ML20212J843
| ML20212J843 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1999 |
| From: | Spector A NRC (Affiliation Not Assigned) |
| To: | Madison A NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20212J847 | List: |
| References | |
| NUDOCS 9910060009 | |
| Download: ML20212J843 (12) | |
Text
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September 28,1999 .
MEMORANDUM TO: Alan Madison Performance Assessment Section Division of Inspection Program Management Office of Nuclear Reactor Regulation
. 'FROM: August Spector inspection Program Branch
~
, Division of Inspection Program Management L Office of Nuclear Reactor Regulation
SUBJECT:
REVISED REACTOR OVERSIGHT PROCESS:
SUMMARY
. OF THE SEPTEMBER 22,1999, MEETING WITH THE NUCLEAR POWER INSTITUTE AND THE PUBLIC TO DISCUSS THE CONTINilED DEVELOPMENT OF THE PERFCRMANCE
' ASSESSMENT PROCESS AND INSPECTION PROGRAM IMPROVEMENTS ,
On September 22,1999, a public meeting was held between the NRC and the NEl to continue exchanging information and views in further development of the concepts sent to the Commission for improving the process of overseeing the safety performance of nuclear power reactors. The meeting agenda, a list of those who attend the meeting, a copy of written I
information exchanged at the meeting, and summary minutes are attached.
Attachments as stated -
- l
Contact:
August Spector q sg l 301-415-2140 :g [
DISTRIBUTION:
NRC File Center !!PB r/f PUBLIC 74IV [
File Name/ Location (A:\NEl
SUMMARY
.WPD)
To receive a copy of thes document, indicate in the bor "C" a Copu without attachment / enclosure "E" s Copy with attachment / enclosure 'N's No copy OFC: PAS \llPB g , PAS \llPB I
NAME: ASpector AMad DATE: 09/N/99 09/f8/99 OFFICIAL RECORD COPY
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I NRC PUBLIC MEETING PARTICIPANT LIST -
DATE: September 22,1999 PLEASE SIGN IN. THANK YOU NAME AFFILIATION David R. Robison NPPD-Cooper Garret E. Smith NPPD-Cooper l
D. M. Olson Virginia Power August Spector NRC Dennis Hassler PSEG Nuclear William A. Allen AEP-Cook I Wade H. Warren SNC I l
Jim Chase OPPD Don Hickman NRC ;
John Butler NEl Michael R. Johnson NRC Wally Beck Com Ed William Dean NRR Richard Rosano NRR Jeff Jacobson NRR Laura Collins NRR (via conference call)
Cornie Holden NRR Tim Fye NRR Alan Madison NRC Jim Hutton PECO Energy Kevin Borton PECO Energy Stephen Floyd NEl j Tom Houghton NEl Pat Loftus Com Ed Greg Gibson So Ca! Ed - Rug IV l
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.%1 Draft
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COMMENTS ON SUPPLEMENTAL INSPECTION PROCEDURES i Generic Comments I
- i it is our intent to ensure that the column procedures actions align with the !
philosophy of each column (column 1thru 5). To complement the procedures further guidance (philosophy) needs to be incorporated in the oversight process {
regarding NRC actions, confidence in the licensee's programs, and indication of !
- failed licensee Corrective Action Program. l The Column 2,3 and 4 procedures need to be revisited (revised) following completion ofindustry guidance on Corrective Actioil Program effectiveness.
Column 2 Procedure General Comments:
Add to inspection Bases Section: .
)
"It is not the intent of this procedure for the inspector to perform all steps of this l procedure for each finding. The inspector may exercise discretion based on the '
inspector's knowledge of,the conditions and steps taken by the licensee".
- 1. page2,4" bullet at top: programmatic issues should be written consistent with l SECY 99-087 "In other words, the focus is on the safety impact of the - i programmatic violations, not on an assessment of the program."
- 2. page 2, Section -01 INSPECTION OBJECTIVES, objective 01.03 should be 1 written: Verify that licensee corrective actions to risk significant performance '
issues have been identified bv the licensee and the licensee has identified the actions address the root causes, the contributing causes, and prevent recurrence.
- 3. Page 2 -02 INSPECTION REQUIREMENTS, should be written to include:
The intent of this inspection procedure is to review the licensee's evaluation l of each issue categorized as White and included in Column Two of the '
Assessment Action Matrix. It is exoected that the insoector will verify the licensee's actions as it certains to the sianificance of the issue. and as described in the licensee's corrective action oroaram. however. It is not a validation nor an indeoendent evaluation of the issue by the insoector. Under the sianificance of colurnn 2. it is exoected that there is confidence reaardina ,
l the licensee's Corrective Action Proaram. The licensee's evaluation should generally address each attribute contained in the inspection requirements section; however, the depth of the licensee's analysis may vary depending on the significance and complexity of the issue and the licensee's program. In some cases, the answers to specific inspection requirements will be self-
- evident with little additional review. Therefore, the emphasis is in the 1 ,
s .
licensee's implementation of their analysis and the Inspection Requirements I are provided as a guide to the inspector. .
- 4. page 4,1st paragraph, strike cut last two sentences: " Weaknesses in the licensee's.... enforcement action. In addition, weaknesses in the licensee's evaluation may require additional NRC supplemental inspections, ...
' adequate corrective actions are specified." These statementare indicative of a column 3 procedure
- 5. 1" bullet at the top of page 2: Remove "all" and clarify only the appropriate requirements contained in the procedure need be completed.
- 6. Specific references to methods or prescriptive requirements of an effective
. CAP should be re-visited once an industry guidance document is made available.
~
Column 3 Procedure
- 1. Page 2, bullet 4: see same comments as #1 regarding column 2 procedure.
- 2. Page 2, Section-01 INSPECTION OBJECTIVE (S), add to each objective so not to confuse with aggregate issues: ... understood for individual and collective (multiole white inouts) issues...
- 3. Page 3,1" paragraph, add: .....and generic implications of the individual and i collective issues, it is the intent not to re-oerform the licensee's evaluation.
however. the insoection should assure that the actions are sufficient to meet l all four of the insoection objectives. The licensee's....
- 4. Page 4, Section -03, General Guidance,2d sentence add: ...to complete their evaluation and/or self-assessment for multiole inouts.
Column 4 Procedure General comments l
Inspection actions should provide reasonable assurance of safety and/or risk l significant system functionality or programmatic compliance with regulatory requirements. To provide this reasonable assurance, inspections should independently assess the effectiveness of multiple processes or programs that are critical to safe operations. This should be accomplished through a safety focused and risk-informed sampling approach to characterize areas where there is a significant current decline in safety margins. Inspection actions that i prescribe specific management actions or solutions should be eliminated.
Examples include 2.02C and D,3.02 B, C and D and 3.03 E18. Licensees should be encouraged to be self-critical and identify historical issues that, if undetected, could potentially result in a current risk or safety-significant issue.
The procedure is designed considerably different than column 2 and 3 procedures. The intent appears to be a broad look at fundamental issues. Up front it needs to be clear that all areas may not be necessary and the inspector should implement only those portions necessary to address the performance 2
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s' area that has significantly declined l'would suggest that a statement in section 02.01 be added. ,
The inspection objective described in 01.01 needs clarification. The wording implies that a column 4 inspection is designed to see if the plant should move into column 5. Criteria to shift to the 5* column should be defined as the results i of the broad inspections that indicate that the finding and/or additional findings which are of red significance level.
The action matrix and the procedure do not describe the actions that might follow from a significant event (red) that is judged to be a new industry issue rather than a plant performance problem. It needs to cover this possibility if the procedure is intended to be used to evaluate event-related single red findings.
Incorporate the footnote from the action matrix. "This procedures is only applicable in cases where the staff has determined that one Red Input is !
indicative of overall licensee performance and additional evaluation and supplemental information are needed." Basis: The procedure as written does not recognize that the procedure is not be applied when entry into the procedure is driven by one Red input which is not representative of licensee performance.
The Action Matrix for the " Reactor Oversight and Assessment Process (ROAP)
Handbook 8.X, page 12 issued May 20,1999 by Sam Collins in the " Pilot Program For the New Regulatory Oversight Process" states in Footnote 1, "It is expected that in a few limited situations an inspection finding of this significance will be identified that is not indicative of over licensee performance. The staff will consider treating these inspection findings as exceptions for the purpose of determining appropriate actions."
- 1. The discussion in 02.03 A.3 does not flow with what follows. It looks like 020.3 A.4 got jammed in the middle. Also, the connection between the number of the attributes elements in 02.03 and the correlation with similar numbering in 03.03 is not obvious. Similarly, the use of the same topic headings for 02.XX and 03.XX is confusing when trying to understand what the section is trying to convey.
- 2. page 3 Paragraph 02.01 First sentence, strike " Assessment" from Assessment Action Matrix.
- 3. page 3 Paragraph 02.02 second paragraph first sentence. Correct to state:
"Once significant performance concems have been identified and the Action matrix aoolies.. " ;
- 4. Section 02.04 is missing or there a typo,in section labeling, l
- 5. Page 3 first word , " leeway" needs to be clarified. If the inspection module is meant to be augmented by other processes or modified by deleting unrelated !
sections of the proposed procedure, the clarification needs to be made I somewhere. See general comments.
- 6. Section 02.01 Strategic Performance Areas (s) Identification. The use of the parentheses for " area (s)" should continue throughout the section.
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.- 7. How will NRC classify inputs? At Philadelphia, the guidance was that a Finding would stay for 4 quarters. This is a conce,n because you could have .
one yellow finding, and a yellow PI later in the year which really have no common cause, or even a common subject, yet an additional column 4 type inspection would be undertaken to review this area.
- 8. Section 3.02, B., (page 9). Strike last sentence. It implies th61 management's support of audit and assessment is linked to QA organization
- j. staffing. Staffing of QA is not an ind!cator and should not be listed here.
l
- 9. Section 3.0.2, E (page 10), regarding the employees concems program.
Change to: "... additional safety issues exist that have not been adequately addressed " and strike " captured by the corrective action program."
10.2.02.D on page 3 is too prescriptive and appears to establish a requirement l for the development and implementation of perfo,rmance indicators. While most everyone is doing this, there is no regulatory requirement to do so.
11.Page 14 item d. is too prescriptive and seems to establish a requirement for the composition of vendor evaluation teams.
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RESPONSE TO PERFORMANCE CONCERNS IDENTIFIED DURING SUPPLEMENTAL INSPECTIONS Numerous questions and comments have been generated during review of the draft .
supplementalinspection procedures with regard to how performance concems, particularly programmatic performance concems, will be handled that are identified during the conduct of supplementalinspections. Three potential approaches are outlined below:
(1). If the original white issue was enforceable and the licensee's response to the violation is unaccepteble, we would inform the licensee that their response is unacceptable and the reasons why. If the originalissue was not enforceable but was risk significant (by definition white issues are risk significant) and the licensee's evaluation of the issue was not sufficient, we would have the option of doing additional supplementalinspections as -
necessary to independently identify the root causes and extent of condition, or we could order the licensee to do so.
With regard to what additional actions need to be taken with regard to the programmatic concern associated with deficiencies in their evaluation, this information could be fed back into the baseline problem identification and resolution (Pl&R) inspection. During the next performance of the Pl&R inspection we would focus on the areas found to be deficient during the supplementalinspection. We would not perform additional supplemental inspections other than those necessary to identify the root causes and extent of condition of the originalissue.
- ESQ M No change to current assessment Limited regulatory leverage for programmatic infrastructure required concems associate with the corrective action program May require significant additional NRC inspection to identify root causes and extent of condition (2) Regardless of whether the original white issue was enforceable or not, we would hold the issue open (i.e. the white finding would not go away) in the action matrix until we were satisfied that the licensee had performed an adequate evaluation and appropriate corrective actions were proposed. This would alter the current policy of removing the issue from the action matrix after four quarters regardless of the adequacy of corrective actions. We would not perform additionalindependent inspections other than those to re review the licensee's evaluation or as a result of movement within the action matrix.
l EBQ M I Increased regulatory leverage for Would require change to assessment programmatic issues associated with the infrastructure to keep white issues on the corrective action program books if corrective action is not adequate l
Limited additional NRC inspection resources required 1
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l (3)- We would issue additional white issues for inadequate corrective action. This would l have the potential to move the licensee further to the right in the action matrix which would result in additional supplemental inspections. We would not perform additional independent inspections other than those to re-review the licensee's evaluation or as a result of movement within the action matrix.
Eao c.on l Maximum regulatoryleverage Could result in significant movement to the i right in the action matrix without the identification of new hardware issues Limited additionalinspection resources Would be departing from SDP philosophy of required not issuing findings for programmatic issues Most pro active of the three approaches No change to current assessment . Would likely be perceived by industry as infrastructure required double jeopardy l
l
i NEI 99-02 (Discussion DraA) 22 September 1999 l
, Calculation 'I The performance indicator is calculated using values reported for the previous four quarters. The
. calculation involves averaging the results of the following two equations.
IDS Unavailability Index = IDS Compensatory hours in the previous 4 quarters i Number of PhysicalSecurity Zones x 8760 hrs CCTV Unavailability Index = CCTV Compensatory hours in the previous 4 quarters Number of Perimeter Cameras x 8760 hrs Indicator Value = IDS Unavilability Index + CCTV Unavailability Index 2
The resulting indicator calculation is augmented by determining whether any individual physical security zones or any perimeter camera exceeded an unavailability of 20% (i.e..
greater than 1752 compensatory hours in the previous 4 quarters).
Definition of Terms 1
Intrusion detection system (IDS) - E-fields, microwave fields, etc.
CCTV- The closed circuit television cameras that support the IDS.
l Compensatory measures: Measures used to meet physical security requirements pending the return of equipment to service. Protected Area protection is not Jiminished by the use of compensatory measures for equipment unavailability.
Compensatory man-hours: 'Ihe man-hours (expressed to the nearest tenth of an hour) that compensatory measures are in place (posted) to address a degradation in the IDS and CCTV systems. When a portion of the system becomes unavailable-incapable of perforndng its intended function-and requires posting ofcompensatory measures, the compensatory man-hour clock is started The period of time ends when the cause of the degraded state has been repaired, tested, and system declared operable. 1 1
If a zone is posted for a degraded IDS and a CCTV camera goes out in the same posted area , the hours for the posting of the IDS will not be double counted. However, if the IDS problem is corrected and no longer requires compensatory posting but the camera requires posting, the hours will start to count for the CCTV category.
Equipment unavailability: When the system has been posted because of a degraded condition (unavailability), the compensatory hours are counted in the PI calculation. If the degradation is caused by environmental conditions, preventive maintenance or scheduled system upgrade, the compensatory hours are not counted in the PI calculation. However, if the equipment is l
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Calculation l
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The performance indicator is calculated using values reported for the previous four quarters. The calculation involves averaging the results of the following two equations.
IDS Unavailability Index = IDS Compensatory hours in the previous 4 quarters Numberof PhysicalSecurity Zones x 8760 hrs .
CCTV Unavailability Index = CCTV Compensatory hours in the previous 4 quarters Number of Perimeter Cameras x 8760 hrs IDS Unavilability Index + CCTV Unavailability Index or V6 2
The resulting indicator calculation is augmented by determining whether any individual I physical security zones or any perimeter camera exceeded an unavailability of 20% (i.e.,
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CCTV- The closed circuit television cameras that support the IDS.
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