ML20206U930
| ML20206U930 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/1986 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8607110241 | |
| Download: ML20206U930 (4) | |
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JUL 071986 i
i MEMORANDUM FOR:
James G. Partlow, Director, Division of Inspection j
Programs, Office of Inspection and Enforcement l
l FROM:
Dennis Kirsch,. Director, Division of Reactor Safety and j
Projects, Region V -
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SUBJECT:
COMMENTS ON DRAFT TEMPORARY INSTRUCTION 2515/XX, "PRA
' DIRECTED OPERATIONAL ASSESSMENT AND READINESS INSPECTIONS"
REFERENCE:
Your memorandum dated May 28, 1986 We have reviewed the subject' document and Mr. Toth of my staff has discussed our comments with Mr. McKee of your staff on June 3, 1986. We understand that the subject TI will probably not be issued in its present form (which casts PRA considerations as a separate and unique inspection). Rather, we-4 understand that the TI may be issued as a document which defines the various
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types of team inspections which may be conducted, recognizing that PRA considerations are only one element of several which enter into the decisions e
of sample selection for either individual or team inspections. The PRA related guidance in the subject TI appears useful, but more appropriate to the NRC training forum.
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We further note that the draft TI is a recast of inspection guidance i
previously issued, e.g.
Mr. Taylor's October 31, 1985 " Guidance for Conducting Team Inspections" and your April 2, 1986 " Safety System Functional
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Inspection Approach." If so intended, the TI should clarify if it supersedes i
such existing direction.
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i 8607110241 860707 l
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MISC IE 22
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A JUL.071986 Our specific comments on the subject draft TI are included in the attachment to this memorandum.
Originc! signed by D.F. K!:xh Dennis Kirsch, Director Division of Reactors Safety and Projects
Attachment:
As stated bbe w/ enclosure:
A. Toth N. Western (RV-86-301)
RSB/ Document Control Desk (RIDS)
G. Cook B. Faulkenberry J. Martin Region V g
As
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13 AToth/ norma ate DKirsch 7/ / /86 7/2,/86 7/1)/86 o
COMMENTS ON TI 2515XX PRA DIRECTED OPERATIONAL ASSESSMENT AND READINESS INSPECTIONS General - The subject TI does not thoroughly reflect applicability of all relevant SALP functional areas. The results of team inspections should be cast into SALP categories to aid in the incorporation into annual appraisals, and to reflect the increasing NRC emphasis on SALP and associated performance indicators. The planning and conduct of the inspection should also reflect the SALP consideration. Table A-3 should be adjusted to reflect appropriate SALP headings, as should the discussion in sections 3, 4 and 6.
General - The inspection preparation discussions should provide more guidance to the team for selecting inspection elements (line items) from existing IE modules and supplementing these with additional lines of inquiry developed during the preparation phase.
It should emphasize that every inspection effort must be assigned to an existing IE inspection module number for l
compliance with manpower reporting system rules.
Specific candidate modules should be discussed under each heading of section 4.
Section 2.02 - The OAR inspection appears similar to the SSFI type inspection except that its suggested scope of considering 20 to 60 potential events would appear to preclude the intensive technical review of system design changes typical of the SSFI approach. The number of events / components appears excessive for a multi-discipline intensive review of activities conducted over a long historic period.
Section 2.03 - The required size of the inspection team appears to be too small to effectively probe deeply into all the related SALP functional
. A team of closer to 8-10 seems more reasonable as discussed in Mr.
areas.
Partlow's April 2, 1986 SSFI guidance.
Section 3.03 - The inspection preparation is an important part of the team inspection, but'the mechanics of team preparation are limiting with respect to conflicting program-goals and administrative support.
Ideally, the team would convene at a central location where reference resources are available and where the team members can interact on a continuous daily basis. The team may consist.of regional ' office staff, consultants and resident inspectors at distant locations from the regional office, and NRC headquarters staff. Travel funds for a full week of preparation activities at the regional office may be limiting. Program objectives of maximum on-site direct inspection effort (DIE) by residents will be compromised by the additional off-site time required for inspection preparation. For Region V these constraints are significant in FY 86-87 and team preparation activities have, and will likely in the future, be required to be performed by individuals working at their normal duty stations. This requires special efforts by an inspection planner / coordinator to obtain references in advance, carefully assign specific individuals to perform specific data base reviews, carefully pre-define the scope of the inspection and pre-assign individuals for particular inspection items.
Frequent telephone conference calls to provide team interaction during the preparation phase, and efforts to consolidate and integrate individual inspection plan elements are necessary.
Section 4.04 - This appears to be an overly general and vague requirement to review the quality assurance and administrative control program.
It is not
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4 shown in Table A-3 as a separate effort, although it'does reflect a specific SALP functional area. Many of the items listed belong under the other specific areas of sections 4.01 and 4.02 (which should be recast into i
relevant SALP functional areas). The QA and Administrative area appears to be an appropriate one for consideration by the Team Leader, who should have 50% of his time available for inspection activities (the other 50% consumed by team coordination activities). He could focus on committee activities in general and associated with the specific sample events addressed by.the inspection plan, and related quality ass
- e audits, quality control systems, and corrective action systems.
Appendix A - This Appendix describes selection of an inspection, sample based upon plant specific PRA studies. The detail appears inappropriate for a TI.
Existing NRC training programs should continue to be relied upon to equip individual inspectors with the knowledge of how to utilize an existing'PRA to identify important safety components.
Table A This table illustrates a useful approach to assign inspection responsibilities to individual team members, ano it is generally amenable to grouping by SALP functional areas. There are alternate and additional 4
functional area headings which should be considered. A sample matrix, similar to Table A-3, would be useful to illustrate applicability of individual line items of applicable inspection modules for each potential event or j
system / component.
Appendix C - This Appendix is a laundry list of data, which appears inappropriate for a TI.
However, the information in Appendix C may be useful j
as long as it is not construed as a requirement.
Appendix D - This Appendix is incomplete in that it implies that only the ten 4
l listed IE modules need be considered. Actually, many more of the MC 2515 l
series of inspection modules are candidates for selection of inspection line item elements to-be incorporated into detailed inspection plans.
(We have identified at least 28 modules which appear appropriate for consideration for an SSFI type inspection.)
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