ML20215J133
| ML20215J133 | |
| Person / Time | |
|---|---|
| Issue date: | 10/22/1986 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8610240318 | |
| Download: ML20215J133 (4) | |
Text
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MEMORANDUM FOR:
Dennis M. Crutchfield, Assistant Director for Technical Support, Division of PWR Licensing - B, NRR FROM:
William F. Kane, Director Division of Reactor Projects Region I
SUBJECT:
B&W OWNERS' GROUP PLANT REASSESSMENT Region I has performed a review of the B&W Owners' Group (BWOG) Reassessment l.
Program, Revision 1, dated August 21, 1986.
In response to your memorandum, dated September 3, 1986, our comments are enclosed. These comments also incor-porate insights from our participation at your September 29, 1986 meeting with l
the BWOG. We hope you will find our comments helpful in evaluating the B&W Owners' Group Program.
Our review included all changes to sections of the program description; but we did not undertake detailed technical review of the various appendices or of results to date.
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NRC Region I's last memo, dated May 23, 1986, on BWOG Revision 0 identified some general concerns as follows.
1.
The need for evaluation of management-related issues.
2.
The importance of aggressive, reliable tracking and verification of the implementation phase.
Regarding Item 1, we understand that management-related issues are not being considered within the scope of reassessment; therefore, we have not commented further in this area.
Regarding Item 2, implementation tracking and certification, we note slight improvement in the BWOG plan in this area.
Some of our enclosed comments sug-gest further improvements. Overall, however, based on the BWOG approach to the area, NRC should anticipate the need to devote significant resources to follow-up and verification of implementation.
Region I believes such effort will be necessary to provide adequate assurance and confidence of individual utility implementation of the reassessment program.
Original Signed By:
William F. Kane, Director Division of Reactor Projects Region I lyh
Enclosure:
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Memo for D. M. Crutchfield 2
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T. Marsh, NRR R. Jones, NRR J. Thoma, NRR:PM R. Weller, NRR W. Paulson, NRR A. Gibson, RII C. Paperiello, RIII J. Gagliardo, RIV J. Crews, RV E. Jordan, IE J. Heltemes, AE00 i
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Memo for D. M. Crutchfield 3
NRC:RI COMMENTS ON B&W OWNERS' GROUP REASSESSMENT PLANT REVISION I Item Section Description Contact 1.
IX.A The plan for ICS/NNI FMEA is good R. Conte and, if properly implemented, should 590-1167 lead to plant specific FMEA's for the ICS/NNI systems.
2.
VI.C It is good that the review includes R. Conte XI, Ques. 3 both Category B and C events. However, 590-1167 the following comments apply:
(1) TAP data should be delineated in an appendix to the report.
(2) An evaluation summary should be included to justify each event as to its Category A, B, C status in the TAP database.
(3) Non-TAP data from pre-1980 should also be delineated in an appendix as noted in (1) and (2) above.
(4) NRC staff should correlate all data to known reports to NRC.
(5) There should also be a detailed review by NRC staff of events in TAP data that were never reported to NRC.
3.
General It remains unclear when and how regional R. Conte comments will be incorporated (probably 590-1167 into Section XI, NRC concerns). We understand NRR is soliciting comments from the regions.
Region I comments are as delineated in a Memo dated June 23, 1986, and they still apply.
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7 Memo for D. M. Crutchfield 4
Item Section Description Contact 4.
VI Region I still disagrees with the R. Blough definition of Category C events.
488-1146 However, other changes to the reassessment program _ render this issue somewhat moot.
It is impor-tant that NRC, in its SER, indicate clearly that we do not consider the categorization to be a reliable in-dicator of the safety significance of an event.
5.
RTS BWOG needs to clearly define how the R. Blough RTS will handle a case where a utility 488-1146 closes a recommendation by implementing
" equivalent measures".
It is important that BWOG preclude the loss of credibi-lity that could result from a NRC finding that a utility has (1) labelled a recom-mendation as " Closed-Operable", but (2) actually has done something substantially different from the recommendation.
I suggest BWOG consider a status category of
" Closed-Equivalent" to highlight when equivalent measures are taken.
6.
RTS RTS should be re-formatted or regrouped R. Blough to show the tie between a recommenda 488-1146 tion and the related concern / priority.
7.
Prioriti-BWOG plans to prioritize concerns, but R. Blough zation not prioritize recommendations.
There-488-1146 fore, it is important for reviewers and evaluators to know what priority the utility places on recommendations. BWOG should (1) establish a standard set of utility priority codes, and (2) esta-blish a mechanism for feedback of utility priorities to be displayed on RTS printouts.
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Mailing Address
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. GUARDS;lNFORMATl0N Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6090 R. P. Mcdonald Senior Vice President Fhntndge Building Mghgggg Ngg[
Docket Nos. 50-348 50-364 October 13, 1986 i
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Director, PWR Project Directorate #2 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. Lester S. Rubenstein Re: Joseph M. Farley Nuclear Power Plant - Units 1 and 2 Regulatory Effectiveness Review
Dear Mr. Rubenstein:
The enclosure to this letter is Alabama Power Company's response to the findings of the Regulatory Effectiveness Review. As we finalize these corrective actions, a revision to our Security Plan will be draf ted and submitted under the provisions of 10CFR50.90.
If you have any questions, please advise.
Respectfully submitted, ALAB OWE CO. PAN s.^ /' R. P. Mcdonald RPM /JGS:amh Enclosure N OWRE COMAINS xc: Mr. L. B. Long SAFEWARDS INFORW10N. Dr. J. N. Grace i'PON SEPARATION Tliis Mr. E. A. Reeves PAGE IS DECONTROLLED. Mr. W. H. Bradford 0610240285 061013 0pk PDR ADOCK 05000348 F PDR g L $AF.EGUARDSilNF.ORMATION _ - - - - -}}