ML20054D230
| ML20054D230 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/1981 |
| From: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19239A281 | List: |
| References | |
| FOIA-81-405 NUDOCS 8204220461 | |
| Download: ML20054D230 (7) | |
Text
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4'n UNITED STATES
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NUCLEAR REGULATORY COMMISSION g
,p WASHINGTON, D. C. 20555
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MAR 3 1981
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e MEMORANDUM FOR:
Darrell G. Eisenhut, Director, Division of Licensing Office of Nuclear Reactor Regulation FROM:
Norman C. Moseley, Director, Division of Program Development and Appraisal Office of Inspection and Enforcement i
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SUBJECT:
DRAFT TI, TMI ACTION PLAN, IE POST-IMPLEMENTATION REVIEW ITEMS Enclosed for your information is a copy of the subject draft TI that we plan to distribute to our Regional Offices for implementation.
Preliminary details.
re16 ting to this matter were discussed in my memoranda to you dated December 29; 1980 and January 26, 1981. The TI includes provisions for distributing completed saiety evaluation reports to NRR.
Therefore, the name and title of the individual designated to receive ~~the SER's is requested. Any tpecific comments relating to the draft TI will also be appreciated.
All individuals identified on the distribution of'tiiis memorandum are also requested to submit comments as appropriate.
In order to meet our scheduled TI distribution date, all comments should be forwarded to F. Nolan of my staff by the close of business on March 9,1981.
t 1pg g rryO~
0" y j Norman C. Moseley Director Division of Program Development and Appraisal Office of Inspection and Enforcement
Enclosure:
Draft TI cc w/ enclosure:
J. Taylor, IE J. H. Sniezek, IE S. E. Bryan, IE J. C. Stone, IE E. Blackwood, IE M. Wilber, IE D. Allison, IE R. Emch, NRR J. Olshinski, NRR fjj4jg61 01111L, SHOLL Y81 *-405
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- U.S. NUCLEAR REGULATORY COMMISSION 3_-
0FFICE OF INSPECTION-AND. ENFORCEMENT "U-INSPECTION TND E'FORCEMENT MANUAL N
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TMI ACTION PLAN, IE POST-IMPLEMENTATION REVIEW ITEMS TI 2515/
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A.
OBJECTIVE The objective of this TI is to identify four specific TMI Action Plan items for which IE has. sole responsibility for: review and evaluation of licensee proposed programs and preparation of IE Safety Evaluation Re;5 orts (SER's) and to provide guidance that will enable the inspector to complete-this efforf.
B.
BACKGROUND INFORMATION R. C. DeYoung's memorandum of April 29, 1980, to IE Division Directors and Executive Officers defined the TMI Action Plan tasks which involve IE.
In addition, S. E. Bryan's memorandum of January 22, 1981, to' Regional Directors provided information concerning IE post-implementation review and evaluation of certain action plan items. One of the items identified in Mr.. Bryan's memorandum was subsequently deleted.as described in a memorandum, N. C. Moseley to D._Eisenhut, dated January 26, l'981.. ' Regional Directois were listed on the
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distribution of that: memorandum.
C.
IE EFFORT As discussed in Section B, IE has sole responsibility for the evaluation and acceptance of licensee proposed actions and preparation of related Safety Evaluation Reports for the four task action plan items that are identified in Enclosure I.
The licensee programs accepted by IE must be in substantial agreement with the NRC acceptance criteria referenced in Enclosure I.
The SER must identify the specific documents that were reviewed by the inspector and the acceptance criteria used to judge acceptance.
The SER must also describe any deviation from the defined acceptance criteria and justification for accepting the deviation. A general SER format is provided as Enclosure 2.
In order to standardize this IE effort, lead responsibilities for the four items is assigned to the following Regional offic'es:
RI - Item 1.A.l.3, Shift Manning, Part 1, Limit Overtime RII - Item 1.C.5, Feedback of Operating Experience RIII - Item II.K.3, Final Recommendations, B&O Task Force, Part 22.a.
Verify Procedures For RCIC Suction.
RV - Item 1.C.6, Verify Correct Performances of Operating Activities Each Region assigned lead responsibility should name one individual to take overall responsibility for completion of this assigned task. This individual will serve as the focal point for all Regions and will have responsibility for rasolution of any nonconformance or nonuniformity of comitments and detennina-tion of acceptability of any compensatory actions to be initiated by IE.
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r TI 2515/
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The lead Region.should contact Messrs. E. Blackwood (Items 1.A.l.3 and 11.1C.3, 22.a) and M. Wilber (Items 1.C.5 and 1.C.6), Division of Resident and Regional Reactor Inspection, IE, for policy matters involving clarifi-cation of acceptance criteria and proposed compensatory actions.
Completed SER's should be signed by the Director, Division of Resident and Project Inspection or counterpart in each Region and then forwarded to the appro-priate lead Region for concurrence. Unsatisfactory SER's should be returned to the originator.for correction as appropriate.
SER's acceptable to the lead. Region should be forwarded to
, NRR with a copy to Messrs. Blackwood (Facilities in RI and RIII) or Wilber (Facilities in RII, RIV and RV) and the NRR Project Manager for the assigned facility.
For those licensee proposals that are not in agreement with the referenced acceptance criteria, the inspector should review with senior onsite licensee representatives specific details regarding the deficiencies.
If the item remains unresolved, the inspector should prepare an SER transmittal memor-andum that identifies the jtem(s) of.gontention and.the licensee's comments.
This package should be forwarded to the lead Region for review and trans-j mittal to Messrs. Blackwood:or b'ilber for concurrence in the recommended compensatory action.
We note that inspection of these items was addressed by Revision 2 of TI 2515/42.
D.
REPORTING REQUIREMENTS A separate SER, applicable to a specific site, must be prepared for each item.
I Therefore, additional detail do not have to be documented in an inspection report.
E.
EXPIRATION The IE review and evaluation of licensee items and preparation of a related SER should be completed by June 1,1981.
For record purposes this TI will be cancelled on October 1, 1981.
F.
IE HEADQUARTERS CONTACT Questions regarding this TI should be addressed to F. J. Nolan (492-8019)
G.
TRACKING SYSTEM INPUT For module tracking. system input (766 Data), record actual time spent for evaluation and SER preparation against module number 255XXB.
In addition, completion status of each item should be entered in the TMI Action Plan Tracking System.
Enclosures:
1.
IE Review Items
-2r SER Format
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TI 2515/
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Issue date:
Page 1 of 1 l
ENCLOSURdI'
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TMI ACTION PLAN - IE REVIEW ITEMS Task Subject References IE Effort itemarks 1.A.1.3(1)
Shift Manning NUREG-0737,
' Review and evaluate Licensee was (LimitOvertime)
Pages 3-6 and the licensee's Program /
required to subm) 37, IE Circular Policy.'for overtime work information to N 80-02, letter froni and assure conformance-by 11/1/80 Eisenhut dated 7/31/80 with references 1.C.5 Feedback of NUREG-0737, Review and evaluate No Licensee operating experience Pages 3-47 and the licensee's Program /
submittal requir(
3-48; NUREG-0660, Policy concernirig the 1
Item 1.C, Section.
feedback of operating B.5, and Eisenhut.
experience to the plant letter dated 5/7/80 staff and assure con-formance with references l.C.6 Verifying correct NUREG-0737, Review and evaluate N'o licensee performance of Pages 3-49 4'nd 3-50; the licensee's Program /
submittal requir(
operating activities NUREG-0660, 'I tems -
Policy for verifying 1.C.6 and 1.D.3;.
the correct performance and NUREG-0585, of operating activities and assure'conformance Reconmendation 5.
with the references II.K.3 (22a)
Final Recommendations NUREG-0737, Review and evaluate Limited to BWR B&O Task Force Pages 3-167;NUREG-0626, the licensee's proce-facilities (Procedures for RCIC Recommendation B.1; and dures for manual oper-Suction)
Eisenhut letter dated ation of the RCIC system 5/7/80 and assure conformance with references;;
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TI 2515/
Issue date:
Page 1 of 3 ENCLOSURE ~2-c c-: :a SER FORMAT h.
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COVER PAGE s
TITLE:
IE REVIEW AND EVALUATION OF LICENSEE CONFORKANCE WITH TMI ACTION PLAN REQUIREMENTS 5..
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT UTILITY FACILITY UNIT N0 DOCKET NO Signature:
, Director, Division of Resident i
and Project Inspection, RI Date:
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o TI 2515/
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Page 2 of 3
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I.
INTRODUCTION In memoranda from N.C. Moseley to D. G. Eisenhut dated December 29, 1980 and January 26, 1981, the Office of Inspection and Enforcement agreed to review and evaluate operating reactor licensees' proposals for four TMI Action Plan items.
The four items, as defined in NUREG-0737, 'Clarifica-tion of TMI Action Plan Requirements, November 1980, are the following:
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Item 1.A.l.3 Shift Manning, Part 1, Limit Overtime (2)
Item 1)C.5, Feedback of Operating Experience (3)
Item 1.C.6, Verifying Correct Performance of Operating Activities (4). Item II.K.3, Final Recommendations, B&O Task Force, Part 22.a.
Verify Procedures for RCIC Suction For the
~ Station, our review and ' evaluation of the
' licensees commitments for Item 1.A.l'.3 are described below.
Inspections to
~. verify compliance;with these commitments are documented in inspection reports.
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II. EVALUA' TION Item 1.A.l.3, Shift Manning, Part 1, limit Overtime We reviewed the licensee's program as described in a letter of March 12, 1981 from to We compared the program to the criteria and guidance provided in the following documents:
1.
NUREG-0737, Clarification of TMI Action Plan Requirements, November 1980, ar)d Enclosure 3.
2.
Letter from D. G. Eisenhut to all licensees dated July 31, 1980 (Included in 1).
3.
IE Circular No. 80-02,-February.1,1980 (Included in 1).
Generally, the licensees program complies with the Guidance and Acceptance Criteria - namely that for individuals in safety related work:
An individual will not be permitted to work more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight.
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b.
There will be a break of at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> between all work periods, An individual will not be required to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any c.
7-day period.
d.
An individual will not be required to work more than 14 consecutive days without having 2 consecutive days off.
For special circumstances that reguire deviation from the above, Circular 80-02 indicates that the exceptions should be approved by the Station Manager.
The 1.___
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TI 2515/
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Page 3 of 3 procedure which_ has been approved by the Station Manager, recognizes one
- 'such circumstance concerning periods of inclement weather when sufficient relief personnel may experience difficulty in traveling to the site.
During these periods, qualified personnel may be required to work more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight until appropriate relief arrives.
We note that
- this exception has been approved by the Station Manager as required by our criteria.
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. Based on our review we have found that the licensees program meets the criteria for this action plan item.
Therefore, we consider it acceptable.
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