ML22262A290
| ML22262A290 | |
| Person / Time | |
|---|---|
| Issue date: | 10/13/2022 |
| From: | Douglas Bollock NRC/NRR/DRO/IRIB |
| To: | |
| Douglas Bollock, NRR/DRO/IRIB, 415-6609 | |
| References | |
| Download: ML22262A290 (21) | |
Text
Inspection Procedure 71111.21N.03 Commercial Grade Dedication Inspection Public Workshop Douglas Bollock U.S. Nuclear Regulatory Commission October 13, 2022
CGD Public Meeting Agenda
- Why we are Inspecting Commercial Grade Dedication (CGD)
- CGD Inspection Procedure Requirements and Guidance
- Lessons Learned from Previous Inspections
- Run through inspection scenarios
- Industry comments/Public Comments
- Question and Answer Period 2
Why Are We Inspecting CGD?
- Relatively few efforts in current baseline inspection, on verifying implementation of verifying Commercial Grade Items (CGI)s meet their design requirements
- Operating experience indicates issues exist regarding CGD performance 3
Why Are We Inspecting CGD? (continued)
- CGD is important ensure new components not manufactured at App B facilities can meet their safety function.
- Less App B vendor facilities, more CGD occurring over the years.
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CGD Procedure and Guidance 5
IP 71111.21N.03 Objective
- IP 71111.21.03 (June 28, 2022), Commercial Grade Dedication, specifies that the objectives are:
To review the implementation of the licensees process for dedicating commercial-grade items (CGIs), as required in applicable portions of Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 (Appendix B) to ensure reasonable assurance is provided that CGIs will perform their intended safety function.
To review implementation of the licensees procurement process for safety-related components as required in Appendix B or 10 CFR 50.69.
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General Guidance Section 02.01 Sample Selection
- The Inspectors will request the licensee to make available:
- Design-basis capability information including function, safety significance, procurement documentation for Commercial Grade Items(CGI)
- See Appendix B to the CGD inspection procedure
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General Guidance Section 02.01 Sample Selection The inspectors will consider the following for selection of a CGD sample for detailed inspection review:
- System Risk
- CGIs with high incidence of corrective maintenance and/or poor performance
- CGIs with questionable assumptions in critical characteristics
- Operational Experience (industry, NRC, site specific) 8
Pre-Inspection Activities
- Discuss inspection with licensee staff and obtain information needed to perform inspection.
- Bagman trip to site, and/or offsite dedication facility.
- Coordinate inspection logistics (site access, badging, inspection team space) with licensee 9
Inspection Process Flow Three months before the inspection begins, the licensee receives information request One month before the inspection, the team leader visits the site/dedication facility to coordinate the inspection On-site activities begin, CGIs inspected. Estimated direct inspection effort is two weeks on site, one week office review Exit meeting held, preliminary observations and findings presented Issues reviewed by regional management and finding review panel Report issuance-estimated 45 days after exit meeting 10
EQ/POV Inspection Lessons Learned 11
EQ Inspection Takeaways
- Included background guidance and regulatory basis and regulatory guidance in the inspection procedure
- Ensured inspectors were properly interpreting each nuclear power units unique licensing basis
- Ensured consistent communication between inspectors and NRR technical/program office
- Modified the minor/more-than-minor screening examples contained in NRC guidance 12
POV Inspection Enhancements
- Identified technical and programmatic points-of-contact within the NRC
- Enhanced training for inspectors was developed (technical/process and inspection implementation focused)
- Tabletop dry runs performed using minor/more-than-minor examples
- Findings review panel established proactively 13
- Q: What has been communicated to stakeholders?
- A: ROP monthly public meetings since September 2021
- CGD inspections replacing POV inspections beginning in January 2023
- NRC incorporated lessons learned from EQ and POV inspection implementation 14
- Q: What is publicly available in regards to CGD material?
- A: Publicly available now:
- Inspection Procedure IP71111.21N.03 (ML22075A251)
- CGD implementation training (ML22249A359) 15
- Q: What are the NRC resources uses per CGD inspection?
- A: 3 NRC inspectors, 2 weeks onsite
- 210 hrs 16
- Q: Will each operating reactor site receive a CGD Inspection?
- A: Yes. Even if sites share a corporate dedication facilities.
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- Q: Will there be other public workshops?
- A: Staff is open to date and location and will consider any input received.
- This is the second planned public workshops for fall 2022.
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Scenario Discussion
- Discuss 2 scenarios of CGD issues and how the NRC staff would assess them.
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Q & A Session 20
For additional information, contact Doug Bollock Douglas.Bollock@nrc.gov 21