ML20154H755
| ML20154H755 | |
| Person / Time | |
|---|---|
| Issue date: | 01/17/1986 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20154H686 | List: |
| References | |
| NUDOCS 8603100368 | |
| Download: ML20154H755 (2) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION p-
/;
b,.
f REGloN IV k,
af 811 RYAN PLAZA DRIVE. SUITE 1000 ARLINGTON. TEXAS 78011 JAN 171986 MEMORANDUM FOR: James E. Taylor, Director Office of Inspection and Enforcement FROM:
Robert D. Martin, Regional Administrator
SUBJECT:
EQUIPMENT QUALIFICATION (EQ) INSPECTION AND ENFORCEMENT PROGRAM During the meeting with your staff on this matter in early December it was stressed how urgently we need to develop an enforcement policy for handing EQ matters.
I would like to add emphasis to the point recently made by Vic Stello. Rather than building an enforcement policy by accretion, which caused difficulty with Appendix R compliance questions, we should very quickly put together hypothetical examples for each severity level and get Comission approval. Then as EQ inspections progress and examples of potential violations are identified, they should be broadly distributed soon after the inspection along with the underlying rationale for the characterization of each finding. I believe this mechanism would result in a well understood enforcement policy that can be consistently applied in all regions.
I suggest that a system of EQ Enforcement Guidance Memoranda, serially numbered and revised as necessary, be used to enable the examples to be collected and controlled until an IE manual chapter or NUREG is issued to define and describe the EQ enforcement policy. EQ EGMS between revisions of the MC or NUREG could keep the policy current.
In addition to guidance on the characterization of findings, I feel that we need a better definition of the relationship between the equipment qualification status of a piece of equipment, its technical specification operability and the allowed grace period in LCO's. Operability traditionally was demonstrated by surveillance and the allowable grace period for continued operation with inoperable equipment was tied more or less loosely to the magnitude of increased risk caused by the equipment outage. With 50.49 in effect, it appears now that operability requires not only a successful surveillance test at the appropriate interval but also that the environmental qualification of the equipment can be demonstrated.
Since environmental qualification ensures that safety equipment can perform its function in the harsh environment, it seems reasonable that the increase in risk caused by a failure to demonstrate environmental qualification is dependent on the probability of the harsh environment coupled with probability of that piece of equipment having to perfonn its safety function. This combined probability probably results in an increase in risk that is one or two orders of magnitude smaller than the additional risk for the equipment being functionally inoperable.
0603100360 060224 PDR ORG NRRC
4 ii e
2.
This leads me to conclude that it would be appropriate to permit a longer grace period under the LCO if equipment inoperability has been caused solely by an EQ issue. For example, if a particular component is found to be i
. functionally inoperable by a surveillance test and the LCO requires that the plant be shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> unless operability is restored, then the LCO l
should say that if inoperability is due to a failure to demonstrate environmental qualification the plant shal.1 be shutdown within 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, 600 i
hours or some other multiple that represents the difference between the probabilities discussed above.
I l
I would appreciate receiving your views on these connents.
9 l
~
i Ywf/4}]l S
Le u l
Robert D. Martin i
Regional Administrator cc:
H. R. Denton, D/NRR T. E. Murley, RA, RI J. N. Grace, RA, RII l
J. G. Keppler, RA, RIII J. B. Martin, RA, RV J. H. Sniezek, EDO 1
i i
l f
l
-