ML20246M838
| ML20246M838 | |
| Person / Time | |
|---|---|
| Issue date: | 08/29/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1752, NUDOCS 8909070262 | |
| Download: ML20246M838 (267) | |
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O UNITED STATES NUCLEAR REGULATORY COhDESSION OZGW A_
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS In the Matter of: )
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SUBCOMMITTEE ON REGIONAL )
PROGRAMS, REGION 1 OFFICE )
AFTERNOON SESSION O
ACRS O'fice Cmy- Ret 5il - -
TOT t.'S : jig Os ins C<.. omit ttee Pages: 146 through 312 P1 ace: King.of-Prussia, Pennsylvania Date: August 29, 1989 HERITAGE REPORTING CORPORATION O osawn,-a -
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UNITED STATES NUCLEAR REGULATORY COMMISSION'S
[' < 3 ADVISORY' COMMITTEE ON REACTOR SAFEGUARDS 4
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7 The contents of this stenographic transcript of the 8 proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at1the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement or data contained in-this transcript.
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UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS In the Matter of: )
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- SUBCOMMITTEE ON REGIONAL )
PROGRAMS, REGION 1 OFFICE )
Tuesday, AFTERNOON SESSION August 29, 1989 Conference Room 475 Allendale Road King of Prussia, Pennsylvania The meeting convened, pursuant to notice, at 1:00 p.m.
BEFORE: DR. FORREST J. REMICK Chairman, ACRS Associate Vice-President for Research Professor of Nuclear Engineering The Pennsylvania State University University Park, Pennsylvania v
ACRS MEMBERS PRESENT:
DR. WILLIAM KERR Subcommittee Chairman Professor of Nuclear Engineering and Director of the Office of Energy Research University of Michigan Ann Arbor, Michigan MR. JAMF.S CARROLL Retired Manager, Nuclear Operations Support Pacific Gas & Electric Company San Francisco, Calf.fornia MR. CHARLES J. WYLIE Retired Chief Engineer Electrical Division j Duke Power Company Charlotte, North Carolina
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, (f ACRS MEMBERS PRESENT: (Continued) n MR. DAVID A. WARD-Research Manager on Special Assignment E.I. Du Pont de Nemours & Company.
Savannah River Laboratory-Aiken, South Carolina DR. IVAN CATTON Professor of' Engineering Department-of Mechanical, Aerospace & Nuclear Engineering, School of Engineering and Applied Science Univet.sity of California Los hgeles, California ACRS COGNIZANT STAFF MDSER:
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~1 A L I E'E H Q 2 H EEEaIQH 2- DR. REMICK: All right,' gentlemen.
Let's i 3 commence.
'4 MR.'STROSNIDER: My name-is Jack Strosnider. I am 5 -Chief of the Materials and Processes Section.
6 And part of what that'section is responsible for 7 is running the NRC's independent measurements program, the 8 NDE Van is the way:it's often referred to. It is actually a 9 trailer, now.
10 At any rate, I wanted to emphasize a couple of 11 things.
12 First, that this is an NRC-wide program. It is 13 run out of Region I. However, we perform inspections for
() 14 ~ all the regions. We put out a request before the'beginning 15 of the fiscal year and we get usually more requests than we 16- can handle from the other regions to perform these type of 17 inspections.
18 The whole concept here is that we go out and 19 independently perform, reperform inspections that the 20 licensees are performing, as required by NRC regulations.
21 These are some of the capabilities we have. The 22 traditional radiography, ultrasonic testing, mag particle 23 testing.
24 We're going to go into the lab and show you some 25 of the equipment that we have.
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- L - Now,very-quickly, I;just wanted to give you'ans
.' 2 idea-what our'schsdule looks'like. No are:on a six-week
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3a cycle..-we spend two weeks in the office preparing'for.the..
H' 4 inspection, two weeks onsite. The. team consists'of Harry.
- 5' l Kirsch,.who is our_ lead reactor engineer for the NDE-
'6 program,.two technicians which-are NRC employees, typicallyf
.7 'two contractor technicians. They'arefonsite:as I-said'two l 8 ; weeks,.and'then.two. weeks back in'the office preparingLtheir 1
'9 report.
un 10 One of the' things I' wanted to emphasize,fif) you 11L look through this and the next page r .which shows the r.
'12 schedule that we are working to this year, this is not,a 13 construction activity any more. We do still go to some
() l 14' construction' sites. And when this was' initially-put 15
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together, that was certainly the emphasis'.. But if you look 1'
16- at;the: plants we're. going-to now, with one or two 17 exceptions, these are operating facilities.
18 We are'looking at major modifications, such as n 19- steam generator replacements, piping replacements. We're 20 looking at their in-service inspection programs.
21 So we very much made it I think into the 22 operations world and there still continues to be a need'in 23 that area as evidenced by the requests that we get.
24- You can see some of the findings we've had, for 25 example, on steam generator replacements where the steam A Heritage Reporting Corporation j U (202) 628-4888 )
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1 generator shells had rejsetable code indications that the 2- -licensee missed. We identified those. They' d be .3 in 3 'their.frecent replacement. We found' problems with surface.
p 4 exams on piping. They had to call in a new contractor to 5 perform all of them. So they phase off.
6 Not only'in.those kind of findings but also in I-l 7 think the psychological aspect that utilities know we have 8 the capability to require these inspections.
9 When they see one of our people walking through 10 the gate with his UT machine, it certainly encourages them 11 to do the best job they can.
12 DR. KERR: Do you think utilities aren't 13 interested in doing a good job?
() 14 MR. STROSNIDER: Oh, I think they are. But I 15 think encouragement certainly helps.
16 And I think that there is, as a result of this
~17 program, there have been improvements industry wide. .I've 18 seen improvements in the qualification of people and 19 procedures, in the techniques. That's not to say the 20 industry isn't working on those things.
21 MR. KERCH: Could I answer one of your questions 22 there?
23 The feeling I have about whether they are 24 interested or not, they are generally so busy they have 1 25 contracted someone to do it and then they forget about them t') Heritage Reporting Corporation
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/s l' and the contractor may not be doing the job that they really 2 think he's doing. That's most of the problems that I see, 3 that whoever he's got is doing the work and not up to 4 standards.
5 MR. STROSNIDER: One other comment I wanted to 6 make is --
7 MR. WARD: Could I ask you a question about this, 8 Jack? -
~9 Some of the findings here don't seem to be related 10 to the use of the equipment in the van. I mean, for
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11 example, one violation here at.A&O is inadequate review of 12 drawings.
17, MR. STROSNIDER: We do also, as part of these
() . 14 inspections, as I indicated, we have four technicians that 15 go out and reperform inspections. Harry typically looks at 16 their programs,.their management and control systems, 17 training for the contractor personnel to make sure that they 18 are qualified, certified appropriately.
19 Some of these things, however, some of the drawing 20 problems we run into, if you go out to inspect a section of 21 pipe and you are asking for the drawing so you could find 22 it, you go out and you can' t find it, well you've found a 23 problem in their drawing.
24 MR. KERCH: In that particular case, that was 25 started from hardware. We had two individual pieces of 1.
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1 hardware that had the same numbers in the drawing. What 2 they did, they did not have a system controlling the changes 3 to the drawings and in fact they-had two parallel-4 -construction, or' fabrication'of a piping assembly, one they l
5 no longer wanted but it was still being fabricated, and 6 there was no control.
7 MR. WARD:- I see. So your inspections are oriented 8 toward physical examination. But if something falls out of 9 that --
10 MR. KERCH: A lot of those things that' fall out of-11 there --
12 MR. STROSNIDER: That is a hardware problem. As I 13 recall, in that specific example,-you went out to look at
() 14 some welds and the welds weren't there. And that is when we 15 determined that in fact they had two different 16 configurations. One of thee should have been scrapped, it 17 should have been segregated from the final design and in 18 fact it wasn't. The drawing didn't reflect it and the 19 hardware was still out there, the people working on it to 20 put it in.
21 But the problem you can get into obviously is in 22 the in-service inspection program. People come back to 23 inspect those welds and to trend what is happening with the 24 drawings if they can't even find that weld. But it did come 25 out of looking at hardware.
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- d. '153 k) 1- One other' comment I wanted to make before we sp) 2 into the lab is that the thing that really makes:the NDE 3 program work is the staff, the people who work these 4 inspections..
5 Harry is Level 3 certified. Our technicians are 6 Level 2 certified. We have one individual'who has passed 7 the EPRI IGSCC section qualification. And what it really 8 takes to maxe this kind of program work is not just the
.9 hardware but the people. And that is an important aspect of 10 it. I.think particularly, this morning, some discussion 11 about recruiting inspectors and that sort of thing, it is 12 very difficult in some cases to find people with these 13- specialties and certifications, with the kind of salaries
() 14 that we offer, the travel benefits that we offer, with 15- people spending really half their time on the road.
16 Folks this is hands-on, so I am going to turn it 17 over to Harry. Right around the corner here we have an NDE 18 team lab which we offer services to any regions which are 19 ' testing alloy anslysis, all the NDE techniques. And I' guess 20 we can spend some time in there and go down and take a look 21 at the trailer.
22 (Subcommittee goes on tour of NDE van.)
23 DR. REMICK: Gentlemen, shall we begin? And you 24 are picking up the subject of quality assurance programs, I 25 hope, Bill?
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1 MR. RUSSELL: Next is P.K. on quality assurance.
2 MR. CARROLL:. If there are any showstoppers in 3 this list of things, I guess I'd like to hear about them.
4 MR. RUSSELL: My personal view is that service 5 water systems have not had enough attention paid for a'long 6 time, that if you did a sensitivity study on the total loss 7 of a system in a PRA space and service water was the system, 8 I think you would find that it would have a rather 9 significant contribution.- It's a rather diverse system.
10 But it is also one that is very important to the ultimate 11 heat sink. An AEOD study is coming out that I think is a 12 fairly good one.
13 MR. DURR: I'm Jack Durr, Chief of the Engineering
() 14 Branch.
15 Dr. Eapen is the Chief of the Special Test 16 Programs Section of the Engineering Branch. And it is best 17 characterized I guess as the go-between operatioas and 18 engineering. Those things that transcend operations and 19 begin to become engineering issues, his section deals.with.
20 Thermal hydraulics, core physics, quality assurance, as we 21 do quality assurance reviews under Part 50 programs.
22 MR. EAPEN: Thank you, Jack.
23 Like Jack said, I am P.K. Eapen, Chief of the 24 Special Test Programs Section.
25 This afternoon I would like to give you a status
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'"3 155 l 1 on the QA program in the region by highlighting a little bit j
2 of the past, the present, and into the future.
3 Before I get into that, I would like to stress the 4 fact that our region was always stressing the effectiveness 5 of quality assurance prrgram implementation.
6 We always encourage our inspectors to walk that 7 extra mile by relating a QA finding or any finding as a 8 matter of fact to performance. And we also define QA a 9 little bit differently at the working level. We define QA 10 as a big picture QA which includes the organizations and 11 committees and so forth that make the backbone of a 12 licensee's organization.
13 And we also believe a good QA will assure that
() 14 things are done right the first time.
15 And last but not least we strongly believe a QA 16 organization is an effective management tool.
17 So with that introduction, let me get into the 18 past.
19 Like I said before, Region I has strong 20 inspections to assess the effectiveness of QA program 21 implementation. And that was essentially rooted in a strong 22 construction program. And in the constructive base, our 23 inspector interfaced with the licensee through quality 24 assurance organizations.
25 That interface indeed provided a high visibility
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1 to the QA organization.
2 And also, the region was extremely fortunate to l 3- get engineers as inspectors. And these engineers worked 4 under effective licensee QA programs. So they knew how work 5 was done under a quality assurance program and they also 6 knew how the work was done in a technically competent 7 manner.
8 Secondly, at least since 1980, that's the time I 9 came on board here, management was always influencing the 10- quality assurance program activities in a positive manner.
11 In the early days of the formation of our Division 12 of Reactor Safety under the guidance of Mr. Martin, we had 13 good guidsnee and support for QA.
.('.) 14 Mr. Ebneter, who was the branch chief at that time 15 brought in excellent concepts of quality assurance and 16 hardware. perspective and reliability and that sort of thing 17 from his knowledge in the aerospace industry and NASA and 18 the reliability activities.
19 Because of that good background, Mr. Ebneter 20 provided good branch directions and he insisted that all of 21 our inspections, regardless of what they are, should 22 interface QA in that particular area.
23 He also believed that the licensee did not pay 24 adequate attention to QA organizations.
25 Like I said before, he also redefined QA as a Q Heritage Reporting Corporation
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2 And he insisted that we go back and check the QA 3 findings and the QA recommendations that the QA organization 4 is making to the licensee and what is coming out of it, if 5 those recommendations and suggestions are being used in a 6 pro-active way.
7 And he also emphasized on the fact that it is 8 important to look at the work and not the paper. Or in 9 other words, he put an end to the so-called " paper 10 inspection."
11 Between 1985 and 1987, there was a QA section and 12 I believe that section was also instrumental in bringing in 13 a certain quality to QA inspections.
() 14 We started implementing performance-oriented 15 inspection. We tried to assure that things are done right 16 the first time. And we also looked at the safety nets, we 17 looked at the doer, we looked at the reviewer, we looked at 18 the supervisory chains, we looked at the QA as a feedback 19 mechanism, and also the management involvement, and last but 20 not least the involvement of outside the utilities and 21 independent assessment by outside agencies.
22 We tried to make the QA inspections as assessments 23 of organizational effectiveness and to do that we looked at 24 the ongoing work. If the work is done right, we concluded 25 that the QA program is implemented adequately.
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- 1. But on the other hand, if the work is not perfect 2 or'being done in accordance with the regulations, we went 3 -back and looked at the program and the procedures that led 4 to that inferior quality work.
5 A good example will be we<will dispatch a 6 mechanical engineer and charge him with the responsibility 7 to look at the activity in mechanical engineering discipline 8 and make an assessment based on his technical knowledge of 9 whether the organization, mechanical engineering
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10 organization, is executing its organizational obligation in 11 a credible fashion.
12 Like I said before, we had the good fortune of 13 having. technically strong inspectors and they were coming 1( ) 14 into the region with a lot of experience, so that definitely 15 added some clout and credence to our inspections.
16 MR. WARD: You've emphasized that point. And I 17 mean your program seems to have depended or benefitted in 18 having what you call strong and experienced engineers.
19 Did you have some unique, were there some unique 20 circumstances that gave you those or what would the program, 21 how would the program have suffered if you had just typical 22 NRC engineers?
23 MR. EAPEN: Okay. I can give you my own 24 experience. I was an inspector in 1984 and 1985. And one 25 of the things that was positive about my experience was I
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'I was. inspecting the areas that I was thoroughly aware that I 2 was charged with and in' developing and implementing as a 3- licensee engineer, so I knew what kind of regulatory 4- requirements we were trying to adopt and what kind of 5= industry standards are.being implemented.
6 So you know, such inspectors-would have some 7 authority,.and subject matter depth with the licensee 8 counterparts. And at that point the licensee got the 9- feeling that the inspectors are not really wasting their 10 time but they are bringing in some technical matter behind 11 the belt.
-12 MR. WARD: The implication is that in other 13 regions'or in other points in time this was not the case?
() 14 MR. EAPEN: Oh,.no. I don't mean to say that.-
15 I'm just highlighting our positive attributes here.
16 We were indeed benefitted by such people here.,
- 17. MR. MARD: Okay. But it is not, I mean,-it is 18 positive, but you seem to be claiming that it is atypical.
19 MR. EAPEN: No. I don't have that claim at all.
- 20 I'm just making a statement of the facts.
21 MR. WARD: Okay.
22 MR. DURR: I think it is fair to characterize that 23 we believe that nur engineers are probably quote "better 24 than the other regions." We would always profess that. But 25 I think that we have had in the past a high caliber of Heritage Reporting Corporation c-O (202) 628-4888 I
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U 1 individual and we have had people from industry with a 2 fairly broad background in quality assurance specifically 3 who have been more or less baptized in that particular 4 discipline.
5 MR. EAPEN: We are also convinced not only the NRC 6 staff but also the licensee that quality is a line 7 organization function and item. Quality is a function of 8 the quality assurance organization.
9 The way we conducted that with the licensees, is 10 the emphasis on effectiveness of audit. Both Criterion 18 11 of Appendix B and ANSI 18-7 require an effective audit 12 program.
13 So our inspectors in the past seemed to go out and
() 14 see how an audit assessed the effectiveness of an audited 15 organization. And that usually got licensees' attention 16 very quick.
17 Because of all this, in the so-called QA 18 inspections, we started to have hardware and performance 19 oriented functions highlighted.
20 And we used to have enforcement conferences coming 21 from the inspections of the QA organization. I have a 22 couple examples here. The best one was at Vermont Yankee 23 where one of our inspectors did an inspection and before l 24 long he found out that they were receiving parts to the 25 hydraulic control unit without doing an adequate inspection.
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1 They claimed that they checked insulation on those-2 items, likewise they checked the dimension, but the package 3 was never opened. So things like that got licensee 4 management's attention in a hurry and we had enforcement 5 conferences to talk about specific hardware and performance 6 weaknesses'1xne.
7 Another inspection was done in 1986 at B&A. The 8 inspection was a team inspection and we said we are going to 9 look at the effectiveness of QA program implementation. And 10 the way that happened was that you have a set of experienced 11 inspectors from different disciplines, for example, 12 mechanical, electrical, operations, going in and looking at 13 the activities being conducted in each of these disciplines n)
( 14 and making an aosessment that the work is done technically 15 right the first time. And then also ye had a series of 16 violations anywhere between not inspecting the welds on the 17 lifting device for the reactor head to not verifying the 18 readings on transportation, radioactive material for 19 transportation.
20 We also believe that because of our effort we were 21 able +.o bring in some technical depth to licensees' 22 organizations. When we started the mission originally, the 23 licensees were doing quote unquote " administrative" type of 24 audits. And when we asked the licensee why you are not 25 getting into the technical details, the answers we were are Heritage Reporting Corporation
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1 not required to do that, but when NRC started to identify 2 technical problems, they got the message in a hurry and 3 before long we started to see technically competent people 4 in the licensee organization.a wel1~.
5 And soon after that we found out that the QA 6 personnel were afforded system training and also at times 7 simulator training to enhance their system knowledge and 8 whatnot.
9 We also played an important role interfacing with 10 our system divisions here, and also when.they inspected from 11 within.
12 One item that comes to my mind is an inspection 13 where one of our. graduate inspectors had a concern regarding
.( ) 14 the quality and the control of the radioactive material that 15 is being prepared for shipment.
16 He wea concerned that there was no QC involvement 17 in that activity. But in the-review between the divisions 18 we identified that in fact the process had a lot of quality 19 control steps but unfortunately the line organization as 20 well as our inspector didn't recognize that. So needless to 21 say, we assisted our division in redre.fting the viclation to 22 really express the concern which was the line organization 23 did not recognize its own quality control function.
24 DR. KERR: Wait a minute. Woujd you go through 25 that again?
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l MR. EAPEN: Okay, 2 DR. KERR: You mean they had quality control but 3 they didn't know it?
4 MR. EAPEN: For example, they had quality control, S when they were solidifying the waste, they were taking 6 samples and they had requirements on less than 2 percent of 7 water or moisture content and so forth, and the way we 8 looked at the problem, you know, if those controls are there t
9 and established, those are all becoming part of the safety 10 net. And that is a lot better than having a quality control 11 technician who has much less knowledge in that area to stand 12 there 100 percent of the time and --
13 DR. KERR: My question is, your implication seemed
() 14 to be that they were unaware of the fact thac they had 15 qual *ty control.
10 And it is a little difficult for me to believe 17 that they would have a procedura of that sort without having ,
10 it have some purpose, so they must have had a hint.
19 MP. EAPEN; Okay. Let me try to explain that. -,
20 What the technician was doing, he was doing the 21 recommendations and the verification of that step. But 22 under the licensee's nomenclature, he wasn't told that he 23 had a part in doing that in controlling the quality of the 24 process.
25 The culture of that organization was that quality s Heritage Reporting Corporation
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v.s 1 control is a responsibility of quality assurance and quality 2 control technicians as opposed to the technician himself was 3 doing the verification of the particular parameter.
4 MR. DURR: The point being that the individual 5 performing the task is really the first line of quality 6 control, quality assurance.
7 DR. KERR: Well, of course. But certainly an 8 organization that had a setup in which this occurs must be 9 aware of why the individual is there and is doing what the 10 individual is doing.
11 I'm puzzled at an interpretation that says that 12 the organization didn't know what they were doing.
13 MR. DURR: The statement I believe is that the im
( ,) 14 organization was not aware that that was the quality control 15 function that the individuni was performing. Thef perceived 16 it as part of the routitte task and not quality assurance.
17 DR. KERR: Well, if a routine task is to see that 18 things are done right, then it tseems to me quality control k 19 is part of the, process.
20 MR. DURR: That is correct.
21 DR. KERR: And it is hard for re to see how one 22 can say that they didn't know what they were doing.
23 MR. DURR: We didn't say that. No, I don't think 24 that was the point he was trying to make. I think the point 25 he was trying to make was that they weren't consciously
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m 1 aware that the sampling process was in fact a quality 2 control function.
3 DR. KERR: Well, I guess I am a little skeptical 4 of that statement. Why would people do it if they weren't 5 concerned about the quality of the operation?
6 MR. DURR: They were concerned about the quality 7 of the operation. What they were unaware of was that that 8 was an integral part of quality assurance, quality control.
9 MR. WARD: They weren't identifying it as part of 10 the QA program.
11 MR. DURR: It wasn't uniquely identified as part 12 of the quality process.
13 MR. RUSSELL: There is a perception in some
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,j 14 utilities that QA and QC can only be performed by those who 35 have QA or QC job titles.
16 MR, MARD: I wonder where they get that?
17 MR. BUSSELL: That's a QA theologian's perception.
16 1E. WARD: Yes.
?. 9 MR ,. RUSSELL: What we have been trying to 20 emphasize is look at the process that is involted, what is 21 being done with the work in situ, and than work backwards 22 from there. And it's like the issue of the effectiveness of 23 audits. We can compare our inspection findings. If we find 24 an issue in an inspection, it is very straightforward to go 25 back and see if the utility has audited that area, yes or (N
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1 no. If they did, did they find the same problem. If not, 2 why not. And that is a mechanism for judging the 3 effectiveness of the audit function.
4 So we are trying to emphasize much more the in 5 process evaluation or performance-based type inspection and 6 less on records. We only get back into records when we have 7 observed a deficiency in the field. But there still is the 8 impression that QA as it was applied during construction, 9 which was a lot of emphasis on records and pedigree and 10 paper, carried over. And some utilities still have that 11 perception.
12 We just found some interesting findings on QA down 13 at Calvert Cliffs with respect to the effectiveness of the
()
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14 QC organization in March of this year.
15 And in effect, the people performing the QC 16 fun.? tion were not trained as well, did not have the same 17 capabilities as the people that they were obse rvir.g anet i 18 evaluating, and it was an ineffective rc;ogrem.
19 It was Icoked at with disregard by the staff that i 20 was doing tha job.
21 So those attitudos still exist and we are still 22 dealing with them.
23 MR. DUP.R: Not only that, but there's been a l
l 24 mystique that has grown up around quality assurance like it 1
25 is a separate entity.
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'167 1 DR. KERR: We know. We know. We also thinh that 2 the NRC, in the past, not the present people, has had some 3 responsibility in building up-this mystique.
4 MR. DURR: I don't deny that. But part of that 5 process is educating managers and people responsible.for 6 prccesses that cuality assurance is their tool. It is a 7 feedback process for them, to tell them what their process 8 is doing.
9 DR. KERR: It would seem to me that your ultimate 10 goal is quality and not necessarily QA.
11 MP. DURR: That is correct.
12 DR. KERR: And in fact the earlier statement that 13 quality has to be built into the process it seems to me is
() 14 the key to the thing.
And if it is not, auditing is not 25 going to help much.
16 MR. DURR: We agree with that.
17 MR. WARD- I still don't understand what was the 18 . issue here I mean, wnat was the problem you saw with this
.19 licensee in this particular example? Why were you telling 20 us about that? What war, the problem?
21 PEL. EA2EN: That is an example where our division 22 worked with inspectore from other divisions as well as from 23 within to resolvc quality assurance problems and help them 24 focus in the right area.
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's 1 to realize also that quality is everybody's business, not 2 only a quality control inspector's business.
3 MR. WARD: So are ycu trying to influence your.
4~ inspector to not cite a licensee for a deficiency if.he is 5 really doing it somehow? Or are you trying to guide the 6 licensee to mahe quality control more part of his --
7 MR. EAPEN: More a part of that. A:sd also when-8 our inspecLors say there is no quality control involvement, 9 we go back and take the next step and assess what are the 10 other measures for assuring the real quality in the process, 11 and identify what is really --
12 MR. WARD: So the inspector may conclude even 13 though at firs by some traditional measures there wasn't
() 14 quality in the process, when he looks a little deeper,'he 15 says no, that's okay.
16 MR. EAPEN: That's okay. But the reason issue is 17 to make sure the product is quality.
16 Let me move on to the present.
19 I can comfortably say that or.r inspectors are 20 assessing real QA during routine and special team 21 inspections. !
22' You will see paragraphs relating to QA and so 23 forth. And I can comfortably also say that we don't have 24 any QA theologians in our region, but we have good QA 25 practitioners.
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(N 169 L) 1 They have a knowledge of team criteria in Appendix 2 B. Using that along with their technical expertise, they 3 could assess the effectiveness of any inspection area.
4 And also, we stress on the fact that things are 5 done right the first time through out inspections rather 6 than looking at certain papers and making sure there is a 7 signature and initials and so forth.
8 Again, I would like to stress that the Appendix B 9 violations that are being written today will have definitely 10 implication of hardware and performance concern.
11 And also, we are seeing an end to the paper 12 inspection era.
13 We have some concerns.
r~
( ,) 14 Some of the new inspectors who come on board may 15 not be as familiar as the old-timers in Appendix B.
16 MR. CARROLL: That may be a blessing.
17 MR. EAPEN: That's true, too.
18 MR. CARRCLL; That's an understatement.
19 DR. REMTCK: Remember this morning 1 said they're i 20 not that old.
21 (Laughter) ,
22 MR. EADEN Also, there is no section in the 23 region responsible for QA. And I think that !s also a mixed j 24 blessing. We are showing the licensees that we can handle
]
25 QA business through routine discipline functions. And the
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1 last concern we got, there used to be a lot of expertise in 2 Headquarters, and they are gradually fading away. And that 3 at times gives us heartburn because when we are in a tight 4 spot with regulatory concern or interpretation, because we 5 have to pull all the stops to get the answers. It would be 6 nice if we had people who could do it from Headquarters.
7 What are the regional actions that are being taken 8 to strengthen these concerns?
9 when we have Monday morning meetings here, and 10 Jack Durr and/or the Division Director will stand up and 11 discuss soms of the QA concerns, we have quality assurance 12 and so forth, and also we have a constant reminder to our 13 inspectors to assess the interface of QA again in routine
() 14 matters.
15 And also we have detailed preparations for our 16 inspections and we insist that our inspectors go out and 17 assess the big picture QA, you know, the real QA and not the 18 little QA where we once were concerned about paper and so 19 forth, 20 DR. REMICK: I have a question that raay sound 21 facetious, but it's not.
22 And that is when you have these Monday morning 23 training sessions, do you ever discuss how QA principios 24 might be applied to the work of the region itself, or the 25 NRC?
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- h- 1 Because this committee on a number of occasions C has asked the question shouldn't the NRC have its own QA l
! 3 program of some form.
4 MR. EAPEN: , I think that is being done at the 5 branet level. For example, when we sign out a report and so 6 forth, we follow with our branch the cardinal principle of 7 Appendix B, Criterion 3, verification, and I think one of B the standing orders in our branch is not to sign our own 9 report froin our own section.
10 So for Jack, in his absence, I make sure that 11 'another Section Chief or a Branch Chief looks at my report 12 before it goes out.
13 So to that extent we try to bring in our
() 14 experience ~into the job.
15 Jack, you might want to comment on that.
16 HR. DURR: Informally, that is practiced. Let me 17 give you an example.
18 The Non-Destructive Examination Laboratory that 19 you just went through, Dr.,Eapen, it doesn't come under his 20 section, by the way, it comes under Jack Strosnider's 21 section, Er. Espen wee detailed to go out and do an audit of 22- that program., and there were for.nal findings and t.here were 23 formal responses to those findings. Corrective actions.
24 When we find we have a problem, the corrective 25 action process is brought in.
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.,,~ 192 L (. .1 So there are elements informally applied to our 2 process here, yes, consciously, because of our quality 3 assurance background.
4 MR. RUSSELL: I.think the question was more 5 broadly' directed toward NRC QA activities. That is an issue-6 which is currently under review by the senior staff.
7 We have had some problems with respect to 8' documentation records, the status of safety issues, 9 management system, other areas where we have not kept as 10 good a track of what we have imposed, what is implemented 11 and what has been inspected.
12 There are formal programs that we have in the 13 region.
() 14 We have a Radiation Safety Committee that 15 periodically reviews radiation safety practices in the 16 region, reviews events and incidents.
17 We have some divisions which as a part of the 18 division plans conduct independent reviews after the 19 issuance cf inspection reporta to feed back information to 20 the authors of those reports regarding their quality.
21 Ne have a number of rachanisms associated with 22 review of prcducts before they are issued to ensure adequate 23 management review.
24 But we do not at this point aave a QA program with 25 a formalized QA audit type function.
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1 MR. EAPEN: Let me move on to the future.
2 I can comfortably say that our inspectors are 3 quite capable of assessing the real QA in the future.
4 Licensee QA organizations are beginning to change 5 in structure. It is a mixed blessing. Some licensees, 6 especially the working level QA personnel, are concerned 7 because they don't know what is happening, what is going to 8 happen to their job and so forth. So there is some anxiety 9 and stress. And en some of the licensees, as the licensee 10 tried to improve the QA, quality responsibility 11 wholeheartedly into the line organization, we get certain 12 feedback, not offfeially, but being at the plant and so 13 forth, we would get some feedback from quality assurance t'
( 14 personnel saying there are some organizational changes, we 15 want to move quality into the line organization. They will 16 pose the open question, is it good, bad or indifferent.
17 Only time can tell.
18 But I think what the licensees are doing is to --
19 MR. WARD: You seem to have an opinion on that 20 already. Right?
21 MR. EAFEN: 77 22 MR. WARD: Ycu think it'a good.
23 1R. EAPEN: I think it's good. And we are going 24 to have some concern while the licensees are on the learning 25 curve, because it's a change and every time there is a r~ Heritage Reporting Corporation
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1 change there is. going to be anxieties and frustrations on 2 the people that are affected by that change. They have to 3 do things slightly differently.
4 So I would say that is a positive change.
5 .The other kind of things for the future, right now 6' Uhe core inspection programs do not include any of the old 7 conventional QA program modules. I don't know whether that 8 is a concern or not. Again, it may not be a concern because 9 the discipline inspectors, if they are adequately trained, 10 they know how to check for conventir.nal QA through their 11 routine inspection.
12 We need to continue this thrust to the licensees 13 that' quality is an internal part of the line organization
'( ) 14 .and we ought to make sure that it stays there and not to the 15 side someplace.
16 From our side, there is a commitment from NRR to 17 revise the NRC inspection procedures, especially the ones at 18 the core, to include the attributes to look at the real 2A, 19 management involvement and that sort of thing. That hasn't
. I 20 been done. But I understand it's being done. J 21 MR. MARD: Could I ask you --
22 MR. EAPEN: Sure.
1 23' HR. WARD: Sorry to interrupt you. But yr said 24 that you are gding to be looking for licensees to make QA ,
i 25 part of their line organization. ;
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1 MR. EAPEN: That's right.
2 MR. WARD: And not off to the side somewhere.
3 It seems to me over the past years, ten years, the l 4 licensees have established a vice president for QA in a box 5 on the side. And my impression was the NRC was encouraging 6 that, forcing that even.
7 MR. EAPEN: Criterion 1 dictates that, right, 8 quality assurance should have sufficient authority.
9 MR. WARD: Well, I don't understand that. What's 10 happening?
11 MR. EAPEN: QA, that organization will be a 12 verifier of quality as opposed to instiller of quality.
13 What the licensees are trying to do is to make sure the line
,a
) 14 organization is aware of their quality assurance.
15 MR. WARD: Okay. What you seem to be saying is 16 that's really going to be, a lot of licensees have put what 1*/ is really QC into that sort of organization.
18 MR. EAPEN: That's right.
19 MR. WARD: So what you are really talking about is 20 putting QC into the line organization and maintaining a 21 small QA organization that just does audits and so forth.
22 MR. EAPEN: Performance oriented. That's what l
! 23 some of the people are trying to do. iou can aee the 24 movement in the QA organization, but the structure is still 25 :riaintained .
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~' 1 MR. MARD: It sounds interesting but I'm still a 2 little confused on exactly what is doing what to whom here.
3 Do you understand?
4 MR.' CARROLL: I think generally, yes.
5- When are you going to ask him the three' questions?
.6 (Laughter) 7 MR. EAPEN: One of the last concerns we have for 8 .the future is to centralize the QA program change reviews so 9 we will have consistency among the regions. And it is my 10 humble opinion that that ought to be done in-Headquarters 11 simply because the rest of the FSAR is now being reviewed by
-12 the project managers in Headquarters but under 50.54 and 13 50.55 regulations, the regions have to review any changes ,
() .14 that are made within 60 days.
15 So it.will be good. There is a central location
-16 for doing that sort of change that will be used in assuring 17 consistency.
18 In conclusion, even though there is no QA section 19 in this region, we are able to assure licensee performance 3
20 and assure that the real QA needs have livened up in this 21 region.
22 We have a challenge in the future to assure that p 23 the real QA is integrated into the licensee line L-
~24 organization. We also have to make sure that the real QA is l 25 everybody's business. -!
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q..i 1 With that, I will conclude my remarks.
2 MR. CARROLL: Is-what you've been describing here 3 something that goes across the country or is this Region I's 4~ view, and Region V may still think traditional QA is great?
5 MR. EAPEN: We have counterpart meetings, we used 6 to have counterpart meetings in the past in the QA area and 7 I'm happy to report that my brother section chiefs from 8 other regions have the same philosophy. They were changing 9 gears to look into performance and that sort of thing. So I 10 would say even though it originally started in Region I in 11 the late 1970s and early 1980s, now it is sproading into 12 other regions as well.
13 MR. CARROLL: Do you want to ask the three
() 14 questions, Dave?
15 MR. WARD: Yes. Actually there are four.
16 MR. CARROLL: Four, okay.
17 MR. WARD: Back in May of this year the ACRS 18- sponsored a meeting which happened to be in San Diego. And 19 the purpose of the meeting was to bring people from foreign 20 nuclear programs together with people from the domestic 21 programs to consider four questions about quality:
22 What is quality?
23 How does one get quality? ,
I 24 How does one know when he has quality? j i 1 25 And how does one prove it to others? l 1
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') 1 I don't think we really got, except on the 2 oblique, I don't think we got real answers to those 3 questions from any of the 40 speakers we had. I think the 4 questions are too fundamental or some would say too simple 5 minded, perhaps, for any of the speakers to address 6 frontally.
7 But I don't know, if I got anything out of that 8 meeting, about the difference between the U.S. approach to 9 quality assurance and the foreign approach, it is that the 10 foreign approaches explicitly depend much more, respect much 11 more and depend much more on I guess professional integrity.
12 And the QA inspectors seem to make an effort to assure 13 themselves not so much looking at the paper and maybe not 14 even looking at results, because it is a pretty thin sample ll 15 of the total zillion parts of a plant that a QA inspector 16 can look at.
17 But they seem to pay more attention to the 18 professional integrity and competence of the organization 19 that was actually doing the work, i l
20 MR. CARROLL: And the tools that that organization 21 used.
i 22 MR. WARD: Yes. And that doesn't seem to be the i 23 direction that the quality programs have taken in the U.S.,
24 including the programs of the NRC.
i 25 What you have been describing here seems to ba l Heritage Reporting Corporation
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1 sort of in that direction but I'm not sure. For example, 2 .you don't seem to be separating QC from QA in your 3 discussion, at least not in the way I'd do.it. Maybe I'm 4 not doing it the right way.
5 But I guess I'm left with kind of a little bit of 6 a floating feeling after hearing your talk. 'I'm kind of L 7 hopeful but I'm not quite sure.
8 DR. REMICK: You think it's in the right direction
.9 but maybe not far-enough?
10 MR. WARD: Yes. Well - yes.
11 MR. DURR: Can I address part of your question?
12 MR. WARD: Yes.
13 MR. DURR: Let me go back to the construction days
() 14 when quality assurance was king, so.to speak.
15 And it got out of hand. I'd be the first to agree 16 to that.
17 What you are talking about is that the individual 18 craftsman has to take pride in workmanship. That is the 19 start of quality. I don't care, you can have all the-20 inspectors in the world, and if the guy doesn't build it 21 right, it doesn't work.
22 And part of the attitude of the industry at that' 23 time wss, when we would have a finding the guy didn't build
- 24 it right, don't worry about it, quality assurance will catch 25 it.
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V 1 Well, I do worry about it. The individual that's 2 building the thing has to build it right to begin with. We 3 can't possibly catch all of those things.
4 So part of the attitude that has to be developed 5 by the industry and by the NRC is that the individual doing 6 the work has to do it right the first time. And to do that, 7 he has to have proper training. And he has to have adequate 8 supervision and he has to have the proper drawings and tools 9 available to him so that he understands what is expected of 10 him. That's the front line of quality assurance.
11 Buried in that then is having proper drawings, 12 having adequate engineering, having proper tools, proper 13 training, all of those things go together to make up quality t's (j 14 assurance as far as our perception is.
15 And quality control is just out there to do some 16 overchecks to make sure that it meets some acceptance 17 criteria, whatever that acceptance criteria is, whether it's 18 engineering or qualitative or whatever that may be.
19 So quality assurance to me is the guy in the field 20 with the tool in his hand that's doing the job. That's 21 where it all begins. And that's what we have to get 22 industry to believe and understand, and we have to get 23 supervision and management to understand that quality 24 control, quality assurance is their tool to make sure that 25 when they say I want X that they get X. And it is a
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b) l' feedback mechanism to tell them that they didn't get X,.they,
'2 got Y. And that's all. It's not a mystical process. . It's 3 very simple. And we've just complicated it'to the extenti 4- that nobody understands it-any more.
5 Does that address your question, or your concern?
6 MR. MARD: Somewhat, yes.
7 MR. DURR:- Okay.
8 MR. RUSSELL: I can't leave this subject. I think 9 that probably the most significant thing that we've done by 10 way of changing the direction comes through the SALP 11 process, with safety assessment quality verification, which 12 Il personally regard as management's report card.
13 It is everything from the onsite review committee,
(); 14 the offsite review committees, the followup on audit 15 results, how effective they are, the whole feedback process.
16 It's trying.to get quality built into line organization and 17 evaluating it. And I think that if one were to give a 18 reading on those sections of the SALP reports, you would see 19 how in fact the region and the agency is treating quality in 20 a broader context today than quality assurance has been in 21 -the past. And I think that is the big picture as to where 22 we are going and how we are using it.
23 And if there are breakdowns, if something is not 24 working, we first ask why did that happen within the line 25 organization. You don't look to the quality assurance
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2 If the quality assurance organization knew about 3 it, and was not effective in getting it fired, then you had 4 two layers that broke down. The line obviously knew about 5 it as well, plus the QA organization.
6 So we take different actions based upon what we 7 find.
8 But I personally believe that that SALP functional 9 area of safety assessment quality verification and how we're 10 using it is what we're looking to, to improve quality in the 11 organizations in the broadest context.
12 DR. REMICK: Thank you very much.
13 MR. DURR: I would like to make one more point.
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( 14 DR. REMICK: Yes. Go ahead.
15 MR. DURR: Relative to quality assurance. Steven 16 Joe, the computer wizard, he was criticized within his own 17 organization for demanding perfection. And his response to 18 that was, if people are put in an environment where they 19 work to quality levels all the time, you don't have to tell 20 them to do things to a certain quality level. They know it 21 is expected of them and they function at that level. And 22 that was his philosopny.
23 And I think that is what we are talking about 24 here. Quality assurance is an attitude that permeates an 25 organization. And either they have it or they don't. And
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O 1 it is instilled in them through management down, all the 2 way. It's got to be a total attitude of the organization.
3 If it's not, it just can't be put to a group over here to 4 make sure that it happens.
5 MR. DURR: I'm charged with addressing technical 6 specifications. I'm Jack Durr, the Chief of the Engineering 7 Branch, for those of you that may have missed it.
8 Technical specifications, as you are aware, are a 9 current topic in the NRR in the tech spec improvement 10 program. And buried in that tech spec improvement program 11 there is the standard tech spec, the new standard tech spec, 12 which is in process and has been delayed. The policy paper 13 has been issued in 1987 and they are holding it in abeyance
( 14 at.this present time.
15 Not much of that impacts the region directly 16 today, 17 I'll explain my slide. As technical 18 specifications, I tried to group some things, to put some 19 order into it.
20 This is the tech spec revision program, the 21 atsndard tech spec, the new star.dard tech spec program, 22 which I just said doesn't have much impact en the region 23 itself today. But buried in that are two what I consider 24 safety items. And that is the 50.59 review process, which 25 is the ENSAC 125 document where the agency is attempting to r Heritage Reporting Corporation
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.p) r 1 get utilities to put some structure into their 50.59 review 2 process.
3 That guideline has been issued. It is available 4- to the industry, industry is being. encouraged to use it. I 5 believe you gentlemen had a presentation on it, for the ACRS 6 on.that same subject just recently, is that true? So I 7 won't belabor that too much.
8 But to me that process is --
9 MR. WARD: This guideline is the --
10 MR. DURR: ENSAC 125.
11 MR. WARD: That's the ENSAC report.
12- MR. DURR: That's the ENSAC Report 125. That's 13 just been issued. It is available to the industry. The NRC
() 14 has not formally endorsed it yet. The intent is that the 15 industry use it for six to nine months. The agency will 16 monitor what the industry is doing. That has not had any 17 structure put to it yet. That is still in the concept 18 stage. And then it would be either endorsed through a 19 generic letter or a regulatory guide.
I 20 That's the status of that program. (
L 21 We get impacted by that through the fact that we 22 go out and periodically do, we use the 50.59 process, plue 23 utilities supply their 50.50 changes that they have made 24 over the year. Those are submitted to the region. And some 25 reviews are done on those things.
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'vl 1 The other issue I've tied into this, because the 2 basis for the technical specification is buried in the 3 design reconstitution program.
4 This is an industry initiative. It's being driven 5 by a lot of things. The agency is obviously interested in 6 it. It is going to be an integral part I believe of the 7 plant life extension program. If they can't come up with 8 the design basis, they are going to have difficulty showing 9 that it can go beyond 40 years, if they can't find the 10 design basis.
11 So the utilities are spending a lot of time and 12 effort. And in Region I there is a significant amount of 13 effort for design basis reconstitution and as some utilities
() 14 would characterize it, as design basis consolidation. They 15 don't have to reconstitute the design basis, they just have 16 to consolidate it, they have to pull it together. It's 17 heading for various places and they've got to pull it 18 together.
19 Some plants may have to reconstitute the design 20 basic. They can't find it. It doesn't exist.
21 I give this alide as an example. This we.e a 22 presentation generally done by Fitzpatrick in Ma.y of 1989 23 and it kind of outlines their program.
24 The prograu was to develop the guidance and design 25 bas.is document, writer's guide format, and that was i (~% Heritage Reporting Corporation
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1 completed for licensing requirements, design criteria, p 2 design attributes, technical requirements, to meet the
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3 licensing design criteria, calculational summaries including 4 the references, and summary of changes and modification.
j 5 They developed part of the program for the high l
L 6 pressure coolant injection in the condensate feedwater 7 system and that is in the final stages of completion.
8 They issued the bid' specification for the 9 remaining systems, and we're talking about 26 more systems 10 here, so it is a fairly extensive program. And that was 11 estimated to be ready by Midsummer and it was going to be 12 completed in five years, so it is a longterm project.
13 They needed to establish new in-house
.( ) 14 infrastructures to control configuration documents and they 15 expected to have that completed by 1990. And that would 16 encompass the calculations and specifications and table 17 rates and licensing commitments.
18 And then they had to collect the documents from 19 outside sources.
20 MR. CARROLL: Out of curiosity, who was the AE?
21 MR. DURR: I don't know that. There's been 22 various AEs. We've had AE3. It's unusual-for us in this l 23 region to have Sergeant and Lundy do much work in this 24 region, but I know Sergeant and Lundy are doing some work in 25 this rregion.
1'
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- NJi 187 1 I give you this slide as an example of a system.
2 :This book, and it is available'for your perusal at your 3 discretion, this is one system and it is done by Public:
4 Service Electric and Gas, this is a 4160 volt electrical 5 system. And this is a design basis package for that one 6 system. And-this is just the references. I mean this 7' consists of references to the documents that support the 8 design basis.
9 And as you.can see, it is a fairly extensive 10 document. It' describes the boundaries. It has the design 11 system descriptions. It has the drawings, it has the 12 calculations. And all these things were referenced in this 13 one document. And that's what this book is here.
() 14 MR.-MARD: Jack, why don't plants have this? I 15 mean do the newest plants have adequate design basis 16 documentation?
17 MR. DURR: They are getting smart. A good example 18 is Public Service Electric and Gas was their own AE for 19 Salan, this is for the Salem plant.
20 MR. WARD: Okay.
21 MR. CURR: They were their own AE. The deuign i 22 during that era was done in-house, and so they found parts ;
L I L 23 of it in some guy's desk; some guy retired and had pieces of J 1
24 it in his garage. g l'
l 25 MR. WARD: What about Seabrook, for example?
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1 HR. DURR: Seabrook, I would expect Seabrook, 2 Yankee Atomic Electric is really kind of the engineering i
3 organization.for that group. I don't know specifically 4 about Seabrook, but I would have very good feelings that 5 they would have control of their design basis, that they 6 would be able to pull that together, 7 And here again that may be a consolidation problem 8 versus a reconstitution problem.
9 MR. WARD: Why would they even have to 10 consolidate? I mean is this a new NRC requirement, to have.
11 a consolidated design basis document?
12 HR. DURR: No. What it amounts to is, let me give 13 you an example.
() 14 For instance, if you want to do plant life 15 extension, you want to go beyond your 40-year license, you 16- are going to have to'come to the Commission and convince us 17 that that plant is capable of running beyond 40 years.
18 MR. WARD: So it is a new NRC requirement for 19 license extennion? Is that what it amounts to?
20 HR. DURR: It would be roquired for you to be able 21 to demonstrate e that the plant is capable of operating beyond 22 40 yearc.
23 MR. WARD: Well, what about an updated FSAR?
24 MR. DURR: But the FSAR in and of itself, the FSAR l
25 is supported by this design basis. )
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1 MR. WARD: Yes, but just the FSAR --
2 MR. RUSSELL: Let me try and put some perspective 1
3 on it.
4 I think if you go back to the safety system 5 functional inspections that the staff performs, we found 6 cases where in the process of making the changes to 7 facilities, that they actually undid part of the design 8 basis, that they removed safety functions.
9 While that started and was first identified I 10 think with the SSFI down At Turkey Point, we've had examples 11 here in Region I associated with auxiliary feedwater systems 12 where we have found single failure points within the 13 auxiliary feedwater system. Licensees have made numerous
( .
14 changes to their facilities.
15 In some cases we get into evaluations of those 16 changes and it becomes a function of what was it originally 17 and how are you changing it.
18 MR. WARD: There is a requirement to update FSARs, 19 right?
20 1% RUSSELL', Yes.
21 MR. WARD: Why isn't that -
22 MR. RUSSELL: The FSAR dees not have sufficient 23 indepth information la it. P. lot of titter you have PNIB 14 drawinys, cae-line schematics that do not have suffleient 25 detail in the design basis on how it functions.
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1 Areas of concern associated with electrical 2 systems, with relaying and logic and protective features are 3 often not described in the FSAR in sufficient detail to do a 4 design change.
5 MR. WARD: So you.are saying that the safety 6 systam functional review experience has shown that something 7 new is needed.-
8 And is that only because of modifications?
9 HR. RUSSELL: In some cases. In other cases, 10 systems as they were turned over, some of the older turnkey 11 plants, there was not a good understanding of what'the i
12 design basis was and the information'was not available and a j 13 utility that goes in later to make a change or.an upgrade !
() 14 has to establish what was the original design basis in order i
15 to make that change. i i
16 MR. WARD:- So is this going to become_a new 17 requirement then~that's going to be backfit on plants?
18 MR. RUSSELL: Right now I would characterize the i 19 situation that is occurring as that a number of utilities 20 are finding themse?ves that ' hey do not have an adequate 21 design basis to support changes that have been made. There 22 are a lot of utility initiatives to do safety system j 23 functional inspections and those inspections are finding 24 problems themselves, and most of these programs are self-25 initiated on'the part of the utilities.
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1 1 There is not the threat or the club hanging over 2 their head that we are going to make this a requirement. We 3 don't have a rule out on tne street or a proposal.
4 But our experience has shown that the actual state 5 of utility knowledge of their design bases varies from plant 6 to plant and their ability to put their hands on it to use 7 it as they find a need to modify it or to take advantage of 8 non-safety systems to respond to events looking at the 9 capabilities, doing PRA analyses. You have to understand 10 how the systems are put together and what the design basis 11 is.
12 If you make assumptions in the PRA, and that's not 13 accurate, you have a severe problem. So a lot of things are
('N) 14 coming together to drive utilities in the direction of 15 really understanding the details of how some of these 16 systems were put together.
17 DR. KERR: Isn't part of the problem that the NRC 18 has not yet decided what it is going to require for life 19 extension and some of the utilities have decided maybe to 20 take some initiative, which they prob.Thay should have done 21 years ago, and come up with something that they think makes 22 sense?
23 MR. RUSSELL: That's correct. And I think that 24 people are recognizing this problem. We are seeing 25 different approaches by different utilities. Some have
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1 programs that are running at the rate of $3-5-million a 2' year. Others are more extensive. Five year programs in 3 planning are not uncommon. Some are just getting started L 4 doing one or two safety system functional inspections and 5 design basis reconstitution.
6 So there is quite a spectrum out there.
7 NRC has clearly been emphasizing. engineering 8 support of operations and one of the keys to offsetive 9 engineering support is an understanding of the design basis 10 of that system.
11 .It's not being driven because we're proposing a t
12 requirement. There's not an advance notice of rulemaking 13 that says you have to have a reconfigure design basis
([ 14 available. It's being driven by need by the utilities.
15 MR. CARROLL: INPO is pushing hard in this area-16 also to ten extent'that they've got workshops in 17 configuration management and things of that nature.
18 MR. DURR: And the other things, for instance, we 19 in this region initiated what we call special electrical 20 inspections where we have gone to older plants and looked at 21 how they control load growth and breaker coordination and 22 that kind of thing, and we found that when you really start-23' looking hard at it, they haven't kept track of this thing.
24 They don't know what they've got.
25 And Salem went back and redid their breaker
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193 l' coordination studies, because they've lost it. They'didn't 2 ~know what they had. And that plant is only like 1975.
3 The other thing,. the other point that I made 4 - earlier, and I've re-emphasized, is the fact that in the 5- ' design basis, the bases for the technical specifications are 6 all not.in the FSAR but they are in the design basis. So'if 7 they want to change a technical specification and they don't 8 have the design basis they will -- so that is another reason 9 for them to capture that.
10 Moving on, the bottom line here, line item 1:L improvements. We have seen some changes in technical l
12 specifications. I'm thinking of Generic Letter 88-12 which 13 took. Appendix R' issues and said licensees, you can take all.
lO 14 ehis ^ree eix e=e er vent each ica1 ereciticatien it.ro=
15 put in this canned statement that essentially says.you will 16 keep the fire hazard analysis report as defined in the fire
.17 hazard analysis report.
18 We've had two near term operating plants that in 19 fact did that. It was-Hope Creek and Nine Mile II both 20 extracted all those Appendix R requirements out of their 21 technical specifications and put in the canned statement.
22 We have one operating plant.that I know of and 1 23 probably several others that are contemplating doing that.
24 However, it is a back burner issue. It is not a priority 25 thing.
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1 The other point is that on line item improvements, 2 the only other one that I know of that has impacted us in 3 the region, and that is taking the organization charts out 4 of the technical specifications.
5 The last point that I wanted to make, I missed, t 6 and that is.the improved standard tech specs, which is 7 quote, the carrot. That is tied to the 50.59 process. _That 8 .is to say that until the industry-can show us they have the 9 50.59 process under control, we don't issue them the new 30 standard tech specs. They've tied those two together.
11 DR. REMICK: When you say "the industry" do you 12 mean on a case by case basis? Licensee basis?
13 MR. DURR: Yes. That's all I have.
14 MR. WHITNEY: Jack, I'm Leon Whitney from NRC' 15 Headquarters, and this is too rich to pass up.
16 I'm running a program of inspector exchanges 17 between us and the Soviet Union and the Soviet inspectors 18 will be going back to NRC Headquarters for two days of 19 briefs of their choosing. And I just worked out with them 20 the agenda. And the design basis reconstitution is 21 something they picked out, something they wanted to hear 22 about.
12 3 DR. REMICK: Does that suggest they might not know 24 what their design basis is either?
25 MR. WHITNEY: It really piqued their interest.
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1 They wanted to know about design engineer qualification and 2 design basis reconstitution programs.
3 MR. RUSSELL: Thank you. Our next speaker is Dr.
4 Knapp.
5 DR. REMICK: Anything we can do to speed up the 6 process we would appreciate, both from the staff and from 7 the committee. It's now 1:45.
8 MR. KNAPP: In that case, I will be as brief as I 9 can.
10 Very quickly, what you will be hearing about, in 11 what I hope will be less than the next hour, will be work 12 that has gone on in the Division of Radiation Safety.and 13 Safeguards on fuel cycle and materials licensees.
() 14 And I would just like to kick it off with a very 15 brief introduction of the division. And much of what I 16 would say you will find in the handout you've just been 17 given.
18 The handout briefly describes the organization and 19 what our responsibilities are and what some of the 20 capabilities are of the staff to deal with them.
21 Very quickly, the division is organized in two 22 branches, one branch under Dr. Velman, responsible for 23 interactions with reactors and fuel facilities and addresses 24 emergency preparedness, Facilities Radiation Protection, 25 which is radiation protection within the facility, Effluents
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. .' ..1 ._ Radiation Protection which is affluents from the-facility-2 and our Safeguards Sectione.
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3 On the other side of the house we have our
/ 4 materials, Nuclade Materials Safety Branch under Dr.
l 5- Bettenhausen, who will speak to you shortly, and he has 6 three ' sections which are responsible principally 'for medical 1 ..
licensees, for broad licensees and for sealed sources, such-7
- 8 'as radiographer l and irradiatora and 'a fourth sa;-tion which 9 is our Licensing Assistance Section. There is a. great. deal 10 of work to do because we are responsible here for about 11 3,000' materials' licensees, both the licensing.and; 1
LF 12 -inspection.
13- Although we have divided the work, the
() jl4 responsibilities of each section as described, any:of the 15 staff of these sections can work with any one of the areas.-
16 DR. REMICK: .How many licensees would.you have if 17 .there were not agreement states? Have you any idea?
18 MR. KNAPP: I would like somebody to' check me on 19 it. I think New York has 1,800 to 2,000. I1think New-20 Hampshire has around 80. We'have around 3,000. I guess
- 21. we'd have 5,500.
22 MR. MARD: So roughly. half?
~
23 DR. REMICK: The workload would double.
24 MR. RUSSELL: You have another 400 or so in 25 Maryland. So it's about half. Material licensees generally L h1 V
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197 e) w 1 follow population trends. And the size of the population 2 determines about the number of hospitals, industrial users 3 byprcduct material licensees.
l 4 DR. REMICK: How many material licensees in 5 Pennsylvania?
6 MR. KNAPP: I can't tell you that off the top of 7 my head.
l 8 MS. FOSTER: 800 or so.
9 MR. KNAPP: About 800. This is Doris Foster who 10 is responsible for our Licensing Assistance Section.
l 11 MR. WARD: As I said, out in Region IV there is an l
l 12 tremendous number of material licensees. And not much 13 population.
() 14 MR. RUSSELL: They have a lot of industry 15 activities.
16 MR. KNAPP: I believe they have about 800 17 materinis licensees. The vast spread of people makes t1eir 18 job rather difficult.
19 MR. WARD: They told us they can't even find some 20 of them. Let along inspectors.
21 MR. KNAPP: I think Ms. Foster can tell you that 22 from time to time we have difficulty locating some of ours.
23 MR. WARD: Really? Okay.
24 MR. CARROLL: 830.
25 MR. KNAPP: In the interests of speed, I am going
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198 I to skip the next viewgraph, but just note that in the 2 diviaica as a whole we have a staff of about 76 people of 3 whom we have about 10 or 12 Ph.D.'s, about 10 or 12 people 4 with Master's Degrees in various specialties anywhere from 5 engineering, radiation, laboratory safety, materials, health 6 physics. And frankly, we have a team that I personally am 7 still getting to know. I've been at this for about six 8 months. But I'm very proud of them and they are some very 9 good people.
10 I would also like to talk very quickly about some 11 of the facilities that we have. And some of these you will 12 have an opportunity to see tomorrow. I believe there is a 13 tour at 1:00 o' clock.
() 14 And among them we have the incident response 15 facility that is associated with the emergency preparedness 16 section which you will be seeing that I think you will find 17 interesting.
18 We have our TLD lab. And you may be aware that 19 Region I has responsibility for TLDs for the entire country. '
20 These are the TLDs that are placed around reactors.
21 We have our Mobile Environmental Laboratory Van.
22 I'm sorry that you won't be able to see that, because that 23 is presently at Millstone. We have a sample preparation and 24 counting laboratory with a variety of instruments. And 25 finally, we also, under Ms. Foster's supervision, we have Heritage Reporting Corporation
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r^T 199 LI 1 our public document, materials docket room, which contains 2 3,000 dockets for the materials licensees.
3 I'll be happy to answer questions.
4 DR. KERR: Under Appendix I of 10 CFR 50 as I 5 remember a licensee has not only to make calculations about 6 releases from the reactor during normal operation but he has 7 to set up a monitoring network to demonstrate that he is 8 operating within Appendix I.
9 Do these TLD rings serve that purpose?
10 MR. KNAPP: No. The TLD rings -- he does his own 11 set, we do ours.
12 DR. KERR: Okay. But does he use TLDs to 13 demonstrate it?
p)
( 14 MR. KNAPP: Licensees also have TLDs. I'd like to 15 be corrected, but I think all of them do have TLD rings.
16 Many times they are located in the same positions as ours.
17 DR. KERR: My question is can one with TLDs 18 demonstrate that compliance with Appendix I exists?
19 MR. KNAPP: No. TLDs are not sensitive enough.
20 DR. KERR: Thank you.
21 MR. RUSSELL: The environmental monitoring 22 programs are quite extensive. TLDs are only one elemen'; of 23 that program. There are also water samples, air camples, 24 points of release, rad monitors in liquid effluent streams, 25 air streams that are used to ensure compliance with Appendix
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1 I of the effluent technical specifications. And TLDs are 2 not used in that context.
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3 DR. KERR: Thank-you.
4 DR. REMICK: Thank you.
5 Our next presentation on the schedule is Fuel 6- Facilities, and your schedule has Mr. Joyner doing that.
7 Actually Dr. Boris and Jerry Roth will do that. Jerry is 8 our lead fuel facility inspector. And he's got a client 9 back in the audience in case you need some help.
10 MR. JOYNER: I thought I would start out by giving 11 you an idea as to the status of the major fuel facilities in 12 Region I, and who they are.
13 United Nuclear Corporation, Naval Products r~3 (j 14 Division, is operational.
15 United Nuclear Corporation Recovery Systems is a 16 facility in Rhode Island which is decommissioning, is in the 17 last throes of decontamination.
18 Combustion Es.gineering is a fuel cycle operation 19 for fabrication of low enriched fuel for reactors, and that 20 is operational.
21 Babcock & Wilcox Apollo is current 22 decommissioning. They have come into a renewal application 23 to authorize them to do some additional work. It's 24 different kinds of work, but not in the fuel cycle area.
25 B&W Parks Township facility was at one time a Heritage Reporting Corporation
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a 201 i) 1 plutonium fuel fabrication facility and is now being used to 2 refurbish reactor components and decontaminate reactor 3 components.
4 Cintichem is operational. Cintichem is the one 5 facility that we have in the region where they produce 6 radiopharmaceuticals from fissioning of uranium oxide.
7 And of course DOE-West Valley under the 1980 8 Demonstration Project Act. We reviewed the operation of the 9 facility in order to assure the health and safety of the 10 public. Exporters at the same time reviewed the operations, 11 all of their SAIs, program plans, et cetera.
12 MR. CARROLL: Where does Cintichem get their 13 radiation? Any particular facility?
() 14 MR. JOYNER: The radiation is done in a non-power 15 reactor onsite.
16 DR. REMICK: Where is that located?
17 MR. JOYNER: Tuxedo, New York.
18 DR. REMICK: That's at 5 megawatts now?
19 MR. JOYNER: Yes. A little bit of information on 20 each of the major facilities.
21 United Nuclear Corporation fabricates cores for 22 nuclear submarines. We had an issue: lack of management 23 attention to radiation safety. That was found through a 24 series of operation safety assessments that were conducted 25 in 1986 to 1987. The licensee instituted a unilateral
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1 improvement program which is currently ongoing, and term 2 reviews indicate that they are in fact doing well with the 3 overall program.
4 Cintichem produces radiophanaaceuticals --
5 DR. KERR: Excuse me. I don't know how much you 6 are willing to talk about this, but what was the problem 7 w1th the radiation safety? Was it exposure or criticality?
8 MR. JOYNER: It was in 1987 they were cited with 9 severe penalty for overexposing an individual to uranium 10 releases in one of the operations.
11 DR. KERR: Exposing an individual to uranium?
12 MR. RUSSELL: If I recall, this is going back to 13 1987.
()
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14 MR. JOYNER: Yes.
15 MR. RUSSELL: The issue was FDC concentrations and 16 when they were using respirators and not using respirators, 17 and the issues with respect to their health physics program 18 to ensure that there were not uptakes by individuals.
19 We felt there was a lack of management attention.
20 There was also a concern with respect to the mixes. And I 21 don't want to get into -- the issues were enrichment of the 22 fuel and what were some of the isotopes in the enrichment 23 and how you calculate MPC concentrations for those -- and 24 I'm hedging the words because this is a transcribed public 25 meeting, and I don't want to get into --
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203-1- DR. KERR: My impression is that the uranium is 2 more toxic than it is' dangerous from radiation, if you are 3 really talking about uranium -
4 MR. CARROLL: That's true, but it is also in 5 Appendix B.
6 'MR. RUSSELL: That's exactly right.
7 MR. JOYNER: Okay. Cintichem. They produce 8 radiopharmaceuticals through fissioning of uranium.
9 We identified again some issues: management 10 controls, contamination control program was lacking in some 11 respects.
12 These were found again through the operational 13 safety assessment and routine inspection.
( 14 They, too, have initiated a unilateral improvement 15 program. And we just recently came back from there and it 16 appears'that these actions are taking hold and things are 17 starting to improve in the facility.
18 DR. KERR: What is a unilateral improvement 19 program?
20 MR. JOYNER: That means they did it on their own 21 without coercion from us.
22 MR. CARROLL: Is that the same facility, it used 23 to be Union Carbide, is that correct?
24 MR. JOYNER: That is correct.
25 MR. CARROLL: So it's the same facility?
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.d 1 MR. JOYNER: Yes.
-2 MR. CARROLL: Any new facility there?
3 MR. JOYNER: No.
4 MR. CARROLL: Okay.
5 MR. JOYNER: They are still basically operating 6 the same way that they were previously, only under the'name 7- Cintichem. The transfer was made in 1985.
8 DOE West Valley of course is a demonstration of 9 the process for solidification of high level liquid waste.
10 Actually, today, it is about 30 percent of the 11 supernatant with a total 600,000 gallons which have been 12 solidified in concrete.
13 They expect to initiate vitrification of the f) 14 sludge sometime in the 1992-93 time period.
15 NRC and DOE have been providing information and 16 status reports periodically to ACNW. So if you people have 17 not been hearing very much about it that's probably one of 18 the reasons.
19 And we monitor ongoing progress through team 20 assessments. We expect to have a team up there within the 21 next two weeks or so.I 22 DR. REMICK: I'm not quite sure I understand where 23 it says solidified in concrete to initiate vitrification of 24 sludge. You mean they go from concrete into vitrification?
25 MR. JOYNER: There are two things.
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- 1' one'is the supernatant,-which is being solidified p ~2 in concrete.
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-3 -DR. .REMICK: . Okay.
4 MR. JOYNER: Okay. . They are going through an ion
- 5. exchange column which is pulling up all'of the cesium:and 6 the strontium and whatever else they can get out of it.
7- What remains then is solidified in concrete.
L '8 The second phase, after they complete the 9 operation of. removal of the 600 out of 660,000 gallons will'
~
10 then be to vitrify two things.
11- -Number one, the sludge that is left in the bottom l,
12 of the. tank, and two the resins that are being dropped into' 13 one of the tanks that they are using to remove the cesium
. 0: 14 a twe ere ei -
15 DR. REMICK: Do they go.through a calcine state 16 first before. vitrification,'do you know?
17 MR. JOYNER: They don't expect to.
18 DR. REMICK: They don't.
19 MR. JOYNER: No. They expect at this point to go 20 right straight through into the glass.
21 We do have a problem facility. And the problem 22 facility is Combustion Engineering. It has been on the 23 agenda about a year now, I guess, maybc a little over a 24 year.
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- :L reactors.
2 The' issues are lack of management controls and
'3 lack of attention to radiation safety.
4 The management problems were found through the 5 operational safety assessment and routino inspections.
li After this was identified, routine inspections 7 found~ corrective action was slow, therefore a confirmatory 8 action letter was issued telling them to in essence prepare 9 an improvement program which is now ongoing.
10 We also conducted a SALP during August 1988 which 11 was issued. And as a result of both the St.LP and the 12 confirmatory action letter, the facility then instituted an 13 improvement program which is ongoing and we are within the
() 14 next couple of weeks again going to have a team inspection 15- going up there to look at the status of the facility with 16 regard to the SALP recommendations.
17- MR. CARROLL: Are SALPs normally done on things 18 like fuel fabrication plants?
19 MR. JOYNER: No.
20 MR. RUSSELL: No. This was a regional initiative.
21 I requested the SALP be performed because I saw an 22 organization that was not responding to civil penalties and 23 other issues.
24 We felt that we needed to do a review, describe 25 where they were, establish a baseline and then be in a
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'\wb' l 1 position to. judge whether they were effective in turning ;
2 around performance over the next two years. l l 3 So we established the.SALP team, we issued the l
4 report, we had a meeting with them. I believe there were !
l 5 ten areas. Five of the areas were rated Category 3.
.6 We are at the midpoint of that SALP cycle now and ,
7 that is the purposs for the team inspection, is to judge' 8 progress along the. path of turning things around up there. i 9 And I believe that we now have Shelby Brewer's 10 attention and that things are going to improve. But we will 1
1 11 wait and see and the-results will speak for themselves as to l
l- 12 whether they do indeed improve the performance of that 13 facility.
( )- 14 DR. KERR: Well, help me a bit. I can understand 15 why a SALP report brings a good deal of pressure on the 16 utility. But a SALP-3 means, if I read these ground rules 17 correctly, that no regulations are being violated, but that 18 improvement could be achieved if people would work at it.
19 MR. RUSSELL: It is minimally acceptable. The 20 margins are not there and the experience is that they cross 21 across'the line and we do have violations periodically.
22 It's not to the point where we shut them down.
23 DR. KERR: The reports are careful to say, at 24 least the ones I read, that a 3 doesn't mean that any 25 regulations are being violated. It just means that there is
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? J 1 room for improvement and it should occur.
2 I wonder how much of a lever it is against this 3 sort of operation?
4 MR. RUSSELL: This company works in the reactor 5 a r e.t . They understand what SALPs are. They manufacture 6 fuel and they provided the incentives for them improving 7 their performance, commercial incentives, because their 8 customers understand very much what SALPs are and what they 9 sean. And when they get hit pretty hard in assurance of 10 quality, criticality, safety, other areas, --
11 DR. KERR: You found it effective, then?
12 MR. RUSSELL: It has thus far been effective but 13 we're only one year through it and we'll see if it turns
(-w) 14 around.
15 The plan is to have the team inspection, assess 16 their performance at the end of two years with another 17 formal SALP and see if they indeed have turned it around.
18 They were having industrial accidents where one 19 worker that was injured lost fingers --
20 DR. KERR: Please don't misunderstand me. I'm not 21 being critical of your judgment that something needed to be 22 done and perhaps even regulations may have been violated.
23 I'm just trying to reconcile what I read in the SALP, which 24 is that a 3 doesn't mean any regulations have been violated, 25 and with what somebody would do who isn't under the gun of Heritage Reporting Corporation
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1 an" operating utility. There you'have I think a different' 2o, 12 kind-of leverage. o E 3 MR. RUSSELL: We've.usedLother levers as well. We 4 have-had Mr. Brewer in for meetings with Mr. Stello and I'
-5, and we've1tried to impress upon them the seriousness with 6' which we view their performance, and it is minimally L .7 acceptable in a number of. areas.
8- DR. 10 ERR: - I. agree Mr. Stello is a lot bigger than 9 Mr.. Brewer. But --
10 (Laughter) 11 MR. JOYNER':. I believe one of the things =that the 4
12 SALP views as a-lever-is also the publicity associated with 13 it. No company wants bad publicity at all, if they can at-
~
. ) 14' least1 help it. And here is a situation with the first
- 15- company,. whatever, to go through this process that.is'very, L 16 very rarely _ conducted for a fuel cycle type facility or this-17 = type of facility.
18 And that in itself gets. media attention because 19 the question comes up, it came up in this case, how come you 20 don't do this routinely? How come this hasn't happened at 21 other facilities? You know that kind of question has come 22 up and I think it acts as a lever.
23 DR. KERR: But the answer you gave was well, we 24 . thought something might be wrong but we really didn't find 25 any regulations being violated.
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,: 1 ' MR. RUSSELL: There were regulations that;were 2' violated,.there was history of civil penalties and: actions.
=3.: 'They-had not'gotten to the point-where we would shut the
- h. 4.- . facility down.
5 DR. REMICK: Where would have been that point?
6 (Laughter) 7 MR. MARD: ' So this.is Governmental regulationLbyL 8 media pressure.
9- MR. RUSSELL: The purpose of the SALP --
^10 MR. WARD: Which has an unattractive ring to it.
11 MR. RUSSELL: The purpose of the'SALP was to 12 collect all the information that we had on the facilitw 13 describe their performance overall. We found that they were 14 minimally meeting our requirements in a number'of areas. -
15 There were other areas that had the effective < improvement.
16 'They were on:an improvement program before that period of-
~17 time.
18 DR. KERR: See, I don't understand the concept of
'19 ' ; minimally meeting a requirement.
20 It seems to me you either meet a requirement or 21 you don't meet a requirement.
- 22. MR. RUSSELL: They had a history in the past of 23- failing to meet several of our requirements.
n 24 DR. KERR: I understand that concept, when you 25 don't meet a requirement. But I don't understand the
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1 significance of minimally meeting a requirement. It seems 2 to me it is a yes-no. If you are under a regulation, either 3 you are meeting it or you aren't.
4 MR. RUSSELL: Let me give you an example. The 5 example of the physical containments around the equipmer.c in 6 the pellet manufacturing process.
7 Prior to this time, they typically had polyethylene bags, temporary containments that often failed, 9 resulted in contamination of the room. And while the 10 contamination made it difficult to work, they c?eaned it up 11 in most cases. We did have some violations where we cited 12 them.
13 They have subsequently manufactured stainless em
(,) 14 steel containments, modified the ventilation system to 15 control the contamination and physically improved the 16 process.
17 The old one met our regulations. The new one has 18 a substantial margin and will likely not result in failures 19 of the containments at a frequency that they were 20 experiencing in the past. They will be able to keep it in 21 place.
22 DR. KERR: If your description of what was 23 occurring is accurate, and I have no reason to doubt it, I 24 don't see why it met the regulations. It seems to me if 25 that's the case that regulations needed to be improved.
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1 MR. RUSSELL: The situation that existed was 2 minimally meeting the regulations and there were a number of 3 cases where they fell below the levels and we did indeed 4 cite them. And we had escalated enforcement. In fact, I 5 believe we had escalated enforcement three times in a period 6 of abo'st two years for essentially the same issues on a 7 repetitive basis.
8 The fact that the staff was somewhat frustrated 9 with their improvement program and their responsiveness to 10 enforcement tools contributed to the decision to have a SALP 11 review to review what the history is in a number of areas.
12 The criticality concerns. Straightforward issues.
13 MR. WARD: Why didn't you shut them down?
()
em 14 DR. KERR: That's the part that puzzles me.
15 MR. JOYNER: They were not really to the place 16 where a major problem existed. But they were right on the 17 ragged edge.
18 MR. WARD: So you know where that edge is?
19 MR. JOYNER: It's difficult to identify an edge.
20 You know that. But they were, you know, it could go either 21 way at that particular point. Something had to occur.
22 MR. WARD: This has come up before. Let me see if 23 I could see what you are doing.
24 In the realities of regulating, you can't possibly 25 audit all of their activities. So you audit some sample I
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1 which is probably kind of small in the case of Windsor.
2 And when you find in your audit of this small 3 sample that on a number of things they are awfully close to 4 going below the real requirement, you kind of suspect that 5 there may be some things you are not auditing where they 6 really are below. So you want to do something about their 7 whole operation.
8 Is that kind of the model that you've got going?
9 MR. JOYNER: It's getting there.
10 MR. MARD: Because this issue keeps coming up.
11 MR. RUSSELL: In the fuel facilities case where 12 this was the first one applied, to the best of my knowledge, 13 I'm not aware of a SALP having been done for any other fuel
() 14 facility. .
15 But that was clearly part of the thinking. The 16 issue is what is the margin between where you are performing 17 and meeting regulatory requirements. If you are minimally 18 acceptable, you would expect, experience would show, that a 19 number of times you fall below the acceptable level, you 20 have violations. You can have a violation and not have the 21 violation be so serious as to shut down the system.
22 The criticality issues were issues with respect to 23 how they controlled it, how they made design changes. We 24 didn't really have issues where we were concerned that there 25 was going to be a criticality event. But the margin that
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1 existed was being eroded.
2 If you stacked pellets too high in a tray and you L !
3 put too many trays together, you can get to the point where 4 you can reduce the margin to criticality and instead of 5 having .9 or .95 you might get to .96 or some number like 6 that due to a breakdown in the engineering analysis. That's 7 eroding margin. Their failure to recognize that and perform 8 the criticality reviews was part of the concern.
9 MR. ROTH: There is one other aspect here that I 10 think is looked at, when you identify a violation and the 11 licensee only zeroes in on what you point out to them but 12 does not look beyond that to other similar situations, in 13 other places.
(~\
i ,) 14 Consequently, you come back in and even though 15 they fixed what you pointed out directly to them. They've 16 left other situations which were somewhat similar to that go 17 and then they consequently come back again.
18 So by pointing out I think two of the areas where 19 they are ineffective in a SALP program and pointing them in 20 the direction of the overall generic improvement, I think is 21 where we make more progress.
22 It's not our job to identify specific deficiencies 23 or noncompliance items.
24 MR. CARROLL: Pragmatically also the alternative 25 Bill points out is why don't you shut them down. I think Heritage Reporting Corporation
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1 realistically you didn't have a good enough case to do that.
2 MR. RUSSELL: We discussed that. In fact, the 3 concept of the SALP was discussed in a senior management 4 meeting where we laid out what had been their history prior 5 to that time.
6 We didn't have any smoking guns that we could use 7 to point to say it's bad enough to. shut them down. We had a 8 long history of concerns and failures to comply with 9 requirements and we felt that a SALP assessment to establish 10 a baseline with them on a formal improvement program that 11 was confirmed by CAO with quarterly meetings and reports and 12 senior management meetings along the way would be sufficient 13 to get their senior management involved and we felt once
(^)
q 14 they were involved and recognized that we were serious that 15 they would get the place squared away.
16 So that was the approach that we chose rather than 17 shutting them down.
18 So we did entertain that concept as well.
19 MR. CARROLL: You probably reasoned that legally 20 you'd have a tough battle if they wanted to challenge you.
21 MR. RUSSELL: I looked at all the facts I had and 22 I made that proposal and it carried the day with the senior 23 management.
24 MR. CARROLL: Senior management being you've 25 referred to a couple of times as the EDO and --
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~) 216 (V 1 MR. RUSSELL: Yes. It's the regional 2 administrators, the office directors and the EDO. And we 3 get together twice a year to review the performance 4 facilities, both reactor fuel facilities and material 5 licensees. 3 I
l 6 DR. REMICK: I think perhaps we should more on to 7 the next topic.
8 MR. BETTENHAUSEN: My name is Lee Bettenhausen and 9 I am Chief of the Nuclear Materials Safety Branch. I' d like 10 to spend a few minutes again going over some of the 11 materials license facts and figures.
12 DR. REMICK: A little bit louder if you could, 13 please.
I) 14 MR. BETTENHAUSEN: Yes, sir. Let me use the 15 microphone.
16 As you can see, the 3,030 materials licensees are 17 roughly distributed, 1,200 medically related, 900 with broad 18 scope implications, universities, research organizations, 19 there are several hospitals that have broad scope license 20 programs. The distribution of manufactured materials that 21 use radiation sources and source material itself, uranium 22 and thorium.
23 There are 900 sealed source applications. These 24 are principally radiography, with a number of uses as 25 installed gauges and various industrial processes and Heritage Reporting Corporation
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1 several large commercial irradiators.
2 Each year this region performs approximately 1,500 3 licensing actions. This involves new licenses, renewals for 4 old licenses, and amendments and we also perform about 1,100 5 inspections of these facilities.
6 As you can see, it is a sizable job tracking these 7 things and as some of the anecdotes go, if you go looking 8 for a gas chromatography source in a small laboratory 9 sometime it will take you two hours to find the place and 20 10 minute to do the inspection.
11- DR. REMICK: Where are the large commercial 12 irradiators in the region?
13 MR. BETTENHAUSEN: One cluster is North New Jersey What, three in
( ). 14 and there is a few more in Massachusetts.
15 North Jersey. And there's cobalt. All the ones in this 16 region are cobalt.
17 DR. REMICK: What are their uses?
18 MR. BETTENHAUSEN: Principally, irradiation and 19 sterilization of hospital materials. I guess there are a 20 few other uses, but that's the main one I've seen.
21 MR. WHITE: Also there is a big market in dog 22 bones. They sterilize Hartz Mountain products.
23 DR. REMICK: Is that right.
'24 MR. BETTENHAUSEN: The gentleman speaking is John 25 White. He is one of my section chiefs.
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1 And for the Recorder, one of the purposes of the 2 irradiation is to irradiate dog bones.
3 DR. REMICK: Are most of the medical 1
4 sterilizations still done by accelerator or are there more 1
5 and more by cobalt?
6 MR. BETTENHAUSEN: I guess we haven't really, 7 there is certainly no increase in that which is done by j 8 cobalt. We have no real measure of what is done by 9 accelerator. There are new facilities being built for 10 cobalt irradiators, it is kind of a static market.
11 In fact, I guess we've had a closure or two. And 12 a couple, we know of one facility that is on the ragged edge 13 of going out of business.
rr
() lL4 DR. KERR: Other than dog bones, any other food 15 irradiation in the region?
16 MR. BETTENHAUSEN: Not food irradiation that we 17 are Tware of.
18 DR. KERR: Thank you.
19 MR. BETTENHAUSEN: Are there any other questions 20 on materials licensees? Again, this does nut include the 21 agreement states that are in Region I.
22 DR. KERR: What is the typical length of a 23 license? How soon does it have to be renewed?
24 MR. BETTENHAUSEN: Five years.
25 DR. KERR: Thank you.
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1 MR. BETTENHAUSEN: This is sort of a thumbnail 2 sketch of the inspections performed this past year. About 3 half have been clean with no violations. About half have 4 resulted in one or more violations. And we have a treadmill 5 of enforcement conferences.
6 23 of them have resulted in enforcement 7 conferences to date.
8 In starting to look st some patterns and trends, I 9 guess I would call your attention to four of these. Most of 10 the violations could have been headed off, again, having sat 11 through the discussion on quality control, by having the 12 person who is responsible for the job, typically the 13 technologist, do it right the first time. The radiation (m) v 14 safety officer should be overchecking these things.
15 Typically he could have caught the kinds of things that we 16 ended up citing in violations.
17 And the third level of review is the radiation 18 safety committee or management oversight group. They could 19 have caught these things with their own audits, and we 20 usually find when we have a case that results in escalated 21 enforcement that all three of those levels are broken down.
22 Another peculiar situation that emerged is that 23 private physicians have found it advantageous to have their 24 own license and their own nuclear medicine facilities in 25 office or in an office complex typically. And these are a r^ Heritage Reporting Corporation
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l' Esmall group of physicians, as you can imagine, the facility
- q. 2 turns out to be a small facility, a technologist part time
[ 3 or maybe full time for a week.
4 The physician ~becomes his own radiation safety 5 officer. And we found out that they really have no 6' fundamental appreciation of what they are buying when they 7 buy into this.
8 So we have finally gone to'a two-step licensing 9 process where when we see a situation like this we first 10 give them a license to get their calibration sources and the 11 . things they need to set up in business and then before they 12 start treating patients, t' ey go out, 'risit the facility and 13 issue them the license to acquire the m:.terial to treat
() 14 patients at that time if everything is okay.
15 This resulted in four or five separate enforcement 16 cases and the pattern was just so difficult for us to deal 17 with that we went to this two-step licensing process.
18 DR. REMICK: How many of those violations in 1989 19 roughly were due to having foodstuffs in areas where 20 radioactive materials were stored or used?
21 MR. BETTENHAUSEN: I'll pick a number like 10 22 percent. It's a very common problem. It's a very common 23 repeat violation, as you know from trying to keep graduate 24 students from taking their sandwich into the laboratory.
25 That's one we have to continue to work on.
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1 Another area we have to continue to pay attention 2 to is radiography. This is an area that it is rather easy 3 to have -- there are no engineered safeguards in the 4 radiographer business. The source is either in the camera 5 shielded in a source or it is out exposed.
6 And if the individual is doing his work, it is out 7 exposed fairly frequently, and the only barriers between 8 that radiation source and sonebody is all in people's minds 9 and ropes and signs and care exercised by people. It is 10 easy to have that break down and it breaks down frequently.
11 I guess we are kind of fortunate we haven't had 12 many substantive exposures in the last year or so. But the 13 potential is there every time.
[)
v 14 And the last one I'd like to speak of briefly is 15 we have had two large irradiator facilities that have not 16 exactly paid close attention to our regulations so that they 17 have been the subject of enforcement conferences that needed 18 attention on our parts.
19 Are there any questions on these?
20 MR. MARD: What's been, well, let's say even the 21 recent history in the region of actual overexposure or 22 injuries or deaths?
23 MR. BETTENHAUSEN: Deaths I can't remember.
24 Patient exposures from medical misadministration we've had 25 three or four in the past year that amounted to several
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I hundred rads.
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1 2 Again, when looked at clinically they turn out not 3 to have been egregious clinically. But the potential is 4 always there for much more.
5 Radiographer exposures, we haven't had any, but 6 our fellow regions have, I guess each one has had -- three 7 has had one, two has had one or two. There have been 8 several exposures of radiographer on the order of 100 rem 9 in the last year. I can't count them offhand, but I can 10 remember about three.
11 The last item I would like to have the inspector 12 who is the lead inspector for it, is the one following the 13 sodium materials.
r
() 14 This is Mr. Frank Costello. He is the lead 15 inspector for a place called Safety Light at Bloomsburg, 16 Pennsylvania.
17 MR. COSTELLO: Well, Safety Light Corporation is 18 the former U.S. Radium Corporation which has operated the 19 Bloomsburg facility since about 1948. It is the same U.S.
20 Radium Corporation that was operating in New Jersey and New 21 York since 1920 or so, maybe earlier.
22 In Bloomsburg, beginning in the late '40s up to 23 about 1970, they used radium, they used cesium, strontium, a 24 little bit of nickel 63, a host of radionuclides, which 25 resulted in contaminated lands and groundwater in the area
(')
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4 s- 223 1 between their' facility and the Susquehanna River, which they 2' ' border on.
~3 Since 1970, the.only one they'would'be using is 4 the tritium. The products they make now are luminous 5- products. Signs, they manufacture watches, they'also could.
6 make'some accelerator coils.
7 But until then they made a whole range of 8 products, heat sources, smoke detector coils, which resulted 9 in contamination of the facility.
10 -Since about 1970 they've had a license which 11 requires them to begin the' decontamination of these 12 facilities 3- the grounds in which they are situated.
13 Not much progress has been made between 1970, and 14 1979. In 1979 the license was made more specific as to whata 1()
15 the requirements were. Requirement was made for an annual 16- report to th3 NRC on the progress of decontamination and the 17 schedule for work.
18 But not much progress was made. There was some 19 decontamination done in the '70s but not very much.
20 In 1980, the U.S. Radium Corporation essentially 21' reorganized themselves so that the contaminated facility 22 went into one division and the rest of the corporation and 23 its assets were put elsewhere in the company and the name of 1:
24 the division was changed from U.S. Radium Corporation to 25 Safety Light Corporation. And the license was amended by Heritage Reporting Corporation
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l 1 the NRC with the NRC believing this was the only substantive 2 thing that was ',appening was they are changing the name of 3 the' corporation to Safety Light from U.S. Radium.
4 In fact what had happened we believe was that the 5 assets of the corporation were separated from the liability l
L 6' for decontamination.
7 Shortly thereafter, this division was sold to some 8 employees who work at the site, spun off totally. separate 9 from the rest of the company. And we were unaware it was 10 happening at the time.
11 In 1983, during a routine inspection, the NRC 12 became aware when we went to the site that the company had 13 been sold and was made known by the president of the company 14 who was working onsite.
15 At the time we asked for additional information 16 about what had happened, and the details of these 17 transactions. And we corresponded back and forth with the 18 licensee until about 1986 when another inspection was done 19 and the licensee was cited for several regulstory violations 20 associated w..th this, and was asked to send in a 21 decommissioning plan.
22 The decommissioning plan would start off with a 23 characterization of the activity onsite and once that was 24 completed, a plan to remove the activity would be 25 forthcoming.
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- 1-We didn't receive one. We have not' received a i
2- -characterization. plan. And so early.this year, I believe it p 3 was in February, March of this year, an order was issued.
4 And the order required both the current Safety L 5 Light Corporation and the descendants of the old U.S. Radium 6 Corporation,:which is now called USR -- and there are 1
7 several USR companies: there'is USR Nbtals, USR Chemicals,.
l . .
8 there are several of them, out in Texas -- to_ jointly _ submit 9 .a site. characterization plan'and'then.upon the approval of
'10 the plan and the implementation of site characterization, 11 eventual cleanup.
12 Extended delay was asked and given. And in June 13 the licensee came in with the site characterization. plan j ) 14 which upon review was inadequate, and did not' meet the 15 requirements of the order.
16 17 18 19 20
-21 22 23
- 24 25
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%J We had several meetings with the licensees and 1
2 during these meetings they said it was clear that there was 3- a real question about what assets would be available to 4 complete the characterization. The licensee said that they 5 do not have the money to either do the site characterization
- 6. or certainly to eventual site cleanup.
7 These facts togeth6r with our realization that 8 previously assets have been separated from liabilities, 9 whether the NRC be concerned about the funding for the site 10 characterization.
11 And so, it was about'a week or so ago now we 12 issued another order and this order requires USR and safety 13 light on a schedule of about -- of a year to put up the
() 14 estimated $1 million in a bond or a trust to ensure that the 15 site characterization will be completed. And the first
-16 payment for this I believe comes to October 2nd.
17 In the meantime, the licensee has submitted a new 18 site characterization plan which appears to be improved from 19 the previous one which we are reviewing technically to see 20 if it's adequate or not, so you have two tracks coming on.
21 On one side we have the technical review of the site 22 characterization'and the other side we have the financial 23 assurance.
24 The current activities of the licensee -- it says 25 here that the tritium operations have been fairly good since Heritage Reporting Corporation O (202) 628-4888
227f J-} 1 1970. Most of the problems result from the activities _ prior 21 to 1970 which result in combination of groundwater, land, 3- and buildings.
.4 There has-been occasional problem -- an ongoing 5 problem of built up of tritium waste which mostly driven by 6 financial concerns is made difficult for licensee to be able 7' to dispose of'its waste. ~As a result of an imposition of a:
, 8. cap on how much waste the licensee is. allowed to accumulate.
9 Basically the NRC is concerned that, we don't want' 10 there to be an amount of waste that we could not eventually 11 ' dispose of, the licensee would go out of business frankly.
12' And.the licensee has been within the last year remain within-13 this and so far successful in doing so. -
'( ) 14 But all that combustion, that problem-plan, our 15 real concern len't with the current activities of the 16 licensee but rather in the capability of cleaning up the 17- plant from past activities.
18 There is some activity of groundwater onsite; 19 there some activity in groundwater offsite. The activity in 20 groundwater offsite, BTPA drinking water standards, we are 21 concerned that the strontium which is measured in water 22 onsite may move offsite and create'more of a public health 23 and safety problem than we have experienced thus far.
24' Any questions?
25 MR. CARROLL: How does superfund money relate to Heritage Reporting Corporation (202) 628-4888
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1 all this?-
2 MR. COSTELLO: Well, if Safety Light were to be 3 unable to remain in business, I think this is one of 4 superfund site. Absent that -- well, as long as they are 5 ongoing concern I don't think superfund will get involved 6 with this.
7 And one other thing that is associated with that 8 is, we don't know and we have asked licensee to find out 9 about this, if there are other hazards material other than 10 radioactive material onsite. I'll be very surprised 11 considering the waste disposal practices of the '50s and 12 such, '60s, '70s, you will find some organics there, oils, 13 things like that.
() 14 MR. CARROLL: Does superfund directly apply to --
15 suppose it is on radioactivity and they went out of 16 business, would it provide funds to clean it up?
17 MR. COSTELLO: I don't know. We were exploring 18 that with the EPA, but I don't think we've had an answer for 19 that.
20 MR. WARD: What do you think the relative public 21 health risk is from -- at this site compared with other 22 sites that might be convening from superfund?
23 MR. COSTELLO: So long as the site is not occupied 24 by housing, by anything which where aquifer is onsite and 25 expose people onsite, the immediate health and safety hazard
~
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.- ) l 1 'is relative small here. And people offsite are not j 2~ currently receiving doses of the contamination of the 3 groundwater.
4 If people were to -- if they were to leave the u 5 site and be sold at -- be occupied by residential housing'it 6 would be very serious. The levels are far excessive of EPA 7 standards and even excessive to NRC standards which can be 8- -higher ~ numbers.
9 The hazard would be that some of them move on to 11 0 the site and dig up the ground. So long as something 11 prevents that from happening, I don't think it would be part 12- of.the EPA.
13 DR. CATTON: So it can continue to be an
( 14 industrial site of some sort?
15 MR. COSTELLO: Before it can be released to an 16 industrial site, they would have allow cleanup done.
17 Industrial sites could wind up moving earth creating 18 airborne hazards. The buildings themselves are 19 contaminated. So there has to be a fair amount of work done 20 even to be able to release it for industrial site.
21 MR. CARROLL: Probably no worse than the UCLA 22 reactor.
23 MR. COSTELLO: Our concern would be that this is 24- now a very small company and not -- from their financial 25 statements not a very well capitalized company, it's owned Heritage Reporting Corporation O's (202) 628-4888
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I by two people and one of them works there. If they are 2 unable to measure how much radioactivity is onsite, we're 3 really concerned about their ability of waste disposal cost 4 to removeLthis onsite. And that's really one of the bases 5 for having the funding order is if nothing else we will have 6 the site characterized.
7 As you may imagine, there are not a lot of records 8 available from their waste disposal practices'in the '50s.
9 Any questions?
10 DR. REMICK: Thank you very much.
11 MR. BETTENHAUSEN: That. concludes the presentation
- 12 on fuel cycles and materials. Dr. Napp had to leave to take 13 a conference call.
'tl',\
j 14 If there are no other questions we'll defer to the 15 next part of the agends.
16 DR. REMICK: All right.
17 Do the gentlemen ask for a break. If so, let's 18 take a 15 minute break coming back five minutes before.
19 (Whereupon, a 15 minute break was taken.)
20 DR. REMICK: Gentlemen, let's continue.
21 And looking at the clock and trying to allow for 22 these good people to be able to go home at a reasonable hour 23 and reminding.our members of happy hour at the hotel doesn't 24 go on indefinitely this evening, why I suggest that we take 25 up the Region 1 inspection activities and try to limit that
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1 to.no more than 30 minutes tote 11y; and the SALP no more
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2 .than 30 minutes; five minutes for the PI program, which will 3 leave us a. half-hour -- with an attempt to get out of here -)
4' at?5:30. So I ask the staff to do as much as they can to 5 expedite and the committee, also.
6 MR. CARROLL: Kerr has made all of these speeches
~7 on SALP, hasn't he.
.8 (Slides being shown.)
L 9 MR. KANE: My name is Bill Kane and I'm Director 10 of the Division'of Reactor Projects and I. threw this 11' unreadable chart up here just to show you what's coming.
lL2 The people who are going to be talking to you are all of my 13 branch chiefs and section chiefs that we have in the
) 14 . building today, and just how we're organized.
15 Generally.we have -- as you can see there, we have:
16- four project branches and they're aligned with two section
.17 chiefs per branch. And typically.three plant,s or so per 18 section.
19 The point of this is that our alignment of branch 20 1, 2, 3, and 4 is consistent with that of NRR; and their
-21 project director is aligned the same as we are. Our 22 principal activities, of course, most of our people are out 23 at the plants, the resident inspectors that we talked about 24 earlier.
25 So with that I would like to start out the process Heritage Reporting Corporation (202) 628-4888
.o 232 L/ with that understanding. I should also point out the 1
2 technical support staff reports directly to me and that 3 staff principally is involved with or has been lately with 4 setting up'and running the inspection program that you're 5 about to hear about. Of course, the program is principally 6 monitored and scheduled at the sites. But the technical.
7 support staff, there's a major activity in pulling'that all B together.
9 The first presenter today will be Gene Kelly who 10 is chief ' of the . technical support staff.
11 MR. WARD: Would a copy of that slide be 12 available, Bill?
13 MR.~ KANE: We could. The reason I didn't, it has
() 14 a lot of names on there and phone numbers and other kind of-15 information. I can get for you tomorrow before you leave a 16 sanitized version of the organization chart, if you would 17 like to have it.
18 MR. WARD:- You don't want us to call anybody on 19 there.
20 (Laughter) 21 MR. KANE: Would that be. acceptable?
22 DR. REMICK: Is that satisfactory, Dave?
23 MR. WARD: Sure.
24 DR. REMICK: Okay, 25 (Slides being shown.)
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1 MR. KELLY: Good afternoon. My name is Gene 2 Kelly. Bill said I was chief of the technical staff who 3 reports to him. The project -- this is a new staff, about a 4 year and a half old now. We've done a little bit of 5 everything in the last year and a half.
6 I'll give you a little of my background in the 7 interest of your earlier questions this morning about where 8 our inspectors come from.
9 I'm not Navy and I'm not shipyard; I'm one of 10 those rare breed, I came from an architect engineering 11 background, for six or seven years. Born and raised in the 12 area, Villanova. I have a Masters in mechanical engineering 13 from Penn and I've been with Region 1 for about seven years
()
fs 14 now. Before this job I was a senior resident at Limerick.
15 I would like to quickly go through today some of 16 the background behind the new program or the new core 17 program, as you know, this past year. The next couple of 18 presenters will talk about team inspections. Our experience 19 with the resident program. And also, the use of 20 performance-based inspections. We'll talk about budget.
21 We'll talk about some of the new program goals, the four 22 goals that were advertised for the new core program and 23 where we are today and whether we' re meeting any of those.
24 The relation of inspection of SALP which, of course, they're )
25 connected. And finally, the planning and prioritization j Heritage Reporting Corporation
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1 schemes we go through in Region 1.
- c 2- This first slide is just a breakdown of budget in 3 'the' region. You can see that.the core is approximately 46 4 percent..'At least that's what'is intended for the total
^
5 inspection FTE. This is FTE to do operating reactor 6 inspections. So.this would not be non power reactors; it' 7 would not be construction, which we did have a little bit 8 left of Limerick-2 this year.
9 We also have about eight percent of our budget 10- this Fiscal 1 Year for mandatory maintenance-teams of which 11 .we've;got about half of them done or more'than half.
12 We have safety issues which is 12 percent of the.
13 budget'which you will see later.on we're not spending much
-0 14 or 1 t-15 And the final fraction is 34 percent which is for 16 regional initiatives.
17 What also is interesting to note is, basically 18' resident'and specialist time.is about 50/50. Although the-19 core is primarily done by the resident, and as Tim mentioned 20 earlier this morning and Bill Russell, the planned large
.21 team initiatives are done by the other division, y
'22 specifically Division Reactor Safety. DRP also has 23 responsibility for reactor type follow-up like AITs.
24 We converted those into hours just using some 25 simple assumptions on the bottom to make sense out of couple Heritage Reporting Corporation t (202) 628-4888 L
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'1_[ .1 Hof the next-slides.
3 MR. KELLY:. Direct' inspection effort.
4 Typically, for a specialist in the region it nas 5 been'usually 20 percent direct inspection effort, sometimes 6 33. 32, I'm sorry, I stand corrected. The project l
7 engineers used1to be 20 percent. It's a goal to getL32 8 , percent direct inspection effort as a specialist. And a 9 resident depending on whether he's the senior or junior i-10 resident is abeat 45 to'50 percent of'his or her time in-
-11 direct inspection activities.
12 DR. KERR: Do all plants have two residents?
13 MR. KELLY: With the exception right now of
- 14 Seabrook.
. 15 MR. KANE: They are'all' budgeted to have'two. We i
16 have -- because of the activity, the pace of activity at two 17 plants -- Shoreham and Seabrook -- we have used that i
18 resident at another -- those residents at another site.
19 'They're all budgeted for these two.
20 MR. KELLY: This is a breakdown as of May 20th
'21 which was our latest available risk data. You can see that 22 we're spending at least in this first year with the new 23 program in excess of what was originally projected for core.
24 We're about 69 percent of our direct inspection has been in 25 the core area; 10 percent has been on teams, whether they be LA Heritage Reporting Corporation LU (202) 628-4888
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'l specialized teams or mandatory teams; 20 percent in.the V.
2 initiatives and reactor area; and a very small fraction, 3 less than one percent on safety' issues which is temporary-4 instructions.
5 I think the heads'and tails to make of this slide 6 are, - essentially, we ' haven't even had a ' full year of 7 experience yet with this new core program.
8 Secondly, we have --
u . .
D 9 DR. KERR: Excuse me. Does everybody but.me know 10 what the.new core program is?
'11 MR. MARD: Yes, I think so.
12 DR. KERR: Okay.
11 3 - DR. REMICK: Is that what you described early this f 14 morning -- was described earlier this morning.
15 MR. KELLY: Well, I can give you a quick 16 description.
17 DR. KERR: No, don't waste time.
18 MR. WARD: Well, go ahead beca.ase I forgot.
19 (Laughter) 20 MR. KELLY: I'll give you a quick one.- Last 21 October 1st we changed the inspection program to a new 22 inspection program and instead of having minimum basJc and
- 23. supplemental, we basically had a based core -- baselino 24 inspection that all plants would get tailored to a category
, 25 that went performer to detect emerging problems.
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. 1- Ms had mandatory teams which for the next two-2 years are maintenance teams. ' Safety issues programs'which:
3- essentially followed the tis, which is a way of'getting at 4' generic issues and one-t'ime basis look.
5 And finally, the regional initiatives and reactor,
'6 which is'the. advertised portion that's flexible,
. 7' discretionary.. And that's basically the new program. We've.
8- been in it since October 1 of'1988 and'as'I said we've had I
9 less than;one full year of experience.
-10 DR. KERR:f~Thank you.
11 'MR. KELLY: You're welcome.
L 12 The other bullet I wanted to say is that later on lL3 I would like to make a conclusion that I think much of the
~
( )- 14 initiatives that are advertised to give us flexibility, 15 advertised as much as 35, 40 percent, sometimes 20 percent 16 :that really because we only.have half of that that's really 17 discretionary. And what I.mean by that is, there is a 118 portion' called reactive which cannot be planned, which we 19 cannot ignore, which is something that is not driven by SALP 20 necessarily, directly and is not something that you.can plan 21' months in advance.-
22 This is some projected numbers based on what we
- 23 see about two-thirds of the way through the Fiscal Year.
24 Again, FTE is full-time equivalent; it's another way of 25 looking at people. You can convert it to hours which you
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1 did with a simple approximation that 832 hours0.00963 days <br />0.231 hours <br />0.00138 weeks <br />3.16576e-4 months <br /> is one FTE.
2 So' based on what we're spending right now you can L 3 see that we do almost half of our work with one-third of our 4 licensees. It's'no surprise.
5 DR. CATTON: Where does that conversion factor L 6 come from? I thought there were 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> in a year, 7 roughly.
8- MR. KELLY: 2080 hours0.0241 days <br />0.578 hours <br />0.00344 weeks <br />7.9144e-4 months <br /> in a year. Then you look 9 at that budgeted time that the resident does versus the 10 specialist, assume the resident gets 45 percent 11 effectiveness of his total time in direct inspection effort, 12 the specialist get 33 percent. Put~them both together and 13 come up with an average that says --
() 14 DR. CATTON: What do they do for the other time?
15 MR. KELLY: Documentation, training, leave, 16 travel.
17 DR. CATTON: Okay.
18 MR. RUSSELL: A direct' inspection hour is one-hour 19 at the site physically doing inspection, is a broad 20 definition. There is some potential for in-office 21 inspection when you' re on the site reviewing records, et 22 cetera. It's the amount of time spent in direct inspection 23 activities as compared to other activities.
24 MR. KELLY: Okay.
25 DR..CATTON: That's fine.
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ms 239 L] 1 MR. KELLY: So you can see that -- in that 2 ascending order, Peach Bottom, Pilgrim, Nine Mile, Calvert, 3' Oyster, Indian Point, Maine and Indian Point-2 consume a 4 large part of our resources. Peach Bottom and Pilgrim, 5 obviously, a year ago we had an excess of 6,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> at 6 each of those facilities, inspection hours.
7 So we're spending a large amount of our inspection 8 time there; a lot of that has to do with teams. And 9 basically, this slide is just to show you that the large 10 fraction of our work is done with a smaller fraction of the 11 licensees inspection.
12 The middle path there Limerick and Salem, TMI, 13 Fitzpatrick, Beaver, Vermont, Shoreham, Ginna, Hope Creek,
() 14 again, about one-third of the to.21 expenditure of 15 inspection time.
16 And then finally, the bottom of the pack, 17 Susquehanna which is almost a straight category 1 performer; 18 Haddam Neck, Yankee Rowe, Seabrook, and the three Millstone 19 sites. I'll note that each one of those Millstones are 20 counted separately, if you considered 1, 2, and 3 as a 21 triple unit, obviously it's in another rank, where 1 and 2 22 is dual units and there's a budget gain there.
23 But that's basically actual credits and where 24 we're putting our time.
25 DR. REMICK: Why is Maine Yankee 5 FTE, what's the
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- 1. problem there?
2 HR. KELLY: They've had a; maintenance team 3 : inspection this. year, that will, you know,'get you anywhere 4 from 5 to 100 to a 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. We did an.SSFI in January
- 5. and February which was a large amount of time. There's:been 6 a event --
7- DR. CATTON: What's that?'
8 MR. KELLY: SSFI, safety system functional 9 inspection. Paul Swetland ic going to talk a little' bit
- L O . about'those teams in the next presentation. It's a deep 11 vertical look.at one system going back down to the design.
12 basis.
13 DR. KERR: They're assessed on the basis of
() 14 manpower expedited there?-
15 MR. KELLY: No, not necessarily; I think it's the 16 other way around. I think -- when we do the assessment we 37 .look at what we spent, but --
18 DR. KERR: They don't have to -- their fee 19 structure is not based on how much time you spend there?-
20 MR. KELLY: Their fee structure -- there is a-21 relationship between what they're build from a licencing fee 22 point of view up to a certain amount of dollars and 23 inspection time, but we don't decide we're going to spend a 24 certain amount and that's it.
25 I'm not sure I understand the question.
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1 DR. KERR: For example, if you do the SIS 2 inspection and the maintenance inspection, they pay for 3 that? Is that directly?
4 MR. KELLY: I'm not sure of how fee billing goes.
5 Some of it is reactive in which there's a ceiling and some 6 of it is just normal inspection which they don't pay anymore 7 above a certain amount. In other words, there's a certain 8 amount and they don't pay anymore and I don't think they get 9 charged a whole heck of a lot more because they've got the 10 major teams. I can check on that for you. I'm not a real 11 expert on fee billing.
12 MR. MARTIN: The other point we made, the 13 maintenance team inspection, a licensee may get one this
( ) 14 year and another one might not. But then the following year 15 since we're going to ultimately hit all the plants they 16 would get one. So they may not pay for it this year, but 17 they would pay for it in future years.
18 MR. KELLY: Another way of saying it is, we're 19 sensitive to overloading a site with team inspections. We 20 have various quarterly reviews and we look at whether a 21 licensee is being overloaded and we may decide to pull back 22 and say, no, another team is not the right thing to do in 23 this Fiscal Year, not necessarily for fee billing but more 24 or less on the impact of licensee's resources.
25 DR. CATTON: What if a plant is just a little bit
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1 more troublesome so you have an extra inspector there, do ;
1 2 they pay a little more?
3 MR. KELLY; Again, I'll have to check on the fee 4 filling rates. I know there is one rate for normal 5 inspection; there's another rate for reactive. And I 6 believe the answer is, no, but I'll have to check that. I 7 just -- I don't know much about fee billing.
8 MR. CARROLL: When Joe Culvin of NUMARC made his 9 presentation to us earlier this month he gave us that, which 10 is inspection hours versus SALP rating for the last year.
11 MR. KELLY: Right.
12 MR. CARROLL: And it sure as hell doesn't look 13 like what you' re showing me in terms of -- I would expect
/T
(,) 14 that if you had a good SALP rating --
15 MR. KELLY: That's a great issue to bring up.
16 You'll notice there is nothing to do with scores up here.
17 MR. WARD: You don't --
18 MR. MARTIN: Is that an average of the SALPs?
19 MR. KELLY: Yes.
20 MR. MARTIN: If you look at the operations area 21 you will find the majority of the inspection is put there.
22 So that was put against operations inspections against 23 operations SALP and you get a very different picture.
24 MR. CARROLL: He made the comment that they tried 25 to correlate it in all kinds of different ways. I think he
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1 even. suggested that way.
2 DR. CATTON: And couldn't.
3 MR. WARD: You know, Jay, I think there's a line 4 _that fit right through that. I mean, there's a lot of 5_ scatter, but I think there's a --
6 MR. CARROLL: It's ending down.
7 MR. KELLY: I have another slide that's going to 8 address that a little.
9 MR. WARD: I don't think he made a very good point 10 there.
11 MR. KELLY: I would like to say there's a real 12 danger in taking scores, adding them and getting an average; 13 that's one.
() 14 Number two, I'm going to make a strong point here 15 that the total hours are really not driven by SALP or vice 16 versa. That, in fact, everybody gets the core regardless of 17 their score. Everybody gets a mandatory team over two 18 years. Everybody gets all the tis and safety issues 19 reviewed eventually.
20 MR. CARROLL: But it was advertised when SALP 21 first came out that, hey, if you do good you're going to 22 have less inspections.
23 MR. KELLY: That's correct. But it's that 24 discretionary component that we're talking about; not the 25' core, not the mandatory team that everybody gets.
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B 1 MR. CARROLL: And your discretionary component 2 turns out to be very low, isn't it?
3 MR.-KELLY: Right now it is; it's running around
'4 20 percent.
5 DR. KERR: So you don't really -- I mean, the 6 amount of. inspection time is not really very closely related 7 to the SALP rating?
8 MR. KELLY: There is a correlation,.but I.think
.9. there's a danger in making it. We have made slides and
- 10 tried to make that correlation and sometimes we see it and
'11 sometimes we don't.
12 DR. KERR: Because I, too, have seen'a~ number of 13 occasions on which the purpose of the SALP rating was.to 14 help the NRC and resource allocation.
15 MR. KELLY: Right.
16 DR. KERR: Resource allocation certainly has a 17 principal component in this fraction time, I would think.
18 MR. WHITNEY: Excuse me, if I could just add on 19 the size of the core. Again, Leon Whitney, NRR 20 headquarters.
21- The size of the core may get changed based on our 22 experience here in the first year. And the fact that 23 initiatives and reactives is very small may be an indicator 24 that the estimates that went into building the new program 25 need to be adjusted. And five years down the road we still
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1 have these sizes, then you might say, okay, the program is 2 what. You've changed a philosophy, don't determine on the 3 philosophy and the estimates may be fine tuned to get back 4 to a larger reactive area than before.
5 DR. KERR: I was simply responding to what I 6 thought was an initial declaration on the part of the NRC 7 staff that if principal use of SALP was in resource 8 allocation.
9 MR. WHITNEY: Correct, sir. I'm just saying that 10 we're in the first year of a new program and the estimates 11 that were used may not reflect reality. This program may 12 need to be changed to the size of the core, et cetera, may 13 need to be changed to get back to a larger effect from the
() 14 initiatives and reactives.
15 MR. RUSSELL: I think the observation is that the 16 better performing plants indeed get less total inspection.
17 And I think that you would see that's even true on the core 18 program, that that is, when you're doing an inspection in 19 the core area if you find a good program and it's well laid 20 out it takes you less hours to inspect it, to get to the 21 same level of confidence that is being performed well.
22 If you 3ooked at the resources applied to the core 23 program at Pilgrim, Peach Bottom and some of the other 24 troubled facilities you would find it's substantially more 25 than that which was allocated by the program.
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) wy 1 MR. CARROLL: There are some utility -- cynical 2 utility people that would say, I don't want to make it easy 3 for them to inspect it. They take up ai rur time on the 4 things they're worried about, so they don't have time to go 5 look'under beds and closets. I would never do a thing like 6 that when I was a utility guy.
f 7 MR. RUSSELL: I think in general we do see a 8 correlation between SALPs and what inspection hours are with 9 the better performing plants generally having fewer 10 irraection hours. It's not a straight line correlation.
11 But I would submit we certainly spend a lot less time on 12 Susquehanna with its scores on SALP than we do on a facility 13 like Eilgrim or Peach Bottom or Nine Mile Point.
e~
() 14 MR. KELLY: There are some subtleties here, too, 15 and your first question on Maine, Maine had I bel.' eve a 3 16 increasing in radiological controls. So there's a lot of 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> associated with radcon at Maine. They've also had 18 some security concerns in the past and I think you will see 19 a larger number of hours in the area of security at Maine.
20 overall they're not advertised as a plant 21 generally known as a problem. But this slide here --
22 jumping ahead a couple -- anticipates that question. And I j 23 would throw forth the theory that there is a very small 24 fraction of our resources that's really directly driven by 25 the SALP.
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' (). 1 I'm trying to work on some correlations now, I
~2 don't have them. But basically-I think the core is-3 : independent of SALPs. And ,I think the maintenance teams to 4 a' lesser extent are also independent, although they're-
, 5 influenced in the sense that we may go to the places that 6 have lower maintenance scores first.
7 But every site will get one eventually. The same 8 is true of the safety issues. And so I get into this 9 discussion of initiatives and I'm here to say that those-10 initiatives which are budgeted at 34 percent we're spending 11 at 20 percent right now; I think half of that is planable 12 and half of it is reactive and we have no resource but tc 13 go.
()
O 14 If there's an AIT many times it's not the SALP 15 score that dictates it, it's the event. And so maybe 10 16 percent, 15 percent of our resources are explicitly driven a 17 priority by SALP recommendations to scores. That's why I 18 think those correlations -- I tried to make a number of 19 them, I'm just not sure what the right thing is.
20 MR. KANE: Not to lose the point, but if you go 21 back to the previous slide I think it reflects -- it's my 22 understanding of what I'm comfortable with, you did point 23 out as a anomaly with Maine Yankee which can be answered by 24 the alignment of the team inspections that happen to hit 25 them.
E '
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248 1 But if you look at grossly across the three 2 categories there you can see that that is a reasonable fit 3 to the. performance of the plan.
4 The less resources are being spent on the better 5 performance.
6 MR, KELLY:- I can show -- what'I have done in the 7- past, I have not'taken an average SALP score. I prefer to 8 take all 23 sites in this region and look at plant 9 operations and look at what their most recent score in 10 operations is and look at the hours in operations. Even 11 when you plot that you see some anomaly. The averages look 12- good. The anomalies may'be'the timing of the team or 13 whatever. We're working on that, but it's something I'm not
- ( ) 14 entirely convinced of.
15 DR. KERR: Well, maybe-if the plant operations is 16 really the key you should only give a rating in plant 17 operations and shouldn't score the other areas.
18 MR. KELLY: It's a radical - you will see that we i 19 spend almost half of our time.in the area, plant ops. I l
20 have a slide that will show you --
21 DR. KERR: I would hope that one did, because it 22 would seem to me that that is a fairly key area.
23 MR. KELLY: Yes.
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1 are in the operations area. But we also have specific 2 health physics resources that look at the health physics 3 program and the interfaces to maintenance and security.
4 Security is --
5 DR. KERR: I'm not suggesting that you don't 6 inspect these; I'm simply saying, don't give them a SALP 7 rating.
8 MR. MARTIN: But even there we have to determine 9 what we're going to do the limited resources for. We cannot 10 give a full suite of inspections to everyone in the reactor, 11 we just don't have those kind of resources.
12 DR. KERR: Just think about it a bit, you know, 13 you might come up with something. The reason that I'm
()
,rs 14 concerned is because the financial people don't look at 15 operations, they look at your average score. And if what 16 you' re saying is, a real indicator of plant condition is 17 maybe not one, but maybe more than one key item, maybe 18 that's what you ought to score.
19 MR. MARTIN: Unfortunately, this was a problem 20 when we developed SALP, we recognized that it was potential 21 for outsiders to abuse the system; it was not made for 22 outsiders. It was made for us to understand --
23 DR. KERR: We both know that this agency is in the 24 limelight and it should be, you know, and that people are 25 going to look at everything you do that they want to look at
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1 and t-tey're going to interpret it, not necessarily the way 2 you and I think it should be interpreted.
31 MR. MARTIN: I understand what you're saying.
4 Unfortunately, we have found a number of places where they 5 have tried to -- for instance, there used to be discussion 6 of an incentive plan'by PUCs based upon SALP ratings.- I 7 think we were successful in convincing those people who put 8 that forward that was not a good idea.
9 MR. KELLY: Any other questions on this~ slide.
10 (No response.)
11 NR. KELLY: We have some more slides that'may'get 12 back to this controversy.
13 This is last year, the same kind of slide, but h 14 last Fiscal Year, ending last September. Again, almost half 15 of our business with one-fourth of our customers.
16' There were four advertised goals for the new 17 program we started last October. One was to give us 18 flexibility to put discretionary resources out there.
19 One was to increase the emphasis on teams.
20 Another was to respond to new generic safety 21 issues.
22 And finally, to focus on disciplinary areas.
23 I've tried to at least give some thought into 24 where we stand with those goals right now. I think the 25 overall conclusion is that it's very premature to tell.
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\ 0' 1 As far as flexibility on allocating resources, the 2 budget allows for 30 percent initiatives. However, as I 3 said to you, I think half of that is really nct 4 discretionary, half of it is reactive that may not have 5 anything to do with the SALP score but everything to do with 6 the event. In that light I think SALP explicitly drives a 7 small portion of the resources that we typically have for 8 extension.
9 And finally, the core itself is a small subset of 10 the inspection program, although we're spending 70 percent 11 on it now and it's budgeted around 40. In fact, in the old 12 program the minimum basic so-called program there were many 13 more modules, many more procedures and this new core is
-( f 14 essentially 10 to 20 inspections.
15 As far as increased emphasis on teams, I think 16 Paul will be able to give you some feel for the fact, and I 17 can give you the budget and the number that there are a 18 large drain on our resources. One major team can really 19 chew up a lot of time. And I think that's just an obvious 20 fact.
21 We've also had large impacts in this region from 22 so-called problem plants. The IATIs that we run, very 23 resource intensive. Long six week commitments, much 24 planning and preparation, lots of hours.
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-U y i now on the team. So we now have, I. guess in the last two 2 years a new guy on the block in sharing the inspection 3 program and that's headquarters. And so we're still in the 4 learning curve in the first year in coordinating teams and 5 that kind of thing. But I think generally we're doing very 6 well. We get a lot of cooperation in drafting headquarters 7 personnel to be on those teams. We've been successful in 8 this region in getting contractor support to help us with 9 some of the major teams including round the clock coverage 10 at Pilgrims and Peach Bottoms that you're aware of. So 11 that's helped.
12 And I guess this increased emphasis on teams, I 13 see it as pushing us into a leaner and meaner day in the r
( j) 14 future. Everyone is talking about the increased use of 15 teams. The impact on both the NRC and licensees and we'll 16 probably be -- I wouldn't be surprised to see smaller teams 17 in the future and not these five, six weeks efforts, you 18 know, large commitments, but maybe smaller teams rf more 19 efficient size.
20 As far as the bullet on responding to meet generic 21 safety issues, basically there was a question Phul gave me 22 earlier in the week that you were interested in how 23 consistency-wise we may treat bulletins or generic letters 24 from site-to-site, from region-to-region. The answer is 25 that we do not typically do inspection anymore unless there Heritage Reporting Corporation
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1 is a.TI written. TI is a temporary instruction. It is 2 ' written out of headquarters. A draft is sent out to all.
.3 .five regions. All five regions respond,. comment; and when 4 the TI is issued that's basically the guidelines we use to 5 inspect. All five regions, every site in each region.
6 So we don't do fire-up on generic letters or 7 bulletins until those tis are issued.
8 DR. CATTON: I was at a meeting last week.on 9' valves and there was some concerned expressed by the 10 utilities about interpretation of the generic letter on 11 valves.
12 What happens with a generic letter; do you just 13 get it in the mail, too?
14 MR. KELLY: Every --
15 DR. CATTON: Or do you have a meeting where you 16 actually go through it in detail as to what its intent is?
17 MR. KELLY: Well, not every generic letter I think 18 gets a follow-up inspection. And on the other hand, if one 19 is intended to have a follow-up inspection, then 20 headquarters will work on some pilots, looks at a couple of 21 sites. They'll go back and draft a TI which is broad 22 inspection guidance for all the regions.
23 Again, as I said, we get a chance to comment, and 24 then eventually we may go out and inspect on it. There are j 25 no explicit planned inspections right now on instrument air b
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1 problems at the sites. If they occur we follow-up and then 2 we deal with then. But that generic letter and instrument 3 air, 88-14 or whatever the number was, we have not 4 explicitly beer. directed to go out and inspect against that 5 yet.
6 I'm not sure -- are you talking about the testing 7- in valves and IST.
8 MR. CARROLL: In-situ testing and motor operated 9 valves.
10 MR. KELLY: I'm not sure what the status of that 11 is yet.
12 DR. CATTON: That's the rule for interpretation.
13 MR. RUSSELL: We have TI issues that describes the
() 14 scope of the acceptance criteria to use. We don't go out 15 and inspect our own based upon the generic letter.
16 Questions related to generic letters or bulletins that have 17 been issued by headquarters should be directed back to 18 headquarters and not to the region. Once the TI has been 19 issued and it's a matter of public record at that time we'll 20 conduct the inspections and do the review and follow-up 21 against " e standards that are described in the TI which 22 flow from .he generic requirement that's issued in the 23 generic letter or bulletin.
24 DR. CATTON: I think this one is of particular 25 interest because I'm not sure how you could write a TI. A IN Eeritage Reporting Corporation kJ (202) 628-4888
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.1 lot of it is subject to interpretation.
2 MR. CARROLL: That's what the TI is going to do.
3 MR. RUSSELL: That is a matter to discuss with NRR 4 and Research. We do not go out and inspect until we have a 5 good guidance as to what we are inspecting for.
6 In the past there was some question about how to 7 do that. We have quite a number of generic letters and 8 bulletins that have been issued in the past; a number of 9 which did not have tis.
10 The process since the reorganization is that NRR 11 will issue a TI. Once that TI has been issued, that subject 12 matter is put in for inspection; and we don't inspect it 13 until we have a TI.
,m 14
(/ DR. KERR: May I ask one question on that last 15 slide, please.
16 MR. KELLY: Yes, sir.
17 DR. KERR: There was mention of station blackout.
18 MR. KELLY: Right.
19 DR. KERR: Now, as I recall there was a generic 20 issue, an unresolved safety issue, and presumably the staff 21 solved the problem. Is that simply a follow-up inspection 22 to see that the problem is really solved?
23 MR. RUSSELL: There's actually been a rule issued.
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.1 program being developed right now by headquarters as to how 2- we are to do those responses.and what priorities to put them.
3 in. That has not yet been turned over to the regions for 4 inspection. That's a headquarters on a pilot basis for a 5 few facilities until that is completed.
6 DR. KERR: Thank you.
7 MR. KELLY: And it is anticipated that TI probably 8 in a year will be issued to the. regions.
9 This slide is a quick breakdown of where we put 10 our time, SALP function area-wise. As I said earlier, 11 almost half of our time typically is spent in the area of 12 operations. Another large fraction in the area'of 13 maintenance and surveillance; engineering and tech support
() 14 15 percent; radiological controls 10 percent; and the other 15 areas 5 percent. That's a typical breakdown.
16 If you look at a SALP report and you look at that-17 table in the back it says total hours and what fractions and 18 what functional areas; there's the breakdown.
39 Now, taking that type of data and correlating it 20 back against scores in those areas for each site and then 21 doing the whole region, I'm working on that. But I think 22 there's a lot of danger in that. Enough said on that with 23 those correlations. That's a typical breakdown in this 24 region.
25 Next slide.
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1 Finally, Region 1. planning.and'prioritization and E 2 scheduling. 'We've basically gone to a process now with'the 3 new program being issued last October.of_ planning. Planning
~4 more than three months ahead. In fact, planning at two
'5- years.
6 It has gone along fairly well this year; it's not 7 without its pain, but we're getting there. There's an 8 initiative in headquarters called'MIPS that you may have 9 heard about, we won't talk about here, but we're on the. road 10 to implementing in Region 1.
11 The next slide,.if you would just jump to that for 12 a-moment.
13 This is basically how we chose to attack that in
() 14 Region 1. Take a simple. Lotus spread sheet,.this is site X 15 -- we didn't want to put.any of the actual sites up here'in l
16 the public meeting. We scope that plan out for a full SALP l
17 cycle. The new. program now has these inspections based on 18 the SALP' cycle. We don't say, once a year, once every three L 19 years; we say, once in a SALP cycle or twice or every other 20 or whatever.
21 We then look at -- we look at all these 22 initiatives and basically you can see these are the core L 23 inspections up top; they're going to get done everywhere.
24 The only proviso is, all of them get done within that one 25 SALP cycle.
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- v 1 The middle-things are the so-called initiatives.
2 We have taken a note that you can't see there that says --
3- you can see that. fictitious amergency preparedness 4 inspection procedure, that's with the number in. It has an 5 "S" next1to it. EPS means that in the SALP an explicit 6 recommendation was made that we would do some extra 7 inspection in that area, obviously because you see a 3 8 ' rating there. That's the way that SALP wou?d influence our 9 direction of additional resources in areas of concern.
10 You also see that we have put up on the top 11 Millstones, so that we can do more efficient planning and L 12 scheduling, avoid conflicts, whether it's an INPO visit,.the 13 licensee having a majoe initiative like their own self-() 14 assessment or SSFI or when the outages is so we can plan z l5 under outages.
.16 And also on the bottom left you see that we've got 17 signatures. This whole thing I guess is a process, a 18 challenge in communications; it's getting three technical 19 divisions to talk to each other, share-their agendas, agree 20 on the priorities. And that's -- this whole thing is an 21 exercise in communication. And we have been fairly 22 successful this year, although it's our first year.
23 Do you want to go back to the other slide for a 24 moment.
25 So basically, we now have plens for each of our 23 f'\ Heritage Reporting Corporation ll (202) 628-4888
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1 sites in the region. They ell superimpose upon each other; 2 and then we look at each quarterly and we basically schedule 3 off each quarter. We're coming up on October, November, 4 December and we'll take a look at what's preplanned in 5 advance for all those sites in those three month periods.
6 We'll take a look at the things in this last quarter that we 7 intended to get done, but for some reason couldn't.
8 And as I said, usually about 50 percent of our 9 best intentions never make it because of the reactive 10 workload.
11 And then finally, the third component is the new 12 things that come up inside the SALP period, emerging safety 13 issues. Things identified by the resident staff. Things e
(m) 14 identified in events or senior management.
15 We then throw all those requests into a little 16 computer program we developed here about five years ago that 17 essentially cranks the number for each request. The number 18 is based on the last SALP score or that area that you're 19 inspecting and which plant it is, the plant status.
20 The higher status is the problem plants. Middle 21 status for NTOLs, places that have refueling outages, 22 whether it's one window of opportunity. And the lower 23 stages, of course, is for plants that are normal average 24 plants. You crank the numbers. You sort them by 25 organizational section. And then you attempt to levelize
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1 .the workload by. priority 1, 2, 3.
2 N o w ,' the world changed on its last October so we 3 had to change'the process, so we have four which gets done 4 -- it doecn't get priority. And then the rest of it is 5 prior 1, 2, 3; and we go through a process, the divisions 6 talking to understand what we can schedule for next quarter.
7 And then once that comes out there is basically 300 requests-8 a quarter and honor about half of that; and then we revise 9 the plans and we march off for the next quarter with new 10 plans.
11 That's our scheduling process. As I said, the 12 reactive workload is essentially anywhere from 50 to 65 13 percent,' depending on the quarter and the issues'and events
~( 14 and what have you. So the best laid plans often get waylaid 15 by the reactive initiatives.
16 The last bullet'on there'is that this region has 17 taken the initiative to advertise and force the senior 18 resident inspector to be the center of focus for the 19 management of the inspection program. Perhaps a little 20 different than the other regions. We feel that that 21 individual is most cognizant at what goes on at that site 22 and is in the best position to make certain decisions and 23- recommendations regarding the priorities and what should and
.24 shouldn't be done.
25 DR. KERR: What does that statement mean, that he Heritage Reporting Corporation
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,1 has the management of1the inspection- prc gram?
2 2 MR. KELLY: I would like to' defer to my division-l 3 fdirector.here.
4 DR. KERR: Did he set up that Lotus program? I 5 MR. KANE: =The term " management" is not the proper 6- term. It is, in fact, the responsibility to have total
-7_ cognizance of what's going on at the site in terms of what's?
8 .on that plan; what's scheduled. If it didn't get done, why
~
9 it didn't_get done. And the ability to identify. ongoing
- 10 issues based on their presence at the site, their monitoring 11 ~ of operations. What are the kinds of things that need to be
- 12. done as we adjust the inspection program quarterly.
13 So that's -- basically that is the one individual-(I 14 that's assigned total cognizance of the inspection' program 15 on that site.
16 DR. KERR: So I should read that aa the senior-
- 17 resident inspector should know what's going on.
18 MR. KANE: And, in fact, if something is not 19 getting done, then we look to that individual through the 20 management chain to make sure that that issue is addressed,
- 21 and he or she causes the issue to be dealt with in a
- 22 conscious management decision made to do or not to an 23 inspection.
24 DR. KERR: Thank you.
- 25 MR. KANE: That's the distinction there.
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'1; MR. KELLY: -At the counterpart meeting that'Dr.
- 2. -Remick was at a-few weeks ago, we spent a full day debating _
! 3' .that' issue with all the residents; so that's an interesting.
4 topic..
'5: And I'm done. If there's'any other questions, 6 I'll turn it over to Paul Swetland.
7 (Slides.being shown~.)
8 MR. SWETLAND: My name is Paul Swetland, I'm~a 9 Reector Project Section Chief here in Region 1. I have 10 responsibility for the Susquehanna, Salem, and Hope Creek 11 Nuclear Power Plants. I'm previously namely nuclear trained 12 and have been senior resident inspector at both Maine Yankee;
~13- and Haddam Neck..
14 My topic for today is the' impact of team
~
151 inspections on licensee performance. And Gene has.already 1 .16 - . mentioned quite a bit about team ~ inspections.
17 Monty, if you will go to the first slide.
18 I basically wanted to provide an overview of the 19 type of. team inspections that NRC is doing. This is~not 20 intended to be a comprehensive list, but it's the type of 21 things-that you'll see and there's some nomenclature that 22' you will be interested-in just from a standpoint of reading-23- documents and so'forth.
24 First, we'll look at the headquarters team
, 25 inspections. We have the incident investigation teams which
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I h 'I are basically agency-wide response to significant non--
2 emergency events.
3 'We have a Davis-Besse or a San Onofre or a Rancho 4 Seco event, we need to find out what's going on in a prompt 5 fashion to be able to address the problems that are apparent 6 there. We will send a group of people,=usually independent 7 from the region involved under the leadership of a senior 8 manager and they will'do a detailed comprehensive overview-9 of that incident.
10 DR. CATTON: How many of those do you have a year?
11 MR. SWETLAND: We don't have a --
12 MR. WARD: Have there really not been any 13 incidents of the magnitude.of those three since then or has
() 14 some perception level or policy changed or.what?
I've heard 15 different.
16 MR. RUSSELL: I believe that there's been improved 17 performance and that the events are not as significant as 18 some of the earlier ones. But I can tell you from being a 19 regional administrator and when I dispatch an augmented 20 inspection team which is a team reporting to~me, there is _
21 discussion between myself, Ed Jordan, and Tom Murley 22 regarding whether this event should be considered for an 23 incident investigation team. And we do review that in each 24 case.
25 In addition there is an after the fact look back A Heritage Reporting Corporation
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.Q) at the AITs that AEOD does to determine whether'they were 1
2 appropriately classified or some should have been escalated.
3 It's my' view that we have used AITs appropriately 4 when called for and there have not been other events which 5 would raise to the level of an incident investigation team 6 reporting to the EDO.
7 I think that the combination of improved 8- performance.on the part of licensees. We're seeing fewer 9 precursors, other indicators are going in that direction.
10 We've had a continuing number of AITs; I don't know what the 11 numbers are. It seems like we have half a dozvn or so'a 12 year up here in Region 1. I don't know what the totals are 13 for US.
( 14 DR. CATTON: Who carries those out, AEOD?
15 MR. RUSSELL: No. An augmented inspection team is 16 a team that has a particular charter on' Division of Reactor 17 Projects, generally assists in developing that charter.
18 They may lead the team or it may be led by another division.
19 It's a report to the regional administrator when 20 completed. And it's done by regional personnel. So we havo 21 support frequently from headquarter offices on AITs. We 22 just had one that finished last week up at Nine Mile Point 23 associated with the contamination in the rad waste building 24 which resulted in an area being unused due to high radiation 25 levels since 1981 with background of 3 R per hour and hot
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1 -spots of a few hundred R per hour in the room.
2 DR. REMICK: And your resident inspectors never do 3- that?
4 MR. RUSSELL: -Well, we have not issued the report 5 yat. We have information that shows that the senior 6 resident at the time back in 1981 following the event did 7 make entries on fue into the area. The company did not 8 report it to us through any documentation we can find, and 9 we're still looking into the issue as to why it wasn't 10 reported and what some of the details are.
11 MR. CARROLL: Why would it happen? Why would they 12 need to have recorded it? That's a controlled area of the 13 plant.
.() 14 MR. RUSSELL: We've identified in the press 15 conference yesterday that there are two reasons. One is 16 that.they use the building as a liquid rad waste facility 17 and they have maintained more than a foot of water on the 18 floor in the area since 1981 and the room did flood to four-19 feet or better, enough to cause 55-gallon drums to become 20 buoyant. When the water level dropped the drums tipped 21 over, they didn't have lids on them and resins and condenser 22 bottoms and other material went on the deck.
23 So they basically made a dry rad waste store room 24 into a tank. There are other questions about facility FSAR 25 updates, whether that was adequate described. There are
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266 1- also questions on deportability under-Part 20 since they.
b 2- lost the use of the facility for more than a day and more 3 than a week.
4- MR. CARROLL: They probably got a 50.59 some place 5 in the file to make all this go away.
6 MR. RUSSELL: They do not, f
7 DR. CATTON: Why aren't AITs on your list?
8 MR. SWETLAND: They're coming.
9 MR. RUSSELL: These are headquarters lists.
10 MR. CARROLL: On IITs, is there -- somebody said 11 the other day that there was a requirement to notify i
12 Congress if you convene one of those; is that true?
13 MR. RUSSELL: I don't know of a --
) 14 MR. SWETLAND: Are you referring to abnormal 15 occurrences? !
16' MR. RUSSELL: We notify the congressional ,
i 17 delegations in the area on the facility when we dispatch l
18 . unit AIT. Whether we have a formal notification required by-l 19 legislation on IIT, I'm unaware if such a requirement ;
20 exists.
21 Significant events in the local area is one that 22 we have learned through practice. It's advisable to notify i 23 our office of congressional affairs and the congressional i members involved. i 25 MR. SWETLAND: Headquarters also conducts !
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.1- . diagnostic evaluation teams.- This is an independent 2i evaluation of licensees who have demonstrated poor.-
i 3 performance. Those sites are selected by senior managers 4 .and AEOD conducts-those inspections.
5 Also, headquarters initiates mandatory team
- 6. inspections. These are comprehensive inspections that are 7' designated for specific program areas. We are currently 8 .- doing-maintenance team inspections as our mandatory 9 component of the fundamental inspection program.
10 And after.the~first few of the inspections are 11 conducted through'the headquarters office, then the
. .12 - leadership is' transferred to the regions. And, in fact,
- 13. Region 1 is'now conducting these inspections, primarily, at i 14' least initially a headquarters team.
15 Headquarters also initiates and conducts safety 16 system functional inspections. This is a vertical slice of 17 all the licensees programs: based on one or two selected-18 systems.- They'll go into a site safety injection and review.
19 maintenance' activities, surveillance activities, operational 20 capabilities of the systems that go into modifications.
21 "Just the whole gamut of licensed activities related to that
.22 system. And from that inspection draw a perspective on both 23 the quality of that particular system, and also the quality
- 24 of the programs that the licensees implement.
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l inspections and we have one ongoing at Oyster Creek this 2 week.
3 Headquarters also conducts safety system outage 4 and modification inspections. This is a more comprehensive 5 look at the modification process across the board. It's 6 normally conducted over several weeks during a refueling 7 outage.
8 And finally, headquarters conducts regulatory 9 effectiveness reviews. These are basically program 10 effectiveness reviews for the security program. It entails 11 using Army Special Services personnel and they actually go 12 out and test the licensee's system. The security experts 13 and people in the business of countering these systems and
([ ) 14 they prove and show the vulnerabilities that may be, in 15 fact, btyond the regulatory basis. As a result they have 16 made a significant improvement in security programs by
( 17 basically pointing out flaws in our regulatory requirements.
18 DR. KERR: Of all those up there which do you 19 think are the most effective in terms of enhancing safety?
20 MR. SWETLAND: Well, each has its own area of 21 safety. I would say the one that's probably the most 22 beneficial is safety system functional inspections, which we 23 will discuss later. But basically we've got most of the 24 utilities conducting their own SSFIs. So we have gone from 25 a few SSFIs conducted by the NRC over an annual period to
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1~ .the point where most utilities may be conducting three to I j
2 six SSFIs on their own every year.
3- And so the scope has broadened. We have defined 4- real problems in terms of design problems in certain. systems S vulnerabilities.and have, I think, in fixing those problems 6 had a large impact on safety.
7 We can move on to region-based inspections. As we 8 discussed, the augmented team inspection is one cut below 9 the IIT. And we normally conduct between six and ten of 10 those a year on average in the regions. It's led by 11 regional people with assistance from headquarters. And we 12 have a lower threshold.
13 Basically. events that occur that are out of the f( f 14~ norm, particularly if there are conditions that either 15 occurred or which we don't understand we generally find and 16 AIT dispatch for that particular event.
17 The region conducts independent performance 18 assessment teams. This is much like a diagnostic. In fact, 19 we started out calling our diagnostics and headquarters 20 usurped our term.
21 These are done usually at the request of a SALP 22 Board to assess licensee performance, either good or bad.
23 We have done more high packs on bad performers than good 24 performers. But it's an effort for us to go out and 25 understand the underlying causes of performance. Not only 2.ritage Reporting Corporation
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l 3 Lack of training? So it's a comprehensive look.
4 DR. KERR: Do you ever find out in this 5 comprehensive look that'you disagree with the SALP ratlags 6 that you're trying to support?
7 MR. SWETLAND: I'm unaware where we have 8 disagreed. We generally have found that the SALPs are 9' adequate but that's why it's independent. It's usually 10 people different from the organization that's involved in 11 putting together the SALP; and that's one of the specific 12 purposes, is to verify that the SALP is an adequate 13 representation.
[ 14 DR. KERR: Up to now there has been no 15 disagreement?
16 MR. WARD: Even though it's independent?
17 MR. SWETLAND: Yes.
18 MR. WARD: Is that support an ongoing SALP 19 evaluation or is it used in the next SALP?
20 MR. SWETLAND: It's used -- its results would be 21 used in the next SALP.
22 The next inspection is noted as an operational 23 safety team inspection. Actually the next two inspections 24 have many names. Different regions call them different 25 things. But the operational safety team inspection is the Heritage Reporting Corporation v (202) 628-4888 L __-_---_
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1 'EDOs description'of this team. We call it an operational 2- assessment team. But it's a comprehensive review of _I 3 operations and support activities including ship coverage..
4 And we would do one of these inspections for a 5 number of reasons, particularly if there was declining 6 performance or a reason to suspect problems at the site, we 7 might dispatch one of these teams.
8 We also have operational readiness assessments 9 which are conducted at different key points in a licensee's 10 history. One would be conducted just prior to licensing to 11 make sure that that facility is, in fact, ready to go into 12 operation.
13 We conduct readiness assessments, plants that have
() 14 been in lengthy shutdowns. That would be something longer 15 than a normal refueling outage, like Peach Bottom.
16- And I also included the category of the 17 independent assessment team inspection which is the term we l
18 use to describe problem plant facility startup inspections.
19 That inspection is a little bit more comprehensive, just i
20 because there is a much more defined set of weaknesses and 1
21 corrective actions to be verified.
l 22 Finally, we have outage and startup inspections.
1 L 23 When a licensee is in a refueling outage there is a lot of 24 activity going on. Many times it's difficult for a single 25 inspector or even two or three residents that we have at a l
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1 site to keep up with those activities; therefore, we may 2 decide to dispatchLan outage team to review modifications or 3- normal refueling activities.
- 4 We might choose to perform this' inspection as a 5 preparatory effort to the plant startup'to make sure that-6 the licensee has performed all of the pre-startup testing-7 and surveillance necessary to assure that the plant is ready 8 to operate.
9 That's really a sum of most of the inspections. I 10 will say that we tend to call any inspection of more than.
11 two or~three people a team inspection. And you will see as 12 we go into the benefits of the inspection that any time you
.13 'get more'than one inspector involved in one effort you get a-() 14 better effort out of that.
15 I wanted to cover a few of the benefits and 11 6' drawbacks of team inspections. First of all, the team 17 provides a multi-discipline review of plant activities. You 18 send an HP inspector to the site, you get an HP outlook.
19 You send an operations type, you get an operations outlook.
20 If you send a team you get a combination of views and you 21 basically will get a better perspective on overall licensee 22 performance.
23 In addition, you get a diversity of inspector 24 views. Not all in reactor operations as black and white; 25 many times there are difference of opinions between
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- 1. inspectors, between licensees and so forth. Having more 2 people to discuss your findings with to'the sounding boards, 3 devils advocates makes for a better inspection.
4 Also, we view it as a much improved inspector 5 training and experience vehicle.
L 6 DR. KERR:
Do you think that linear with a number 7 of people or it goes to square and up to what point?
8 MR. SWETLAND: I think as; Gene alluded, two 9 inspectors are probably out and you don't get much contact.
10 Three or four is probably good.- You start getting over a 11 half a dozen inspectors and you start losing, you know, that 12 benefit to the extent that 10 or 12 or 15 inspectors is very 13 hard for the team manager to control and to get all those
() ~
14 benefits out.
15 Additionally, team inspections get higher 16 visibility and attention and that has both positive and 17 negative aspects. But you really do-get much more attention 18 from the licensee and a much more efficient inspection 19 vehicle when you show up on site with three or four people, 20- particularly led by a regional manager.
21 Some of the drawbacks, obviously, the licensee's 22 effort needed to coordinate and to respond to a team is very 23 intensive. They estimate four to five to one ratio of their 24 personnel to yours in order to support your efforts.
25 Also, many teams are conducted during outages.
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(Bt 1 This is when the licensee's personnel are most busy.
2 They're strapped; it's difficult for them to conduct both 3 their oute.ge activities and respond to the team. ]
4 Also, the team inspections are very resource 5 intensive for NRC. We have our normal schedules planned out 6 and all of a sudden we need to conduct an AIT at such and 7 such a facility. You have to find six individuals and 8 cancel what they were doing, send them to the site. They 9 also get involved with documenting that report in a very 10 short period of time, which takes your administrative 11 resources. And while they're doing that something else 12 isn't being done and somebody has got to suffer somewhere.
13 HR. WARD: And while they're doing that something else isn't getting done, of course, applies to the licensee.
h 14 15 I'm glad to see the order you listed those drawbacks.
16 MR. SWETLAND: The last slide is some of the.
17 achievements that we've made as a result of team 18 inspections.
19 Basically, we've seen the good quality inspections 20 that have resulted in similar ongoing efforts by the 21 licensees. 1 made the example of SSFIs. If we embarked on 22 a team effort that is beneficial to the licensees it shows 23 them safety problems, they're going to go out and do the 24 same thing to make sure that you can't find them.
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I that we have are, in fact, a benefit from that standpoint.
2 Also, significant findings, particularly in the 3 ' design area have given a lot of the older licensees the 4 initiative to go out and recover their design-basis. If-I' 5 come in and ass a licensee why is it that this pump is only 6 putting out 500 gallons per minute when it appears that it.
- 7. ought to be' putting'800 gallons per minute out and they 8 can't find you an answer, they have troubis. It's trouble 9 during the inspection because they might have a safety 10 problem as-a result of it; it's unanswered.
11 But it also indicates to them that they have lost 12~ a substantial amount of the design basis of that plant.- So 13 in Region 1 we have a substantial number of licensees
(),
7~
14 spending a lot of money to try and recover that in.<<.mation.
15 Not only for today explain the safety basis of the plant, 1-6 but looking forward to licensee renewal and being able to 17 justify why that plarat is able to continue operation in the 18 future.
19 DR. KERR: On the basis of your experience do you 20 think it's likely that most plants will be able to extend 21 their licenses for, say, another 30 years?
22 MR. SWETLAND: I wouldn't have any basis to judge 23 that. It's certainly true that those that recover and know 24 their design basis will be able to show that the plants 25 continued to meet their original design basis, whether or f') Heritage Reporting Corporation LJ (202) 628-4888 o_ - _ _ . - _ _
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-s 276 1 not that's going to be judged to be sufficient.
2 DR. KERR: Or that they may be able to show that 3 they can't meet another 30 years either?
4 HR. SWETLAND: They certainly might be able to do 5 that, particularly reactor vessels for --
6 DR. KERR: You don't have a gut feeling in either
'~
7 direction at this point?
8 MR. SWETLAND: No. We're still in the middle of 9 determining from an NRC standpoint what are going to be the 10 acceptable measures of license extensions. And until we 11 have made that determination, no, we wouldn't have a feel 12 for what that is.
13 DR. KERR: If the NRC headquarters people ask you
() 14 to write down the things that you thought were important, 15 could you do it?
16 MR. SWETLAND: If I sat down and thought about it l
17 I could think of things that are important to me. But I 18 think from a -- it's more important from an agency policy 19 standpoint to determine if Yankee Rowe is safe enough from a 20 licensing perspective knowing that it doesn't meet all the 21 modern reg guides and ANSI standards and so forth.
22 DR. KERR: No, I just wondered if you thought 23 about it enough so that if you had the responsibility of l
24 setting up these criterion and if you think you know enough 25 to go about doing it?
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1 MR. SWETLAND: I think the one major question that 2 I need answered for me is, how good are the reactor vessels; 3 how long is their life? We've justified that they're out to 4 40 years. And, you know, how much longer can they go in 5 terms of radiation.
6 MR. CARROLL: That's easy, you just anneal them.
7 MR. SWETLAND: Pardon?
8 MR. CARROLL: You just anneal them.
9 MR. SWETLAND: That's a possible answer, but we 10 don't have the technology developed at this point.
11 MR. CARROLL: The Russians are already doing it.
12 It's easy.
13 MR. SWETLAND: I mentioned before the REP. program
() 14 has also resulted in substantial security program 15 improvements. We had many utilities who would say to our 16 . inspectors, you know, we meet our security program and 17 indeed they did. We said you will have a fence and the 18 fence will have a monitoring system.
19 You get one of these Green Berets who goes and 20 gets under the fence or gets over it or whatever and arrives 21 at the control room without the security program knowing 22 what's going on. You know, it makes the point to them and 23 you've significant improvement.
24 DR. KERR: How do you make sure that these guys 25 don't get shot?
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1 MR. SWETLAND: Because it'a pre-planned. It's a-E2 . pre-announced inspection.- 'The licensee knows about~it.
- 3. 'Their management knows what's going on. .And,.in fact, most
~
- 44 /of the people observe it happen.
5 -- What you're looking for'is whether or not the
'6 . . security' system alarms.
7 DR. KERR: Oh.
8- MR. SWETLAND: So if the guy balks over the fence
'9 and doesn't get an alarm that's.another thing.
_10- .DR...KERR: I thought he also had'to get
.11 observation of the guards, you don't require them to do.
12 that?
13- MR. SWETLAND: Not all plants have observation.-
-14 Most. plants, camera systems and so forth are assessment 15 devices. They; rely on the actuation.of alarm, train the 16 camera over and look, so there is a' continuous ---
17 DR. KERR: In order that I get into one of the
-18 power plants, I have to go through'a bunch of people.
19 MR. SWETLAND: 'That's'right.
20 DR. KERR: Is there some way --
21 DR. REMICK: We go through the gate.
-22 MR. SWETLAND: In other words, this -- you know, 23 the premise of the program is you gather licensee management
'24 and say, we're going to do it, these are the types of things 25 we' re going - to do. There are no hidden efforts going on; Heritage Reporting Corporation (202) 628-4888 1'
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7 1 they' re just testing the system.
2 MR. CARROLL: I've always, having been subjected q l
3 to the world's first RER on security several years ago, 4 always wondered what the regulatory basis for it was. As it 5 was explained to me, your plan certainly complies with all 6 the regulations, but we're bringing in a bunch of Green 7 Berets who incidentally lost seven to nothing. No, seven.
8 and one tie-up. We were bringing in a bunch of experts on 9 security systems and saying, hey, sure you meet the 10 regulations but we're going to ask a whole bunch of what-if 11 questions or do a whole bunch of things beyond the 12 regulations to see if we can find any junks in your armor.
13 We don't do that necessarily with other kinds of
,~
() 14 inspections.
15 MR. SWETLAND: Well, in fact, we are doing that 16 more and more and it's called " performance based 17 inspection." As the indicator or as the name implies, 18 you're looking for the regulatory effectiveness.
19 MR. CARROLL: Yes.
20 MR. SWETLAND: Are we, in fact, getting out of the 21 fact that that plant meets the regulations? Are we getting 22 in effect a program?
23 If the team proves that there are vulnerabilities 24 then, yes, it may be beyond the current regulation for that 25 plant. But the licensee has the obligation to protect that.
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(-) 1 And if you show them a vulnerability most of them are, you 2 know, per fectly willing to solve the problem.
3 DR. KERR: Well, does the NRC staff -- I realize 4 this is not your responsibility, but does the NRC staff in 5 Washington think it has some responsibility to change the 6 regulations or is it just assumed that regulations are 7 supposed to be effective?
8 MR. SWETLAND: Well, all the findings that they 9 make, in fact, are factored into, you know, their subsequent 10 review. I mean, it may take a revision to a reg guide and 11 that may take, you know, several years and they may have 12 research do some work on it and that sort of thing. But 13 they don't get lost.
,r
() 14 MR. RUSSELL: I'm not sure that the 15 characterization is completely black and white. It has been 16 reviewed, the security system meets the regulation.
17 I would submit that if a person could get in 18 without being detected, notwithstanding that we've reviewed 19 the plan, and the licensee in implementing that plan needs 20 to string the alarm systems in a manner that preclude >
21 access without getting an alarm.
22 So in that context I would say the regulation 23 provides the objective and then got it implemented some way.
24 MR. CARROLL: We were getting subjected to a lot 25 of what-if kind of things that went well beyond any
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2 MR. RUSSELL: But they do locate such things as U
3 alarm system fails or is out of service, the question of 4 multiple frilures. But I think that the fundamental issue 5 was to test the effectiveness of the protected syctem. Did 6 it identify weaknesses in some plans which could be 7 amendment by licensees? Some things were pointed out which 8 were nor effective.
9 So I don't think it's a black and white case of 10 saying because the NRC has approved the plan that we believe 11 meets all the regulations that it, indeed, does in its 12 implementation.
13 MR. CARROLL: And a plan that also has been (g
_) 14 inspected over the years by the region.
15 MR. RUSSELL: And we find all the time where we've 16 got areas where there are vulnerabilities to vital areas 17 that could provide access that we've been reviewing and 18 looking at and either a new inspector with a different 19 perspective. And we haven't caught it in the inspection 20 program.
21 MR. CARROLL: Okay.
22 MR. RUSSELL: The next area was performance-based 23 inspection or resident inspectors.
24 (Slides being shown.)
25 MR. JOHNSON: My name is John Johnson, I'm Chief
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1 -of Project Branch 3 in DRP, recently taken over the branch.
2 I have the experience of having Pilgrim and Seabrook in'the 3 branch as well as four other plants.
4 My background includes Navy experience and about
.5 eight and a half years in the Navy and 11 years with the 6 NRC. I was a resident inspector. I was a region-based 7 inspector; I've been a supervisor in Division of Reactor 8 Safety and a supervisor in the Division or Reactor Projects.
9 DR. KERR: And your name really is John Johnson, 10 that's not an assumed name.
11 (Laughter) l 12 MR. JOHNSON: That's the name my parents gave me.
13 I've chosen these topics to talk about. They're
() 14 not all inclusive, obviously. I started.with positive 15 benefits of the use of resident inspectors.
16 The first thing that comes to mind is.real-time 17 observations. One of our resident inspectors was in a BWR 18 containment when the plant was pressurized getting ready to 19 startup from a refueling outage and noticed wet lagging.
l 20 And since that time quite a few beat up yards have replaced 21 their resurge pipe. But if he hadn't been there and he 22 hadn't seen that wet lagging, I don't know, it may not have 1
L 23 happened so soon. But I think the fact that he was there, 1
l 24 he had the opportunity to go in the drywell and do the 25 inspection. The reactor coolant system was pressurized.
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'1 ' .If I recall back to when it happened'there was 2 some question, he had quite a bit of discussion with the 3 licensee about whether they're going to take the lagging.off 4 or not. But that was the first feet of pipe that we noticed 5 the IGSE seam. And it was because he was there, he was 6 doing a real-time observation of that activity.
7 We probably have a lot of different. examples, but 8 'the main purpose is to have someone onsite to watch things 9 as they happen.
10 We also try to do that as much as we can with 11 region-based inspectors, but they are at the site for a 12 given period of time and they have a certain set of things-13 to choose to watch while they're there, but the residents 14 have a much broader opportunity.
( ).
15 DR. REMICK: How much time do resident inspectors 16 spend off of normal shift?
17 MR. JOHNSON: We have a policy of requiring so 18 much percentage of time in back shift inspections and also 19 in addition to that what we call deep back shift inspections 20 between basically 10:00 p.m. and 5:00 a.m. and on weekends.
21 We have both an individual goal. Basically, I 22 think it runs around 10 percent of their time. Quite often 23 the residents volunteer to do this on overtime and they're 24 not necessarily required to.
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1 hour basis, so if they can work it out with the site 2 activities and their management back in the region, they can 1
3 adjust their hours so they can do back shift inspections and J 4 still have it within the 40-hours. And that's worked out 5 pretty well and it has given them some of the flexibility 6 that we expect.
7 We espect them to be available in off-hours to 8 look at things.
9 DR. CATTON: What fraction of your resident 10 inspectors have degrees or are degree engineers?
11 MR. JOHNSON: I would say well over 95 percent. I 12 think we have a few resident inspectors that are, not very 13 many. Less than a handful of inspectors who do not have a t,,~) 14 degree. Maybe --
v 15 DR. CATTON: I'm not aware of any.
16 MR. JOHNSON: We might have one.
17 MR. KANE: One that I'm aware of.
18 MR. JOHNSON: Yes, I was going to say one.
19 MR. KANE: I was looking at the list here, I can 20 tell you.
21 MR. CARROLL: But the non-degree people are 22 typically long time Navy enlisted?
23 MR. JOHNSON: Well, the one we have has a lot of 24 Navy experience. He has utility experience. He was the 25 operations manager at a utility and he is, I think, one
(
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'l English course away from a degree.
h- 2 So from a standpoint of technology I don't think- ,
3 -- from an education standpoint he's-missing'--
4 DR. CATTON: And he's going to school now?
5 DR. REMICK: Those.English courses quite often do
'6 engineers in.
7 MR. JOHNSON: That's probably why it's the last.
8 (Laughter)
.9 MR. JOHNSON: The second most -- the second item I 10 have listed is emergency response. We can assure that the 11 resident inspector will be in the control room when an 12 accident happens, but because their normal work location is 13 at the site you have a greater chance of having them there,
() 14 possibly, and also within a close commuting. distance so they
-15 can be called.
16 Realizing the resident' inspectors are not going to lL7 direct the activities and not going to control the event, so 18 to speak. I pointed out what I feel are their two major 19 jobs and that is to monitor the conditions during an 20 emergency and to provide direct contact with senior NRC 21 officials.
22 As an example I'll point out, the confidence I 23 think our senior managers feel when they can talk directly 12 4 to an NRC employee on site. Not that they don't have the 25 same or can't have the same kind of feeling talking to a
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2 Ginna's steam generator tube rupture event several 3 years-ago, I think when that happened our chairman, if not 4 the chairman the senior official was on the E&S phone 5 talking directly to the resident inspector in the control 6 room and had a good feeling for real-time events.
7 Site-specific knowledge almost goes without t,
8 saying,.the person becomes one of the NRC's most 9 knowledgeable person about that facility. It makes it-10 efficient. The coordination with NRR and our licensing 11 issues, if we're involved with a tech spec amendment, the 12 resident inspector is usually very well versed in what the 13 current situation is at the site.
() 14 Systems knowledge, probably one of the most 15 familiar people in the NRC about the plant system as well as 16 certain people at the plant.
17 Onsite interface with licensee local officials and 18 the public. I won't talk too much about the licensee, but 19 the local officials and the public I think I'll explain a 20 little bit.
21 We're getting more and more interest from the 22 states. We're getting more and more interest with the local 23 officials in the oversight of reactor safety and their 24 interest. We have civilians around Pilgrim that have their I 25 own radiation meters and they monitor the radioactive es Heritage Reporting Corporation
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) k 1 releases from the plant and they call up and talk to a 2 resident inspector and say, my meter went up, what's going l I
3 on at the plant. And the resident can gi-~ him some !
4 information and put things in perspective.
5 The same thing with the local officials. The 6 mayors of these towns when they see an augmented inspection 7 team is being sent to their locale they are immediately 8 questioned by all the citizens in the area and they need to 9 put things in perspective, too.
10 And the resident inspectors periodically go out 11 and meet with the mayors and selectmen, describe to them how 12 we do our business and set up a rapport; and it has been 13 pretty favorable. We don't -- in some particular places 14 there is more interest, of course, the resident inspector's
({ )
15 time is going to be guarded because you can get a lot of 16 phone calls.
17 Inspection efficiency, less travel time. I guess 18 associated with that you could say it's less cost for the 19 travel. But the time I think is significant, too. If we 20 take a difficult site in Region 1 that takes maybe five 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> for someone to get there by plane, five hours there 22 and five hours back that's 10-hours. If this travel is done 23 during working hours you've lost 25 percent of your work.
24 Generally, it's much more efficient.
25 So negative factors, a tendency to be called by me
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1 to do work, let's have the resident check this. Lots of 2 people -- we try to manage this so that it doesn't get out 3 of hand. We try to have the section chief in the region be 4 the major interface with a lot of questions, but there is 5 just so many people that want to talk to the resident 6 inspector, to take his time away from getting out into the 7 plant. This is something we have to continually work at.
8 This is a big issue; we have to continually keep ourselves 9 from - push more and more the administrative task on the 10 resident inspectors.
11 They have part-time clerical aids to help them, 12 but the phone calls keep coming. And once the public has i 13 your telephone number the phone sometimes never stops e
j (m) 14 ringing. We have tape machines and we provide it to them s
15 and ask them to take some of their calls on the tape machine 16 so they can screen them; and that seemed to help out some.
17 Rotation policy. Rotation policy is in effect for 18 a number of reasons, one of which is potential for loss of l
l 19 objectivity. Another one, maybe after while it's always 20 good to get some new ideas, but it can definitely have a
. 21 negative effect on morale and family stress.
}
22 We have been fortunate, I don't think in this l
23 region we've had too many major isst;es with forced 24 relocations, unhappy people. Well, we' re getting to the l 25 point where we' re going to be coming up on some relocations l (~N Heritage Reporting Corporation
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' l' fand we still have.more to-learn in the future'as to whether 4 2~ these -families really ;want to move and where they're going 3 to move to.
, 4 When, in fact, we a t see any objectivity
.5 problem; but.we are coming up on time frame and it could" C
6 be a loss of some' good resources if individuals do not stay.
.7 with the NRC. But in all cases we have, we're still trying
'8- - to keep those resources and provide career paths for.them.
9 The high loss rate dilute? experience ~1evel and 10 site continuity. Because of the experience the resident 11 inspectors get, a broad. range of issues they deal with some-12 radiation protection issues; security issues; and certainly, 13' operational issues.
) )_ 14 Their experience is highly regarded and well 15- received. We've had -- I can almost count 10 or'12 senior 16 residents over the past couple of years that have gone to 17 headquarters to provide jobs in NRR and Commissioner F
-18 Assistant positions and'so forth.
19 MR. MARD: What about going to the utilities?
20- MR. JOHNSON: Going to the utilities? I think 21 we've -- several years ago I think we've had-two that come 22 to mind. But I don't remember very many in the last two or 23- three years.
. 24 MR. KANE: The only one I can recall recently is 25 -- well, losing a resident inspector was an individual
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290 Q 1 training to become a resident inspector that went to work 2- ~for a utility in another region.
3 DR. KERR: Since they started executing them, and 4 when they did-that it was a small number.
5 MR. JOHNSON: The resident inspector is approached 6 by the utility when he's inspecting, even off-handily 7 whether he would Fa interested in anything. If the answer-B is anything other than an immediate, no, then he is 9 considered to be interested or in the phase of negotiation 10 and he would immediately be requested to come back to the 11 region or to go to another site. He would not be allowed to 12 evaluate or inspect that utility at all.
13 We have had inspectors that had expressed some
() 14 interest in going to work for or if they had decided to look 15 outside the NRC for employment to inform their supervisor, 16 say, sometimes it's in another region, inform their 17 E-pervisor and they're allowed to take leave.
18 But if it involves anything to do with their 19 assigned duties of inspection, then they are immediately 20 removed from that.
21 MR. RUSSELL: In fact, the issue is a bit 22 stronger, it's a violation of regulations under Part 0 and 23 the individual has to seek and obtain his superviscr's 24 approval in advance of solicitation for employment. And l 25 that covers all employees, not just the residents. And 1
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1 management does have the right to say, no, you may not. And-2 in that. instance, then the employee has the right to quit l
3 and seek employment if he wishes. But we can assign work p
4 and in the process of assigning that work we can be assured l 5 that he's not going to have conflict of interest in carrying 1
[ 6 out the mission of the agency.
7 So he has to solicit management approval'first and 8 then he can negotiate. So that's why anything other than an
- 9 absolute, no, as John has indicated, really needs to be 10 promptly brought to management's attention and he needs to 11 get approval. And that approval would involve the signing 12 of other duties in the interim and that could result in a 13 relocation because we would not assign him back to that
() 14 site.
15 MR. JOHNSON: The last information I have here is 16 the greater sense of isolation on and off work. On work the 17 inspector, just about all sites but not, we have two 18 inspectors: a senior resident and a resident. There are 19 some sites that only have one. So there is another NRC 20 person there.
21 There are region-based inspectors that are on site 22 periodically. But by and large, the resident -- there can 23 be a sense of isolation. We do a lot to help that out.
24 Usually every day, sometimes five and ten times a day the 25 inspector is on the phone with a section chief in the region Heritage Reporting Corporation O.
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il talking about problems, status of plan,.different things.
2 - We bring the inspectors into the region for 13' counterpart meetinge. . We try to get'them involved in team
-4 inspections, involved in other sites and so forth. We try 5: to do a lot to let them know that we're all here and they
- 6. have our support and they're certainly not alone.
7- Off work is something'that I don't know that.
8 you're too much aware of, but it's really of importance that
'9 a' lot of highly visible and sites where there's a lot-of 10- public interest,:a lot of demonstrations and so forth.
11 There are -- I think a sense of isolation sometimes with-12 families, sometimes the residents feel like the public isf 13 ' anti-utility and they're anti-NRC and so they do have
() 14 . somewhat of a, I guess, sense that when they go to meet with 15 their neighbors the discussion centers around nuclear power.
- 1 16 What are ths problems that are causing the local community 17 and so forth.
18- I know-a few of our sites'that the inspectors had-19 certainly -- I wouldn't say been harassed, but some of the 20 local newspapers and some local citizens certainly make life
- 21 rough for them. So it is a tough thing. I don't think the 22 region-based inspectors necessarily have to put up with-it' 23 because the residents are there all the time. It's 24- something that's not easy to deal with.
25' MR.-WARD: Do the residents get called on by the L '
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7- s 293 A) local civic clubs or PTAs or anything like that?
1 2 MR. JOHNSGN: We had the senior resident at 3 Fitzpatrick was asked by the local Lyons Club to come and he 4 came at their meeting and told the Lyons Club what the NRC 5 did and how they did their job. Now, that wac well 6 received.
7 It's usually not those types of organizations that 8 are really the sense of isolation.
9 MR. WARD: Yes.
10 DR. CATTON: It's like being a cop.
11 MR. CARROLL: Or a utility employee.
12 (Laughter) 13 MR. JOHNSON: I guess so.
() 14 (Slides being shown.)
15 MR. McCABE: My name is EB McCabe, and that's one 16 word EB and not initials. Several generations ago I would 17 probably be called Ebenezer; I've been corrupted down to EB.
18 I started off in the nuclear Navy. I served on a 19 destroyer. Took conventional submarines and two nuclear 20 submarines. I then went to work for Babcock and Wilcox, a 21 Diamond Power Corporation subsidiary where I worked in the 22 nuclear controlled engineering field. Then I came to the 23 NRC, within the AEC and I worked as an inspector in the 24 region, a section chief for special inspections and I'm 25 section chief of project inspections, that's what I do now.
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1 I had the Seabrook site, the Ginna site, and the 2 Maine Yankee site.
3 I'm familiar with team inspections from personal 4 participation in the Shoreham operational readiness 5 assessment team inspection, and from reviewing the Seabrook 6 AIT. So I have a history of onsite program in my mind.
7 Our previous inspection focus -- and when I say 8 focus I mean it's an emphasis, not a total change from what 9 we have today. We were compliance oriented. We felt or our 10 rule were that if you met code of federal regulations, the 11 operation was sata.
12 We looked at records a lot. That's because we 13 went to the sites once every three or four months and we had e-(, 14 records to look at. We didn't have activities to observe in 15 the three days every three or four months. But we did try 16 to schedule our inspections so that we got there when 17 activities were occurring.
18 We have now institutionalized performance 19 inspections. Priority one is safety. Compliance is 20 important as it affects safety. If you break a rule and 21 there's no safety impact our enforcement policy allows us to 22 disregard that from issuing or from -- as a violation. We 23 keep a record of it. We don't make a citation. We don't 24 require the licensee to reply to them.
25 DR. KERR: How do you judge whether it affects Heritage Reporting Corporation
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2 MR. McCABE: Through our training. Through the 3 examination of the enforcement policy. What's the 4 definition of category 1, 2, 3, 4, 5 violations. Evaluation 5 of the impact of the non-compliance.
6 An example of an item that was judged not 7 important safety some time ago was an allegation received 8 from an I&C technician who said that they calibrate the 9 gauges and not in accordance with the procedures. It turns 10 out that if you calibrate a gauge to 100 psi and it reads 11 105 the procedures calls you for subtracting 105 from 100, 12 if you minus five percent, you're in five percent error. He 13 said they were subtracting it the other way. You subtract 14 105 the other way you get a plus five percent just to get a
( )_
15 five percent error. He said they weren't following 16 procedures and that's the problem. That's the type of thing
, 17 we get into in that area.
18 Our inspectors all go to the PWR series, the BWR 19 series of both. And they go through the resident inspector 20 qualification training program and when they're qualified 21 and given an oral Board for that qualification, we consider
-22. them qualified to make the safety judgments. And they do so 23 in conjunction with regional management.
24 They make off, like John said, five or ten times a 25 day. And we feed it back and forth and say, what is the f'} Heritage Reporting Corporation
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'l safety significance? It's essential that they focus on 2 safety.
3 DR. KERR: I'm not opposed to focusing on safety, 4 I just wondered how you judged'it and I th' ink you've given 5 me the answer I needed.
6 MR. McCABE: We focus more on activity 7 observation. We have more people in the region to do so.
8 We have the residents on site to do so.
9 And as it has already been noted, we have'our 10 headquarters offices that are going out in the field 11 inspecting. Both to assist us and now team inspections.
12 Licensing project managers have visited my site and done 13 inspections. We incorporate that.
-( ) 14 MR. CARROLL: That's a relatively new development, 15 isn't it?
16 HR. McCABE Yes, it ist in the past couple of 17 years we started that.
18 MR. CARROLL: Because for years you never saw the 19 licensing guy unless you went to Washington.
20 MR. McCABE: Yes. I think it's big improvement.
21 The more we get our agency out in the field the better off 22 we are including me and everybody else here.
23 Event reconstruction, this is where we use records 24 and this is how we use records. I'll get into the 25 discussion of the Seabrook AIT, that's what we did. We r-'y Heritage Reporting Corporation
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1l looked at the records. We interviewed people. We 2 reconstructed the event, phased it through. Did events and 3 causal factor analysis.
4 That gets us to what happened because even with 5 . residents and our'special program, we can't be there all the 6 time.
7 What are the indicators of performance-based 8 inspection? There is more reference in our findings to 9 principle rather than to compliance. We will go to a little 10 more general requirements like 10 CFR 50, Appendix B. We 11 can go to 10 CFR 50, Appendix A, the general design 12 criteria. Ten years ago that was not a practice. But we 13 get there and we take what happened and then we evaluate it;
() 14 and then we go to what enforcement action do we pose based 15 upon the safety significance and what the rules are.
16 Team inspections. We have -- you've heard about 17 the AITs, perhaps the IITs and other teams. We also did 18 team special inspections. We did a special inspection on ,
19 one of my facilities recently with three inspectors. We 20 have over the years done special inspection with groups.
l 21 We used the synergism you get from teams. We-22 evaluated events, specific item. Again, we conclude, what 23 is the safety significance of this event? What do we want 24 to do about it?
, 25 SALP. I'm sure you're familiar with SALP; they're l
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1 totally. performance-based. A violation comes up in an area 2 because of a significance'to safety. We have even seen_
3 civil penalties assessed in an area in a SALP, and that SALP
-4 rated as category 1 in that area, based upon when it 5 happened, the significance of it, what the licensee's
'6 corrective actions were, and how he got over the overall 7 SALP period.
8 DR. KERR: Incidentally, in some SALP reports and 9 in conversations with other people I have gotten the 10 statement that in order that the plant or the management or 11 whatever continued to get a particular SALP rating 12 improvement had to be shown over each period.
13 MR. McCABE: That's true.
14 DR. KERR: In other words, the SALP rating this 15 year would not be a SALP rating next year if performance 16 were the same.
17 MR. McCABE: I think that's true from several l
18 viewpoints. As the SALP program has grown and progressed 19 the licensees have gotten better. If we applied the 20 standards that were applied six or seven years ago into a p 21 SALP, we would probably have almost all the utilities in 22 category 1 in all areas.
23 DR. KERR: So it's not an objective measure of 24 performance at all?
25 MR. McCABE: No, it's definitely subjective. But
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.299 1 subjective including this area is good because. This area 2 is poor because. The subjectivity has to be explained.
3 DR. KERM No, but what you're saying is,'you 4 expect continued improvement -- continued improvement in 5- order to maintain the same SALP rating.
6 MR. McCABE: Yes.
7 DR. CATTON: _It's like grading on the curve.
8 MR. McCABE: Yes.
9 MR. WARD: Forever.
10 MR. McCABE: Forever, yes.
11 Is there any organization in your mind that never.
l 12 has to improve? There is not in mine.
13 MR. WARD: I think that's the big problem; I don't 14 -know how to deal with it. Staying level seems to be 15 unstable. I agree with you.
16 MR. McCABE: I was always taught that you either 17 go ahead or you fall behind, you do not stand pat anywhere.
18 That's the basic philosophy of life, isn't it.
19 MR. CARROLL: Not necessarily; it depends on what i
- l. 20 you're talking about.
l 21 DR. REMICK: I suspect we could get into an 22 argument here for a couple of hours.
23 MR. CARROLL: Let's find out what a silver bullet 24 is.
~25 MR. WARD: I think we ought to deal with this at
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2 MR. McCABE: In my division if you want to turn 3 the division director pink you put in no violations were 4 identified or no violations were found and let him see the 5 report. Because that indicates that all you were looking l
l 6 for was compliance. Indicates, doesn't mean it. It's not 7 sure. But it's an indicator.
8 So we've gono to the idea, the concept that we 9 look for safety inadequacies and we say, no inadequacies 10 were found. And the report has to substantiate that.
11 Report letter to silver bullets. Well, it's like 12 Barney on the Andy Griffith show, he gives me one silver 13 bullet. Each report, and in that report forwarding letter
() 14 we take what we think is the most important thing that we 15 found during that inspection. And it's very often not a l
l 16 violation. And we communicate that to the licensee vice 17 president. That's our silver bullet for that inspection.
18 And in extreme cases we're allowed one or two 19 silver bullets. That's how we focus on performance.
20 MR. CARROLL: And these are always in a negative 21 connotation?
22 MR. McCABE: No, they do not .
23 MR. CARROLL: Sometimes they're positive?
24 MR. McCABE: Sometimes they're positive. A number 25 of times in my section at Millstone our silver bullet was rN Heritage Reporting Corporation I
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L' p- 301 V 1' .very complimentary about an activity the licensee had 2 conducted. Not always, no. That was the only. silver bullet 3 I had.
4' DR. KERR: I have to applaud and I don't see how 5 one can avoid applauding what you're saying about 6 performance-based inspection, in that the regulations may 7 not determine safety and they may not. But the alternative, L 8 it seems to me is that now the performance and the judgment 1
9 and what you finally do, enforcement or otherwise, depends 10 on the judgment of either individuals or teams, because it's 11 no longer based on regulations.
12 Now, that's great if the team is made up of fine, 13 upstanding, intelligent, competent people like those in
() 14 Region 1. But suppose that you happen to get a group of l 15 people who weren't so competent and so understanding and 16 maybe even included some who tended to be vindicative. You
- 17. now find yourself in a situation in which you are not using 18 regulations to judge safety, you're using the judgment of 19 these individuals.
20 MR. WARD: You've seen this in a lot of western 21 melodramas, this same issue.
22 DR. KERR: I won't pursue it further. But it 23 makes me uneasy.
24 HR. McCABE: I would say that that would tend to 25 drive the inspection program to a m< re compliance oriented, Heritage Reporting Corporation (202) 628-4888
302 0 1 if that should occur. That would be the tendency to the 2 management.
3 DR. KERR: But you see, there isn't anything wrong 4 with compliance if it's compliance to an adequate set of regulations.
6 MR. McCABE: True.
7 DR. KERR: If, on the other hand, one assumes that 8 the regulations can never be changed, which seems to be the 9 exception in the NRC now, that you can improve; then I guess 10 you don't have any other alternative.
11 But the problem seems to be the existing set of 12 regulations grew up when plants were being constructed, and 13 so they are aimed at a construction era. They' re not really
() 14 aimed at operating plants. And there's been, so far as I 15 can see, no effort to modify them so they are appropriate to 16 operating plants, rather what you have done -- and maybe 17 this is the only thing you can do is to say, obviously those 18 regulations are inadequate, what we'll do is we will 19 continue to inspect and operate these plants but we won't 20 use the regulations anymore, we'll use our judgment.
21 Now, oversimplifying some, but that's some of what 22 I see.
23 DR. REMICK: At the same time will keep 24 consistency amongst all the regions, to be subjective but 25 will somehow maintain consistency.
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m-n,q Qi. 1 MR. McCABE: Well, I cannot vouch for consistency.
t-L 12 among the. regions. I can say that the inspectors and LE .3 managers I taught with from other regions there is an 14 . amazing commonality of outlook from the ones I have gone to 5 l school:with,- the ones'I talk on the telephone with, the ones.
6 I meet on other occasions; our approach is very much the 7 same.
L 8 As it is implemented, obviously when you have five 9 different regional administrators, and you go back all the 10 way'down to resident inspectors, there is highly personal 11 application of standards and requirements. Some people are 112 just better at some things than others; we can't change 13 that.
'( ) '14 Let's get back to the other point. I would say to 15 really go literally by an adequate set of regulations you 16- have to. identify all the permeations and combinations of 17 numan nature and equipment. And that's to say that I can 18- fit -- a profit rule to'every situation is something that 19 mankind has never achieved.
20 And I agree we could do a lot better, but we'll 21 never get totally there.
22 DR. KERR: Look, nobody is asking for perfection, 23 and I certainly would be the last one to ask for perfection.
F 24 I'm simply suggesting that maybe some consideration ought to 25 be given to improving the existing rules because they might
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7 1 Lbe more-nearly appropriate.to regulating operating plants 2 than this set of rules which we have. And I realize --
e f 3 .maybe wet're talking tocthe wrong people, maybe this is 4: headquarters, but they must listen'to you guys occasionally.
t.
l -5' .And if you go to them and say, look, these damn rules are
.6 just inadequate for operating plants, and that's what you're 7 telling me, _ why don't you gays do something about them; 8 maybe they'll listen to you.
9 HR. McCABE: 1Nell, in a sense you have taken some 10 words right out of my mouth. And I have said that, and the 11 gentleman I said it to was a regional administrator well 12 'over 10 years ago and he said, I was involved in writing 13- those-rules and I saw how:they were written and I saw the
)- 114 interaction of people. If you did it and went through the'
- 15. whole process all over again, you would be lucky to come
~
16 through with as good a set of regulations. That's what his 17 response was. And I accepted that response as that.of a 18 knowledgeable, intelligent man.
19 MR. CARROLL: Wasn't there another problem today, 20 also, and that's the backfit rule?
21- MR. McCABE: Yes.
22 MR. CARROLL: It makes it difficult --
23 MR. McCABE: It'E- very much --
24 MR. RUSSELL: Excuse me, I'd like to comment, I 25 think we're getting into an area that I think is neither
- r* ; Heritage Reporting Corporation (202) 628-4888
1 z~s 305 t'
).
1 black nor white.
2 What was described vis-a-vis performance-based 3 inspection is looking at taking observations and applying 4 your judgment to those observations. You still have to take 5 the next steps. If you propose to go into enforcement space 6 you got to clearly articulate what the violation is and what 7 the requirements are.
8 MR. CARROLL: You know as well as I do, that's the 9 easiest thing in the world, you just read something out 10 of a --
11 MR. RUSSELL: It is not always the easiest thing 12 to do, you must still describe what it does. And licensees 13 have learned that if they feel that they are not being
() 14 properly handled that there are mechanisms where they can 15 appeal those issues. And we do have safeguards built into 16 the review process through management reviews and others 17 before the issue is promulgated or the violation is 18 promulgated.
19 So I believe that we do have a set of regulations 20 which provide the framework and provide objectives that are 21 appropriate to use.
22 I can recall in 1983 through 1985 when I was in 23 headquarters we were proposing general operating criteria 24 comparable to general design criteria which would establish 25 guidance in such areas as training, maintenance, and other r^ Heritage Reporting Corporation
's (202) 628-4888
l
- 306 i/
I areas. And I would submit that that's probably the genesis 2 of NUMARC and some of the other industry activities to 3 preclude regulation in those exeas.
4 Appendix B does address issues associated with 5 operation. Procedures are required to operate the facility.
6 Section 6 of the tech specs which describes the procedures 7 you're supposed to have, you can in most cases cite a 8 licensee for failing to follow their own procedures. And 9 that's a citation that can be developed quite 10 straightforward.
11 The purpose of this presentation was not one to 12 emphasize compliance with very prescriptive narrow 13 requirements and go out and inspect against that issue. It
() 14 was broadly to observe how the activity is being conducted.
15 Are they being conducted safely.
16 If you determine that an area is not, you then go 17 back and look at the issues and develop the appropriate 18 evidentiary basis to support a violation.
19 DR. KERR: It seems the regulation goes basically 20 by the SALP program and SALP can't cite any on the basis of 21 the SALP process.
22 What I have seen, for example, a recent SALP 23 rating 1: which the cover letter asked the licensee to tell 24 them -- write a report tell them how they were going to 25 improve their SALP rates.
(^} Heritage Reporting Corporation
(_/ (202) 628-4888
y ~ .-
- g, < g.' 307
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'1- Now,.that becomes a requirement in the mind'of a 2 licensee.
3 MR. RUSSELL:. I do not' disagree at-all-that the 4 SALP.is.a.very effective tool to obtain the corrective.
5 action.from-licensees. And, Bill, I think we have learned 6 how to use'quite.well.
p
- g. .7 DR. KERR: And yet it's based entirely on the
.8 judgment of the people who write the report.
9 MR. McCABE:
I would submit.that it's based on-
. 10 more than that. SALP carries a lot of weight because the 11- - licensees who= receive them evaluate them as credible. That
-12' if'all the licensees who are receiving SALPs,.SALPs that
- 13 they were making invalid comments about.them or about their I 14 contemporary whom they know, that there would have been a 15 . great deal more fewer.
16 I have had presidents of utilities tell me that 17 this SALP that he just got was valid, agreed very much with 18 his own assessment and he regarded it as the most valuable 19 input on how his facility is operating ~outside his own 20 organization. That was how Mr. Furlan who was then 21 Northeast Utility described the SALP to us in a SALP 22 meeting.
23 MR. KANE: We're going to have an agenda item here 24 which is SALP, I guess if we get to it.
25 I guess the important thing is to understand'when Heritage Reporting Corporation (202) 628-4888
- _ _m __-m_ _.____.m_. - _ _ _ _ _ . _ _ _ _ . -
308
- 1. we go through that process to understand a little bit about L 2 how it works. It is not left to the writer of the report or 3 the input to make a determination as to where the licensee 4 stands with respect to category 1, 2, or 3, trends and so 5 forth. .That's a function of a Board.
6 Many people on that Board are independent from 7 that writeup that is prepared for them. In fact, most of 8 them -- and it's that process which is intended to derive 9 our assessment of performance. Ultimately that is testing 10 up and down the line including the regional administrator 11 ultimately and then the licensee beyond that.
12 So it is not left up to the judgment of a single 13 individual or individuals as to what that reading should be.
~
[) 14 Thatl process we'll try to explain when we get into that part 15 - of the presentation 16 The performance-based inspections are obviously 17 necessary. If you look at the category 3 level which you 18 spoke to before as being a 4, if you will, of regulatory 13 requirements and measuring, if you will, through 20 performance-based inspections where the licensee stands with 21 respect to that 4. And we will try to answer that and 22 explain that aspect.
23 You could hardly do an effective SALP without 24 performance-based inspections.
25 MR. McCABE: The performance-based inspections are
,/~'3 Heritage Reporting Corporation V (202) 628-4888
~ c( 309 E II ' I 1 inherent to what we do.
2 DR. REMICK: I don't think anybody is arguing l 3 against performance-based inspections at all. It's how 4 they're used and how SALP is used. I think we best go on I
5 . with your presentation, you're running out of town.
6 MR. KANE: I think we're ready for the next.
t 7 presentation or we're ready for a break and pick up the 8 ' issue tomorrow morning.
9 DR. REMICK: Yes, I think we should terminate for 10 today. I appreciate everybody following my advice and we l 11 were going to spend 30 minutes and we just spent almost two j 12 hours. I appreciate all the support.
13 We're going to certainly have to cut things
() 14 tomorrow. Let'me just ask a couple questions here so the 15 staff can do some planning.
16 The performance indicator programs, is there 17 anything there that the committee specifically wanted 18 addressed or is there anything that Region 1 can'tell us on 19 that?
20 Let's scratch that one.
21 Safety management focus, I think we can safely 22 scratch. We had that on there because we made a commitment 23 to the full committee a couple of years ago, and we went 24 around the region, we've explored that with all the other 25 regions. I think we can safely scratch that. That's 9, r~' Heritage Reporting Corporation I (202) 628-4888
310
.[g
\' 1 .yes. I think 9-A and B unless there is a specific request.
2 MR. CARROLL: I guess I'm generally interested in 3 what's going on between the regions and INPO, if there is 4 anything going on.
5 MR. KANE: I can cover that in about one 6 sentence, very little. I participated since I've been 7 regional administrator in one meeting with INPO as part of 8 our bilateral exchange discussion. Most of the interface is 9 through onsite activity is reading reports after INPO 10 evaluation'is completed where utilities bring that 11 information to our attention.
12 But as far as an interaction with INFO with the 13 regions that would be a very rare occurrence. We have had 14 some inspectors that have been involved in the observation
(}
15 of INPO activities in the past, but that's principally a 16 headquarters interface activity.
17 NUMARC is the same way, it's a headquarters 18 interface, very little interface with the region.
19 MR. CARROLL: And that is true also of problem 20 plants?
21 MR. KANE: Yes.
22 MR. CARROLL: For example, you had no inkling when 23 Pete wrote his PEPCO letter when it was coming --
24 MR. KANE: It caught PEPCO by as much of a 25 surprised, his January lith letter. Yes, we had no inkling Heritage Reporting Corporation O (202) 628-4888
k p
c ,f4 311.
P T"J 1 ~that that was coming and that was from INPO and we found out 2 about it at the same time everyone else did.
P 3, The only interaction on problem plants is that 4 where INPO is going to conduct an evaluation we find out 5 what that is, and.in my view, INPO is a consultant to the 6 utility as a part of the utility self-assessment process, 7 and the utility needs to factor that into their readiness.
8 and when they tell me they're ready I expect that they have 9 -gotten INPO concurrence that they are-ready before they make 10 that statement. And then I go in and independently find 11 out.
12 MR. CARROLL: Okay.
13 DR. REMICK: Another one I raise a question and
() 14 maybe we can just defer deciding until we know how things go 15 tomorrow, fitness for duty, is there any strong interest on 16 the subcommittee members on that?
17 MR. WARD: No.
18 DR. REMICK: Dave --
19 MR. WARD: I said, no.
20 DR. REMICK: Okay, I'm sorry.
21 How about from the region standpoint?
22 MR. KANE: No, because we're still waiting for the 23 guidance from headquarters on'how to conduct the inspection 24 rule.
25 DR. REMICK: Well, that relieves the schedule Heritage Reporting Corporation (Q_/ (202) 628-4888
i g.- 312-5_ e i 1 somewhat-tomorrow and.we'11 remain flexible from there on.
2 We thank you very much.
E 3 MR. KANE: We'11 pick up with Bill Chain with:SALP 4 tomorrow morningt: performance indicators; and then to into 5' the-problem plants.
6- DR. REMICK: Right.
7 (Whereupon, at 5:54 p.m. the meeting was adjourned I
8- to-reconvene tomorrow morning'at 8:30 a.m., Wednesday,
- 9 August 30, 1989.)
10 11 12 13
-. 14 15 16 17 18 19 20 21 22 23 24 25 g Heritage Reporting Corporation
-C/ (202) 628-4888
.m_
[j A/ 1 CERTIFICATE
'3 This'.is to certify that'.the attached proceedings before the 4- United States Nuclear Regulatory Commission in the matter 5 of: ADVISORY COMMITfE ON REACIOR SAFEGUARDS
'6 .Name:. SUBOOMMITIEE ON RDGIONAL PROGRAMS, REGION l' OFTIG 7
8 -Docket Number:
9 Place: King of Drussia, Pennsylvania 10 Date: August 29, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the 15
~
' direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing.
proceedings.
18 /a/ w?77 >L fA/%f 19 (Signature typed) : IRWIN L. COFFENB {
- j. 20 Official Reporter l
l 01 Heritage Reporting Corporation 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 L
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' + REAL-TIME OBSERVATIONS WITNESS ACTIVITIES AS THEY HAPPEN
+ EMERGENCY RESPONSES MONITOR CONDITIONS, DIRECT CONTACT WITH SENIOR NRC 0FFICIALS
+ SITE SPECIFIC KNOWLEDGE
+ ON-SITE INTERFACE WITH: LICENSEE, LOCAL 0FFICIALS, PUBLIC l
. + INSPECTION EFFICIENCY; LESS TRAVEL TIME THAN REGION BASED TENDENCY TO BE CALLED BY OR TASKED BY MANY TO D0 WORK "kET'S HAVE THE RESIDENT CHECK THIS" ROTATION POLICY: AFFECT ON MORALE AND FAMILY STRESS HIGH LOSS-RATE DILUTES EXPERIENCE LEVEL AND SITE CONTINUITY GREATER SENSE OF ISOLATION ON AND OFF WORK O
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PAST EXPERIENCES / CURRENT PROBLEMS I
IMPACT OF LATEST REVISIONS TO ENFORCEMENT POLICY (BENEFITS EXPECTED / PROBLEMS SEEN)
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5 LOL PAST EXPERIENCES / CURRENT PROBLEMS ESCALATED ENFORCEMENT (CIVIL PENALTIES / ORDERS) FOR POWER REACTORS IN REGION I HAS' INCREASED OVER THE PAST YEAR, BUT IS CLOSE TO PREVIOUS YEARS IF' EQUIPMENT QUALIFICATION CIVIL PENALTIES ARE NOT INCLUDED:
AVERAGE NO. FY 89 NO.
FY 84 - FY 88 -TO DATE .
(REGION I) (REGION I)
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- CIVIL PENALTIES 8 13 *
.Q ORDERS 2 0 l
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- LESS IF EQUIPMENT QUALIFICATION CIVIL PENALTIES ARE NOT INCLUDED AVERAGE NO. FY 89 NO.
FY 84 - FY 88 TO DATts (ALL REGIONS) ALL REGIONS)
. POWER REACTORS CIVIL PENALTIES 45- 50
- O oaoeas 4 I MATERIALS / FUEL FACILITIES /RESEARCH RXs ,
CIVIL PENALTIES 35 51 ORDERS 11 12
_ INCLUDES 10 EQUIPMENT QUALIFICATION CIVIL PENALTIES O.
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.WERE THE SUBJECT OF REGION I OPERATIONS CIVIL PENALTIES IN THE PAST YEAR DEFICIENCIES. CAUSES AND CONCERNS IN0PERABLE ECCS PUMP ,R00M COOLERS FAILURE TO DETECT DURING ROUTINE SURVEILLANCE TESTS DUE TO AN INADEQUATE TEST OPERATION OF REACTOR WITH EXCESSIVE FAILURE TO COMPLETE A WRITTEN SERVICE WATER TEMPERATURES SAFETY EVALUATION TO ASSURE NO OL: onaevIewto s^reTY ouesTIow -
EXISTED i SAFETY LIMIT VIOLATED IN THAT LESS FAILURE TO FOLLOW PROCEDURE LESS THAN TWO RECIRCULATION LOOP DISCHARGE VALVES IN FULL OPEN INADEQUATE CONTROL OF MAINTENANCE :
POSITION WHILE SHUTDOWN ACTIVITIES !
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PAST EXPERIENCES / CURRENT PROBLEMS l.-
- SOME OF THE DEFICIENCIES, AS WELL AS RELATED CAUSES AND CONCERNS, THAT WERE THE SUBJECT OF REGION I SECURITY CIVIL PENALTIES IN THE PAST YEAR DEFICIENCIES CAUSES AND CONCERNS DEGRADED PROTECTIVE BARRIFRS SECURITY LIEUTENANT' FAILED TO COR9ECT WHEN IDENTIFIED INADEQUATE TRAINING INADEQUATE CONTROL OF CONTRACTORS
'Q INADEQUATE COMPENSATORY MEASURES IN THAT GUARD NOT POSTED, POSTED INADEQUATE COMMUNICATIONS BETWEEN MAINTENANCE AND SECURITY IN WRONG AREA, OR SLEEPING FAILURE TO FOLLOW PROCEDURES ISSUANCE OF A VITAL AREA KEY TO AN SECURITY PERSONNEL MISSED NUMEROUS UNAUTHORIZED INDIVIDUAL OPPORTUNITIES TO IDENTIFY AND CORRECT THE ERROR (e.g., KEY INVENTORIES)
It! ADEQUATE CONDUCT OF SEARCHES OF FAILURE TO FOLLOW PROCEDURES PERSONNEL AND PACKAGES ENTERING THE PROTECTED AREA FAILURE BY MANAGEMENT TO CORRECT A RECURRING PROBLEM
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PAST EXPERIENCES / CURRENT PROBLEMS.
1-SOME OF THE DEFICIENCIES, AS WELL AS RELATED CAUSES AND CONCERNS, THAT-WERE THE SUBJECT OF'A REGION I EMERGENCY PREPAREDNESS CIVIL PENALTY IN THE PAST YEAR:
DEFICIENCIES- CAUSES Ai45 CONCERNS.
l-
. PERS0idEL RESPONSIBLE FOR CLASSIFYING INADEQUATE TRAINING / TESTING EMERGENCIES UNABLE TO 00 50 FAILURE TO RESPOND TO DEFICIENCIES INADEQUATE MANAGEMENT ATTENTION
' IDENTIFIED DURING PREVIOUS INTERNAL TO PROGRAM
-AUDITS BY QA GROUP s I
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- SOME OF THE DEFICIENCIES, AS WELL AS RELATED CAUSES AND CONCERNS, THAT WERE THE SUBJECT'0F REGION I EQUIPMENT QUALIFICATION CIVIL PENALTIES IN THE PAST YEAR DEFICIENCIES CAUSES AND CONCERNS
' FAILURE TO MAINTAIN A FILE OF FAILURE TO PERFORM TESTING DOCUMENTATION T0 DEMONSTRATE ITEMS WOULD PERFORM INTENDED FAILURE TO ASSURE APPROPRIATE FUNCTIONS DOCUMENTATION IN FILE 0
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s 10 PAST EXPERIENCES / CURRENT PROBLEMS I
- SOME OF:THE DEFICIENCIES, AS WELL AS RELATED CAUSES AND CONCERNS, IN OTHER AREAS THAT WERE THE SUBJECT OF REGION I CIVIL PENALTIES IN PREVIOUS YEARS i
l AREA DEFICIENCIES CAUSES AND CONCERNS 1
RADIATION PROTECTION' OVEREXPOSURE AND INADEQUATE SURVEYS SUBSTANTIAL POTENTIAL FOR OVEREXPOSURE INADEQUATE CONTROL OF HIGH RADIATION AREAS
' TRANSPORTATION SHIPMENT OF PACKAGES INADEQUATE OR LACK OF WITH EXCESSIVE SURVEYS RADIATION LEVELS q
D WRONGDOING DISCRIMINATION F0s MANAGEMENT OR SUPERVISORY RAISING SAFETY CONCERNS FAILURE TO RESOLVE CONCERNS' 10.
LATEST. REVISIONS TO ENFORCEMENT POLICY-PURPOSE OF REVISIONS (BENEFITS EXPECTED)
- PROVIDE GREATER INCENTIVES, BOTH POSITIVE AND NEGATIVE, FOR THE LICENSEE TO. IDENTIFY-. VIOLATIONS AND COMPREHENSIVELY CORRECT THEM
- ALLOW-NRC STAFF ADDITIONAL AUTHORITY TO EXERCISE THIS USE 0'F ENFORCEMENT
' DISCRETION
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. . i OL LAiEST REVISIONS TO ENFORCEMENT FOLICY NATURE OF KEY REVISIONS
- NRC MAY EXERCISE ENFORCEMENT DISCRETION (WITH THE CONCURRENCE OF THE DEPUTY EXECUTIVE DIRECTOR FOR NUCLEAR MATERIALS, SAFETY, SAFEGUARDS AND OPERATIONS SUPPORT), AND REFRAIN FROM ISSUING CIVIL PENALTIES FOR:
ISOLATED ISSUES IDENTIFIED AND CORRECTED BY THE LICENSEE AND NOT REASONAELY PREVENTABLE BY PRIOR NOTICE PAST PROBLEMS IDENTIFIED AND CORRECTED BY A FORMAL VOLUNTARY LICENSEE EFFORT ADDITIONAL EXAMPLES OF PROBLEMS IDENTIFIED AND CORRECTED h BY THE LICENSEE FOR WHICH ENFORCEMENT ACTION HAS ALREADY BEEN TAKEN
- NRC MAY EXERCISE ENFORCEMENT DISCRETION (WITH THE CONCURRENCE OF THE DEPUTY EXECUTIVE DIRECTOR FOR NUCLEAR MATERIALS, SAFETY, SAFEGUARDS AND OPERATIONS SUPPORT) BASED ON THE MERITS OF THE CASF O
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,f I LATEST REVISION TO ENFORCEMENT POLICY NATURE OF KEY _ REVISIONS (CONTINUED)
- NRC MAY EXERCISE ENFORCEMENT DISCRETION (AT THE REGIONAL LEVEL) AND NOT ISSUE A NOTICE OF VIOLATION FOR AN ISOLATED NRC IDENTIFIED SEVERITY' LEVEL V (LOWEST LEVEL) VIOLATION IF CORRECTED BEFORE THE END OF THE INSPECTION
! NRC MAY INCREASE THE AMOUNT OF CIVIL PENALTIES EVEN HIGHER IF NRC IDENTIFIED THE VIOLATION AND THE LICENSEE SHOULO HAVE REASONABLY IDENTIFIED THE VIOLATION S0ONER, OR THE-LICENSEE PROVIDES INADEQUATE RESPONSE TO PRIOR NOTICE 0 0F THE PROBLEM, OR
'THE VIOLATION INVOLVES MULTIPLE EXAMPLES, OR THE VIOLATION EXISTS FOR AN EXTENDED DURATION A
U-l____________.__________ _ _ _- _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ -
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LATEST REVISIONS TO THE ENFORCEMENT POLICY
- PRIOR TO THE LATEST REVISION TO THE ENFORCEMENT POLICY, THE STAFF'S AUTHORITY TO EXERCISE DISCRETION CONSISTED OF THE FOLLOWING:
- 1. FROM THE ENFORCEMENT POLICY REFRAIN FROM ISSUING A NOTICE OF VIOLATION FOR CERTAIN LICENSEE IDENTIFIED SEVERITY LEVEL IV OR V VIOLATIONS IF:
CORRECTED REPORTED (IF REPORTABLE) l
- NON WILLFUL NOT REASONABLY PREVENTED BY PRIOR CORRECTIVE ACTIONS.
O- '
aera^1" eaos issutuo ^ "ot1ce or vio'^11o" or C1vt' ren^'Tv roa SEVERITY LEVEL III VIOLATION AT A PLANT IN AN EXTENDED SHUTDOWN CAUSED BY A MAJOR SAFETY EVENT OR GENERALLY POOR PERFORMANCE OVER A LONG PERIOD IF:
LICENSEE IMPLEMENTING A PROBLEM IDENTIFICATION AND CORRECTIVE ACTION PROGRAM NRC CONCURRENCE IS NEEDED PRIOR TO RESTART VIOLATIONS ARE NON WILLFUL VIOLATIONS ARE BASED ON ACTIVITIES PRIOR TO THE SHUTDOWN
- 2. FROM ENFORCEMENT GUIDANCE MEMORANDA 85-15,85-15A, AND 85-15B PERMIT THE REGIONAL ADMINISTRATOR TO GRANT TEMPORARY RELIEF FROM A TECHNICAL SPECIFICATION LIMITING CONDITION FOR OPERATION IN i CERTAIN LIMITED CIRCUMSTANCES l PURPOSE IS TO PROMOTE' SAFETY BY NOT IMPOSING UNNECESSARY L TRANSIENTS ON AN OPERATING PLANT, OR NOT DELAYING REACTOR l' STARTUP DUE TO LITERAL READING OF A TECHNICAL SPECIFICATION UNDER CERTAIN CONDITIONS WHERE THERE IS N0 SAFETY REDUCTION
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- PROBLEMS SEEN.
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- N0' APPARENT PROBLEMS SEEN TO DATE lN' IMPLE4ENTING THIS REVISED POLICY
~
- REVISIONS HAVE' NOT-'TO DATE RESULTED IN A.SIGNIFICANT DECREASE IN THE NUMBER OF ESCALATED ENFORCEMENT ACTIONS. IN FACT, THERE HAS BEEN A SIGNIFICANT INCREASE. IN THE NUMBER OF ESCALATED ACTIONS TO MATERIALS LICENSEES.
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SUGGESTED CHANGES TO THE POLICY
' OBTAIN AUTHORITY TO ISSUE CIVIL PENALTIES AND ORDERS AGAINST VENDORS WHO CAUSE VIOLATION AT LICENSED FACILITIES (CE IS EVALUATING)
- DBTAIN AUTHORITY TO ISSUE ENFORCEMENT ACTION DIRECTLY AGAINST NONLICENSED INDIVIDUALS
,,, ENGAGED IN WRONGDOING WHICH AFFECTS LICENSED
\ ,
-('-J ACTIVITIES (COMMISSION HAS APPROVED THIS POLICY AND HQ STAFF IS PREPARING APPROPRIATE RULE CHANGES) l l
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4.A. MAINTBENT PROGRAMS ,
- 1. C(Pteff ON PR0iGH1 POLICY.STA1DOIT i
'lq STATBENT SHOULD PLACE SKCIAL EPPHASIS ON: i i
.i RELIABILITY CENTERED MAINTENANCE ll PREVENTIVE AND PREDICTIVE PROGRAMS ~
ENGIEERING SUPPORT O
ROOT CAUSE ANALYSIS !
i TENDING l
APPLICATION OF RISK SIGNIFICANCE CONCEPTS 1 I-1 \
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ALSO EEDS TO ADDESS 00NTRACTOR 1 RAINING DEDICATION OF C0ffERICAL GPADE PARTS EEDS TO C0l61 DER CURRENT REGULATORY GUIDANCE (R.G. 1,33 AND ANS 3.2) - EXPECTATI0tB FOR QA/0C OVERVIEW
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EGULATORY GUIDE ON MAINTENANCE PROGRAMS EEDED TO DEFItE D
TERMIN0 LOGY IN POLICY STATEE NT V
=- _ _ - _ _ _ _
' h 4,A.2- SLIDE 1 EGIONAL EXPERIENCE WITH t
LICENSEE'S MAINTENANCE PROGRAMS
' (ESULTS OF MAINTENANCE TEAM INSPECTION j MAINTENANCE TEAM INSPECTIONS aiHF0 PED BY EGION I SITE DATE TYPE PEACH BOTTOM 2 & 3 7/88 2 BWRs MAINE YANKEE 10-11/88 FYR(E) 11-12/88 2 BhRs
{ NIE MILE 1 & 2 LIERICK 1 & 2 1-2/89 2 BWRs VERMDUTYANKEE 2-3/89 BWR-INDIAN POINT 3. 3-4/89 PWR(W) 1;IDIAN POINT 2 4-5/89 PWR(W)
MILL 5T0lE 1, 2 & 3 4-7/89 BWR,PWR(CE),
FMR(W)
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SLIDE 2-U. \fl.A.2 SIGNIFICANT STRONG /P0OR PERFORPERS -i j
FUNCTIONAL AREA FUNCTIONINGWELL INADEQUATE FUNCTIONING' !
OVERALL FIVE OE PLANT PERFORMANCE FIVE DE N ONE O MMGM SUN h
I FIVE NONE MAINIDIANCE IPPLDefTATION 1,
L NOTES: VIOLATIONS WERE IDENTIFIED DURING FIVE INSPECTIONS l
MAlfREtMNCE TREE USED AS GUIDNCE 1:
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TYPES OF DEFICIENCIES OBSERVED i
DURING MTI'S :
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I (2) LACK OF VENDOR MANUAL C0fRROL, ND UPDATES, NO SYSTEM. j (3) DO NOT USE RISK ANALYSIS FOR PM OR WORK PRIORITIZATION.
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~(4) EQUIPENT HISTORIES LACKit0 OR HARD TO USE.
1
.(5) NO TRENDING OR FAILURE ANALYSIS SYSTEMS, l (6). MAltRENANCE PROCEDURES HARD TO FOLLOW OR AE T00 GEERAL.
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(7) LITTLE OR NO QC INVOLVUENT AT STE PLANTS.
(8) SYS1B4 ENGIEERS NOT INVOLVED IN Malt 0DIANCE. .
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.<W L)4.A.2 SLIE 4 ESILTS OF MAINENANT E AM INSN CTIO_NS_
NLPBER OF PLAES WEE MAIN 1BRNCE TREE DEFICIENCIES WEE IDENTIFIED FUNCTIONAL AEAS- (CHART ED OR YELLOW)
PROGRAM DESCRIPTION POLICY 4 (PB, if1P-1, W, IP-2)
TREE BLOCKS 3.1, 3.2 IDENTIFY EQUIREEES 4 (PB, tfiP-1,. W, IP-2) -
-3.4,4.2,4.7.
VENDOR MANUAL CONTROL 3 (W, W, IP-2) 6.1,3.4,3.6,5.8-W (PB, W, if1P-1, LIM, W,
~d RISKCONSIDERATION 7 4,3,5.5 IP-3,IP-2)-
L EQUIPE NT HISTORY 6 (PB, W, if1P-1, W, IP-3, 5.3,2.2,3.7 IP-2)
L TENDIIK3 AND FAILURE ANALYSIS 7 (ALL) 6.4,4.2,5.3 L AWilNISTRATIVE PROCEDURES 5 (PB, W, W, IP-3, IP-2) 3.6,5.8,4.4 i
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C 4. A.2 : SLIE 4 ESULTS OF MINTBANCE TEAM INSPECTIONS (CO Rit0ED)
NLNBER OF PLAf(TS W E E
'~ DEFICIENCIES WEE IDENTIFIED
. MIfffENANCE TEE FUNCTIONAL AEAS (CHART ED OR YELLOW)
WORK ORDERS / INSTRUCTIONS 4 (PB, W , IP-3, IP-2) 5.8,5.2,5.4,6.1 5 (PB, W, LIM, IP-3, IP-2)
PROCEDURE ADIERENCE 4.X, 5.X, 6 X 4 (PB, W , LIM, IP-2) hV QC IfNOLVEWNT 4.4, 5.X, 6.X.
3 (PB, W , IP-2)
RADIATIONCONTROLS
-4.5,5.1,5.4,6.1 SYSTEM ENGINEERS 3 (fNP-1, LIM,IP-2) 4.2 o
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j li.A.3 LICEEFF EFFORTS TO ENHANCE SKILL LEVELS /CAEER PROGESSION OF MAINTENANCE RRS0tEL BASED ON MAINIDIANCE TEAMS PLANT CAPACITY AND PLANT LIFE EXTENSION EMPHASIS CEATE NEED FOR MDE AND BETTER TRAINED MAINTENANCE PERSONNEL-.
AND ENGIEERS TRAINING PROGRAMS
- . ARE MDE FORMAL AND ACCREDITED
- USE IMPRUED FACILITIES,10CK-UPS AND SPAE EQUIPMENT Q -
FOR HANDS-0N TRAINING AE GEARED FOR lECHNICAL SKILL UPGRADE
~ INCLUDE MAINTENANCE ASSIST EXPERIENCE FACILITY SPONS0ED EDUCATION CEATES OPPORTUNITIES FOR L ADVANCEENT i
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TO STAFF ENGIEER NRC EXRCIS COLLEGE DEGEES FOR MANAGERS (ANS 3.1)
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PROPOSED INDICATOR DEFINITION (AE0D/S804B)
TIE OMNGE IN THE RATE OF REPORTED COMP 0NElR FAILURES PER M0tEH (AS PEPORTED ON NPRDS)
C0lHEtRS:
(1) flRC USE OF NPRDS TO RAE LICENSEE PERF0PFANI f%Y EFFECT DATA RELIABilllY O (2) PI SHOULD BE USED TO SPOT ADVERSE TRENDS, ICT TO RANK PLAfRS (3) SINGLE INDICATOR f%Y NOT BE SUFFICIEtif TO RANK PLANTS (4) A COMBINATION OF INDICATORS SHOULD BE C0ftSIDERED:
FMIfffENAN I RELATED LER'S EQUIROR OUT OF SERVIE UNPLANNED TRIPS DUE T0 l%IffiBMBE ING.UDING ESTING n
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NRC REGION I ACRS REGIONAL SUBCOMMITTEE PROGRAMS MEETING AUGUST 29, 1989 y
6.A.1 ASSESSMENT OF LICENSEE PERFORMANCE REGION I INSPECTION ACTIVITIES WORKLOAD AND SCOPE BUDGET AND PERFORMANCE NEW PROGRAM G0ALS RELATION TO SALP PLANNING AND PRIORITIZATION O
GENE KELLY DIVISION OF REACTOR PROJECTS TECHNICAL SUPPORT STAFF O
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l CURRENT FY 1989 REGION 1 BUDGET
. - IMC 2515 OPERATING REA'CTORS--
A. BUDGET (FTE) B. TOTALS ELEMENT RESIDENT / SPECIALIST EIE ; HOURS PERCENT CORE 31.52 / 16.31 47.83 40,359 46 MANDATORY TEAM 1,91 / 6.87 8.78 6,363 8 SAFETY ISSUES 4.78 / 7.28 12.06 9,323 12 9.55 / 26.28 35.83 26,441 34 Q REGIONAL INITIATIVE AND. REACTIVE TOTALS 47.76 / 56.74 104.50 82,486 100 A. I' RESIDENT FTE = 45% DIE OR 936 HOURS B. 1 SPECIALIST.FTE = 32% DIE OR 666 HOURS 4
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- FLEXIBILITY TO ALLOCATE RESOURCES BASED UPON PERFORMANCE:
30% BUDGET FOR INITIATIVES AND REACTIVE EFFORT FOLLOWUP IS TYPICALLY NOT DISCRETIONARY SALP DRIVES A SMALL PORTION OF THESE RESOURCES THE CORE IS A SMALL SUBSET OF INSPECTION (FROM PREVIOUS MINIMUM / BASIC)
INCREASED EMPHASIS ON TEAMS:
FREQUENTLY STRAIN RESOURCES (USE CONTRACTORS)
- PROBLEM PLANT IMPACTS (E.G., IATI) ARE MAJOR
() -
REGIONAL / HEADQUARTERS CONFLICTS TOWARDS " LEAN AND MEAN" RESPOND TO NEW (OR GENERIC) SAFETY ISSUES:
GENERIC LETTER AND BULLETIN FOLLOWUP DELAYED FEEDBACK AT BACK-END MISSING FOCUS RESOURCES ON SPECIFIC DISCIPLINARY AREAS OF EMPHASIS:
MAINTENANCE TEAMS AND SSFI'S REQUIRE NRR PROGRAM OFFICE DIRECTION (E.G.., WRITE TI, PERFORM PILOT INSPECTION)
EVENT y, STATION BLACKOUT REQUIRE SER'S ISSUED PRIOR TO INSPECTION O
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J RELATION OF INSPECTION TO SALP ONE OF THE STATED PURPOSES OF THE INSPECTION PROGRAM IS TO
" GATHER INFORMATION TO SUPPORT SALP EVALUATIONS."
- THE NRC'S REVISED MANUAL CHAPTER 2515 PROGRAM (BEGUN IN OCT 88)
CONSISTS OF A FIXED WORKLOAD AND A " FLOAT" PORTION. THE FIXED CORE SUBPROGRAM IS A BASELINE EVALUATION (10-20 PROCEDURES)
E55ENiiALLY THE SAME FGR ALL REACTOR SITES REGARDLESS OF SALP CONCLUSIONS, AND IS EXPECTED TO EXPEND APPROXIMATELY 46% OF REGION I RESOURCES. CORE IS TAILORED FOR A CATEGORY 1 PERFORMER.
OTHER ELEMENTS OF THE 2515 PROGRAM INCLUDE INSPECTIONS THAT ARE " INFLUENCED" BY SALP, BUT NOT IN A STRONG SENSE. A ,
MANDATORY TEAM INSPECTION OF MAINTENANCE PROGRAMS FOR THE
,)- NEXT TWO YEARS IS BEING CONDUCTED AT ALL REACTOR SITES.
DECISIONS ON WHICH SITES RECEIVE THOSE TEAMS FIRST IS INFLUENCED BY SALP ASSESSMENTS OF MAINTENANCE. THESE ARE RESOURCE INTENSIVE INSPECTIONS (500-1000 MAN HOURS PER SITE) AMOUNTING TO 8% OF BUDGET WHICH, BECAUSE OF THEIR CONDUCT DURING OUTAGES, HAVE LARGE IMPACT ON UTILITY STAFFS.
THAT ELEMENT PRIMARILY DRIVEN BY SALP CONCLUSIONS ARE TERMED REGIONAL INITIATIVES. PLANNED INITIATIVES, AT REGIONAL MANAGEMENT'S DISCRETION, INCLUDE INSPECTIONS EXPLICITLY RECOMMENDED BY THE SALP BOARD. INITIATIVES ARE EXPECTED TO EXPEND 34%.0F OUR RESOURCES, AND ARE THAT PART OF THE ,
PROGRAM WHICH HAVE THE MOST FLEXIBILITY FOR MANAGEMENT DECISIONS. THERE IS, HISTORICALLY, A 50/50 SPLIT BETWEEN UNPLANNED VERSUS PLANNED WORKLOAD WHICH IS THE REACTIVE COMPONENT (E.G., AIT RESPONSE).
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, 2-YEAR PLANS BASED ON SALP CYCLES
. QUARTERLY PRIORITIZATION USING PLANT STATUS AND SALP SCORES (WISHLIST) 250 TO 300 REQUESTS FOR INSPECTIONS OVER A THREE MONTH TIMEFRAME AT 23 SITES
($) -
APPROXIMATELY 65% OF THOSE REQUESTS ARE COMMITTED TO (I.E., 150-175 INSPECTIONS PER QUARTER), AND '
50-75% OF THOSE SCHEDULED ARE SUBSEQUENTLY COMPLETED BY THE END OF THE QUARTER REACTIVE WORKLOAD TYPICALLY SUPPLANTS ONE-THIRD OF PREVIOUSLY PLANNED / SCHEDULED WORK -
INCOMPLETE INSPECTIONS ARE SUBSEQUENTLY RESCHEDULED MANAGEMENT OF EACH SITE'S INSPECTION PROGRAM ASSIGNED TO SENIOR RESIDENT INSPECTOR M
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IMPACT OF
. . TEAM INSPECTIONS ON LICENSEE PERFORMANCE O
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AGENCY-WIDE RESPONSE Td A. SIGNIFICANT NON-EMERGENCY EVENT DIAGNOSTIC EVALOATION TEAM (DET) .
INDEPENDE'ST TYAL'UATION OF UNDERLYING CAL'SES FOR POOR LICEN$EE PERFORyNCE MANbATORY TEAM INSPECTION (MTI) '
COMPREHENSIVE IllSPECTION OF AN AGENCY-SELECTED.PROGRkM AREA AT ALL FACILITIES CURRENT MT! COVERS MAINTENANCE SAFETY SYSTEM FUNCTIONAL INSPECTION (SSFI) '
"VERTICLE SLICE" APPROACH TO ALL PRCGPAM AREAS AS THEY APF_Y TO ONE OR MORE SELECTED SYSTEMS .
SAFETY SYSTEM OUTAGE MODIFICATION INSPECTION (SSOM1)
COMPREHENSIVE REVIEW OF SYSTEM MODIFICATIONS AND THEIR IMPACT ON SYSTEM OPERABILITY I
REGULATORY EFFECTIVENESS P.EVIEW (RER) g
~
EVALUATION OF SECURITY PROGRAM EFFECTIVENESS THROUGH PRACTICAL CHALLENGES TO PHYSICAL SECURITY SYSTEMS O
I. REGIONAL LAM INSPECTIONS
-AUGMENTED INSPECTION TEAM (AIT) ' t RENIONAL RESPONSE
-TO SELECTED
- MERGENCY EVENTS I ~
I INDEPENDENT PERFORMANCE'. ASSESS
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PERFORMANCE NG CAUSES FOR (GOOD QESERVE OPERAT!NfAL SAFETYT) TEAM INSPECTI '
INCLUDING SHIFT AND COVERAGECOMPREHE ,
SUPPORT ' ACTIVITIES, PERATFONAL READINESS I ATI) ASSESSMENT CONSTRUCTION OR OPERATE SHUTDOWN)
FOLLOWING A FACILITY KNEW A OUTAGE /STARl-UP INSPECTIONS TEAM COVERAGE OF REFUELING OUTAGE READINESS FOR START-UP FROM AN OU AGE I
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TEAM lNSPECTION BENEFITS
+ MULT!-DISCIPLINED., REVIEW.0F PLANT ACTIVITIES -
+ DIVERSITY OF INSPECTOR VIEWS ",
+ ' IMPROVED INSPECT 0'R TRAINING AND EXPERIENCE i
+ , HIGHER Y!sIBILITY_- ND~ ATTENTION '
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TEAM INSPECTION DRAWBACKS O 'ic' eases cooaoia^Tro" ^"o atseo"se aeouiaes 'i-s to 2 a^Tio 0F TEAM SUPPORT PERSOf4NEL '
fiANY TEAMS CONDUCTED DURING OUTAGES WHEN LICEllSEE PERSONNEL ARE MOST BUSY -
NRC RESOURCE INTEllSIVE I
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ACHIEVEMENTS -
GOOD QUALITY LICENSEE EFFORTS.INSPECTIONS (SSFIS) HAVE RESULTED IN SIMILAR ON601'NG SIGNIFICANT
_DE$16N BASIS RECOVERY. FINDINGS HAVE SUPPORTED LICENSEE EFFORTS ~
RER PERF0gMANCE MEASUREMENTS HAVE RESULTED IN SUBSTANTIAL '"
SECURITY PROGRAMj AND EQUIPMENT UPGRADES.
DIAGNOSTICS OF P00R PERFORMANCE. / IPA'TS HAVE RESULTED IN BETTER NRC UNDERST '
IITS/AITS PROVIDE A TIMELY COMPREHENSIVE APPROACH TD
, UNDERSTANDING SIGNIFICANT OFF-NORMAL EVENTS.
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. ;O QA PROGRAMS PAST \
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V PAST l'
ROOTED IN STRONG CONSTRUCTION INSPECTIONS H THE LICEN.TH THROUGH QA ORGANIZATIONS MR. EBNETER'S INFLUENCE
- AEROSPACE / NASA RELIABILITY
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- BRANCH DIRECTION TO REVIEW Qh INTERFACE IN E
- QA REDEFINED AS A MANAGEMENT TOOL
- EMPHASIS ON WORK AND NOT PAPER O
~
%s QA SECTION INFLUENCE
- BEGINNING OF PERFORMANCE BASED INSPECTIONS
- QA INSPECTIONS WERE ASSESSMENTS OF ORGANIZATIONAL EFFECTIVENESS ONGOING WORK
- INSPECTIONS WERE DONE BY STRONG AND EXPERIENCED ENGINEERS O
V
- CONVINCED QUALITY IS A LINE ORG. FUNCTION AND NOT QA'S
- HARDWARE AND PERFORMANCE ISSUES BEGAN TO APPEAR IN APPENDIX B V
- ENFORCEMENT CONFERENCES TO DISCUSS HARDWARE AND PERFORMANCE ISSUES STEMMING FROM QA INSPECTIONS O
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- BROUGHT IN TECHNICAL DEPTH TO LIC. QA ORGANIZATIONS
- QA PERSONNEL BEGAN TO RECEIVE TECHNICAL AND SYSTEM TRAINING
- TRAINED NRC PERSONNEL TO DO BIG PICTURE QA INSPECTIONS
- PARTICIPATED IN THE DEVELOPMENT OF A COURSE FOR PERFORMANCE BASED INSPECTION O
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_ _ _ _ _ _ _ - _ _ _ ._ _. )
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' \J PRESENT REGION IS ASSESSING REAL QA IN ROUTINE CTIONS AND S INSPECTIONS VERIFY THAT THINGS ARE IME DONE RIGH APPENDIX B VIOLATIONS ARE ALL BASED MANCEON HARDW CONCERNS NO MORE PAPER INSPECTIONS CONCERNS NEW INSPECTORS ARE NOT FAMILIAR WITH APPENDIX B THERE IS NO SECTION IN THE REGION RESPONSIBLE F ,
1 IPERTISE IN HQ IS FADING AWAY
- % 1 V i REGIONAL ACTIONS TO KEEP UP THE AWARENESS OF APPENDIX B MONDAY MORNING TRAINING' SESSIONS DEMONSTRATE THE USE OF APPENDIX ASSESSING PERFORMANCE o -
PREPARATIONS STRESS THE IMPORTANCE OF ASSESSING BIG PICTURE QA IN EA INSPECTION O
I e
FUTURE INSPECTORS ARE CAPABLE OF ASSESSING THE REAL QA D LICENSEE CA ORGANIZATIONS ARE BEGINNING TO (si CORE INSPECTIONS-DO NOT INCLUDE ASSESSMENT OF NEED TO ASSURE QUALITY IS INDEED ANORGANIZATIONINTEGRAL P NEED TO REVISE NRC INSP.
PROCEDURES TO BRING PERFORMANCE AND ATTRIBUTES O
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IEB 85-03 Inspection Results Beaver Valley
~
Unit 1 - One Unresolved Item:
a) Review adequacy of' thermal overload relay settings Units 1&2 - One Unresolved Item; a) Review of torque switch settings to the MOVATLdata base thrust values and need justification for MOVs to operate under maximum differential pressure conditions Calvert Cliffs Units 1&2 - Two Violations and three Unresolved Items:
- 1) Violations:
a)No procedure for setting the limit switches and providing lubrication for SMB-00 and SMB-3 operators o
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- \_/
b)As-found torque switch settings different from those in response to Bulletin
- 2) Unresolved Items:
a) Lubrication deficiencies b) Influence of seat. wear on the limit-switch setting for valves which are closed on limit switch only c) changes to bypass switch settings affecting indication and limit switch settings Indian Point 2
- One Deviation and thtee Unresolved Items:
- 1) Deviation:
a) Failure to revise MOV maintenance procedures in a timely manner to include limit and torque switch settings
- 2) Unresolved Items:
I a) Inadequate review of adequacy of thermal overloads b) Inadequate engineering review of the as-left MOV switch settings
( ) c) Thermal overload drawing discrepancies
Maine Yankee.
k)b .
'1)One Unresolved Item:
a) Review impact of valve seat? wear and maintenance of limit switch setpoints for valves .that are closed purely on limit switch Nine Mile. Point 1&2
- No significant findings Peach Botton 2'43
- No significant findings Pilgrim 1)One Unresolved Item:
a) Lack guidelines which would prompt.
re-testing of valves to assure valve operability c
-a
.'IMI Unit 1
~ (%/~')
1)Three Unresolved Items:
a) Review of analysis to ensut. <alve can operate at target thrust values and lack of control of torque switch settings or thrust values b) Lack guidelines which would prompt re-testing of valves to assure valve operability c) Review of calculations to support adequacy of MOVs to operate under undervoltage conditions v
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Attachment-1
,y MOV Inspection Attributes l' '..
Generic Letter 89-10 TI'2515/73 Region'I
, 1. Incorrect torque switch settings X X 2 .- - Spring- pack .' _ X i 3. Stem packing tightness X X-r .
- 4. Excessive inertia X
- 5. Loose or tight stem-nut locknut X
- 6. Incorrect limit switch settings X X
- 7. Stem wear X X 8 .- Worn gears-
~9. Grease problems X 10'. Motor insulation or rotor degradation X
- 11. Incorrect wire size or degraded wiring X I'2. Disk / seat thermal binding
- 13. Water in internal parts X X
- 14. Undersized motori X
- 15. Valve position' indication X tL6. Failure of handwheel declutch mechanism X
~ 17. Relay problems _ . X
- 18. Thermal overload switch settings- X
- 19. Bearing wear
- 20. Broken ~1imit or torque switch components X
'21. Missing torque switch limiter plate X
- 22. Improperly sized actuator X
- 23. Hydraulic lockup
- 24. Incorrect metallic materials X
'25. Degraded voltage X
- 26. Motor control logic X
- 27. Excessive seating /backseating force X
- 28. Incorrect reassembly after maintenance X X
- 29. Unauthorized modifications or adjustments X X
- 30. Torque or limit switch binding X O_ _-_- _ _
g O
PERFORMANCE BASED . INSPECTION A. PREVIOUS INSPECTION FOCUB
- 1. COMPLIANCE => BAFE OPERATION.
- 2. RECORDB REVIEW CDUE TO LESS SITE PRESENCE) .
B. PERFORMANCE INSPECTION FOCL[E
- 1. SAFETY.
- 2. ACTIVITY OBSERVATION.
- 3. EVENT RECONSTRUCTION.
C. INDICATORS
- 1. MORE DIRECT APPLICATION 'OF PRINCIPLES Co.g., 10CFR50 APPENDIX B) .
- 2. MORE ONSITE PRESENCE, RESIDENT, REGION-BASED, & HQ.
- 3. TEAM INSPECTIONS.
- 4. SALPs.
- 5. INSPECTION FINDINGS, e.g., NOT "No violations were found" BUT "No inadequacies were found."
- 6. REPORT LETTER " SILVER BULLETB" O
I L..*.
1
,e' DIVISION OF RADIATION SAFETY AND SAFEGUARDS (DRSS)
The Division licenses and inspects approximately 3,000 materials licensees and maintains the Public Document Room and official files for the associated
' dockets. The Division is also responsible for inspection of health physics, emergency preparedness, environmental monitoring, radiological measurements, and safeguards at 32 power reactors,14 non-power reactors, and 2 fuel facilities. Further, the Division maintains the region's emergency response capability, and radiological laboratories. Finally, the Division is responsible for the national NRC TLD Direct Radiation Monitoring Network. The Division i Director reports to the Regional Administrator.
1
- 1. Facilities Radiological Safety and Safeguards Branch (FRSSB)
The Branch discharges the Division's responsibilities for reactors and fuel facilities, through the four Sections discussed below. The Branch is also responsible for the radiological laboratories, the TLD Network, and emergency response capabilities. The latter area includes procedures and training, as well as maintenance of the Incident Response Center and other resources. The Branch perfonns 250 to 300 inspections per year,
- a. Facilities Radiation Protection Section The Section addresses onsite radiological protection at reactors and fuel facilities, including ALARA programs and exposure to radiation and radioactive materials, both during normal operations and outages, and radwaste. The Section is staffed by seven radiation specialists and health physicists.
- b. Effluents Radiation Protection Section The Section is responsible for radioactive materials leaving reactors and fuel facilities, including liquid and gaseous effluents, and for solid waste systems, transportation, and environmental monitoring.
The Section is responsible for the radiological laboratory, the Mobile Laboratories, and the National TLD Monitoring Network. It is staffed by eight health physicists and specialist laboratory staff,
- c. Emergency Preparedness Section The Section maintains the Incident Response Center. assesses licensee emergency plans and exercises, coordinate with other Federal agencies such as FEMA, and assures the Region's readiness to respond to events. It is staffed by eight emergency preparedness specialists and emergency response staff.
O
G g s I
- d. Safecuards Section The Section evaluates security program effectiveness at licensee facilities, including physical systems, guard training and i qualification, and contingency plans and responses. It also addresses I accountability for special nuclear materials at reactors. It is staffed by nine reactor engineers, safeguards and security specialists, assistants and auditors.
I
- 2. Nuclear Materials Safety Branch !
The Branch is responsible for nuclear materials as discussed by section below. Section responsibilities have been assigned to parallel comparable branches at headquarters in NMSS. Staff members in Section A, B and C are cross-trained to perfom license reviews and inspections in areas other than those assigned to their particular Section. Approximately 1100 inspections and 1500 licensing actions are completed annually,
- a. Nuclear Materials Safety Section:: A, B, and C 1
O sectioa a is resvoasidie for the iiceasias aa inspectioa of the medical uses of byproduct materials, including medical institutions, private practices, medical distribution operations and pacemakers.
The Section is staffed by ten health physicists and nuclear medicine specialists and is responsible for about 1200 licensees.
Section B is responsible for the licensing and inspection of broad scope academie and research licensees, source and special nuclear materials users, manufacturing and distribution under exempt and specific licenses, and waste services. The Section is staffed by nine health physicists and is responsible for about 900 licensees.
Section C is responsible for the licensing and inspection of sealed sources in industrial applications, such as irradiators, radiographer, fixed and portable gauges and well logging, as well as waste disposal. This Section is also staffed by nine health physicists and is responsible for about 900 licensees.
- b. Licensing Assistance Section The Licensing Assistance Section is responsible for: docketing license applications relating to byproduct, source and special nuclear materials; administration of reports of inspections, inquiries and investigations involving such licensees; several automatic data processing systems for tracking the status of work.
O wort products ad resource utiiiratioai ad <>rfety or fararmatioa on and for byproduct materials ifcensees. The section is staffed by a chief and five reference, processing, and licensing assistants.
4 'o 1
L DIVISION OF RADIATION SAFETY AND SAFEGUARDS (DRSS)
H l
The Division licenses and inspects approximately 3,000 materials licensees and maintains the Public Document Room and official files for the associated
. dockets. The Division is also responsible for inspection of health physics,
, emergency preparedness, environmental monitoring, radiological measurements.
l- and safeguards at 32 power reactors,14 non-power reactors, and 2 fuel facilities. Further, the Division maintains the region's emergency response I
capability, and radiological laboratories. Finally, the Division is responsible for the national NRC TLD Direct Radiation Monitoring Network. The Division i Director reports to the Regional Administrator.
- 1. Facilities Radiological Safety and Safeguards Branch (FRSSB)
The Branch discharges the Division's responsibilities for reactors and
, fuel facilities, through the four Sections discussed below. The Branch is also responsible for the radiological laboratories, the TLD Network, and emergency response capabilities. The latter area includes procedures and training, as well as maintenance of the Incident Response Center and other resources. The Branch performs 250 to 300 inspections per year.
- a. Facilities Radiation Protection Section O. The Section addresses onsite radiological protection at reactors and fuel facilities, including ALARA programs and exposure to radiation and radioactive materials, both during normal operations and outages, and radwaste. The Section is staffed by seven radiation specialists and health physicists.
- b. Effluents Radiation Protection Section The Section is responsible for radioactive materials leaving reactors and fuel facilities, including liquid and gaseous effluents, and for i solid waste systems, transportation, and environmental monitoring.
The Section is responsible for the radiological laboratory, the Mobile Laboratories, and the National TLD Monitoring Network. It is staffed by eight health physicists and specialist laboratory staff.
- c. Emergency Preparedness Section The 3ection maintains the Incident Response Center. assesses licensee emergency plans and exercises, coordinate with other Federal agencies such as FEMA, and assures the Region's readiness to respond to events. It is staffed by eight emergency preparedness specialists and emergency response staff. l O .
i i
l&
l
- d. Safeguards Section The Section evaluates security program effectiveness at licensee I facilities, including physical systems, guard training and qualification, and contingency plans and responses. It also addresses accountability for special nuclear materials at reactors. It is staffed by nine reactor engineers, safeguards and security i specialists, assistants and auditors.
- 2. Nuclear Materials Safety Branch The Branch is responsible for nuclear materials as discussed by section below. Section responsibilities have been assigned to parallel comparable branches at headquarters in NMSS. Staff members in Section A, B and C are cross-trained to perform license reviews and inspections in areas other than those assigned to their particular Section. Approximately 1100 inspections and 1500 licensing actions are completed annually,
- a. Nuclear Materials Safety Sections A, B, and C h Section A is responsible for the licensing and inspection of the medical uses of byproduct materials, including medical institutions, private practices, medical distribution operations and pacemakers.
The Section is staffed by ten health physicists and nuclear medicine specialists and is responsible for about 1200 licensees.
Section B is responsible for the licensing and inspection of broad scope academic and research licensees, source and special nuclear materials users, manufacturing and distribution under exempt and specific licenses, and waste services. The Section is staffed by nine health physicists and is responsible for about 900 licensees.
Section C is responsible for the licensing and inspection of sealed sources in industrial applications, such as irradiators, radiographer, fixed and portable gauget and well logging, as well as waste disposal. This Section is also (tWed by nine health physicists and is responsible for about 900 licensees.
- b. Licensing Assistance Section The Licensing Assistance Section is responsible for: docketing license applications relating to byproduct, source and special nuclear materials; administration of reports of inspections, inquiries and investigations involving such licensees; several automatic data processing systems for tracking the status of work, g work products and resource utilization; and a variety of information on and for byproduct materials licensees. The section is staffed by a chief and five reference, processing, and licensing assistants.
~
O amassas savam stavan seassa PRESENTED AT THE ADVISORY COMMITTEE Ot' REACTOR SAFEGUARDS REGIONAL PROGRAMS SUBCOMMITTEE MEETING REGION I
~
KING OF PRUSSIA, PA AUGUST 29-30, 1989 O
BY JACK STROSNIDER, CHIEF MATERIALS 4 PROCESSES SECTION O
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,1. FOULING FROM SEBIMEiiT BEPOSITION 7th TtR 18.7 11 8.8 BIDFOULING Tin Ttil 1111 15.8 3 4.0 CORROSION EROSION- ItR Tiu 1ML 29.8 111 12.8 11R TRL 11 PIPE COATING' FAILURE 1 1.1 FOREIGN BEBRIS 1 1.1
- 2. SINGLE ' F AILURE ANE 111 3.3 Tiu 1 24.8 BESIGN DEFICIENCIES
.'FLOOBING 1 1.1 1 4.8
- 4. EQUIPMENT FAILURES Tiu Tiu tiR 19.4 1144. 111 32.8 111
- 5. PERSONNEL-AND 11R 11 7.5 1111 16.8 PROCEDURAL' ERRORS
- 6. SEISHIC BEFICIEHCIES 11R 7th 1 11.8
- THE INCIDENCE OF BIDFOULING & EROSIOHe
-CORRDSIDH HAS DECREASED
- DESIGH DEFICIENCIES ARE IDENTIFIED AT A HIGHER RATE
- THREE UNITS MADE ist TIME REPORTS OH SMS FOULING IN '88 '89
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i as 800 800 ,
name aseampvamm sammame i
.YCNKEE ROWE SEAL COOLER FLOW TO BOTH RHR CHECK UALUES~
PUMPS COULB BE LOST THROUGH INSTALLEB IN AN ISOLATED HEAT Hx BUE TO EACH* RHR PUMP FAILURE OF A SINGLE ISO UALUE' COOLING LINE
- YANKEE RONE CONT AINMENT- COOLING UNIT HEAT BETERMINED BY j REMOUAL INABEGUATE BUE TO: EN6 ANALYSIS 1 (1) THROTTLEB OUTLET UALUES, (2) NONESSENTIAL LOABS NOT
- ISOLATES ON LOCA AND (3) HIGH BELTA P ACROSS Hx PEACH BOTTOM 2 IMPROPER UENTING OF PUMP - IDENTIFIED B" STRUCTURE AND LEUEL TRANSMITTER TESTING, STAMBPIPES COULB RESULT IN FINED PRIOR
< BRAINING HEhT SINK AND ESH TO RESTART BOOSTER-PUMPS HAB INABEGUATE SUCTION FLilW UNDER CERTAIN CONDITIONS CELUERT CLIFFS BRAIN LINES IN THE SERVICE WATER IDENTIFIED BY PUMP ROOMS HAB NO BACKFLOW AN OPERATOR, PROTECTION CHECK UALUES INSTALLEB CALUERT CLIFF 1 FAILURE OF A SINGLE CHECK UALUE IDENTIFIEB IN INSTRUMENT AIR SYSTEM COULB BURING TEST HAUE LEB TO LOSE OF SALT SERUICE WATER SYSTEM MIME MILE- 2 NON-C ATEGORY .IE RELAYS SPECIFIEB RELAYS RE-IN BESIGN BRAMING WERE INSTALLEB PLACEB AND IN CATEGORY 1E AUTOMATIC OPENING SIMILAR CIRCUIT FOR THE DISCHARGE UALUES PROBLEMS-ON 5 0F 6 SERUICE WATER PUMPS LOOKEB FOR gNCLUSIDH: APPROPRIATE ITEM 4 0F GL 09-13 IS
r B & DOS EMn 3xP3GD3033
- ORIGINAL CEMENT LINED CARBON STEEL PIPING MAS '
EXPERIENCES LINING FAILURES, CORROSION AND CRACKING
- SECTIONS REPLACE WITH TYPE 316 SS (ALLOY 625 WELB i METAL) EXPERIENCES PITTING CORROSION -
l
- A PROGRAM ~ IS CURRENTLY IN PROGRESS TO REPLACE SMS l- PIPIMS WITH Al-6XN (ALLOY 625 WELD MATERIAL)
- NRC INSPECTION IDENTIFIED USE OF NONCODE REPAIRS (WELD OUERLAYS) ON 3* TYPE 316 PIPING - ULTIMATELY ACCEPTED AFTER NRR REUIEH
- WELBING PROBLEMS WITH NEW AL-6XN/ ALLOY 625 WELBS -
PSEA6-PLACEB TEST COUPONS IN SMS CORROSION TEST LOOP TO ABBRESS CONCERN O
samses passe a sus aspaassmas
- CEMENT LINED CARBON STEEL PIPE MAS NAS A MISTORY OF LEAKS AHB ONE COMPLETE FAILURE (1988)
- CORROSION INITIATES AT PARTIAL PENETRATION HELBS
- LICENSEE IS MONITORING CORROSION BY RADIOGRAPHY e JULY 1987 INSPECTION IDENTIFIEB USE OF REPAIRS (OUERLAYS AND CLAMPS) NOT IN ACCORBANCE WITH COBE -
LEAKING JOINTS WERE SUBSE9EUNTLY REPAIRED i O
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- IN THE PAST 2 YEARS MILLSTONE 3 NAS . EXPERIENCES ABOUT }
8 LEAKS IN THE COPPER-MICKEL CLAB CARBON STEEL SMS PIPING BUE TO EROSION-CORROSION ,
- THE LICENSEE NAS A MONITORING PROGRAM INCLUDING UT THICKNESS MEASUREMENTS, TRENDING, AND REPAIRS
- REPAIRS WERE FOUND BY HRC INSPECITON TO BE OUTSIDE CODE
$UBSEGUENTLY ACCEPTED AFTER NRR REUIEW O i asumasvB .
- DECREASE IN EROSION / CORROSION PROBLEMS CONSISTENT HITH LICENSEE INITIATED MONITORING AND CONTROL PROGRAMS l
- NRR NAS DISTRIBUTED, FOR COMMENT, A BRAFT GENERIC LETTER ABBRESSING ISSUE OF TEMPORARY REPAIRS i OUTSI3E COBE I
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O. 1 BassaBa saves 3 so-as emm 33353E R.EEBPERETBE PRSD32M ,
a 6.L. 89-13 ISSUED JULY 18, 1989
- REQUIRES:
BIDFOULING CLHTROL PROGRAM UERIFY Hx OPERABILITY INSPECION AND MAINTENANCE PROGRAM CONFIRM FUNCTIONALITY IN:ACCORDANCE HITH. DESIGN BASIS CONFIRH ADEQUACY OF MAINTENANCE, OPERATING & EMERGENCY PROCEDURES, AND TRAINING Q AB0dE REQUIREMENTS ARE CONSISTENT HITH REGION I EXPERIENCE
- IMPLEMENTATION: BEFORE STARTUP FOLLONING REFUELING OUTAGE BEGINNING AFTER 4/18/91 o NO TEMPORARY INSTRUCTION UNDER
-DEVELOPMENT AT THIS TIME
- REGIONAL INSPECTIONS:
SUBIECT TO. AV AILIBILITY OF RESOURCES AND OTHER PRIORITIES NOULDN'T START FOR APP A YEAR LER DATA CAN BE USE TO IDENTIFY SAMPLE OF PLANTS FOR INSPECTIDH O
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MAJOR REGION I' FUEL CYCLE FACILITIES-STATUS.
UNITED NUCLEAR CORPORATION-NAVAL r CDucTS OPERATIONAL UNITED NUCLEAR CORPORATION-RECOVERY SYSTEMS DECOMMISSIONING-COMBUSTION ENGINEERING OPERATIONAL BABC0CK~AND WILCOX-APOLLO' DECOMMISSIONING O BABC0Cx AND wItC0x-eARxS 10wNSNIP REACTOR eaureMENT REFURBISHMENT CINTICHEM OPERATIONAL DOE-WEST VALLEY SUPERNATANT REMOVAL FROM TANK 8D-1 e
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L/h UNITED NUCLEAR CORPORATION-NAVAL PRODUCTS, MONTVILLE, CT 1.
FABRICATES CORES FOR NUCLEAR SUBMARINES ISSUE: LACK OF MANAGEMENT AMENTION TO RADIATION SAFETY FOUND THROUGH OCTOBER 1986 OPERATIONAL SAFETY ASSESSMENT AND ROUTINE INSPECTIONS LICENSEE INSTITUTED UNILATERAL IMPROVEMENT PROGRAM REGION I INSPECTORS CON 71NUE TO FOLLOW THE IMPROVEMENT PROGRAM-O
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CINTICHEM, INCORPORATED - TUXEDO NEW YORK P'/ DUCES RADIOLOGICAL THROUGH FISSIONING OF URANIUM OXIDE ISSUES: LACK OF MANAGEMENT CONTROLS LACK OF CONTAMINATION CONTROL PROGRAM FOUND THROUGH MAY 1987 OPERATIONAL SAFETY ASSESSMENT AND ROUTINE INSPECTION
,] LICENSEE INSTITUTED UNILATERAL IMPROVEMENT PROGRAM REGIONAL INSPECTORS CONTINUE TO FOLLGV THE IMPROVEMENT PROGRAM
4 9 '
O DOE WEST VALLEY, NEW YORK DEMONSTRATION PROJECT DEMONSTRATION OF PROCESS FOR THE SOLIDIFICATION OF HIGH LEVEL LIQUID WASTE ABOUT 25% OF THE SUPERNATANT (600,000 GALLONS) SOLIDIFIED IN CONCRETE'TO INITIATE VITRIFICATION OF SLUDGE NRC AND DOE PROVIDE INFORMATION AND STATUS REPORTS PERIODICALLY TO ACNW NRC MONITORS ONGOING PROGRESS THROUGH. TEAM ASSESSMENTS. NEXT TEAM
'([) ASSESSMENT SCHEDULED .:0R SEPTEMBER 1989 i
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h PROBLEM FUEL FACILITY:
COMBUSTION ENGINEERING, WINDSOR CT ISSUES: LACK OF ATTENTION-TO RADIATION SAFETY-LACK OF MANAGEMENT CONTROLS PROBLEMS FOUND THROUGH OPERATIONAL SAFETY ASSESSMENT-AND ROUTINE INSPECTIONS ROUTINE INSPECTION FOUND CORRECTIVE ACTION SLOW-CAL ISSUED -
SEPTEMBER 9, 1988 SPECIAL SALP CONDUCTED AUGUST, 1988 O-FACILITY INSTITUTED-IMPROVEMENT PROGRAM
.NEXT STEP: SALP ASSESSMENT TEAM SCHEDULED SEPTEMBER, 1989 l.
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PROBLEM FUEL FACILITY:
COMBUSTION ENGINEERING, WINDSOR CT ISSUES:
LACK OF ATTENTION TO RADIATION SAFETY LACK OF MANAGEMENT CONTROLS PROBLEMS INSPECTIONS FOUND THROUGH OPERATIONAL SAFETY ASSESSME ROUTINE INSPECTION SEPTEMBER 9, 1988 FOUND CORRECTIVE ACTION SLOW-CAL ISS SPECIAL SALP CONDUCTED AUGUST, 1988
'O FACILITY INSTITUTED IMPROVEMENT PROGRAM NEXT STEP: SALP ASSESSMENT TEAM SCHEDULED SEPTEMBER, 1989
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DOE WEST VALLEY, NEW YORK DEMONSTRATION PROJECT-DEMONSTRATION OF PROCESS FOR THE SOLIDIFICATION OF HIGH LEVEL LIQUID WASTE ABOUT 25% OF THE SUPERNATANT (600,000 GALLONS) SOLIDIFIED IN CONCRETE TO INITIATE VITRIFICATION OF SLUDGE NRC AND DOE PROVIDE INFORMATION AND STATUS REPORTS PERIODICALLY TO ACNW g NRC MONITORS ONGOING PROGRESS THROUGH TEAM ASSESSMENTS. NEXT TEAM 1, ASSESSMENT SCHEDULED JOR SEPTEMBER 1989 l
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l CINTICHEM, INCORPORATED - TUXEDO NEW YORK l
PRODUCES RADIOLOGICAL THROUGH FISSIONING OF URANIUM OXIDE ISSUES: LACK OF MANAGEMENT CONTROLS LACK OF CONTAMINATION CONTROL PROGRAM FOUND THROUGH MAY 1987 OPERATIONAL SAFETY ASSESSMENT AND ROUTINE INSPECTION Q LICENSEE INSTITUTED UNILATERAL IMPROVEMENT PROGRAM REGIONAL INSPECTORS CONTINUE TO FOLLOW THE IMPROVEMENT PROGRAM e
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o i UNITED NUCLEAR CORPORATION-NAVAL PRODUCTS, MONTVILLE, CT l
FABRICATES CORES FOR NUCLEAR SUBMARINES ISSUE: LACK OF MANAGEMENT ATTENTION TO RADIATION SAFETY FOUND THROUGH OCTOBER 1986 OPERATIONAL SAFETY ASSESSMENT AND ROUTINE INSPECTIONS LICENSEE INSTITUTED UNILATERAL IMPROVEMENT PROGRAM O REGION I INSPECTORS CONTINUE TO FOLLOW THE IMPROVEMENT PROGRAJi O
MAJOR REGION I FUEL CYCLE FACILITIES-STATUS UNITED NUCLEAR CORPORATION-NAVAL PRODUCTS OPERATIONAL UNITED NUCLEAR CORPORATION-RECOVERY SYSTEMS DECOMMISSIONING CCMBUSTION ENGINEERING OPERATIONAL BABC0CK AND WILCOX-APOLLO DECOMMISSIONING O BABC0Cx AND WItC0x-PARxS T0wNSNIe REACTOR eoVIeMENT REFURBISHMENT CINTICHEM OPERATIONAL 00E-WEST VALLEY SUPERNATANT REMOVAL FROM TANK 80-1 1.
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l DESIGIT CONFIGURATION COliTROL TYPICAL FIT" PATRICK MAY 1989 GUIDAliCE AND DESIGIT BASIS DOCU:!EIIT WRITERS GUIDE FORMAT p COMPLETED FOR:
- LICEllSING REQUIREME!!T
- DESIGN CRITERIA
- DESIGIT ATTRIBUTES ; TECHNICAL REQUIREMENTS TO MEET LICENSING AND DESIGN CRITERIA
- CALCULATIONAL SUMMARIES (INCLUDI!!G REFEREliCES)-
SUMMARY
OF CHANGES AND MODIFICATIONS PILOT PROGRAM FOR HPCI AND CONDENSATE / FEEDWATER SYSTEM Ili FINAL STAGE OF COMPLETION
() BID SPECIFICATION FOR REMAINING SYSTEMS ( APPROXIMATELY 26-)
ESTIMATED YEARS TO BE READY BY MID-SUMMER AND COMPLETION IN 5 ESTABLISH NEW IN-HOUSE INFRASTRUCTURE CONTROL BY CONFIGURATION DOCUMENTS ( 1990 )
- CALCULATIONS
-SPECIFICATIONS
- CABLE RACEWAY
- LICENSING COMMITMENTS COLLECT DOCUMENTS FROM OUTSIDE SOURCES
t CONFIGURATION BASELINE DOCUMENTATION TABLE OF CONTENTS Section , Pace LIST OF' EFFECTIVE PAGES ii - iv TABLE OF CONTENTS at LIST OF TABLES vi LIST OF FIGURES vii LIST OF APPENDICES viii PREFACE ix - xi 1.0 FUNCTIONAL DESCRIPTION 1-1 1.1 Purpose- 1-1 1.2 System Boundaries 1-1 2.0 APPLICABLE CODES, STANDARDS AND 2-1 REGULATORY DOCUMENTS 2.1 General Design Criteria 2-1 2.2 Regulatory Documents 2-2' 2.3 Codes and Standards 2-5 3.0 SYSTEM DESIGN BASIS 3-1 3.1 System Performance Requirements 3-1 3.2 Piping Pressure and Temperature 3-12 C} -
Criteria 3.3 Separation / Redundancy / Motive Power 3-12 ,
Diversity Requirements !
\- 3.4 External / Internal Hazards 3-13 J 3.5 Special Testing Features 3-14 3.6 Inservice Inspection Requirements 3-16 3.7 System Design and Safety Analysis Margin 3-16
- 3. 8. Structural Requirements 3-17 4.0 COMPONENT DESIGN BASIS 4 -1.
5.0 SYSTEM OPERATION 5-1 5.1 Functional and Operability Matrix (FOM) 5-1 5.2 System Equipment, Controls, and Interlocks 5-3 6.0 ACCIDENT ANALYSIS 6-1 7.0 DESIGN BASIS-EVOLUTION 7-1 8.0 CALCULATIONS 8-1
9.0 REFERENCES
9-1 10.0 SYSTEM DIFFERENCES (SALEM 1 vs SALEM 2) 10-1 TABLES - SEE LIST OF TABLES vi 1 FIGURES - SEE LIST OF FIGURES vii APPENDICES - SEE LIST OF APPENDICES viii O O PSEG Nuclear Department
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4KV Auxiliar* Power System R: ,;
uy , 1988 DE-Ce ' 0011(Q)
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O ,
MOBILE NONDESTRUCTIVE EXAMINATION LABORATORY
' Since July 1981, over 65 inspections have been conducted at reactor sites throughout the country using the mobile Nondestructive Examination (NDE)
L laboratory. Over the past few years the focus of the Mobile NDE team inspections has expanded to include activities at' operating as well as construction sites. Routine mobile NDE inspection activities at operating ,
f acilities include independent NDE to verify the quality of piping and j component replacements, system modifications and licenset inservice inspection i activities. Examples of special inspections at operatint facilities include ;
inspection of the Waterford 3 modification program, Peach Bottom 3 piping !
replacement and D.C. Cook steam generator replacement. The mobile NDE laboratory has also been used to provide independent assessments in support of
- allegation followup and investigate..s.
The laboratory consists of a specially equipped trailer, designed to provide transport cad storage of equipment, a dark room for manually developing radiographic tilm, and a place te work and review results. The assigned personnel and contractors perform radiography, ultrasonic, liquid penetrant and magnetic particle examinations. Visual examinations of piping, pipe
' support and structural welding are also performed, along with testing of concret,e and electrical cabling. In addition, the laboratory has acquired a
$( state of the art ultrasonic testing system to further enhance NRC's capability to independently evaluate service induced defects such as stress corrosion cracking.
The laboratory 'is staffed by three NRC inspectors, supplemented by two I contractors. The lead inspector is an NRC engineer qualified as an American Society for Nondestructive Testing (ANST) Level III examiner. The two remaining NRC inspectors and two contractors are qualified to at least ASNT Level II in the disciplines precticed under the program along with AWS welding inspector certification. The laboratory crew also has EPRI qualification for the detection of intergranular stress corrosion cracking.
The program is a joint effort of NRC headquarters and field offices, and is operated out of the Region I office. This year the original NDE van was replaced with a specially built trailer. Experience indicates that the new trailer is a dependable and cost effective replacement, whose design and enhanced capabilities appropriately address long standing deficiencies with its predecessor. The Region I offices include a complementary nondestructive examination laboratory in which activities such as hardness testing, alloy analysis, ferrite measurements and nondestructive examination of unirradited materials can be performed.
The Independent Nondestructive Examination Program continues to provide the NRC with a qualified staff and equipment to independently access the quality of licensee construction, modification and inservice inspection activities.
me o e k a y W pS c c r u ii c e a V N n e i q d r o r r . A e . j f i a t l p y l ( t n e n n r eb n S f a c o r oh m i s ut e t c c f o . r i q e f t y e o et n e t n e e f d ot g a o z a t n D d c i l t y c i i s e o e i t e g t d t r n s l i f n w d n l l c a u t n r a f i e ni l e i c s n o e r i t d ej e t a w n i t- ' s p u t n i r e t s u o d e d . r d n e u y e O e s n r i a e E e e d o s r t t a I P d t pD . c d i t od a eb r ( ( a N e o I l M d l o t c : nd n t r d d cl n b t l i t o i g a P t l e f a a c u h r i n n d ( u e l t S o t e p a t o ei . c w l t G n p p g a . p ci . c y nn r e e N e o e s n r s e t s nf o o e t f h
! t i c n o g gf p c t et t i d c s 0 a t ci r o no s e nt t t t n e p N t a a n w t i n pi r a e e u r ur I S c nU d w n i s oe u r e r t oi F i u) f e a o np p q bl e o et t e r 2 o r ri l I x i f l c s a h b ) ( d t a e e r l l b n r ue c t a 1 . e e a o al a I c e p f ( s s t f c sl nT f c e t i ns y . e U b oi i n e N . u c r h e b r s h o . f v o rS c c q e o pgi e m c ) t g wi s s eA o i j f a d n e n3 c n e t mf e f r s nl e r nt ei t I ( eI i n e o r ef p m o e r m g e t L i . j p ve t t r o e s n e e e s 4 e ei ed I nt n t a n r .t l t el d t r p ri o ud ei i r o odi d s u o e r a d i l s t s f e e q o v e 'd ,
m s e e e t e e uy d l r t d s r nng e p l d n e nt t v a t w c e u e nr e n I S r o nl o t o a a l t e r n v p e o v o r N f s u e i s i uu o nl f e e l g t pl i e s O no e p t y t q q s e p o pt o nt t e o t pnd e I o r s a s a e e e mm o c s i e e r s a o oit T i y n e r t t d d r uok r e e s u t e t ri us C t c up e o t o a a n c c c pf r s s ot r opt q E c a i p l n l nn u o n o me nii l o n l mai P e u e p o v a vI I D I L I d uM V vnu vI cL S pq e r l e i N s e r r p e o o) ) v) ) ) ) ) o) ) et e o) d I nd h o n n o w1 2 i 1 2 3 4 5 w1 2 nun w1 n2 I e T f I O c T ( ( F ( ( ( ( ( T ( ( O b O T ( I 8
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3 NDE VAN INSPECTION CAPABILITIES Isotope Radiographic Testing Contact Ultrasonic Testing Prod or Yoke Magnetic Particle Testing Liquid Penetrant Testing Visual Weld Examinations Metal Alloy Analysis Hardness Testing
- - Metal Thickness Measurements Stainless Steel Delta Ferrite Measurements .
Comprehensive review of licensee welding documentation, material certifications, NDE reports and radiographs.
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Onsite independent monitoring and oversight of PSI /ISI activities.
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