ML20045J236
| ML20045J236 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Stenger D WINSTON & STRAWN |
| Shared Package | |
| ML20045J237 | List: |
| References | |
| NUDOCS 9307230218 | |
| Download: ML20045J236 (7) | |
Text
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Mr. Daniel F. StengerO
^Pr41as.190 Winston & Strawn 1400 L Street, N.W.
Washington, D.C.
20005-3502
Dear Mr. Stenger:
Thank you for your letter of March 23, 1993, in which you offered suggestions regarding the scheduling and conduct of NRC major activities at reactor facilities.
As a representative of the Nuclear Utility Backfitting and Reform Group (NUBARG), you are aware that the changes made to the NRC Inspection Manual in the area of controlling team inspections were initiated as a result of the Regulatory Impact Survey.
In our progress report of August 18, 1992, to the Commission regarding implementing activities in response to the Regulatory e that we would reevaluate the limits established in ImpactSurvey,weindicatf_0T)aspartoftheregularinspectionprogram Inspection Manual Chaptert 03 reviews and modify the limits as necessary to ensure they are appropriate.
(See SECY-92-286, Enclosure 1, Item 7.)
As you noted, we have initiated a broad review of the reactor inspection program, starting with the assessment conducted by the Office of Policy Planning (0PP).
In addition, the Regulatory Review Group (RRG) will consider, among other matters, how regulations are applied in the licensing and inspection process. Also, since December 1992, the Office of Nuclear Reactor Regulation (NRR) has been conducting a self-assessment of the reactor inspection program, which includes many of the elements discussed in your letter.
I intend to integrate the findings from NRR's self-assessment, any RRG comments regarding the inspection program, and the OPP recommendations in order to develop and implement appropriate adjustments to the reactor inspection program.
The staff has considered each of your suggestions and has developed comments on the four specific areas you identified.
Staff comments are provided in the enclosure. We will give your suggestions further consideration in our development of changes to the inspection program.
Orig nal si ed by haE ! N.
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or Executive Director dM/S for Operations
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SIAFF COMMENTS ON NUBARG SUGGESTIONS 1.
Definition of Major Activities Major activities are defined as visits to commercial reactor sites by a group of four or more personnel for five or more days for the purpore of inspecting, conducting research information visits, conducting licensing audits, or other activities requiring significant licensee input or interactions.
The intent of this definition is to include activities such as pilot inspections, audits, and follow-up.
We do not object to modifying the limitation of four or more persons for five or more days.
In actual practice, we would consider teams of four or more persons inspecting for 20 or more person-days to comprise a major activity. However, we believe that a limitation expressed only in person-days is not appropriate.
For example, one inspector on site for seven weeks is not, in our opinion, a major activity. On the other hand, three inspectors on site for several weeks may qualify as a major activity, at least from the standpoint of requiring significant licensee input or interactions. The staff will study this matter and determine if the limitation can be phrased to relate more closely to impact on licensees.
i 2.
Imolementation/Schedulino of Major Activities The staff prepares preliminary schedules for team inspections which take into consideration major activities, as well as other activities such as initial and requalification operator examinations, emergency preparedness exercises, INP0 visits, plant outages, and visits of lesser duration.
The objectives of the preliminary schedule are to avoid scheduling conflicts and to minimize any significant impacts on licensees.
We are working on improvements to scheduling inspections and other activities affecting licensees. As part of our assessment of the implementation of the inspection program, we are receiving feedback and suggestions regarding the use of the Master Inspection Planning System (MIPS).
We are also receiving feedback from licensees on how well regional offices are scheduling, including whether there is an increase in inspection activity near the end of a SALP period.
Regarding your specific suggestions:
A.
We are not in a position at this time to specify a minimum period of time between team inspections.
Since the current standard is no more than four major activities per SALP period, and SALP periods can be as short as 12 months, one could assume that major activities would occur, on the average, no more frequently than once per 1
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(J~Y quarter. Major team inspections are a subset of major activities and would be expected to occur less frequently. Therefore, we may be able to provide guidance yh criteria to regional offices that they should strive to schedule major _ team inspections with a minimum period of four to six months between the inspections.
B.
We' agree that better use of MIPS would be beneficial. As part of the assessment process, we are evaluating the implementation of.
MIPS, as well as the effectiveness of this system as a scheduling tool, and will make necessary improvements.
C.
With respect to prior notification to licensees, under Inspection Manual Chapter 0300, " Announced and Unannounced Inspections," the staff provides advanced notification for major team inspections as much as 9 months but, in general, at least 2 to 3 months before conducting the inspection. We are in the process of developing a system to publish the MIPS for each licensee that would project NRC activities for about six months. We believe that these actions.
should serve to provide sufficient notification to licensees of scheduled inspections.
In addition, licensees are aware that they.
may be subject to major team inspections with the publication of the NRC Inspection Manual Temporary Instructions covering such activities.
Licensees have used this knowledge to conduct self-assessments in advance of the NRC inspection.
Scheduling as much as a refueling cycle in advance would create a significant burden on j
the NRC due to the need to respond to events and issues with limited resources.
Some team inspection programs conducted in response to such events or issues are completed in less than a refueling cycle.
D.
We agren that major inspection activities should not be scheduled during plant outages unless, of course, the objectives of the inspection can be satisfied only during an outage.
l 3.
Acolication of Limitations to Multi-Unit Sites and Multiple Plant Sites i
It is the intent of Chapter 0301 that the limitations on major activities apply on a site basis unless the units at the site are of different design or orcrated under different management programs. With i
respect to obtaining relief for a licensee with multiple sites, a l
licensee may request a change in the planned schedule of an inspection.
Inspection Manual Chapter 0300, Section 05.04 discusses this matter.-
4.
Continuina Review of Inspection Burden j
I The staff has initiated a program to review the results and
(
effectiveness of a major team inspection program after some experience has been gained.
For example, the Service Water System Operational Performance Inspection described in Temporary Instruction 2515/118 was initiated in December 1992. A review will be performed by September 1993. This review will not be performed from strictly a cost 2
O o
effectiveness standpoint, but costs to both NRC and the licensees will be considered.
Instructions for recent major team inspections have included provisions for a reduction in the scope of an inspection or a waiver of the inspection based upon taking credit for recent NRC inspections with equivalent scope.
The Commission is considering a procedure that would allow a licensee to perform a self-assessment in lieu of an area of emphasis team inspection being performed by NRC.
In such a case, NRC could audit the performance of the licensee's assessment or review the results and corrective actions.
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5 B.
Schedulina and Control of inspections. especially team inspections Issue - Concerns were raised concerning the number of NRC onsite activities. Specific concerns focused on the scheduling and control of NRC onsite activities, especially team inspections.
Action / Description Status / Lessons learned 6.
Revise Inspection Manual Chapter (IMC) 0301, Completed The staff revised IMC 0301 on September g
" Coordination of NRC Visits to Commercial Reactor 30, 1991.
Sites" to expand guidance to provide controls to cover all types of major NRC visits and clearly define the types of major activities for which the restrictions apply. The manual chapter limits the number of major team inspections that may be eg conducted during a licensee SALP cycle without yg xg senior regional and program office concurrence to A
four per SALP cycle.
In light of the potentially y) equally significant impact of major non-inspection activities such as research information visits or b
licensing audits, the guidance will be expanded to
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provide controls to cover all types of major NRC 7
visits.
)g 7.
Reevaluate the limits established in IMC 0301 Ongoing.
Reviews of inspection program h
as part of regular inspection program reviews and implementation performed to date indicate that y
modify them as necessary to ensure they are major activities are being controlled and scheduled g
appropriate. This action addresses concerns in accordance with IMC 0301, and established expressed by the industry that the number of major guidelines appear appropriate.
N NRC visits to sites permitted without management review and approval should be further reduced.
UNITE 38TATES 8
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EDO Principal Correspondence Control
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FRON:
DUE:
EDO CONTROL: 0008704 DOC DT: 03/23/93 FINAL REPLY:
Nicholas S. Reynolds Counsel to the Nuclear Utility Backfitting Cnd Reform Group To:
James M. Taylor FOR SIGNATURE OF:
- GRN CRC NO:
Ex0cutive Director DESC:
ROUTING:
REQUEST SOME NEEDED CLARIFICATION OF THE Taylor LIMITATIONS ON " MAJOR ACTIVITIES" SET FORTH IN Sniezek CHAPTER 0301 OF THE NRC INSPECTION HANUAL Thompson Blaha
.DATE: 03/26/93 Knubel Bateman ASSIGNED TO:
CONTACT:
Vollmer, OPP NRR Murley Jordan, AEOD SPECIAL INSTRUCTIONS OR REMARKS:
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