ML20283A573

IP 43006 Inspection of the Implementation Strategies Regulation Regarding the Use of National Safer Response Centers

ML20283A573
Person / Time
Issue date:	10/16/2020
From:	Savwoir N NRC/NRR/DRO/IQVB
To:
Savwoir N
Shared Package
ML20289A806	List: Inspection Manual Change Notice 20-051, Table of Contents for Inspection Manual Change Notice 20-051 ML20169A502 ML20202A459 ML20202A478 ML20262H116 ML20283A573
References
CN 20-051
Download: ML20283A573 (7)

Text

NRC INSPECTION MANUAL IQVB INSPECTION PROCEDURE 43006 INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES REGULATION REGARDING THE USE OF NATIONAL SAFER RESPONSE CENTERS PROGRAM APPLICABILITY: 2507 43006-01 INSPECTION OBJECTIVE To verify that vendors storing, handling, and supplying portable equipment to be used by licensees comply with 10CFR50.155 Mitigation of beyond-design-basis events and NRC Order EA-12-049 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12056A045), which added requirements for mitigation strategies for beyond-design-basis external events. The NRC will perform an inspection of the Strategic Alliance for FLEX Emergency Response (SAFER) program every 3 years alternating between National SAFER Response Centers (NSRC) located in Memphis, Tennessee and Phoenix, Arizona.

43006-02 INSPECTION REQUIREMENTS 02.01 The inspector reviews the program, instructions, procedures, plans, and policies and verifies, by observing vendor activities, document reviews, and interviewing vendor staff, that the selected vendor has implemented effective programmatic controls for FLEX-related activities. The vendors chosen program to ensure licensees are in compliance with the NRC order should be based on the appropriate criteria contained in the contractual agreement between the vendor and the licensees. The vendors program should be based on the criteria contained in the NRC-approved revision of NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, and 10CFR50.155 Mitigation of beyond-design-basis events.

02.02 The lead inspector will prepare an inspection plan in accordance with IMC 2507, Vendor Inspections. The inspection plan should provide the scope and basis for the inspection; describe the proposed evaluation of the vendors activities, including the chosen program procedures and its implementation; and identify the work assignments for each inspector. The inspection plan shall consider inspection of the critical and quality attributes identified in the Phase 3 site response plans.

43006-03 INSPECTION GUIDANCE:

The vendors program should contain procedures, policies, and instructions that meet the minimum capabilities of off-site resources. NEI 12-06, section 12.2, describes an acceptable scope and provisions envisioned for the proper management for off-site FLEX-related activities.

The inspector will take into consideration the 10 areas described in Section 12.2 while conducting the inspection to ensure the vendor has implemented adequate controls for these Issue Date: 10/16/20 1 43006

inspection areas: procurement of materials, equipment and services, conduct of tests, maintenance of equipment, storage and staging of equipment, and corrective actions.

Specific Guidance. The lead inspector should focus the inspection effort based on the program elements specified in the NEI 12-06 and the SAFER program documents to meet the requirements of 10CFR50.155 Mitigation of beyond-design-basis events and NRC Order EA 049. This Inspection Procedure (IP) is a modified version of IP 43002, Routine Inspections of Nuclear Vendors because the vendor is not required to implement a program that complies with Appendix B to 10 CFR Part 50. This is because the equipment is for beyond-design-basis events.

To prepare for the inspection, the inspector should become familiar with:

• 10CFR50.155 Mitigation of beyond-design-basis events

• RG 1.226 Flexible Mitigation Strategies for Beyond-Design-Basis Events

• Interim staff guidance (ISG) JLD-ISG-2012-01, Revision 0, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12229A174) and

• Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide, Revision 0 (ADAMS Accession No. ML12242A378).

These documents describe the NRCs expectations for off-site support including what Phase 3 equipment is necessary. The NRC endorsed the licensees proposed plans for off-site support via letter dated September 26, 2014 (ADAMS Accession No. ML14265A107). The NRC sought reasonable assurance that the National SAFER Response Centers (NSRCs) would be capable of delivering the FLEX equipment to support licensees compliance with 10CFR50.155 Mitigation of beyond-design-basis events and NRC Order EA-12-049. The inspection scope focused on the programmatic elements delineated in Section 12 of NEI 12-06. The focus of the NRCs inspection of the NSRC is to verify deployment capabilities are met against 10CFR50.155 Mitigation of beyond-design-basis events and NRC Order EA-12-049.

After the inspector becomes familiar with the vendors program and implementing procedures, the inspector will select a sample of activities and equipment for review. For the selected activities, the inspector should request that the vendor provide (or make available for review) a complete package of the pertinent records. The inspector should include procurement documents, equipment specifications, maintenance records, calibration records, and associated documentation pertinent to the area of review. The inspectors should also review the vendor's programs and procedures, controlling processes and activities. In addition, the inspector may use the results of the most recent NUPIC audit to verify licensees assessment of their vendor and to verify that any deficiencies identified are being properly addressed in the corrective action program.

The inspector should evaluate the effectiveness of the vendor's implementation of its program using the guidance below.

03.01 SAFER Program. Verify the vendors program implementation in accordance with NEI 12-06 by performing the following:

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a. Verify that the vendor program identifies the items and activities to which it applies, and that these activities are accomplished under suitably controlled conditions.

b. Verify that the organizational description addresses the organizational structure, functional responsibilities, levels of authority, and interfaces.

c. Verify qualifications, responsibilities, and duties of personnel performing activities affecting FLEX equipment. In order to verify that personnel have been adequately trained, the inspector may conduct interviews with the personnel to ensure that they have an understanding of the activities they are performing commensurate with their responsibilities.

d. Verify that vendors emergency response process and systems, as described in the site response plans, operate as designed by reviewing documentation of established maintenance and testing program activities.

e. Verify that vendors employees know, who is responsible for receiving the activation call and what would be the staffs responsibilities for responding to the call in case of emergency.

f. Verify that the vendor is implementing procedures to control changes that could affect the procurement, program procedures, testing, and maintenance of FLEX equipment and that changes do not impact any critical function (e.g., revision to Equipment Techncal Requirements Document does not omit important parameters). Verify that any changes were properly communicated between licensees and the vendor (i.e. review SAFER Equipment Committee meeting minutes and recent update to FLEX strategies).

g. Verify that the vendor has established and implemented FLEX equipment handling, maintenance, calibration, test and inspection procedures including any such activities applicable to sub-vendor activities (i.e. contracted testing or calibration services). Also ensure they include quantitative and qualitative acceptance criteria for determining that activities have been satisfactorily accomplished.

h. Verify the Memorandum of Agreement (MOA) Between the Department of Defense and the NRC for Helicopter Support (ML17290B180) is in effect. The memorandum remains in effect for a period of five years, starting on the date of the final signature unless otherwise agreed to in writing.

03.02 Procurement Control. Select a sample of procurement documents and verify the implementation of procurement document controls by performing the following:

a. Verify that the vendor has established and implemented procedures for the control and release of procurement documents as well as subsequent changes.

b. Verify that the vendors (i.e., PEICos) procurement documents to its suppliers include the licensees quality requirements, including: technical, administrative, regulatory, and reporting requirements, such as, specifications, codes, standards, settings, parameters, critical characteristics, tests, and inspections. Verify that procurement documents comply with the FLEX equipment critical functions.

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c. Verify that equipment procured and stored at the NSRCs is 1) as specified in the purchase orders and 2) as required for their intended use per the applicable licensees specifications (e.g., use of appropriate standard mechanical and electrical connections).

d. Verify that any necessary equipment to support the deployment of the FLEX equipment is available and properly maintained.

e. Verify that contracts with road and air providers (see step 3.01,h if MOA is in effect) are in place, valid and updated to ensure assumptions (i.e. no single external event will preclude capability to supply needed resources to licensees) for deployment of FLEX equipment remain valid.

f. Verify that the vendor has a documented method for the identification and control of nonconforming material and components to preclude inadvertent use.

03.03 Test, Maintenance and Measuring & Test Equipment (M&TE) Control. Assess test, maintenance, and M&TE controls by performing the following:

a. Verify that the vendor has established and implemented procedures for testing and maintenance. Examples of tests and maintenance activities include receipt inspection, preventive and post-maintenance testing, post-modification, tests after operational or emergency use, and proper use of M&TE.

b. Verify that test procedures include or reference test objectives, test requirements, applicable prerequisites, and acceptance criteria contained in the applicable technical documents.

c. Verify that preventive maintenance tests are properly challenging the critical function (i.e pump discharge presure is verified) and when deficiencies are identified verify that the proper corrective actions are taken (i.e. FLEX strategies requires action within 90 days).

d. Verify that the vendor documents test results and results are evaluated by a qualified individual to ensure satisfactory test requirements. Test records, as a minimum, should identify the item tested, date of test, tester or data recorder, type of observation, instruments used and the validity of their calibration, results and acceptability, action taken in connection with any deviations noted, and the individual evaluating test results.

e. Verify that the vendor calibrates, adjusts, and maintains M&TE at prescribed intervals prior to use. Verify that the vendor defines the method of calibration for each device.

Verify that the vendor perforns calibration using certified equipment having known valid relationships to nationally recognized standards. When M&TE is found to be out of calibration, provisions in the procedures should require an evaluation to verify if previous inspection or test results are affected.

f. Verify controls are in place to document and prevent nonfunctional Phase 3 equipment from deployment.

g. Verify maintenance history is communicated and evaluated against both NSRCs to support all deployment configurations.

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h. Verify NSRCs generators have adequate load sharing capabilities, pairing availability, and are identifiable.

03.04 Handling, Storage, and Deployment. Assess handling, storage, and depolyment controls of FLEX equipment by performing the following:

a. Verify that the vendor has established and implemented procedures for the control of deployment activities when the response centers are activated. This includes proper staging, loading of trucks, marking and labeling, storing of site-specific and generic licensee equipment, out of service status, shipment of items and components, and control of limited shelf life materials.

b. Verify that personnel are familiar with the bill of laddings already prepared and stored for immediate use and ensure it matches the different storage areas as they pertain to the different licensees. Bill of laddings should specify all the FLEX equipment to be shipped in case of activation and the available means of transportation to meet the deployment requirements, including current agreements with shipping companies.

c. Verify that operators responsible for ensuring the right equipment is shipped and properly stored post maintenance activities are experienced or trained.

d. Verify that spare parts for the FLEX equipment are available and in good condition for use at the NSRC and potentially to support licensee needs.

e. Verify NSRCs Site Response Plan (SRP) contain measures to deploy site specific Phase 3 FLEX equipment.

03.05 Corrective Action. Select a sample of corrective action reports and related documents for review. Assess corrective action controls by performing the following:

a. Verify that the vendor has established and implemented procedures for correcting conditions affecting FLEX equipment as defined by the vendors program.

b. Verify that corrective action reports provide for documentation and description of the condition, the cause and corrective action taken to prevent recurrence when applicable, review and approval by the responsible authority, status of corrective actions reviewed, and follow-up action taken to verify timely and effective implementation of corrective action.

c. Verify that the vendor adequately assesses and documents program deficiencies (e.g., receipt inspection rejections, equipment malfunction, maintenance test failures, etc.) in its corrective action program. Vendor personnel, licensees or sub-suppliers may report program deficiences and operating experience.

43006-04 REPORTING REQUIREMENT Inspectors will document any issues in accordance with IMC-0617, Vendor and Quality Assurance Implementation Inspection Reports. Any issues identified will be processed in accordance with the more-than-minor criteria in the IMC. The highest enforcement action will be issuance of a nonconformance (NON) with the expectation that the vendor will address these Issue Date: 10/16/20 5 43006

issues in their corrective action program because these facilities are implementing beyond-design-basis requirements. If numerous deficiencies are identified it is expected that licensees address how they are coordinating with the vendor on the resolution of these issues.

43006-05 RESOURCE ESTIMATE This inspection procedure is used for the triennial assessment of the off-site national response centers SAFER program that supports licensees in a beyond-design-basis event. The resource estimate for this inspection procedure is approximately 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> of direct inspection effort. The resource estimate is based on a 32-hour week inspection performed by two inspectors alternating per NSRC site on a three-year basis.

43006-06 REFERENCES Manual Chapter 2507, Vendor Inspections (ADAMS Accession No. ML13247A725)

NEI 12-06, Rev 4, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (ADAMS Accession No. ML16354B421)

JLD ISG 2012 01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (ADAMS Accession No. ML12229A174)

Staff Assessment of National SAFER Response Centers established in response to Order EA-12-049, dated September 26, 2014 (ADAMS Accession No. ML14265A107)

Updated Staff Assessment of National SAFER Response Centers established in response to Order EA 12-049, dated September 20, 2018 (ADAMS Accession No. ML18157A014)

Memorandum of Agreement Between the Department of Defense and NRC for Helicopter Support (ML17290B180)

Regulatory Guide 1.226, Rev. 0, "Flexible Mitigation Strategies for Beyond-Design-Basis Events"(ADAMS Accession No. ML19058A012)

Staff Assessment of Nuclear Procurement Issues Corporation (NUPIC) SAFER Commitment to NRC Order EA-12-049 (ADAMS Accession No. ML20015A553)

END

Attachment:

Revision history Issue Date: 10/16/20 6 43006

Attachment 1 - Revision History for IP 43006 Commitment Accession Description of Change Description of Comment Resolution and Tracking Number Training Required Closed Feedback Form Number Issue Date/ and Completion Date Accession Number Change Notice (Pre-Decisional, Non-Public Information)

N/A ML16271A278 This is the initial issuance of an Inspection N/A ML16271A292 09/30/16 Procedure that will be used to verify CN 16-025 licensee's satisfactory implementation of NRC Order EA-12-049, as it pertains to the Phase 3 implementation plan for off-site support during a beyond-design-basis emergency.

N/A ML20283A573 Periodic review. Add guidance from N/A N/A 10/16/20 lessons learned during inspections at both CN 20-051 facilities (ML17117A576- Memphis, ML17012A186-Phoenix) to address alternating tri-annual inspection frequency, nonfunctional/spare (N+1) equipment controls, maintenance communication and evaluations, and load sharing.

Issue Date: 10/16/20 Att1-1 43006