ML20024G932
| ML20024G932 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/15/1991 |
| From: | Eapen P, Lopez A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20024G930 | List: |
| References | |
| M91-048-07, M91-48-7, NUDOCS 9105020149 | |
| Download: ML20024G932 (64) | |
Text
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U. S. NUCLEAR REGULATORY COhihilSS10N REGION 1 Report No.
hiol 048 Docket Nos. As listed in Attachment 1 License Nos. As listed in Attachment 1 Licensee:
A1lintriin Attachment 1
Participants:
As listed in Attachment I hiceting At: Sheraton Valley Fo.tge. King of Prussia. Pennsylvania hiecting Conducted: Esbruary 20 21. 1991 Prepared by:
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M A. EJopez, keactor Engineer,' Systems Section, date' Engineering Branch, DRS Approved by:
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Dr. P. K. Eapen, Chief, Systems Section,
' date Engineering Branch, DRS hiecting 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 sesen action items for the industry.
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Region 1 Meeting Report M91-048 Iable of Contents l'aEC t
1.0 Purpose 3
2 2.0 General Overview 3
3.0 Summary of Workshop Group 4
Presentations 4.0 Conclusion 6 - List of Attende:s
- - Meeting Agenda - Speakers Slide Presentation
, Workshop Group Summaries l
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1.0 Purriose 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, i
2.0 General Overview l
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 c Call to Assembly, an Introduction, and a Welcome, hir. J. H. Sniezek, NRC Deputy Executive Director for Operations, and i
hir E. J hiroczka, Northeast Utilities Senior Vice President of Nuclear Engineering and Operations then addressed the symposium. Both hir. Sniczek and hir. hiroezka eloquently discussed the theme of the symposium, "The Engineering Role in Plant Support." They provided an excellent basis for promoting open discussion during the i
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 i
process including 10CFR 50.59 reviews. Each workshop gro..n was lead by two l
facilitators, one cach from the NRC and licensee, and had approximately 15 25 participants.
t The participants returned the next morning to the same workshop group as the day before for approximately two hours to finalize discussions and to develop recommendations.
1 At 10:30 a.m. on February 21,1991, a speaker, Mr. hl R. Tresler, Diablo Canyon Engineering hianager, Pacific Gas and Electric Cempany, and Chairman of Region V I
Engineering Managers' Forum addressed the symposium, hir. Tresler discussed the experiences at the Region V Engineering Managers' Forum. The slides from hir.
Tresler'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 conclusions. 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 Workshop Group Patentations A.
Elements of a good encineering organi7ation 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:
prioritize its activities from a safety perspective and establish a.
clear lines of responsibility and accountability b.
be responsive to the needs of its customer (operations, maintenance,...)
c.
maintain a well quali6ed 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 operabilitv/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.
5 d.
lack of adequate guidance for reportability 2.
Ercommendations l
a.
NRC establish consistent guidance on operability and reportability (NRC Action item 1) b.
Industry develop design basis standards with NRC cndorsement (NRC Action item 2, Industry Action item 1)
Industry establish guidelines for the timeliness for operability c.
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 item 4, Industry Action item 3)
C.
The modification mocess including 10CFR $0.59 reviews The three working groups on this subject concluded the following:
1.
the modincation 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 procest, and the 50.59 review process, respectively l
l Weaknesses 1.
design change process is cumbersome 2.
temporary modincations may be bypassing the modification process l
3.
design bases are not adequately defined 4.
control of contracted modification work is not adequate 5.
inadequate prioritization and control of backlog l
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l Rctemmendations i
l 1.
NRC and Industry train their respective personnel in the modification l
process (NRC Action item 4, Industry Action item 3) l 2.
Licensee establish clearly developed design basis documents for each i
unit using NRC endorsed standards (industry Action item 4) 3.
Industry define categories of modification with NRC endorsement (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 item 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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N1TACOIMENT 1 i
LIST OF ATTENDEES A.
Reaion I Licengita LICENSEE DOCKET #
LICENSE.#
ATTENDEES 1,
BG&E 50-317 DDR-53 Charles Cruse 50-318-DPR-69 Peter Katz Robert Waskey 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-cf NY Mike Lee Pete Szabados.
5.
Duquesne Light 50-334 DPR-66 Kenneth E. Halliday Company' 50-412 CPPR-105 Nelson R. Tonet 6.
GPU Nuclear 50-219 DPR-16 Jim Byrne Dave Distet Greg Gurican.
William Heysek James W..Langenbach Max Helson Ed O'Connor Art Rone Richard-Skillman Pc rick Walsh 7.
Long Island 50-322 NPF-19 Ed lerpont Lighting Co.
B.
Niagara Mohawk 50-220 DPR-63 Michael Carson Power Corp.
50-410 NPF-54 Gregory Gresack i
Rob Oleck l-1 Bill Yaeger
- 9. Northeast. Nuclear 50-245
~DPR-21 Michael Bigiarelli Energy-Company 50-336 DPR-65 Brendan'J. Duffy.
l 50-423 NPF-49
.G. Leonard Johnson John'S. Keenan Edward J. Mroczka R. L. McGuinness
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C. Fred Sears 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. Parsons
LICENSEE DOCKEI_f LICENSE #
hTTENDEES
-11.
PECO 50-352 NPF-39 Jim Basilio 50-353 CPPR-107 William Bloomfield Wes Bowers Frank Cook Jack Evans Al Fulvio David Foss
-i 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 Gul' lick of State of NY Terry Herrmann Gus Mavrikis Steve Smith Vic Walz
- 13. Public Service 50-443-CPPR-135 Terry Harpster of NH 50-444 CPPR-136 Joe Vargas-
-Moises Burzstein Thomas M. Crimmins Scott Gillespie
.:ee Griffis Bruce Hall Michael Morroni Bruce.Preston Martin-E. Raps
. John P. Ronafalvy Frank Thomson
- 16. Yankee Atomic 50-029-DPR-3 Peter Anderson Electric Co.
John Hoffman-William' Jones Dave King Robert Shone George Tsouberous
B.
Licensger From Othe NRC Rea(qDa LICENSEE ATTENDEED i
1.
Florida Power Bill Shelley and Light 2.
Toledo Edison Vernon Watson C.
Other Participants OTHER ATTENDEES 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 Marc Boothby Alan Chan Tim Chitester Louis Hirst E.
J. Hubner Tom Szabo 7.
NUS Corp - Florida Michael Johnson Peter S.
Jordan I
Eric R. Smith
. _.. _. _ _. -. _ ~
D.
The-Nuclear Reculat'ory Commission i -
QIIISI' ATTENDEES 1.-
HQ Bob Capra 2.-
HQ Jin Chung 3.
HQ Dick Clark 4.
HQ Al'DeAgazio l
S.
HQ Richard L.
Emch
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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 1
- 12. HQ Jeff Jacobson i
- 13. HQ-Wayne Lanning i
- 14. HQ Erasmia Lois i
- 15. HQ Dan Mcdonald f
- 16. HQ James G.
Partlow
- 17. HQ Uldis-Potapovs
- 18. HQ Mark F. Reinhart
- 19. HQ Jim Sniezek l
- 20. HQ John Stolz
- 21. HQ David L. Wiggington l
1.
RII Caudle H. Julian
- 2. RII-Francis Jape-3.
RIII Mark Ring
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4.
RIV Johns Jaudon t
1.
RI-Scott Barbor 2.
RI Walter Baunack-3.
RI Lee Bettenhausen-f 4.
RI Norman Blumberg 5.
RI Fred Bower 6.
RI-Suresh K. Chaudhary-i 7.
RI Rich Conte i
8.
RI Larry Doerflein i
9.
RI Jacque P. Durr 10 RI P.K.
Eapen i
- 11. RI Harold Eichenholz
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- 12. RI Pete-Eselgroth-t
- 13. RI E. Harold Gray
- 14. RI Harold I..Gregg.
15.-RI Peter Habighorst
- 16. RI Sam Hansell 17.- RI Donald Haverkamp r
- 18. RI Tom Hiltz E
- 19. RI M. Wayne Hodges l
- 20. RI Kerry Ihnen i
- 21. RI Jon Johnson
- 22..RI Herbert Kaplan
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- 23. RI Paul Kaufman-
- 24. RI Gene Kelly
- 25. RI-James C.-Linville
- 26. RI Al Lohmeier-I
- 27. RI Thomas T. Martin
- 28. RI Marie Miller l
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OrrIQ.0 ATTENDEEE
- 29. RI Dan Moy
- 30. RI George Napuda - retired
- 31. RI William Oliveira
- 32. RI Steve Pindale
- 33. RI Len Prividy
- 34. RI John Rogge
- 35. RI Glenn Tracy 364 RI Ed Wenzinger
- 37. RI Barry Westreich
- 38. RI Peter Wilson
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0 ATTACHMENT 2 1
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Symposium / Workshop Engineering's Role In Support Of Plant Activities
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h9fliDA Wednesday. February 20, 1991 12:00 - 12:50 p.m.
Registration 12:50 - 1:00 p.m.
Call to Assembly Harold I. Gregg l
-Senior _ Reactor Engineer Division of Reactor Safety, RI t
l 1:00 - 1:05 p.m.
Introduction M. Wayne Hodges Director I
Division of Reactor Safety, RI
'.:05 - 1:15 p.m.
Welcome Thomas T. Martin Regional Administrator, RI 1:15 - 1:55 p.m.
Keynote Speaker James H. Sniszek Deputy Executive:
Director for Operations, NRC 1:55 - 2:35 p.m.
Keynote Speaker Edward J. Mroczka
'r. Vice President Nuclear Engineering and Operations Northeast Utilities 2:35 - 3:00 p.m.
Break 3:00 - 5:00 p.m.
Breakout Sessions-l Toolc Room 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 10CFR50.59 Reviews Merion Room, or Quaker Room i
f 4
Thursday, February 21, 1991 8:00 - 10:00 a,m.
Breakout Sessions - Refinement of most significant issues.
Tonic Room Location A.
Elements of a Good Engineering Berwyn Room or Organization Devon Roora 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 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 Summary Feedback 2:15 - 2:30 p.m.
Break 2:30 - 3:15 p.m.
Second Group Breakout Session Facilitators.
Summary 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
4 ATTACHMENT 3
JAMES H. SNIEZEK DEPUTY EXECUTIVE DIRECTOR FOR OPERATIONS, NRC 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 1
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i IMPROVEMENT OF OPERATIONAL SAFETY i
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SAFE ENOUGH ARGUMENT
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i BACKSLIDE TOWARD INADEQUACY a
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PRINCIPLE OF COST EFFECTIVE SAFETY IMPROVEMENT s
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i RESPONSIBILITY FOR SAFETY i
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u UTILITY RESPONSIBLE FOR SAFETY i
a NRC IS REGULATOR i
i NEED FOR NUCLEAR INDUSTRY SAFETY CULTURE
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j TRUST IS FOUNDATION OF NRC/ UTILITY RELATIONSHIP u
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RELATIONSHIP WITH UTILITIES LICENSE BASED ON TECHNICAL / MANAGERIAL COMPETENCE a
- NRC HANDS OFF, IF TRUE
- NRC ACTIVE INVOLVEMENT, IF NOT TRUE a
NRC EMPHASIS ON COMMUNICATION OF EXPECTATIONS
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UTILITY CERTIFICATION OF PERFORMANCE s
UTILITY. RESPONSIBLE FOR SAFETY EVALUATION 1
m NRC RESPONSIBLE TO REGULATE I
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ESTABLISH MANAGEMENT EXPECTATIONS I
s MEASURE IMPLEMENTATION OF MANAGEMENT EXPECTATIONS i
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ESTABLISH A STABLE PROCESS a
CONDUCT ACTIVITIES IN A PROFESSIONAL MANNER
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i REGULATORY IMPACT' SURVEY (CONTINUED 1 1
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e ACTIVITIES SHOULD CLEARLY ENHANCE SAFETY l
u ACTIVITIES SHOULD BE COST-BENEFICIAL i
a RESOURCES SHOULD BE FOCUSED ON AREAS NEEDING IMPROVEMENT i
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CONDUCT A MANAGEMENT SELF-ASSESSMENT l
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INSPECTION _ PRINCIPLES
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INSPECTORS NEED TO ALWAYS BE ALERT FOR SAFETY ISSUES -- EVEN THOSE OUTSIDE THEIR AREA 0F EXPERTISE I
m PRIMARY EMPHASIS IS ON SAFETY WITH THE RECOGNITION THAT NRC REQUIREMENTS ARE SUPPOSED TO BE MET REGARDLESS OF SAFETY IMPORTANCE m
DEGREE OF REACTION / RESPONSE BY INSPECTORS DICTATED BY SAFETY IMPORTANCE l
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ACCEPTANCE CRITERIA ARE BASED ON AGENCYWIDE POSITIONS, NOT ON INDIVIDUAL REVIEWER / INSPECTOR DESIRES i
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1 INSPECTION PRINCIPLES l
PERFORMANCE INDICATORS ARE USED TO HELP DETERMINE DIRECTION, SCOPE a
AND DEPTH OF INSPECTION EFFORT AND ARE NOT A DISPOSITIVE HEASURE 0F PERFORMANCE BY THEMSELVES a
ANALYSIS OF MANAGEMENT EFFECTIVENESS IS BASED ON RESULTS OF i
MANAGEMENT EFFORTS AND NOT ON ANALYSIS OF
- SKILLS, STYLES OR POPULARITY i
q FOCUS OF INSPECTION IS PRIMARILY ON END PRODUCT; HOWEVER, PROCESS s
0F ENSURING QUALITY ALSO IMPORTANT IN ORDER TO ENSURE CONSISTENT QUALITY t
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INSPECTION PRINCIPLES i
STANDARDS OF PP.0FESSIONALISM 0F INSPECTORS EXCEED THE STANDARDS a
EXPECTED OF LICENSEE PERSONNEL APPLICATION OF' REGULATORY EXPECTATIONS IS CONSISTENT FROM INSPECTOR
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TO INSPECTOR AND FROM PLANT TO PLANT INSPECTION APPROACH AND TECHNIQUES ARE SUCH THAT INSPECTOR AND a
LICENSEE TIME AP,E EFFECTIVELY USED 1
INSPECTORS ARE QUALIFIED COMMENSURATE WITH DIFFICULTY OF TASK s
INSP_ECTIO.N PRINCIPLES INSPECTION FINDINGS ARE ACCURATELY AND PROMPTLY COMMUNICATED TO a
APPROPRIATE LEVELS OF UTILITY MANAGEMENT BOTH DURING AND AT THE END OF THE INSPECTION a
INSPECTION ACTIVITIES APPROPRIATELY RECOGNIZE THE EFFORTS OF INDUSTRY SELF-EVALUATION ORGANIZATIONS SUCH AS INPO AND DO NOT INTERFERE WITH YHE LICENSEE /SELF-EVALUATION ORGANIZATION INTERFACE l
NRC MANAGEMENT IS PROMPTLY INVOLVED WHEN FUNDAMENTAL DIFFERENCES a
CANNOT BE RESOLVED BETWEEN INSPECTOR-AND LICENSEE
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-t INSPECTION PRINCIPLES l-a I
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IN PLANT SOURCES OF INFORMATION ARE GUARDED IN ORDER TO PROMOTE l
FREE EXCHANGE BETWEEN STAFF AND INSPECTORS i
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COMUNICATIONS ABOUT THE LICENSEE OR LICENSEE PERSONNEL ARE i
CONTAINED WITHIN THE REGULATORY FRAMEWORK l
s BE RECEPTIVE TO ALL ALLEGATIONS AND TREAT ALL PUBLIC INQUIRIES WITH-i t
RESPECT AND PROFESSIONAL RESPONSE
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s INSPECTORS MUST GENERATE AN AURA 0F INDEPENDENCE IN ALL DEALINGS WITH THE LICENSEE 1
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.. - -... -. ~ - _. _,, -. _ -., _... _.. - _ _ _... ~.. - - - - _ -. -.. - _. - - - -.. -. _, - -
L S_UMMARY a
MOST NRC/ UTILITY INTERFACES ARE POSITIVE l
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INTERFACES MUST BE STRAIGHTFORWARD AND HONEST i
a RESULT IN EFFECTIVE AND EFFICIENT SAFETY PROGRAMS
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GREATER NRC EMPHASIS ON PROPER INTERFACES IN THE FUTURE 4
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The Engineering Role In Plant Support L
k E. J. Mroczka Senior Vice President Nuclear Engineering and Operations Northeast Utilities 4
NRC Region I Workshop I
February 20-21, 1991
"NRC PRINCIPLES OF GOOD REGULATION" Independence Openness Efficiency C1arity Reliability l
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f INDEPENDENCE o
"Nothing but the highest possible standards.of ethical performance and professionalism should influence regulation.
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- However, independence does not imply isolation.
o All available facts and opinions must be sought openly I
from licensees and other interested members of the public.
t The many; and possibly conflicting public interests o
involved must be considered.
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Final decisions must be based on objective, unbiased o
assessments of all information, and must be documented l
with reasons explicitly stated."
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OPENNESS o
" Nuclear regulation is the public's
- business, and it must be transacted publicly and candidly.
j o
The public must be informed about and have the opportunity to participate in the regulatory process as required by law.
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Open channels of communication must be maintained with Congress, other government agencies, licensees, and the
- public, as well as with the international nuclear community."
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l EFFICIENCY o
"The American
- taxpayer, the rate-paying consumer.
and Iicensees 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.
l o -NRC must establish means to evaluate and continually 1
upgrade its regulatory capabilities.
1 Regulatory activities should be consistent with the degree o
l of risk reduction they achieve.
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Where several effective alternatives are available, the option which minimizes the use of resources should be adopted.
Regulatory decisions should be made without undue delay."
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INTEGRATED REGULATORY REQUIREMENTS IMPLEMENTATION SCHEDULE j
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"IRRIS provides a simple mechanism that will l
o encourage implementation of plant modifications offering the most safety for resources spent; help to evaluate and set balanced priorities for an l
o entire set of pending requirements; and i
- o help to avoid duplication of efforts to enhance safety."
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I CLAPlTY i
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" Regulations should be coherent, logical, and practical.
i o There should. be a clear nexus between regulations and agency goals and objectives whether explicitly or implicitly stated.
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Agency positions should be readily understood and easily applied."-
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REPORTABILITY J
l NRC Guidance Should be Consistent l
l Prompt Reports (10CFR 50.72)
Licensee Event Reports (10CFR 50.73) j
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Inspection and Enforcement Should be Consistent l
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t Inspector to Inspector
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Region to Region t
I Degraded Conditions, Operability Determinations, i
and JCO's
- Terminology and Requirements i
need to be worked out.
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More Rewards for Self Assessment j
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RELIABILITY i
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" Regulations should be ' based on the best available o
knowledge from research and operational experience.
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Systems. interactions, technological uncertainties, and the j
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diversity of licensees and regulatory activities must all be 1
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acceptably low level.
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i Once established, regulation should be perceived to be o
reliable and not unjustifiably.in a state of transition.
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Regulatory. actions should always be fully consistent with o
t written regulations and should be promptly, fairly, and j
decisively administered so. as to lend stability to the j
nuclear operational and planning processes."
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I CONCLUSIONS I
i "NRC PRIbCIPLES OF GOOD REGULATION" are also I
i Good Principles for Engineering Support e
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Independence Openness Efficiency i
Clarity
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Reliability i.
NRC and Licensees Working Together as Professionals t
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ENGINEERING syn 8FOSNnt i
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REGION V ENGINEERING 1
MANAGERS FORUM i
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Mike Tresler Diablo Canyon Power Plant - PG&E i
Engineering, Manager l
Room A1400
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333 Market Street San Francisco, CA 94106
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REGION 5 ENGINEERINO MANAGERS' FORUM BACKGROUND i
- APS
- PG&E
- SCE
- SMUD
- WPPS i
PURPOSE e Meet Quarterly e Shared Knowledge / Experience e Unified Position / Working Task Forces e Improve Communication
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e Tech. Eval. Of Supplier Qual. / Deficiencies 'l l
e Spare / Replacement Configuration Control l
e Performance History CGD l
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i e Detection Of Fraudulent Materials
- e Information Exchange
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REGION V
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e Issue Definition / Containment e Shared Experience At All Levels
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e Conflicting Demand On Time e Top Level Participation In Task Forces e
Tension Between " Set Ways" And New Guidance e Documents Must Be Useful & Used O Variability In D.E Org., Staffing, Capability And Responsibility
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ENGINEERING l
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I e Add Plant To Membership j
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l e United Position On Critical Issues l
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ATTACHMENT 4
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1 4
0 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.
people (8) d.
NRC interface (7)
Good encineering organizations prioritize plan effectively allocate resources to their work Elements 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 l
d.
balance reactive and proactive e.
communications, communications, communications f.
key to maintaining design quality and configuration t
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 1
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4 Group 1 2
Elements a,
technical competence b,
proactive assertive engineering c.
communications listen d.
quality of process / product c.
NRC acceptance of acceptable solution f.
escalate professional differences
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Group 2:
Facilitators Harold Gray (NRC), Fred Sears (Northeast Utilities)
Industry participants: 14, NRC participants: 5 Enctors 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 denned with respect to responsibilities and accountabilities Attributes a.
continual improvement b,
economical operation c.
common goals d.
teamwork e.
effective self assessment f.
conformance to requirements g,
well denned, available, usable design basis h.
connguration management i,
lessons learned application j.
new technology usage k.
customer satisfaction Encineerine concerns "riroblems" a.
LTA Design Basis - documentation and organization b.
Resource Management 1.
connicting 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 communications, education, sharing e.
f.
decision tools p.
staff training, development h.
cultivate positive NRC/ utility relation
ltoup 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 solutions of engineering concerns can be reached by good management practices, e.
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.
4
' ' ' ' ' ' ~ "
5 OPERABILITY /REPORTABILITY DETERMINATIONS AND DEGRADED CONDITIONS Group 1:
Facilitators - Jon Johnson (NRC), Wes Bowers (PECO)
Industry participants: 14, NRC participants: 8 i
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 dnign safety function (s) including operation under prescribed accident conditions. The i
determination must be made in a timdy manner.
What is sufficient evidence?
hhte Recommendation / solution Who 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 desien bases?
hate Recommendation / solution M'ho design bases publish design bases standard utility is unbounde<1 including guidance and and component level NRC endorse refine and clarify WRT safety function clarify functional capabilities clarify L'BI clarify difference (if any) operability between design bases for or reportability operability (T.S) and reportability (50.72, 50.73)
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Group 1 6
Timeliness of operability determinations hius Recommendation / solution L'ho unclear process use a two step process utility /INPO (accountability
- 1. screen (operability priority) determination) and
- 2. F/U analysis rerme timeliness publish / endorse guidance NRC/NUMARC guidance
- use STS 1 CO action times use IPE/PRA to prioritize lack of knowledge /
train engineering support utility /1NPO sensitivity to staff timeliness needs Suggestion 3 for imnroved guidance for onnability clarify that the following can be used
- engineering judgement
- test results
- analysis compensatory action operating experience operating parameters
- 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 NUMARC guidance on design basis defmition and examples l
l
7 Group 2:
Facilitators Rich Conte (NRC), Bob llyram (Pp&l.)
Industry participants: 13, NRC participants: 8 permat open forum aired concerns focused on positive aspects
$clected four key concerns positive aspects into process objectives focused on key concerns QbitCli10 assurance of nuclear safety clear expectations communication / action on generic conditions ef0cient and effective mutually agreeable eng involvement in operability /reportability clear and consistent promote initiative / 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 Operability /Reportability major concerns define concepts and terms on operability a,
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 N
Group 2 8
Major concern No.1 Define concepts and terms a.
operability degraded condition workability JCO!BCO 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 hhdor concern Nol - 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 of 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 Maior concern No. 3 - Use of engineeringjudgement 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 c.
make engineers responsible and accountable for the above f.
Initial through final stages of operability determination how is engineering judgement to be applied i
Group 2 9
i Summary a.
disseminate information
- 1. pending guidance
- 2. this conference b,
industry interaction at working level c.
focus on expectation as opposed to prescriptive guidance q
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10 Group 3 Facilitators - 12e Bettenhausen (NRC), Bruce Preston (PSE&G)
Industry participants: 13, NRC participants: 10 What value! criteria do you use for operability determinatioirs design / purchase specs design bsis licensing basis (FSAR, SER, LC, etc.), or safety limit basis (2200oF, containment i
pressure, etc.)?
1.
technical specification values must be used if availab!-
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.
FSAR 80K 3.
Ultimate safety limit i.e., containment pressure 60K can current conditions be used also 1.e., river water temp (heat sink) -
yes Operable ASME code versus tech spec operability pumns 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 unknowrn 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 LCO)
EiDC section 111, class 3 and B31.1 - a thru wall leak of below minimum wall condition does not 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:
Group 3 11 Qualification problems such as these generally Det operability problems electrical separation 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 ooerability calls no new NRC regulations utility develops written policy; elements include:
prompt initial screen by knowledgeable group a.
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 onerability cuidance be promulgated?
1.
NRC incorporate in inspection manual and by generic letter (in progress) 2.
NUMARC/INPO take initiative for industry guidance, e.g., NS AC (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 s.
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12 MODIFICATION PROCESS INCLUDING $0.59 REVIEWS Group 1 Facilitators P. K. Eapen (NRC), Nelson Tonet (DLC)
Utility participants: 6, NRC participants: 6 Discussion tooies 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 nrocess strengths NSAC 125 effective resource utilization weaknesses needs standards needs guidelines for results lacks consistent training required recommendations / comments good DBD, reduce potential for inadequate safety reviews improve NSAC 125 with samples of adequate / good evaluations for short term utility should develop standards individually enhance NRC inspector training 2.
temnorary modificatio0 process strengths timely and effective utilization can help to keep the plant safe provides more effective utilization of resources
Group 1 13 I
weaknesses can bypass modification process l
challenges con 0guration control reviews may lack detail can become numbers game recommendations / comments better define maintenance vs mod upfront good DBDs necord to properly manage process 4,
design change procen i
strengths controlled process maintains DBDs controls plant con 0guration
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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 l
integrated living schedule provides for effective backlog control regulators / inspectors need better training to understand processes conclusions N
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design change process continues to improve
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further training needed
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NSAC 125 enhancements could be benencial effective screening is necessary integrated scheduling can provide more effective resource management L
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14 Group 2 Facilitators - Jim Linville (NRC), Bill Yaeger (Niagara Mohawk)
Industry par:icipants: 7, NRC participants: 4 Strengths of 50.50 process 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 j
50.59 process appears to work well for major modincations Major problem areas difficulty in applying 50.59 process to the modification process commensurate with the nature of the modification major modifications minor modifications temporary modi 0 cations (including electrical jumpers and lifted leads) generic modi 0 cations design equivalent changes non safety related systems DAh maximize safety minimize resource impact Rprommendations 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 i
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15 Group 3 Facilitators - Gene Kelly (NRC), Charles Cruse (BG&E)
Industry participants: 10, NRC participants: 4 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 basis 50.59 process fosters well documented and assessable design basis NSAC 125 Olls long standing void 50.59 enables integrated multi disciplinary review 50.59 process started early helps provide design framework Concerns / problems (in nrioritized order) what is the safety analysis report (scope, detail, referenced documents) 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 123 "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 report, 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)
Problem 2 - does 50.59 process aonly to "as found" design eroblems (design basis respytitution) 50.59 process dsm apply to "as found" design problems develop " tiger team" of small dedicated engineering / licensing group to address "as found" design problems - use screening process A
O Group 3 16 Problem 3 - how far should 50.50 process be ap.pjitd2 resolve problem 1 (SAR question) clarify need for 50.59 process procedure changes temporary mods long term equipment outages (silent mods) develop screening process provide training on screening criteria add step at end of mod process to perform self assessment of 50.59 process Conclusions NSAC 125 is a good start but it need additional clarity what is SAR temporary mods procedure changes in progress work definition of important to safety
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NUCLEAR REQULATORY COMMissl0N T
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November 9.1990 i
Hr. 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 k
We have reviewed the ' Design Besis Program Guidelines' developed by the Nuclear Management and Resources Council (NUMARC) forwarded to us by NUMARC's letters of May 16 July 2, and October 17,1990. We appreciated the opportunity to interface with your staff during the development of the guidelines. We note that your staff was responsive to the coments and concerns that the (l.$. huclear Regulatory Coemission (NRC) staff expressed during the developernt of the guidelines.
We believe that NUMARC's approach will prvvide a useful fraswwork and worth-while insights to those utilities undertaking design basis programs of vsrfous scopes. We share your view that no single best approach exists for a design basis program. We understand that utilities must often address unique situs-tions. Therefore a variety of approaches can satisfy the basic need to develop a centralized loca, tion for design bases information that emphasizes the design intent and provides an index to important design documentation. It is important to stress that a facility should not be modified unless sufficient information is available to demonstrate that adequate design margins will be saintained.
We believe that Section VI of the cuidelines regarding validation of the facility against current design information is of particular immrtance. 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 summarises our thoughts on several areas that the NLMARC guidelines do not address extensively. You any want to consider issuing further NUMARC guidance in these areas as you receive responses frem utilities on use of the guide 11nts.
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 NURIE document will contain factual infomation i
regarding programs as they were being implemented at that time and will des.
cribe program strengths and weaknesses and problems encountered by stilities.
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Mr. Willier H. Rasin t e
We view your deYeloptient of tht Design Basis Program Guidelines' to be &
positive step in an area that will continue to be of great importance.
Sincerely, Original signed by:
William T. Russell, Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation
Enclosure:
NRC Observattor.s of Design Document Reconstitution Programs Distributien:
JMTaylor, ED0 JHSniezek, EDO HLThompson EDO JLBlaha,EDO ELJordan,IE00 JLieberman, OE TEMurleyl NRR FJMiraglia,NRR HRR NRR WTRussel JGPartlow FPGillesple,NRR Dittrutchfleid NRR CD$ryre, NRR JERichardson NRR CERossi NRR BKGrimes,NRk BDLiaw, NRR WDLanning, NRR EVImbro, NRR RAGrasst, NRR Ehbrach,NRR PTMcKee, NRR ETTana NRR-5483 MCBrih ers E00 5483 MKMcAllister,NRR5483 TTMaru.ti,kl MWHodges RI SDEbneter,RI!
AFGibson, RII ABDavis,Rll!
HJMiller, RIII RDMartin, RIV LJCallan, RIY JBnartin, RV RP21 merman, RV Central Files PDR E00 R/F DRIS R/F RSIB R/F Mb
- Seebreviousconcurrence RSIBi RIS SC:RSIB:DRIS C:Pa ; !$
Dd ADT NRR KAMiller*:bt EVImbro*
W)L ing Tech E6 84 WTRussell 10/15/90 10/15/90 4/ /90 10/17/90 1{/f/90 19/(/90 W
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1 ENCLOSURE NRC Cosments on Design Document Reconstitution programs (1) Template Approach
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Thedesigndocumentreconstitution(DDR)processshouldresult$pconfie dence that sufficient design documentation is available (4) to verify the implementation of the design bases, (b) to provide justification that ke design parameters, such as the pump het positive suction head, are ade i
to ensure that a structure quately accounted for in the design and (c) intended safety function. Une system, or component ($50) will perform its approach to developing a system or topical design bases document is to first identify a template of design parameters. Such a template would (a establish and define the functionality and operability requirements of)$$Cs,(b)demonstratetheconformanceof$5Cstothedesignbases,and (c) demonstrate that $$Cs will perform their intended safety functions.
A review could then be performed to establish the degree to which the e
available design documents support the parameters defined in the template.
This process would identify areas that require additional design docur.entation.
(2) Design Document Technical Review-The design document reconstitution program should include a technical review of the supporting design parameters design calculations, and analysts. This technical review would verify that the design documents are technically sound and consistent with the as. built facility. The available design documents should be reviewed to identify areas where design information is technically inadequate or not consistent with the as built facility.
(3) Concept of Essential Desian Documents In performing a design document reconstitution program certain design documents will probably be unretrievable or will contaIn inconsistencies, i
While the hRC does not advocate the regeneration of the complete set of design documents, it is important that certain design documents are available to support plant operation. The design documents in this sat will be referred to as the ' essential design documents
- and are further defined as Category I herein. All Category I design documents must be accurate, and tiose that are unretrievable need to be regenerated.
Category 1 design documents are those documents that are necessary to support or den.cnstrate the conservatism of technical specification values, suc1 as pump flow calculations or setpoint calculations. Additional design documents included in Category I would be those necessary for (a)engineeringorganizationstouseinsupportingplantoperationsand (b) the operators to use in quickly responding to events. Exasples of I
i Category I documents include, but are not limited to, electrical load
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setpoint lists valve lists instrumnt lists,ing and instrumente-fuse lists, breaker Itsts, Q lists, diesel generator lo. d sequencing pip
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tion. diagrams,flowdiagrams,electricalsingle.linediagramsandschamat-its, and breaker and fuse coordination studies.
(4) PrioritiratiponofMissinnorInadeaunteDocuments Use of a prioritization methodology in considering whether to regenerate missing or deficient documents can ensure that the-licensee foches resources on the more safety significant items in a timely menner. An initial screening process would enable the )icensee to determine the significance, effect on plant operability, and reportability requirements related to the sissing or inadequate documentation.
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 syster setpM nts or surveillance requirements. These documents a
ces.cnstrate that the 51Cs addressed by technical apecifications will perform their active safety functions.
Category !! - Design documentation that defines controlling parameters or demonstrates the active functionality of safety-related $$Cs that are not explicitly addressed by the technical specifications, but that support the 55Cs addressed by technical specifications such as heating, ventilating, ar.d air conditioning systems.
Category III - Design documentation that defines controlling parameters or demonstrates ective functionality of safety related S$Cs not included in Categories I or 11.
Category IV - Design documentation that defines controlling parameters or demonstrates the functionality of safety related 5$Cs with regard to passiveconsiderations(e.g.,seismicconsiderations).
Category V - Design documentation that demonstrates the design of non safety $$ts is such that its failure would not impair the functionality of safety-related S$Cs (e.g., seismic 11/1 considerations).
(6) Design bases vs. Desian Document Reconstitution Reestablishment of the design bases without reconstitution of the support-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.estabitsh a continuity among the various levels of desirn information (e.g., design calculations and design bases documents) and w'th the physical plant characteristics of the facility. The DDR program should ensure that the design bases dscuments accurately reflect the source design documents, the design output docu-ments accurately reflect the design bases, and the plant configuration is 49 in accordance with the design output documents.
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This information requiring document reconstitution can be evaluated in-relation to the document categories, as defined herein. The IIRC considers that all Category I essential documents that are inaccurate, unretrievable, or not yet produced should be regenerated in an expeditious manner.
a licensee may be able to generate test data or kse othkr beans HoweYer,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 t;in Category 1 document in a period of time gneurate l
with its evaluttad safety significanca.
A licensee my not need to regenerate design documents for Categories !!
through Y if other supporting inforn tion or test data is available to demonstrate that an 55; can perform its intended safety function. For example, it may not be necessary to regenerate all missing pipe support it can be calculations if, based on reanalysis of a sufficient sampleIf a demonstrated that adequate design margins exist. However, modification 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 modified 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 modiflcation must be regenerated to establish a point of departure for the proposed sedification and to quantify the design margin available following the proposed installation of the modification.
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