced with operability determinations

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Group 2 8

Maior concern No.1 - Define concepts and terms a.

operability degraded condition workability JCO/BCO

,j capable of perf functionality qualification design basis timeliness b.

distinguish postulated events (how far do you go) versus current configuration events (normal conditions) c.

avoid determinations of inoperability because of lack of documentation d.

once defined as above, distinguish workability versus functionality and/or operability versus qualification Major concern No. 2 - Define the process administrative procedure to address operability determinations (including organization a.

roles and responsibilities) should be left to licensee initiative b.

let (responsibility not defined by group) establish process criteria which focus on:

timeliness, prioritization, quality ot documentation, etc. (here again licensee initiative) although the NRC says that the pending guidance contains no new requirements c.

(reports / records procedures), the reality is the opposite because of licensee initiative to establish controls Major concern No. 3 - Use of engineering udgement j

a, recognize its use as variable but viable b.

document the thought process for the engineering judgement c.

encourage people to think d.

demonstrate competence in applying engineering judgement e,

make engineers responsible and accountable for the above f.

initial through final stages of operability determination - how is engineering judgement to be applied

Group 2 9

Summary a.

disseminate information 1, pending guidance

2. this conference b.

industry interaction at working level e,

focus on expectation as opposed to prescriptive guidance j

f 1

3

10 Group 3 Facilitators - Lee Bettenhausen (NRC), Bruce Preston (PSE&G)

Industry participants: 13, NRC participants: 10 What value/ criteria do you use for operability determinations - design / purchase specs - dnign basis licensing basis (FSAR, SER, LC, etc.), or safety limit basis.(2200 F, containment pressare, etc.)?

1.

technical speci0 cation values must be used if available 2.

10CFR safety limits 3.

other -

example:

containment fan coil units BTU capacity being tested - is tech spec operability based on 1.

purchase spec - design? 100K 2.

FSA~R 80K 3.

Ultimate safety limit - i.e., containment pressure 60K can current conditions be used also -i.e., river water temp (heat sink) -

yes Operable - AShtE code versus tech spec operability pumps and valves 1.

GL 89-04 directs that device is inoperable if test results are in action range -

appropriate tech spec LCO should be entered (basis-degradation cause unknown, l

device could fail immediately) 2.

ASME section XI allows for analysis to change action range value using 50.59, maintaining component operable per tech specs (i.e., enter LCO, do analysis, exit l

LCO) 2122 section III, class 3 and B31.1 - a thru wall leak of below minimum wall condition does not I

automatically equate to an inoperable condition (i.e., analysis of flow and structural impact using LCO time as a marker)

Appendix R, EQ, electrical separation discrepancies versus operability:

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e Group 3 11 Qualification proble:ns such as these generally att operability problems electrical separ. tion problem does not necessarily call for associated equipment to be inoperable Appendix R equipment still operable but compensatory actions to deal with fire need to be taken operability an issue if accident causes failure and loss of emergency function Timeliness of onerability calls no new NRC regulations utility develops written policy; elements include:

a, prompt initial screen by knowledgeable group b.

timeliness commensurate with safety significance and plant conditions; tools:

PRA, LCO action statements detailed evaluation to support initial screen decision within time bounds, e.g.,

c.

3 days How should operability guidance be promulgated?

1.

NRC incorporate in inspection manual and by generic letter (in progress) 2.

NUMARC/INPO take initiative for industry guidance, e.g., NSAC (need next month) 3.

plant unique program with region buy in 4.

NUREG or regulatory guide for utility to construct program 5.

do nothing The group favors #2

12 MODIFICATION PROCESS INCLUDING 50.59 REVIEWS Group 1 Facilitators - P. K. Eapen (NRC), Nelson Tonet (DLC)

Utility participants: 6, NRC participants: 6 Discussion tooics f

1.

50.59 review process 2.

temporary modification process 3.

design change process

- reviewed strengths and weaknesses

- developed recommendations for improvement 1.

50.59 review orocess strengths NSAC 125 effective resource utilization i

weaknesses s

needs standards needs guidelines for results lacks consistent training required recommendations / comments

(

good DBD, reduce potential for inadequate safety reviews 1

improve NSAC 125 with samples of adequate / good evaluations for short term utility should develop standards individually enhance NRC inspector training 2.

temocrary modif' cation process strengths timely and effective utilization can help to keep the plant safe provides more effective utilization of resources i

e 4

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a Group 1 13 weaknesses can bypass modincation process challenges configuration control

j reviews may lack detail can become numbers game recommendations / comments better denne maintenance vs mod upfront good DBDs needed to properly manage process 3.

design change process strengths controlled process maintains DBDs controls plant configuration weaknesses process perceived as cumbersome potential AE or contractor interface problem daily plant support may detract potentially excessive reviews performed recommendations / comments DBDs essential to be successful integrated living schedule provides for effective backlog control regulators / inspectors need better training to understand processes Conclusions design change process continues to improve further training needed NSAC 125 enhancements could be beneficial effective screening is necessary integrated scheduling can provide more effective resource management

\\

l 14 1

Group 2 Facilitators - Jim Linville (NRC), Bill Yaeger (Niagara Mohawk)

Industry participants: 7, NRC participants: 4 l

Strengths of 50.59 nrocess 1

there has been a significant improvement in safety as a result of the 50.59 process 50.59 process has improved greatly in the last few years. It is more substantial and better documented. Less perfunctory NSAC 125 and design basis reconstitution have contributed significantly to these improvements 50.59 process appears to work well for major modifications Maior problem areas l

difficulty in applying 50.59 process to the modification process commensurate with the nature of the modification major modifications minor modifications temporary modifications (including electrical jumpers and lifted leads) generic modifications design equivalent changes non-safety related systems Goals maximize safety minimize resource impact Recommendations for industry clearly define modification categories and which parts of the review process are applicable in order to minimize resource impact develop screening process similar to that suggested in NSAC 125 establish well developed design basis establish generic processes to the extent possible -

Recommendations for NRC publish a position on the acceptability of NSAC 125 Establish clear staff guidance on application of position train NRC staff on application of guidance manage inspection and enforcement of guidance to provide consistent application with focus on potentially safety significant oversights

15 Group 3 Facilitators - Gene Kelly (NRC), Charles Cruse (BG&E)

Industry participants: 10, NRC participants: 4 i

l Strengths 50.59 gives flexibility to utility good 50.59 process helps clarify design basis 50.59 process gives engineering a better understanding of design br, sis 50.59 process fosters well documented and assessable design basis NSAC 125 fills long standing void 50.59 enables integrated multi disciplinary review 50.59 process atarted early helps provide design framework Concems/oroblems (in orioriti7ed order) what is the safety analysis report (scope, detail, te : meed documents) r does 50.59 apply to as-found, design basis reconstitution " findings"

" changes" - where do they end? How far should 50.59 be applied?

distinction between licensing and design bases threshold for " temporary" modifications distinction between safety related and important to safety (and definition of the latter)

NSAC 125 "in progress" change clarity 50.59 review of procedure changes scope / criteria for " screening" processes measures of 50.59/ modification effectiveness Problem 1 - what is S AR?

recommendations provide guidance on whether emergency plan, environmental reixnt, and like documents are part of the SAR management meeting between NRC and utilities (NUMARC) incorporate guidance in NSAC 125 delete items not important to safety from SAR add documents clarifying " licensing basis" to next SAR update (SERs, GL responses)

Problerr;.2_ does 50.59 nrocess ap.oly to "as found" design oroblems (design basis reconstitution) 50.59 process $bg_s apply to "as found" design problems develop " tiger team" of small dedicated engineering / licensing group to address "as found" design problems - use screening process I

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Group 3 16 Problem 3 - how fsLMyald 50.59 process be amGed2 resolve problem 1 (SAR question) clarif need for 50.59 process f

procedure changes temporary mods-long teran equipracnt outages (silent mods) develop sueening process provide training on creeniiig ciiteria add step at end of mod process to perform self assessment of 50.59 process i

Conclusions

- NSAC 125 is a good start but it need additional clarity what is SAR temporary mods i

- procedure changes in progress work definition of important to safety i

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UNITED sTATis sf T

NUCLEAR REGULATORY COMMISSION S

M4eHme7oN, D, c.30866

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November g. 19g0 Mr. William H. Rasin Director, Technical Division 6

Nuclear Management and Resources Council Suite 300 1776 Eye Street N.W.

Washington,DC 20006-2496 Dear Mr. Rasin We have reviewed the " Design Basis Program Guidelines" developed by the Nuclear Management and Resources Councti (NIE9C) forwarded to us by HMAC's letters of May 16,,1uly 2,, and Detober 17,1990. We appractated the opportunity to interface with your staff during the development of the guidelines. We note that your staff was responsive to the coements and concerns that tht U.S. Nucler P.egulatory Comission (hRC) steff expressed during the development of the guidelinea.

We believe that NWRC's approach will proYide a useful framework and worth-while insights to those utt11 ties undertaking design basis programs of various scenes. We share your view that no sintle best approach exists for a design bas'is procram. V4 understand that util. ties soust often address unique situa-tiona. Therefore, a varisty of spproache* can satisfy the basic need to develop a centralized h:ation for design bases information tiat emphasites the design intent sud arovides an index to important design 4ccumentation.

It is important i

l to stress tant a facility should not 'on modified unless sufficient information is available to demnstr6ta that,sdaquate design margins will be urintained.

We believe that Section Y! of the Sorsation is of par 11cular immrtance.

videlines regardita validation of the facility against current desicn in The goal of any design reconstitution program should be to establisi confidence that the existing facility is in accordance with the current design documents and that any deviations are reconciled.

The Enclosure sunnarizes our thoughts on several areas that the NMRC guidelines do not address extensively. You may want to consider issuing further NMRC guidance in these areas as you receive responses from utilities on use of the guidelines.

In the near future, the NRC will issue a NUREG document containing perspectives on utility design control programs and design document reconstitution programs gained from a survey of the programs of six licensees and one nuclear steam supply system vendor. The NURE6 document will contain factual information regarding programs as they were being implemented at that time and will des.

cribe program strengths and weaknesses and problems encountered by utilities.

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-Mr. William H. Rasin

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We view your development of th6 ' Design Basis Program Guidelines' to be a posithe step in an area that will continue to be of great-importance.

sincerely, Original signed by:

William T. Russell, Associate Director for Inspection end Technical Assessment Office of Nuclear Reactor Regulation

Enclosure:

NRC ObserYations of Design Document Reconstitution Prograss D_istribution:

JMTaylor, EDO JH$nierek EDO HLThompson EDO JLBlaha,E00 ELJordan,AEOD JLiebennan, OE TEMurley HRR FJMiraglia, NRR WTRussell NRR JGPartlow NRR FPGillesple,NRR Diltrutchfleid.NRR CD$ntyre,NRR JERichardson NRR CERossi. NRR BXGrimes,NRd l

BDLiaw, NRR WDLanning, NRR R

EV!mbro, NRR RAGramm, NRR EWBrach,NRR PFNcKee, NRR ETTana NRR-5483 HCBridgers ED0 54B3 MKHcAllister,NRR-5483 TTNart<n,Il l

MWHodges RI

$DEbneter, RI!

AFGibson, RI!

ABDavis,Rl!!

HJMiller, RIII RDMartin, RIV LJCallan, R!Y JBMartin,RV RPZisarrman, RV Central Files PDR EDO R/F DRIS R/F RSIB R/F Mb

  • See stevious concurrence RSIB ]RIS SC:RSIB DRIS C:R$

IS D

ADT NRR MAHiller*:bt EVImbro*

W]Ll ing Tech Ed i

WTRussell 10/15/90 10/15/90 ID/p /90 10/17/90 f/90 1p/ (/90 o w t o p %

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ENCLO5URE t

NRC Coenents on Design Document Reconstitution Programs (1) prelate Approach Thedesigndocumentreconstitution(DDR)processshouldresult$pconfi-dance that sufficient design documentation is available (a) to verify the implementation of the design bases (b) to provide justifiestion that key such as the pump net positive suction head, are ade-design parameters,for in the design and(c)toensurethatastructureOne quately accounted system, or component (550) will perform its intended safety function.

approach to develo a system or topical design bases document is to ste of desig parameters. Such a template would first identify a t

( ) establish and de ine the functionality and operability requirements o )$$Cs, (b) demonstrate the conformance of $5Cs to the des

(

demonstrate that $5Cs will perform their intended safety functions.

A review could then be performed to establish the degree to which ths e

available design documents support the parameters defined in the template.

This process would identify areas that require additional design documentation.

(2) Desian Document Technical Review The design document reconstitution program should include a technical review of the supporting design parameters design calculations, and This technical review would verify that the design documents analyses.

are technically sound and consistent with the as-built fact ilty. The available design documents should be reviewed to identify areas where design information is technically inadequate or not censistent with the as built facility.

(3) Concept of Essential Desian Documents In performing a design document rewnstitution program certain design l

documents will probably be unretrievable or will cont 4In inconsistencies.

While the NRC does not advocate the regeneration of the complete set of i

design documents, it is important that certain design documents are l

available to support plant operation. The design documents in this set

)

will be referred to as the " essential design documents" and are further defined as CateJory I herein. All Category I design documents aust be i

accurate, and tiose that are unretrievable need to be regenerated, i

Category I design' documents are those documents that are necessary to i

sup? ort or den.custrate the conservatism of technical-specification valuss, i

i suc1 as pump flow calculations or setpoint calculations. - Additional design documents included in Category I would be those necessary for i

(a)engineeringorganizationstouseinsupportingplantoperationsand.

(b) the operators to use in quickly responding to events. Examples of Category I documents include, but are not limited to, electrical load 9

4gh 1

0 fuse lists, breaker instrument lists,ing and instrum nta-valve lists lists, setpoint lists lists, Q-lists, diesel generator lo,ad sequencing pip tion. diagrams,flowdiagrams,electricalsinglelinediagramsandschemat-ics, and breaker and fuse coordination studies.

(4) Prioritization of Missinn or Inadecuste Documents Use of a prioritization methodology in considering whether to regenerate missing or deficient documents can ensure that the licensee focitses resources on the more safety significant items in a timely manner. An initial screening process would enable the licensee to determine the significance, effect on plant operability, and reportability requiraunts related to the missing or inadequate documentation, i

One way to rank the importance of design documents according to safety significance is as follows:

Category 1 - Design documentation that supports or defines technical specification safety limits, limiting conditions for operation, limiting safety system setpoints or surveillance requirements. These documents i

cesenstrate that the $$Cs addressed by technical specifications will perform their active safety functions.

Category !!

Design documentation that defines controlling parameters or demonstrates the active functionality of safety-related SSCs that are not explicitly addressed by the technical specifications, but that support the 55Cs addressed by technical specifications such as heating, ventilating, and air conditioning systems.

Category !!! - Design documentation that defines controlling parameters or demonstrates ective functionality of safety-related $$Cs not included in Cttegories 1 or II.

Category IV - Design documentation that defines controlling parameters or I

desionstrates the functionality of safety related $$C$ with regard to passiveconsiderations(e.g.,seismicconsiderations).

i Category V - Design documentation that demonstrates the design of non safety S5Cs is such that its failure would not impair the functionality of safety-related $$Cs (e.g., seismic 11/1 considerations).

(5) Design Bases vs.- Desian Document Reconstitution Reestablishment of the design bases without reconstitution of the support-4 ing essential design documents may not provide a sufficient amount of information to support future modifications and current plant operation.

The objective of a DDR program is to establish a continuity among the variouslevelsofdesioninformation(e.g.,designcalculationsanddesign bases documents) and w< th the physical plant characteristics of the facility. The DDR program should ensure that the design bases documents accurately reflect the source design documents, the design output docu-ments accurately reflect the design bases, and the plant configuration is in accordance with the design output documents.

9 i

8 2

(- o s

This information requiring document reconstitution can be evaluated in relation to the document categories, as defined herein. The NRC considers that all Category I essential documents that are inaccurate, unretrievable, or not yet produced should be regenerated in an expeditious unner.

a licensee may be able to generate test data or Use othkr means However,lish a high level of confidence that the systesi can fulfill its to estab safety functions.

If so, then the licensee may be able to schedule the regeneration of the Category I document in a period of tim conseensurate with its evaluated safety significance.

A licensee my not need to regenerate design documents for Categories !!

through V if other supporting infora tion or test data is available to demonstrate that an $5C can perform its intended safety function. For it my not be necessary to regenerate all missing pipe support exar.ple, ions if, based on reanalysis of a sufficient sarple,f a calculat it can be demonstrated that adequate design margins exist. However,i rodification is proposed that would affect a pipe support, it would have to be reanalyzed if a valid analysis did not exist.

It is important to stress that a facility should not be sedified unless sufficient information is available to demonstrate that adequate design Therefore all missing calculations or design u rgins will be maintained.

documents necessary to support a sediflcation must be regenerated to establish a point of departure for the proposed modification and to quantify the design margin available following the proposed installation of the modification.

I i

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..

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