ML20197G366
| ML20197G366 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1997 |
| From: | Jeffrey Jacobson NRC (Affiliation Not Assigned) |
| To: | Richards S NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9712310002 | |
| Download: ML20197G366 (15) | |
Text
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December 15,_199i se MEMORANDUM TO: Stuart Richards, Chief Events Assessment, Generic Communications and SpecialInspection Branch THRU:
Donald Norkin, Section Chief Events Assessmen.t. Generic Communications and SpecialInspection Branch FROM:.
Jeffrey Jacobson, Senior Operations Engineer l original signed by l Events Assessment, Generic Communications and SpecialInspection Branch
SUBJECT:
ATTENDANCE AT REGION I ENGINEERING MANAGER'S FORUM On December 10,1997, I gave a presentation entitled " Configuration Management issues identified During NRC Design inspections" to the Region i Engineering Manager's Forutn. In attendance were approximately 45 individuals, mostly engineering managers from Region I and Region ll licensees. A copy of the presentation is attached to this memorandum.
The presentation focused on the types of programmatic weaknesses we have seen in the configuration managsment area during the conduct of our inspections, as well as some specific root causes. The presentation was well received by those in attendance and provided a benefit to those licensees that may not be subject to an NRC design inspection.
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December 15, 1997
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MEMORANDUM TO: Stuart Richards, Chief Events Assessment, Generic Communications and SpecialInspection Branch
--THRU:
Donald Norkin, Section Chief Events Assessmen.t, Generic Communicatiws
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and SpecialInspection Branch
- FROM:
Jeffrey Jacobson, Senior Operations Engineer -l original signed by l Events Assessment, Generic Communications and SpecialInspection Branch
SUBJECT:
ATTENDANCE AT REGION l ENGINEERING MANAGER'S FORUM
. On December 10,1997, I gave a presentation entitled " Configuration Management issues identified During NRC Design Inspections" to the Region i Engineering Manager's Forum. In attendance were approximately 45 individuals, mostly engineering managers from -
Region I and Region ll licensees. A copy of the presentation is attached to this memorandum.
The presentation focused on the types of programmatic weaknesses we have seen in the configuration management area during the conduct of our inspections, as well as some specific root causes. The presentat:en was well received by those in attendance and provided a benefit to those licensees that may not be subject to an NRC design inspection,
Attachment:
As stated Distribution: (.Il u t/ 4 g A/.c 4 c.e,,/)
. Central File PECB R/F
~JJacobson DNorkin PDR DOCUMENT NAME: G:\\JBJ\\PRESMEM To receive a coay of this document, indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = No copy OFFICE PECB PECB
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JJacobsd[f DNorkin DATE 12/s 12[167 OFFICIAL RECORD COPY i
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6 CONFIGURATION MANAGEMENT ISSUES IDENTIFIED--
DURING NRC DESIGN INSPECTIONS 4
JEFFREY JACOBSON, NRR PRESENTED TO REGION ONE ENGINEERING MANAGER'S FORUM ON DECEMBER 10, 1997
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PRESENTATIOrl OVERVIEW U
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- DEFINITION OF CONFIGURATION i
MANAGEMENT l
l EXAMPLES.OF CONFIGURATION l
MANAGEMENT SYSTEMS GRAPHS OF INSPECTION FINDINGS SORTED BY CAUSE, DISCIPLINE, AND NSSS PROGRAMMATIC CATEGORIES OF WEAKNESSES OBSERVED DURING NRC DESIGN INSPECTIONS AND POTENTIAL ROOT CAUSES 8
l DEFINITION OF CONFIGURATION MANAGEMENT l
CONFIGURATION MANAGEMENT INCLUDES i
SYSTEMS, PROCESSES, AND PROCEDURES l
NECESSARY TO:
ENSURE THE ADEQUACY OF THE ORIGINAL DESIGN - THAT THE DESIGN CONFORMS TO SPECIFICATIONS AND REQUIREMENTS l
CONVERT THE ORIGINAL DESIGN IN TO AN AS-BUILT OPERATIONAL FACILITY CONTROL THE INTEGRITY OF THE DESIGN AND THE AS-BUILT FACILITY -
TO ENSURE THAT THE DESIGN IS NOT COMPROMISED BY IMPROPER l
OPERATION OR MODIFICATION
1 EXAMPLES OF CONFIGURATION MANMIEMENT SYSTEMS, PROCESSESm AND PROCEDURES l
DESIGN CONTROL PROGRAM MODIFICATION. CONTROL PROGRAM TAGOUT AND EQUIPMENT STATUS CONTROL PROGRAMS OPERATING AND MAINTENANCE PROCEDURES DRAWING AND PROCEDURE CONTROL PROGRAMS CORRECTIVE AQTION SYSTEM - (1)
USED TO IDENTIFY CONFIGURATION DISCREPANCIES AND (2) PROVIDE i
FEEDBACK ON CONFIGURATION MANAGEMENT SYSTEM EFFECTIVENESS
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4 INSPECTION FINDINGS BY CODE. ALL NS$$
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q Finding CodeDescription a original design error b design documentetion discrepancy c calculation error (other than onginal design) diack of supporting documentation e original design implementation error f system modification error g not operated in accordance with heensing basis himproper maintenance i inadequate corrective acteon j inadequate procedure l
k inadequate technical specification 1 inadequate testing m
FSAR discrepancy nPost TMI Upgrade error oinadequate 60.69 pundergoing staff review gother l
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1 Idechanical Findings 28.
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FINDINGS BY NSSS - NORMALIZED FOR NUMBER OF SYSTEMS REVIEWED l
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P_RQ_GBAMMATIC CATEGORIES OF WEAKNESSES IDENTIFIED DURING NRC DISIGN-INSPECTIONS l
QRIGX4ALDESLGN ERRORS PO, t jTIAL CAUSES:
INADEQUATE CONTROL AND SPECIFICATION OF INTERFACES ASSUMPTIONS NOT APPROPRIATELY VALIDATED LACK OF A SYSTEMS BASED APPROACH TO DESIGN f
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INADEQUATE CORRECTIVE ACTION l
POTENTIAL CAUSES:
LACK OF EXPERIENCE / KNOWLEDGE IN CORRECTIVE ACTION PROGRAM EVALUATORS - SYSTEM DESIGN NOT UNDERSTOOD L
RESPONSIBILITY FOR EVALUATION NOT l
CLEARLY DELINEATED SIGNIFICANCE OF DESIGN ISSUES NOT L
COMMUNICATED TO EVALUATORS CORRECTIVE ACTIONS LIMITED DUE TO i
BUDGETARY OR OPERATIONAL CONCERNS INEFFECTIVE ROOT CAUSE ANALYSIS
INADEQUATE 50.59 EVALUATION i
POTENTIAL CAUSES:
BREADTH OF ISSUE NOT FULLY UNDERSTOOD DESIGN REVIEWS OVERLY COMPARTMENTALIZED
- l DESIGN BASIS DOCUMENTATION INADEQUATE TO ALLOW FOR THOROUGH EVALUATION L
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1 INAD_l!QUATE TESTING OF SAFETY RELA 7ED COMPONENTS i
l POTENTIAL CAUSES:
ALL SAFETY FUNCTIONS OF i
COMPONENT NOT UNDEPSTOOD i
COMPONENTS ROLE IN ACCIDENT l
MITIGATION NOT CLEARLY DELINEATED TESTING NOT PERFORMED UNLESS L
REQUIRED BY TECH SPECS.
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4 INCONSISTENCIES IN IMPLEMENTATl.ON OF ACCIDENT EVALUATION MODELS POTENTIAL CAUSES:
4 SYSTEM INTERFACE BETWEEN LICENSEE AND MODEL VENDOR i
I ASSUMPTIONS NOT APPROPRIATELY VERIFIED REPORTING REQUIREMENTS NOT FULLY l
UNDERSTOOD REVIEW RESPONSIBILITIES NOT l
CLEARLY DELINEATED 1
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l OTHER POTENTIAL CAUSES FOR DESIGN WEAKNESSES i
EFFECTIVE ASSESSMENTS OR AUDITS OF CONFIGURATION MANAGEMENT PROGRAMS NOT PERFORMED i
ORIGINAL DESIGN ASSUMED TO ALWAYS BE CORRECT PRO-ACTIVE ASSESSMENTS OF AS-BUILT DESIGN NOT PERFORMED COR i
WHEN PERFORMED ARE NOT RIGOROUS;l CONFIGURATION MANAGEMENT ASSUMED TO BE SOLELY AN ENGINEERING FUNCTION 4
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