ML063060618: Difference between revisions
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| issue date = 10/18/2006 | | issue date = 10/18/2006 | ||
| title = Inspection Plan for Palisades 06-009, 10/30/2006 - 12/15/2006 | | title = Inspection Plan for Palisades 06-009, 10/30/2006 - 12/15/2006 | ||
| author name = Lougheed V | | author name = Lougheed V | ||
| author affiliation = NRC/RGN-III | | author affiliation = NRC/RGN-III | ||
| addressee name = | | addressee name = | ||
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This information can be used by the team members in order to divide up the components to be reviewed during the information gathering visit.IV.Team Preparation Activities1.First In-office Preparation WeekThe intent of the first preparation week is to begin narrowing down the components andoperational experience to be reviewed during the inspection. The components identified by the lead and SRA will be divided between the team for further review determined during the information gathering visit. Working with the SRA, the senior inspectors will identify a preliminary list of risk-significant components. Based on previous experience, plant walkdowns, discussions with the resident staff, andreviews of procedures and other documents, inspectors may identify other components that should be reviewed. The team will select 16-19 components for in-depth review during the inspection. These selections should be complete during the information gathering week or at the latest, the second in-office preparation week.Dependent upon other assigned duties, inspectors should review the revised inspectionprocedure to familiarize themselves with the process for selection of components, operator actions, and operating experience; and conducting the inspection. Previous Palisades CDBIInspection Plan-4-CDBI inspection reports, such as Kewaunee (IR 05000305/2005002, ML050950237), | This information can be used by the team members in order to divide up the components to be reviewed during the information gathering visit.IV.Team Preparation Activities1.First In-office Preparation WeekThe intent of the first preparation week is to begin narrowing down the components andoperational experience to be reviewed during the inspection. The components identified by the lead and SRA will be divided between the team for further review determined during the information gathering visit. Working with the SRA, the senior inspectors will identify a preliminary list of risk-significant components. Based on previous experience, plant walkdowns, discussions with the resident staff, andreviews of procedures and other documents, inspectors may identify other components that should be reviewed. The team will select 16-19 components for in-depth review during the inspection. These selections should be complete during the information gathering week or at the latest, the second in-office preparation week.Dependent upon other assigned duties, inspectors should review the revised inspectionprocedure to familiarize themselves with the process for selection of components, operator actions, and operating experience; and conducting the inspection. Previous Palisades CDBIInspection Plan-4-CDBI inspection reports, such as Kewaunee (IR 05000305/2005002, ML050950237), | ||
Perry (IR 05000440/2006009, ML061250451), Duane Arnold (IR 05000331/206007, ML061580073) and Monticello (IR 05000263/2006009, ML062190468) should also be reviewed.Inspectors should begin identifying some operating experience issues, either componentspecific, common cause, or generic issues that they may want to evaluate during the inspection. The operations inspector should begin identifying operator actions to be evaluated during the inspection.Since most preparation activities will be during the next two weeks, inspectors shouldnot spend a significant amount of time this week on preparation activities. | Perry (IR 05000440/2006009, ML061250451), Duane Arnold (IR 05000331/206007, ML061580073) and Monticello (IR 05000263/2006009, ML062190468) should also be reviewed.Inspectors should begin identifying some operating experience issues, either componentspecific, common cause, or generic issues that they may want to evaluate during the inspection. The operations inspector should begin identifying operator actions to be evaluated during the inspection.Since most preparation activities will be during the next two weeks, inspectors shouldnot spend a significant amount of time this week on preparation activities. | ||
Recommendation is under eight hours time charged.2.Onsite Information Gathering Visit Week and Second In-office Preparation Week a.GeneralDuring the information gathering week, the team will commence their review todetermine which components, operator actions, and operating experience will be selected for review. Final selections of items for review will hopefully be completed by the end of this week, but some selection may go into the next week. A matrix will be developed to identify what each inspector is assigned to verify during the inspection. All inspectors and contractors will need to complete the site specific training to obtain unescorted access to the plant. The contractors are authorized to work a total of 40 hours for the information gathering visit and the second in-office preparation week. b.Component SelectionThe sample selection of 15-20 components should be based on risk significance and theleast available margin. The team will initially select more than the minimum required to ensure the minimum number of samples are met. If it is determined that either the team does not have the time or resources to complete all of the selected components, they will not be included as part of the number of completed samples.Margin is defined by the inspection procedure to be a combination of design margin,corrective action insights, maintenance history, design changes, complex design schemes, and maintenance rule insights. Design margin is typically defined as the difference between the actual (or predicted) and required performance of a system, component, or operator action. Low margin can be a function of the original design, caused by design modifications, power uprates, or can be due to degraded material conditions.Inspection samples (safety or non-safety risk significant components) should beidentified at the major component (e.g. pump, motor operated valve, etc.) or procedural step level to assist in inspection planning. Included within the selected sample should be passive components such as sump screens, strainers, piping, cables, etc., whose Palisades CDBIInspection Plan-5-failure could impact system functionality, component design functions that involve a lot of operation and human actions, availability/reliability issues, and components design attributes which are not fully demonstrated through testing. To the extent practical, the sample should include a diverse range of equipment. The team in their selection of samples should attempt to limit the number of systems involved (i.e. select pump, valve, strainer, etc, in same system, if possible), which will limit the amount of preparation time required to understand design and system requirements necessary to conduct a successful inspection.In order to identify low margin areas, the inspectors should review detailed calculationconclusions associated with the identified risk-significant components to identify areas of low margin. For the initial component selection, the inspector need not review the details of the calculation, but rather should identify calculations showing little margin between predicted results and calculation and/or regulatory acceptance criteria. Once this identification is complete, no further review of the calculation is necessary until the component is selected.In addition, the margin review should include corrective action program insights andrepetitive maintenance summaries associated with the identified risk-significant components as poor performing components may be indicative of inadequate design. | Recommendation is under eight hours time charged.2.Onsite Information Gathering Visit Week and Second In-office Preparation Week a.GeneralDuring the information gathering week, the team will commence their review todetermine which components, operator actions, and operating experience will be selected for review. Final selections of items for review will hopefully be completed by the end of this week, but some selection may go into the next week. A matrix will be developed to identify what each inspector is assigned to verify during the inspection. All inspectors and contractors will need to complete the site specific training to obtain unescorted access to the plant. The contractors are authorized to work a total of [[estimated NRC review hours::40 hours]] for the information gathering visit and the second in-office preparation week. b.Component SelectionThe sample selection of 15-20 components should be based on risk significance and theleast available margin. The team will initially select more than the minimum required to ensure the minimum number of samples are met. If it is determined that either the team does not have the time or resources to complete all of the selected components, they will not be included as part of the number of completed samples.Margin is defined by the inspection procedure to be a combination of design margin,corrective action insights, maintenance history, design changes, complex design schemes, and maintenance rule insights. Design margin is typically defined as the difference between the actual (or predicted) and required performance of a system, component, or operator action. Low margin can be a function of the original design, caused by design modifications, power uprates, or can be due to degraded material conditions.Inspection samples (safety or non-safety risk significant components) should beidentified at the major component (e.g. pump, motor operated valve, etc.) or procedural step level to assist in inspection planning. Included within the selected sample should be passive components such as sump screens, strainers, piping, cables, etc., whose Palisades CDBIInspection Plan-5-failure could impact system functionality, component design functions that involve a lot of operation and human actions, availability/reliability issues, and components design attributes which are not fully demonstrated through testing. To the extent practical, the sample should include a diverse range of equipment. The team in their selection of samples should attempt to limit the number of systems involved (i.e. select pump, valve, strainer, etc, in same system, if possible), which will limit the amount of preparation time required to understand design and system requirements necessary to conduct a successful inspection.In order to identify low margin areas, the inspectors should review detailed calculationconclusions associated with the identified risk-significant components to identify areas of low margin. For the initial component selection, the inspector need not review the details of the calculation, but rather should identify calculations showing little margin between predicted results and calculation and/or regulatory acceptance criteria. Once this identification is complete, no further review of the calculation is necessary until the component is selected.In addition, the margin review should include corrective action program insights andrepetitive maintenance summaries associated with the identified risk-significant components as poor performing components may be indicative of inadequate design. | ||
Component review should also include evaluation of the impact of plant modifications or licensing basis changes on available margin. In particular, licensing changes that canreduce safety analysis margins, such as extended power uprates, should be considered.The SRA and resident inspector may be able to provide additional insights that would beuseful in the selection of samples for review. c.Operator Action SelectionThe operations inspector should review the list of risk significant operator actionsprovided by the licensee, and with insights provided by the SRA and the resident inspector, select 3-5 for review during the inspection. A review of operating procedures, and operator task analysis validation studies should be performed to identify critical operator actions with little margin between the time required and the time available to complete an action. Based on the operator actions selected, the inspector should request from the licensee the procedures necessary to conduct the operations. d.Operating Experience SelectionBased on the components selected, inspectors need to review the list of recentoperating experience provided by the licensee and select potential issues that can be reviewed by the team. Other operating experience that the inspectors are aware of that may be relevant to the components selected can also be selected for review. In addition, the team should identify for review one or two generic or common cause issues that are not related to the selected samples (e.g., station blackout, ATWS, GL 89-13, etc.), some of which may relate back to selected components. Some of the operating experience selected should cover initiating events and barrier integrity cornerstones. | Component review should also include evaluation of the impact of plant modifications or licensing basis changes on available margin. In particular, licensing changes that canreduce safety analysis margins, such as extended power uprates, should be considered.The SRA and resident inspector may be able to provide additional insights that would beuseful in the selection of samples for review. c.Operator Action SelectionThe operations inspector should review the list of risk significant operator actionsprovided by the licensee, and with insights provided by the SRA and the resident inspector, select 3-5 for review during the inspection. A review of operating procedures, and operator task analysis validation studies should be performed to identify critical operator actions with little margin between the time required and the time available to complete an action. Based on the operator actions selected, the inspector should request from the licensee the procedures necessary to conduct the operations. d.Operating Experience SelectionBased on the components selected, inspectors need to review the list of recentoperating experience provided by the licensee and select potential issues that can be reviewed by the team. Other operating experience that the inspectors are aware of that may be relevant to the components selected can also be selected for review. In addition, the team should identify for review one or two generic or common cause issues that are not related to the selected samples (e.g., station blackout, ATWS, GL 89-13, etc.), some of which may relate back to selected components. Some of the operating experience selected should cover initiating events and barrier integrity cornerstones. | ||
Palisades CDBIInspection Plan-6-Based on those issues identified, the team will narrow down the samples to 4-6, which will be divided between team members. e.Specific Component AssignmentsOnce it is determined which components, operator actions, and operating experiencesamples will be reviewed, and in consultation with the inspectors, the lead inspector will make specific assignments to individual inspectors. Once the components have been assigned, each inspector should obtain sufficient familiarity with the chosen components, operator actions, and operating experience samples and their associated systems to understand the design and safety requirement for the samples selected and their associated system. The inspectors should also review the flow paths in which the selected mechanical components are located and other components in those flow paths that could potentially affect their function.For each component or inspection area assigned, the inspector needs to develop a list of attributes (see IP 71111.21, section 02.02 for examples) that will bereviewed during the inspection.The inspectors' review should also identify potential areas where the interface betweenengineering and operations procedures can be reviewed by the operations inspector to ensure design requirements are adequately implemented into procedures.The inspectors should review the list of modifications performed on their assignedcomponents to determine whether any are either complex, reduce margin, required for power uprate, etc., to determine whether that modification should be considered for review during the inspection. Although the inspection procedure does not identify a specific number of modifications that need to be reviewed, the team will select approximately five modifications for review. These modifications will be selected by the team from those identified by individual team members. f.TraineesDependent upon other assigned duties, the two trainees may not be participating duringthe preparation weeks. However, in order to maximize their participation during their onsite weeks, they will be assigned some components for review. Therefore, the trainees should make a good faith effort to complete the above "Specific Components Assignment" activities prior to their first week on site. g.Requests for Additional InformationDuring the course of the inspection, team members should request their licenseecontact to provide any specific information and/or documents they want to have readily available when they return to the site. This might include any specific modification packages, calculations, drawings, condition reports, procedures, schedule walkdowns, etc. Licensee computers will be available in the conference room with access to at least condition reports and procedures. | Palisades CDBIInspection Plan-6-Based on those issues identified, the team will narrow down the samples to 4-6, which will be divided between team members. e.Specific Component AssignmentsOnce it is determined which components, operator actions, and operating experiencesamples will be reviewed, and in consultation with the inspectors, the lead inspector will make specific assignments to individual inspectors. Once the components have been assigned, each inspector should obtain sufficient familiarity with the chosen components, operator actions, and operating experience samples and their associated systems to understand the design and safety requirement for the samples selected and their associated system. The inspectors should also review the flow paths in which the selected mechanical components are located and other components in those flow paths that could potentially affect their function.For each component or inspection area assigned, the inspector needs to develop a list of attributes (see IP 71111.21, section 02.02 for examples) that will bereviewed during the inspection.The inspectors' review should also identify potential areas where the interface betweenengineering and operations procedures can be reviewed by the operations inspector to ensure design requirements are adequately implemented into procedures.The inspectors should review the list of modifications performed on their assignedcomponents to determine whether any are either complex, reduce margin, required for power uprate, etc., to determine whether that modification should be considered for review during the inspection. Although the inspection procedure does not identify a specific number of modifications that need to be reviewed, the team will select approximately five modifications for review. These modifications will be selected by the team from those identified by individual team members. f.TraineesDependent upon other assigned duties, the two trainees may not be participating duringthe preparation weeks. However, in order to maximize their participation during their onsite weeks, they will be assigned some components for review. Therefore, the trainees should make a good faith effort to complete the above "Specific Components Assignment" activities prior to their first week on site. g.Requests for Additional InformationDuring the course of the inspection, team members should request their licenseecontact to provide any specific information and/or documents they want to have readily available when they return to the site. This might include any specific modification packages, calculations, drawings, condition reports, procedures, schedule walkdowns, etc. Licensee computers will be available in the conference room with access to at least condition reports and procedures. | ||
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Inspection of some broad-based attributes, such as those described in the inspection procedure, cannot be accomplished by a single inspector working independently of the rest of the team. However, to avoid duplication of work, each individual will be assigned primary responsibility for the attributes being inspected. For example, if a mechanical inspector is assigned to review a motor-operated valve, they may need an electrical inspector to review the degraded voltage calculation. The lead inspector will facilitate these types of reviews and will attempt to assign them at the start of the inspection to equalize the work load between inspectors.Inspectors should plan their workload so that all major areas are preliminarily reviewedprior to the end of the first two onsite weeks of the inspection. The last onsite week should primarily be spent reviewing responses to questions previously asked, resolving issues, and developing any findings. This does not mean that new inspection can't be done; just that doing so leaves little time to develop issues before the end of the inspection. c.MentoringDuring each of the onsite inspection weeks, the team will be accompanied by aninspector in training. Both Juan Ayala (electrical) and Vijay Meghani (structural) are experienced engineers so the focus of their participation will be on inspection techniques. Both trainees will be assigned a limited number of components to inspect. | Inspection of some broad-based attributes, such as those described in the inspection procedure, cannot be accomplished by a single inspector working independently of the rest of the team. However, to avoid duplication of work, each individual will be assigned primary responsibility for the attributes being inspected. For example, if a mechanical inspector is assigned to review a motor-operated valve, they may need an electrical inspector to review the degraded voltage calculation. The lead inspector will facilitate these types of reviews and will attempt to assign them at the start of the inspection to equalize the work load between inspectors.Inspectors should plan their workload so that all major areas are preliminarily reviewedprior to the end of the first two onsite weeks of the inspection. The last onsite week should primarily be spent reviewing responses to questions previously asked, resolving issues, and developing any findings. This does not mean that new inspection can't be done; just that doing so leaves little time to develop issues before the end of the inspection. c.MentoringDuring each of the onsite inspection weeks, the team will be accompanied by aninspector in training. Both Juan Ayala (electrical) and Vijay Meghani (structural) are experienced engineers so the focus of their participation will be on inspection techniques. Both trainees will be assigned a limited number of components to inspect. | ||
Palisades CDBIInspection Plan-8-The team leader is proposing to pair Juan with Carey Brown and George Skinner. Vijay will be paired with Jim Neurauter and Maty Yeminy. Keith Walton is also requested to provide operational mentoring. Finally Patricia Lougheed will provide oversight and will ensure that requested on the job training activities are occurring. d.Inspection Objectives (IP 71111.21, Sections 02.02a, 02.02b, 02.02c, 02.02d and 02.03)For the inspection attributes and inspection activities identified during the preparationweeks, conduct a detailed design review of the selected components' calculations, surveillances, and other associated system documentation to confirm each of the specified attributes for your assigned areas (02.02a). Perform plant walkdowns of selected components to verify as-built condition is consistent to design requirements and inspect component for material condition; and review components corrective action and maintenance history that could affect the components to function (02.02b). The operations inspector should verify performance of risk significant operator actions, along with a walk-through of a sample operations procedures for the selected components (02.02c). Review modifications to ensure design bases, licensing bases, and performance capability have not been degraded (02.02d). Review the licensee's evaluation and disposition of selected operating experience to ensure it has been adequately addressed (02.03). e.Identification and Resolution of ProblemsIdentifying Design Issues - threshold and corrective action programSample of Problems - verify appropriateness of corrective actions f.In-office InspectionInspectors should be aware of the direct inspection hour limits for this inspection. Sincethe inspection is conducted over an 8-week schedule with six inspectors versus the inspection procedure 7-week schedule and five inspectors, the number of hours used during the in-office weeks should be carefully monitored as to not exceed the total hours allotted for this inspection. If significant issues arise that require use of more hours, the lead inspector and branch chief should be informed prior to expending the resources. | Palisades CDBIInspection Plan-8-The team leader is proposing to pair Juan with Carey Brown and George Skinner. Vijay will be paired with Jim Neurauter and Maty Yeminy. Keith Walton is also requested to provide operational mentoring. Finally Patricia Lougheed will provide oversight and will ensure that requested on the job training activities are occurring. d.Inspection Objectives (IP 71111.21, Sections 02.02a, 02.02b, 02.02c, 02.02d and 02.03)For the inspection attributes and inspection activities identified during the preparationweeks, conduct a detailed design review of the selected components' calculations, surveillances, and other associated system documentation to confirm each of the specified attributes for your assigned areas (02.02a). Perform plant walkdowns of selected components to verify as-built condition is consistent to design requirements and inspect component for material condition; and review components corrective action and maintenance history that could affect the components to function (02.02b). The operations inspector should verify performance of risk significant operator actions, along with a walk-through of a sample operations procedures for the selected components (02.02c). Review modifications to ensure design bases, licensing bases, and performance capability have not been degraded (02.02d). Review the licensee's evaluation and disposition of selected operating experience to ensure it has been adequately addressed (02.03). e.Identification and Resolution of ProblemsIdentifying Design Issues - threshold and corrective action programSample of Problems - verify appropriateness of corrective actions f.In-office InspectionInspectors should be aware of the direct inspection hour limits for this inspection. Sincethe inspection is conducted over an 8-week schedule with six inspectors versus the inspection procedure 7-week schedule and five inspectors, the number of hours used during the in-office weeks should be carefully monitored as to not exceed the total hours allotted for this inspection. If significant issues arise that require use of more hours, the lead inspector and branch chief should be informed prior to expending the resources. | ||
Contractors are also not scheduled to work the in office week between the 3 rd and 4 thonsite weeks.VIIssues and FindingsAny issues arising from the inspection are to be preliminarily evaluated using MC 0612,MC 0609 and the Palisadesy specific Phase 2 worksheets prior to more than 4 | Contractors are also not scheduled to work the in office week between the 3 rd and 4 thonsite weeks.VIIssues and FindingsAny issues arising from the inspection are to be preliminarily evaluated using MC 0612,MC 0609 and the Palisadesy specific Phase 2 worksheets prior to more than [[estimated NRC review hours::4 hours]]inspection time being spent on them. The lead inspector will have copies of theworksheets available on site. Doing a preliminary evaluation will ensure that inspection Palisades CDBIInspection Plan-9-effort is focused on risk significant activities and will provide direction for areas needing exploration in order to confirm a finding.Unless an issue can be shown to be greater than minor, additional inspection time (overthe [[estimated NRC review hours::4 hours]]) should not be spent. If an issue appears greater than minor, then sufficient questions need to be asked of the licensee to enable the inspectors to confirm any assumptions and complete the Phase 1 and 2 worksheets. Green findings will be documented in the inspection report. Findings that appear to be "other than green" or apotential operability issue shall be immediately brought to the lead inspector's attentionso that it can be discussed with the licensee and the senior reactor analyst. If a colorcannot be determined by the end of the inspection, the issue will be described as an "unresolved item," pending final determination of the appropriate risk significance. | ||
Enforcement action will be handled in accordance with the Enforcement Policy.VIIDocumentation a.Inspection QuestionsDetailed design inspections normally result in a number of questions being raised. These questions are to be given to the licensee verbally - or, if written, the licensee must copy the information and the inspector must retain the written document. Nowritten information is to be provided to the licensee.Questions should not be "stored up" to the end of the day, but given to the licensee reasonably soon after being generated. As part of the daily interfaces with the licensee, the lead inspector will go over the status of outstanding questions. Therefore, the team members need to keep the lead inspector apprized of any concerns regarding the timeliness or quality of responses to questions.Lack of response to questions will not be accepted as a reason for any delay inproviding an input unless the licensee did not respond in a reasonable time frame (usually 24 hours), the lead inspector has been informed of the delay and has discussed it with the licensee prior to the exit, and the issue is one that has been determined to bepotentially "greater than minor." Any document requests generated on the day of thedebrief or afterwards must be approved by the lead inspector, must pertain to areasalready inspected and must be only for the purpose of finalizing a finding or ensuring anaccurate document list entry. b.Report PreparationThe report will be prepared in accordance with the guidance in MC 0612, MC 0620,Region III model inspection report, and regional procedure 1220. It's recognized thatRP 1220 does not strictly apply; however, it provides the best guidance available for formatting of the report and document lists. Input will primarily consist of a list of the Palisades CDBIInspection Plan-10-documents reviewed and a scope section for each component reviewed, unless afinding meets the guidance for documentation. The team will prepare the report inputsin WordPerfect, following the format of the Perry inspection report, which includes adocument list in a table format. Issues which an inspector considers as meeting the criteria for inclusion in the report shall be discussed with the lead inspector prior to preparing an input. Finding input shall consist of both the detailed write-up for the body of the inspection report and the associated paragraphs for the summary of finding section of the inspection report. Inputs are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the exit.In keeping with the requirements of MC 0620, only those documents which werereviewed as part of meeting an inspection attribute are to be included. The document list does not include procedures reviewed as part of preparation for the inspection. | Enforcement action will be handled in accordance with the Enforcement Policy.VIIDocumentation a.Inspection QuestionsDetailed design inspections normally result in a number of questions being raised. These questions are to be given to the licensee verbally - or, if written, the licensee must copy the information and the inspector must retain the written document. Nowritten information is to be provided to the licensee.Questions should not be "stored up" to the end of the day, but given to the licensee reasonably soon after being generated. As part of the daily interfaces with the licensee, the lead inspector will go over the status of outstanding questions. Therefore, the team members need to keep the lead inspector apprized of any concerns regarding the timeliness or quality of responses to questions.Lack of response to questions will not be accepted as a reason for any delay inproviding an input unless the licensee did not respond in a reasonable time frame (usually [[estimated NRC review hours::24 hours]]), the lead inspector has been informed of the delay and has discussed it with the licensee prior to the exit, and the issue is one that has been determined to bepotentially "greater than minor." Any document requests generated on the day of thedebrief or afterwards must be approved by the lead inspector, must pertain to areasalready inspected and must be only for the purpose of finalizing a finding or ensuring anaccurate document list entry. b.Report PreparationThe report will be prepared in accordance with the guidance in MC 0612, MC 0620,Region III model inspection report, and regional procedure 1220. It's recognized thatRP 1220 does not strictly apply; however, it provides the best guidance available for formatting of the report and document lists. Input will primarily consist of a list of the Palisades CDBIInspection Plan-10-documents reviewed and a scope section for each component reviewed, unless afinding meets the guidance for documentation. The team will prepare the report inputsin WordPerfect, following the format of the Perry inspection report, which includes adocument list in a table format. Issues which an inspector considers as meeting the criteria for inclusion in the report shall be discussed with the lead inspector prior to preparing an input. Finding input shall consist of both the detailed write-up for the body of the inspection report and the associated paragraphs for the summary of finding section of the inspection report. Inputs are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the exit.In keeping with the requirements of MC 0620, only those documents which werereviewed as part of meeting an inspection attribute are to be included. The document list does not include procedures reviewed as part of preparation for the inspection. | ||
Corrective action documents generated as a result of the inspector's questions shall be called out separately from corrective action documents that were in the licensee's system prior to the inspection. It is strongly recommended that inspectors keep a list of documents up-to-date to ensure that no documents are missed.XIIIHRMS Information a.Overall Time ManagementThe baseline inspection hours primarily encompasses only those hours spent startingwith the first on-site inspection week and prior to the exit meeting. Time spent during the two in-office preparation weeks and the information gathering week are to be charged to prep. Baseline inspection hours do not include time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-mail, or keeping track of hours to correctly credit them. However, they do include time spent in team meetings and in preparing for team meetings. Between 10 to 15% of the baseline hours are to be spent in evaluating problem identification and resolution efforts. b.Baseline Inspection ChargesThe hours given for the this procedure is as follows:ProcedureMinimumNominalMaximum71111.21347408470As a result, each inspector should be able to charge approximately between 102 | Corrective action documents generated as a result of the inspector's questions shall be called out separately from corrective action documents that were in the licensee's system prior to the inspection. It is strongly recommended that inspectors keep a list of documents up-to-date to ensure that no documents are missed.XIIIHRMS Information a.Overall Time ManagementThe baseline inspection hours primarily encompasses only those hours spent startingwith the first on-site inspection week and prior to the exit meeting. Time spent during the two in-office preparation weeks and the information gathering week are to be charged to prep. Baseline inspection hours do not include time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-mail, or keeping track of hours to correctly credit them. However, they do include time spent in team meetings and in preparing for team meetings. Between 10 to 15% of the baseline hours are to be spent in evaluating problem identification and resolution efforts. b.Baseline Inspection ChargesThe hours given for the this procedure is as follows:ProcedureMinimumNominalMaximum71111.21347408470As a result, each inspector should be able to charge approximately between 102 and[[estimated NRC review hours::117 hours]] over the 3-week inspection period. Contractors are allotted [[estimated NRC review hours::272 hours]] of direct inspection effort (136 each). c.Preparation Charges Palisades CDBIInspection Plan-11-The lead inspector has estimated that each inspector should charge approximately [[estimated NRC review hours::60 hours]] to BIP for this inspection over the three week preparation period. The information gathering week and the two in-office preparation weeks (completion of selection process). If an inspector is unable to prepare due to other work demands, please discuss this with the lead inspector (who will then work with management to ensure proper inspection preparation occurs.) This should not be a problem as most preparation is performed onsite. During these three weeks, no time should be assigned to inspection. d.Documentation ChargesDuring the inspection, any time spent documenting items which have been reviewed isto be charged to BID. Also the time spent on the exit meeting is to be charged to BID. | ||
If the inspector has no findings, documentation time should be between 6 and 15 hours. | If the inspector has no findings, documentation time should be between 6 and [[estimated NRC review hours::15 hours]]. | ||
Documentation of findings should take about 20 hours, depending on their complexity. | Documentation of findings should take about [[estimated NRC review hours::20 hours]], depending on their complexity. | ||
These hours may be adjusted, dependent upon the number and extent of findings. | These hours may be adjusted, dependent upon the number and extent of findings. | ||
Please note that this does not change the time period over which the input is due: It still will be five working days following the exit. e.Checking E-mail and Other Such ActivitiesFor planning purposes, the lead inspector has assumed that each inspector will spend amaximum of 2 hours each on-site week of the inspection, maximum of 8 hours, checking e-mail, HRMS, or doing other activities not directly related to the inspection. | Please note that this does not change the time period over which the input is due: It still will be five working days following the exit. e.Checking E-mail and Other Such ActivitiesFor planning purposes, the lead inspector has assumed that each inspector will spend amaximum of [[estimated NRC review hours::2 hours]] each on-site week of the inspection, maximum of [[estimated NRC review hours::8 hours]], checking e-mail, HRMS, or doing other activities not directly related to the inspection. | ||
This time, if used, should be charged to general administration. f.Travel ChargesAll travel time is to be charged in HRMS to an IPE code of "AT", including travel duringnon-regular hours (see below). For planning purposes, a total of approximately 24 hours travel is allotted to each inspector (6 per week). This is based on nominal driving travel time to the site. g.OvertimeBased on the number of inspectors and the allowed direct inspection hours, overtime foreach regional inspector should be minimal and normally not exceed 3 hours per onsite week. The overtime is to only be used to meet the inspection requirements or if an issue comes up at the end of the day that requires resolution. Inspectors need to inform the team leader if overtime will be used. Overtime must be claimed in HRMS if used. Any overtime spent traveling (although there shouldn't be any) also must be claimed inHRMS using the overtime code of "CPETV". h.Trainees and Mentoring Palisades CDBIInspection Plan-12-Trainee time should be charged to ZT0007, "Qualification Training". Time spent mentoring, that is above and beyond normal inspection type assistance, should be charged to W90156, "Safety Professional/Entry Level Development and Coordination." | This time, if used, should be charged to general administration. f.Travel ChargesAll travel time is to be charged in HRMS to an IPE code of "AT", including travel duringnon-regular hours (see below). For planning purposes, a total of approximately [[estimated NRC review hours::24 hours]] travel is allotted to each inspector (6 per week). This is based on nominal driving travel time to the site. g.OvertimeBased on the number of inspectors and the allowed direct inspection hours, overtime foreach regional inspector should be minimal and normally not exceed [[estimated NRC review hours::3 hours]] per onsite week. The overtime is to only be used to meet the inspection requirements or if an issue comes up at the end of the day that requires resolution. Inspectors need to inform the team leader if overtime will be used. Overtime must be claimed in HRMS if used. Any overtime spent traveling (although there shouldn't be any) also must be claimed inHRMS using the overtime code of "CPETV". h.Trainees and Mentoring Palisades CDBIInspection Plan-12-Trainee time should be charged to ZT0007, "Qualification Training". Time spent mentoring, that is above and beyond normal inspection type assistance, should be charged to W90156, "Safety Professional/Entry Level Development and Coordination." | ||
This would include explaining inspection techniques, discussing how to assess thesignificance of an issue, or accompanying a trainee on a plant tour purely for the purpose of on-the-job training. Qualified inspectors should use their best judgement when charging to this code. i.In-Office WeekIn order to ensure that the maximum inspection hours are not exceeded, it is likely thatinspectors will be asked to perform other tasks during the in-office weeks. As noted in item j. below, inspectors should keep close track of total inspection hours, if working on the inspection during an in-office week. This does not mean that inspection cannot be done, just that the inspector needs to be aware of the time spent and be able to justify the work product. j.Tracking of TimeBecause of this inspection could come close to the maximum allotted hours, it isimperative that each inspector keep close tabs on their hours and not exceed the number of hours listed in Item b., above. If it appears that the inspection cannot be completed within the time limitations described above, the lead inspector should be notified as soon as possible. The lead inspector will then consult with the branch chief as to available options, which might include reassignment of tasks.IXInterface and Coordination Meetings a.Entrance MeetingThe team will conduct the entrance meeting on Monday, November 13, 2006, tentativelyscheduled for 1:00 p.m (est). Team members are expected to arrive onsite to attend the entrance meeting. b.Licensee DebriefingsDaily debriefings with the licensee will start Wednesday, November 15 th at 8:00 a.m. These daily meetings will normally be between the lead inspector, or her designee, and the licensee, with team member attendance on an as-needed basis. c.Routine InteractionsThroughout the inspection, team members are expected to have routine interactionswith licensee employees. It is expected that these interactions will be professional in Palisades CDBIInspection Plan-13-nature and will normally be conducted without the lead inspector present. Inspectors should keep track of any questions or requests for further information arising from these meetings. d.Team MeetingsTeam meetings during the information gathering week will be held on Tuesday,Wednesday, and Thursday at 3:00 p.m. The intent of these meetings is to discuss the selection of components, operator actions, and operating experience that will be reviewed during the inspection. An additional team meeting may be held, if necessary during the in-office preparation week on November 9, 2006, to finalize selection of components. Team meetings during the onsite inspection weeks will be held starting Tuesday,November 14, at 3:00 p.m. The meetings will last approximately 40 minutes. The intentis to allow each inspector, including the lead inspector, to briefly discuss the day's activities/issues, status of inspection activities, and any administrative or logistics items. An extensive team meeting will be held on Wednesday, December 13, 2006, to discussthe team's findings and determine what issues will be mentioned at the exit. This meeting will probably begin at 2:00 p.m. and will probably run longer than normal team meetings. e.Final De-briefThe final de-brief with the licensee will be held on Thursday, December 14, 2006,around 2:00 p.m. Inspectors should be ready to discuss in some detail the areas they inspected, observations, and any potential violations/findings. f.Exit MeetingThe team will conduct the exit meeting on Friday, December 15, 2006, tentativelyscheduled for 11:30 a.m. Team members are expected to attend the final exit meeting and to be prepared to present any of their findings to the licensee.XLogistics a.TravelAccording to the RIII travel web page, Palisades is approximately 150 miles away. Thelead inspector has allotted approximately 3 hours driving time for both the first and last days of the onsite weeks for Region III inspectors. Additional travel time needed shouldbe discussed with your branch chief. There is no need for Sunday travel. Additionally,the lead inspector requests that everyone use good judgement in all travel Palisades CDBIInspection Plan-14-arrangements. If severe weather conditions arise, it is expected that inspectors will take sensible precautions during traveling. b.HotelsPer diem for Palisades is 63/39/102. There are a number of hotels in South Haven, withadditional hotels in the St. Joseph/Benton Harbor area. Carlson Travel, which should be used by all NRC inspectors, was able to arrange a rate of $59 at the South Haven Holiday Inn Express. When speaking with Carlson (John), remind them that this is a team inspection and that other inspectors are staying in South Haven MI. Contractors should call the hotel and ask to speak to either Jessica or Jenny to get at least the government rate of $63. Let them know you are with the Palisades NRC inspection team. c.Inspection LocationThe inspection team will be located in the main building outside the fence (second floor). d.Badging and DosimetryThe licensee is checking on badging for everyone. An e-mail will be sent out to all teammembers with the Palisades "read and sign" site access information. It is recommended that all team members take this opportunity to refresh their site access. e.Hours of WorkInspectors are expected to generally adhere to their normal working hours. Significant changes should be coordinated with the lead inspector but will be accommodated to the extent possible. However, compressed days off should be changed to a non-onsite week. Inspectors desiring to work overtime on their compressed days off need to individually coordinate this with their branch chief prior to the inspection. f.Work at HomeIt is acceptable to the lead inspector for inspectors to have perform work-at-home forany of the in-between weeks, the documentation week, and for parts of the preparation weeks, dependent upon the hours limitations discussed above. The lead inspector is willing to work with other inspectors to develop specific activities and work products to provide to the branch chief for approval. Please note that work-at-home must be approved by the appropriate branch chief. | This would include explaining inspection techniques, discussing how to assess thesignificance of an issue, or accompanying a trainee on a plant tour purely for the purpose of on-the-job training. Qualified inspectors should use their best judgement when charging to this code. i.In-Office WeekIn order to ensure that the maximum inspection hours are not exceeded, it is likely thatinspectors will be asked to perform other tasks during the in-office weeks. As noted in item j. below, inspectors should keep close track of total inspection hours, if working on the inspection during an in-office week. This does not mean that inspection cannot be done, just that the inspector needs to be aware of the time spent and be able to justify the work product. j.Tracking of TimeBecause of this inspection could come close to the maximum allotted hours, it isimperative that each inspector keep close tabs on their hours and not exceed the number of hours listed in Item b., above. If it appears that the inspection cannot be completed within the time limitations described above, the lead inspector should be notified as soon as possible. The lead inspector will then consult with the branch chief as to available options, which might include reassignment of tasks.IXInterface and Coordination Meetings a.Entrance MeetingThe team will conduct the entrance meeting on Monday, November 13, 2006, tentativelyscheduled for 1:00 p.m (est). Team members are expected to arrive onsite to attend the entrance meeting. b.Licensee DebriefingsDaily debriefings with the licensee will start Wednesday, November 15 th at 8:00 a.m. These daily meetings will normally be between the lead inspector, or her designee, and the licensee, with team member attendance on an as-needed basis. c.Routine InteractionsThroughout the inspection, team members are expected to have routine interactionswith licensee employees. It is expected that these interactions will be professional in Palisades CDBIInspection Plan-13-nature and will normally be conducted without the lead inspector present. Inspectors should keep track of any questions or requests for further information arising from these meetings. d.Team MeetingsTeam meetings during the information gathering week will be held on Tuesday,Wednesday, and Thursday at 3:00 p.m. The intent of these meetings is to discuss the selection of components, operator actions, and operating experience that will be reviewed during the inspection. An additional team meeting may be held, if necessary during the in-office preparation week on November 9, 2006, to finalize selection of components. Team meetings during the onsite inspection weeks will be held starting Tuesday,November 14, at 3:00 p.m. The meetings will last approximately 40 minutes. The intentis to allow each inspector, including the lead inspector, to briefly discuss the day's activities/issues, status of inspection activities, and any administrative or logistics items. An extensive team meeting will be held on Wednesday, December 13, 2006, to discussthe team's findings and determine what issues will be mentioned at the exit. This meeting will probably begin at 2:00 p.m. and will probably run longer than normal team meetings. e.Final De-briefThe final de-brief with the licensee will be held on Thursday, December 14, 2006,around 2:00 p.m. Inspectors should be ready to discuss in some detail the areas they inspected, observations, and any potential violations/findings. f.Exit MeetingThe team will conduct the exit meeting on Friday, December 15, 2006, tentativelyscheduled for 11:30 a.m. Team members are expected to attend the final exit meeting and to be prepared to present any of their findings to the licensee.XLogistics a.TravelAccording to the RIII travel web page, Palisades is approximately 150 miles away. Thelead inspector has allotted approximately [[estimated NRC review hours::3 hours]] driving time for both the first and last days of the onsite weeks for Region III inspectors. Additional travel time needed shouldbe discussed with your branch chief. There is no need for Sunday travel. Additionally,the lead inspector requests that everyone use good judgement in all travel Palisades CDBIInspection Plan-14-arrangements. If severe weather conditions arise, it is expected that inspectors will take sensible precautions during traveling. b.HotelsPer diem for Palisades is 63/39/102. There are a number of hotels in South Haven, withadditional hotels in the St. Joseph/Benton Harbor area. Carlson Travel, which should be used by all NRC inspectors, was able to arrange a rate of $59 at the South Haven Holiday Inn Express. When speaking with Carlson (John), remind them that this is a team inspection and that other inspectors are staying in South Haven MI. Contractors should call the hotel and ask to speak to either Jessica or Jenny to get at least the government rate of $63. Let them know you are with the Palisades NRC inspection team. c.Inspection LocationThe inspection team will be located in the main building outside the fence (second floor). d.Badging and DosimetryThe licensee is checking on badging for everyone. An e-mail will be sent out to all teammembers with the Palisades "read and sign" site access information. It is recommended that all team members take this opportunity to refresh their site access. e.Hours of WorkInspectors are expected to generally adhere to their normal working hours. Significant changes should be coordinated with the lead inspector but will be accommodated to the extent possible. However, compressed days off should be changed to a non-onsite week. Inspectors desiring to work overtime on their compressed days off need to individually coordinate this with their branch chief prior to the inspection. f.Work at HomeIt is acceptable to the lead inspector for inspectors to have perform work-at-home forany of the in-between weeks, the documentation week, and for parts of the preparation weeks, dependent upon the hours limitations discussed above. The lead inspector is willing to work with other inspectors to develop specific activities and work products to provide to the branch chief for approval. Please note that work-at-home must be approved by the appropriate branch chief. | ||
Attachment ADESIGN REVIEW QUESTIONS-15-During the design review, inspectors should consider the following questions:Valves1.Are the permissive interlocks appropriate? | Attachment ADESIGN REVIEW QUESTIONS-15-During the design review, inspectors should consider the following questions:Valves1.Are the permissive interlocks appropriate? | ||
2.Will the valve function at the pressures that will exist during transient/accidentconditions?3.Will the control and indication power supply be adequate for system function? | 2.Will the valve function at the pressures that will exist during transient/accidentconditions?3.Will the control and indication power supply be adequate for system function? | ||
Revision as of 09:23, 13 July 2019
| ML063060618 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/18/2006 |
| From: | Lougheed V NRC/RGN-III |
| To: | |
| References | |
| IR-06-009 | |
| Download: ML063060618 (16) | |
Text
COMPONENT DESIGN BASES INSPECTION (CDBI)BASELINE INSPECTION PLANPalisades Nuclear PlantINSPECTION REPORT NUMBER 05000255/2006009(DRS)Inspection ObjectivesThis inspection fulfills the baseline inspection program requirements for biennial InspectionProcedure (IP) 71111.21. The inspection's objective is to verify that design bases have been correctly implemented for the selected risk significant components and that operating procedures and operator actions are consistent with design and licensing bases. This is toensure that selected components are capable of performing their intended safety functions.
This inspection verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for which there are no indicators to measure performance.Inspection Dates:October 30 through December 15, 2006Exit:December 15, 2006Applicable Inspection ProceduresIP 71111.21"Component Design Bases Inspection," dated June 22, 2006IP 71152"Identification and Resolution of Problems" (reference)Prepared By:/RA/10/18/06P. Lougheed, Engineering InspectorDateApproved By:/RA/10/18/06A. M. Stone, Branch Chief, DRSDateReviewed By:/RA/10/19/06C. Lipa, Branch Chief, DRPDate Palisades CDBIInspection Plan-2-INSPECTION PLAN DETAILS I.INSPECTION TEAMP. LougheedSenior Engineering Inspector (lead)(630) 829-9760VPL@nrc.govJ. NeurauterSenior Engineering Inspector(630) 829-9828JEN@nrc.govC. BrownEngineering Inspector(630) 829-9605CEB1@nrc.govK. WaltonOperations Inspector(630) 829-9836RKW@nrc.govJ. Ayala 1NRR Project Manager (Training)(301) 415-4063JXA3@nrc.govV. Meghani 2Engineering Inspector (Training)(630) 829-9751VLM1@nrc.govD. PassehlSenior Reactor Analyst(630) 829-9872DXP@nrc.govG. SkinnerElectrical Contractor (412) 963-9889(cell)georgebsg@cs.comM. YeminyMechanical Contractor (305) 926-120Matyyeminy@hotmail.com 1Juan will be participating the week of November 13 - 17 only 2Vijay will be participating the weeks of November 27 - December 1 and December 11 - 15II.Detailed Inspection ScheduleLead Inspector Preparation:October 16 - 20, 2006Preparation at Region III Offices:October 23 - 27, 2006Information Gathering Visit Onsite:October 30 - November 3, 2006Preparation at Region III Offices:November 6 - 9, 2006 3 Inspection Onsite Weeks:November 13 - 17, 2006November 27 - December 1, 2006 December 11 - 15, 2006In-office Weeks:November 20 - 24, 2006 3December 4 - 8, 2006Exit Meeting:December 15, 2006 3These weeks contain Federal holidays Preparation of Inspection Report
- Inputs Due: December 23, 2006, COB*Draft Completed: January 12, 2007
- Management Review and Approval Completed (target): January 19, 2007 Palisades CDBIInspection Plan-3-Inspection Report Must Be Issued Before January 29, 2007 (45 days from exit)III.Lead Inspector Preparation Activities a.GeneralThe lead inspector will review the licensee material received and work with the SRA tonarrow down the list of risk significant components provided by the licensee. Although the lead inspector and SRA will provide the team with a narrowed down list, this does not mean that other components can not be selected for review. The lead inspector will also complete a detailed inspection plan. b.Information RequestsAs part of the inspection preparation, the lead inspector contacted the licensee,informed them of the scope of the inspection, and requested that the necessary information be provided to the inspection team. The information request letter was sent to the license on September 13, 2006. The requested information was received back from the utility on October 11, 2006. c.Distribution of Collected InformationOn Monday, October 23, 2006, if not prior, the lead inspector will distribute theinspection plan, the information provided by the licensee, as well as information provided by the SRA. The majority of the information should be provided electronically.
This information can be used by the team members in order to divide up the components to be reviewed during the information gathering visit.IV.Team Preparation Activities1.First In-office Preparation WeekThe intent of the first preparation week is to begin narrowing down the components andoperational experience to be reviewed during the inspection. The components identified by the lead and SRA will be divided between the team for further review determined during the information gathering visit. Working with the SRA, the senior inspectors will identify a preliminary list of risk-significant components. Based on previous experience, plant walkdowns, discussions with the resident staff, andreviews of procedures and other documents, inspectors may identify other components that should be reviewed. The team will select 16-19 components for in-depth review during the inspection. These selections should be complete during the information gathering week or at the latest, the second in-office preparation week.Dependent upon other assigned duties, inspectors should review the revised inspectionprocedure to familiarize themselves with the process for selection of components, operator actions, and operating experience; and conducting the inspection. Previous Palisades CDBIInspection Plan-4-CDBI inspection reports, such as Kewaunee (IR 05000305/2005002, ML050950237),
Perry (IR 05000440/2006009, ML061250451), Duane Arnold (IR 05000331/206007, ML061580073) and Monticello (IR 05000263/2006009, ML062190468) should also be reviewed.Inspectors should begin identifying some operating experience issues, either componentspecific, common cause, or generic issues that they may want to evaluate during the inspection. The operations inspector should begin identifying operator actions to be evaluated during the inspection.Since most preparation activities will be during the next two weeks, inspectors shouldnot spend a significant amount of time this week on preparation activities.
Recommendation is under eight hours time charged.2.Onsite Information Gathering Visit Week and Second In-office Preparation Week a.GeneralDuring the information gathering week, the team will commence their review todetermine which components, operator actions, and operating experience will be selected for review. Final selections of items for review will hopefully be completed by the end of this week, but some selection may go into the next week. A matrix will be developed to identify what each inspector is assigned to verify during the inspection. All inspectors and contractors will need to complete the site specific training to obtain unescorted access to the plant. The contractors are authorized to work a total of 40 hours1.667 days <br />0.238 weeks <br />0.0548 months <br /> for the information gathering visit and the second in-office preparation week. b.Component SelectionThe sample selection of 15-20 components should be based on risk significance and theleast available margin. The team will initially select more than the minimum required to ensure the minimum number of samples are met. If it is determined that either the team does not have the time or resources to complete all of the selected components, they will not be included as part of the number of completed samples.Margin is defined by the inspection procedure to be a combination of design margin,corrective action insights, maintenance history, design changes, complex design schemes, and maintenance rule insights. Design margin is typically defined as the difference between the actual (or predicted) and required performance of a system, component, or operator action. Low margin can be a function of the original design, caused by design modifications, power uprates, or can be due to degraded material conditions.Inspection samples (safety or non-safety risk significant components) should beidentified at the major component (e.g. pump, motor operated valve, etc.) or procedural step level to assist in inspection planning. Included within the selected sample should be passive components such as sump screens, strainers, piping, cables, etc., whose Palisades CDBIInspection Plan-5-failure could impact system functionality, component design functions that involve a lot of operation and human actions, availability/reliability issues, and components design attributes which are not fully demonstrated through testing. To the extent practical, the sample should include a diverse range of equipment. The team in their selection of samples should attempt to limit the number of systems involved (i.e. select pump, valve, strainer, etc, in same system, if possible), which will limit the amount of preparation time required to understand design and system requirements necessary to conduct a successful inspection.In order to identify low margin areas, the inspectors should review detailed calculationconclusions associated with the identified risk-significant components to identify areas of low margin. For the initial component selection, the inspector need not review the details of the calculation, but rather should identify calculations showing little margin between predicted results and calculation and/or regulatory acceptance criteria. Once this identification is complete, no further review of the calculation is necessary until the component is selected.In addition, the margin review should include corrective action program insights andrepetitive maintenance summaries associated with the identified risk-significant components as poor performing components may be indicative of inadequate design.
Component review should also include evaluation of the impact of plant modifications or licensing basis changes on available margin. In particular, licensing changes that canreduce safety analysis margins, such as extended power uprates, should be considered.The SRA and resident inspector may be able to provide additional insights that would beuseful in the selection of samples for review. c.Operator Action SelectionThe operations inspector should review the list of risk significant operator actionsprovided by the licensee, and with insights provided by the SRA and the resident inspector, select 3-5 for review during the inspection. A review of operating procedures, and operator task analysis validation studies should be performed to identify critical operator actions with little margin between the time required and the time available to complete an action. Based on the operator actions selected, the inspector should request from the licensee the procedures necessary to conduct the operations. d.Operating Experience SelectionBased on the components selected, inspectors need to review the list of recentoperating experience provided by the licensee and select potential issues that can be reviewed by the team. Other operating experience that the inspectors are aware of that may be relevant to the components selected can also be selected for review. In addition, the team should identify for review one or two generic or common cause issues that are not related to the selected samples (e.g., station blackout, ATWS, GL 89-13, etc.), some of which may relate back to selected components. Some of the operating experience selected should cover initiating events and barrier integrity cornerstones.
Palisades CDBIInspection Plan-6-Based on those issues identified, the team will narrow down the samples to 4-6, which will be divided between team members. e.Specific Component AssignmentsOnce it is determined which components, operator actions, and operating experiencesamples will be reviewed, and in consultation with the inspectors, the lead inspector will make specific assignments to individual inspectors. Once the components have been assigned, each inspector should obtain sufficient familiarity with the chosen components, operator actions, and operating experience samples and their associated systems to understand the design and safety requirement for the samples selected and their associated system. The inspectors should also review the flow paths in which the selected mechanical components are located and other components in those flow paths that could potentially affect their function.For each component or inspection area assigned, the inspector needs to develop a list of attributes (see IP 71111.21, section 02.02 for examples) that will bereviewed during the inspection.The inspectors' review should also identify potential areas where the interface betweenengineering and operations procedures can be reviewed by the operations inspector to ensure design requirements are adequately implemented into procedures.The inspectors should review the list of modifications performed on their assignedcomponents to determine whether any are either complex, reduce margin, required for power uprate, etc., to determine whether that modification should be considered for review during the inspection. Although the inspection procedure does not identify a specific number of modifications that need to be reviewed, the team will select approximately five modifications for review. These modifications will be selected by the team from those identified by individual team members. f.TraineesDependent upon other assigned duties, the two trainees may not be participating duringthe preparation weeks. However, in order to maximize their participation during their onsite weeks, they will be assigned some components for review. Therefore, the trainees should make a good faith effort to complete the above "Specific Components Assignment" activities prior to their first week on site. g.Requests for Additional InformationDuring the course of the inspection, team members should request their licenseecontact to provide any specific information and/or documents they want to have readily available when they return to the site. This might include any specific modification packages, calculations, drawings, condition reports, procedures, schedule walkdowns, etc. Licensee computers will be available in the conference room with access to at least condition reports and procedures.
Palisades CDBIInspection Plan-7-VOnsite Inspection Activities a.Plant WalkdownsThe team will perform a general walkdown of the plant during the information gatheringweek. This will allow inspectors to become familiar with the plant, observe components assigned, and identify other potential areas for inspection. During the inspection weeks, each inspector is expected to conduct a detailed walkdownof their assigned components and their associated systems. The intent of the component/system walkdowns is for the inspectors to obtain basic familiarity with the systems, material condition of equipment, where components are located, etc. in order to accomplish inspection objectives. During the walkdowns, the inspectors are also asked to be aware of general plant material conditions. Any abnormal or questionable conditions should be brought to the lead inspector to discuss with the resident staff and the licensee.The operations inspector is expected to conduct walkdowns with plant operationspersonnel as needed to determine the feasibility of performing required in-plant operator actions. b.InspectionSuccessful completion of the CDBI inspection procedure requires a full understanding ofhow the components and their associated system operates, and is supposed to operate.
Inspection of some broad-based attributes, such as those described in the inspection procedure, cannot be accomplished by a single inspector working independently of the rest of the team. However, to avoid duplication of work, each individual will be assigned primary responsibility for the attributes being inspected. For example, if a mechanical inspector is assigned to review a motor-operated valve, they may need an electrical inspector to review the degraded voltage calculation. The lead inspector will facilitate these types of reviews and will attempt to assign them at the start of the inspection to equalize the work load between inspectors.Inspectors should plan their workload so that all major areas are preliminarily reviewedprior to the end of the first two onsite weeks of the inspection. The last onsite week should primarily be spent reviewing responses to questions previously asked, resolving issues, and developing any findings. This does not mean that new inspection can't be done; just that doing so leaves little time to develop issues before the end of the inspection. c.MentoringDuring each of the onsite inspection weeks, the team will be accompanied by aninspector in training. Both Juan Ayala (electrical) and Vijay Meghani (structural) are experienced engineers so the focus of their participation will be on inspection techniques. Both trainees will be assigned a limited number of components to inspect.
Palisades CDBIInspection Plan-8-The team leader is proposing to pair Juan with Carey Brown and George Skinner. Vijay will be paired with Jim Neurauter and Maty Yeminy. Keith Walton is also requested to provide operational mentoring. Finally Patricia Lougheed will provide oversight and will ensure that requested on the job training activities are occurring. d.Inspection Objectives (IP 71111.21, Sections 02.02a, 02.02b, 02.02c, 02.02d and 02.03)For the inspection attributes and inspection activities identified during the preparationweeks, conduct a detailed design review of the selected components' calculations, surveillances, and other associated system documentation to confirm each of the specified attributes for your assigned areas (02.02a). Perform plant walkdowns of selected components to verify as-built condition is consistent to design requirements and inspect component for material condition; and review components corrective action and maintenance history that could affect the components to function (02.02b). The operations inspector should verify performance of risk significant operator actions, along with a walk-through of a sample operations procedures for the selected components (02.02c). Review modifications to ensure design bases, licensing bases, and performance capability have not been degraded (02.02d). Review the licensee's evaluation and disposition of selected operating experience to ensure it has been adequately addressed (02.03). e.Identification and Resolution of ProblemsIdentifying Design Issues - threshold and corrective action programSample of Problems - verify appropriateness of corrective actions f.In-office InspectionInspectors should be aware of the direct inspection hour limits for this inspection. Sincethe inspection is conducted over an 8-week schedule with six inspectors versus the inspection procedure 7-week schedule and five inspectors, the number of hours used during the in-office weeks should be carefully monitored as to not exceed the total hours allotted for this inspection. If significant issues arise that require use of more hours, the lead inspector and branch chief should be informed prior to expending the resources.
Contractors are also not scheduled to work the in office week between the 3 rd and 4 thonsite weeks.VIIssues and FindingsAny issues arising from the inspection are to be preliminarily evaluated using MC 0612,MC 0609 and the Palisadesy specific Phase 2 worksheets prior to more than 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />inspection time being spent on them. The lead inspector will have copies of theworksheets available on site. Doing a preliminary evaluation will ensure that inspection Palisades CDBIInspection Plan-9-effort is focused on risk significant activities and will provide direction for areas needing exploration in order to confirm a finding.Unless an issue can be shown to be greater than minor, additional inspection time (overthe 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />) should not be spent. If an issue appears greater than minor, then sufficient questions need to be asked of the licensee to enable the inspectors to confirm any assumptions and complete the Phase 1 and 2 worksheets. Green findings will be documented in the inspection report. Findings that appear to be "other than green" or apotential operability issue shall be immediately brought to the lead inspector's attentionso that it can be discussed with the licensee and the senior reactor analyst. If a colorcannot be determined by the end of the inspection, the issue will be described as an "unresolved item," pending final determination of the appropriate risk significance.
Enforcement action will be handled in accordance with the Enforcement Policy.VIIDocumentation a.Inspection QuestionsDetailed design inspections normally result in a number of questions being raised. These questions are to be given to the licensee verbally - or, if written, the licensee must copy the information and the inspector must retain the written document. Nowritten information is to be provided to the licensee.Questions should not be "stored up" to the end of the day, but given to the licensee reasonably soon after being generated. As part of the daily interfaces with the licensee, the lead inspector will go over the status of outstanding questions. Therefore, the team members need to keep the lead inspector apprized of any concerns regarding the timeliness or quality of responses to questions.Lack of response to questions will not be accepted as a reason for any delay inproviding an input unless the licensee did not respond in a reasonable time frame (usually 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />), the lead inspector has been informed of the delay and has discussed it with the licensee prior to the exit, and the issue is one that has been determined to bepotentially "greater than minor." Any document requests generated on the day of thedebrief or afterwards must be approved by the lead inspector, must pertain to areasalready inspected and must be only for the purpose of finalizing a finding or ensuring anaccurate document list entry. b.Report PreparationThe report will be prepared in accordance with the guidance in MC 0612, MC 0620,Region III model inspection report, and regional procedure 1220. It's recognized thatRP 1220 does not strictly apply; however, it provides the best guidance available for formatting of the report and document lists. Input will primarily consist of a list of the Palisades CDBIInspection Plan-10-documents reviewed and a scope section for each component reviewed, unless afinding meets the guidance for documentation. The team will prepare the report inputsin WordPerfect, following the format of the Perry inspection report, which includes adocument list in a table format. Issues which an inspector considers as meeting the criteria for inclusion in the report shall be discussed with the lead inspector prior to preparing an input. Finding input shall consist of both the detailed write-up for the body of the inspection report and the associated paragraphs for the summary of finding section of the inspection report. Inputs are to be e-mailed to the lead inspector within 5 working days (10 calendar days) of the exit.In keeping with the requirements of MC 0620, only those documents which werereviewed as part of meeting an inspection attribute are to be included. The document list does not include procedures reviewed as part of preparation for the inspection.
Corrective action documents generated as a result of the inspector's questions shall be called out separately from corrective action documents that were in the licensee's system prior to the inspection. It is strongly recommended that inspectors keep a list of documents up-to-date to ensure that no documents are missed.XIIIHRMS Information a.Overall Time ManagementThe baseline inspection hours primarily encompasses only those hours spent startingwith the first on-site inspection week and prior to the exit meeting. Time spent during the two in-office preparation weeks and the information gathering week are to be charged to prep. Baseline inspection hours do not include time spent in travel, entrance or exit meetings, major licensee debriefs, checking on e-mail, or keeping track of hours to correctly credit them. However, they do include time spent in team meetings and in preparing for team meetings. Between 10 to 15% of the baseline hours are to be spent in evaluating problem identification and resolution efforts. b.Baseline Inspection ChargesThe hours given for the this procedure is as follows:ProcedureMinimumNominalMaximum71111.21347408470As a result, each inspector should be able to charge approximately between 102 and117 hours4.875 days <br />0.696 weeks <br />0.16 months <br /> over the 3-week inspection period. Contractors are allotted 272 hours11.333 days <br />1.619 weeks <br />0.373 months <br /> of direct inspection effort (136 each). c.Preparation Charges Palisades CDBIInspection Plan-11-The lead inspector has estimated that each inspector should charge approximately 60 hours2.5 days <br />0.357 weeks <br />0.0822 months <br /> to BIP for this inspection over the three week preparation period. The information gathering week and the two in-office preparation weeks (completion of selection process). If an inspector is unable to prepare due to other work demands, please discuss this with the lead inspector (who will then work with management to ensure proper inspection preparation occurs.) This should not be a problem as most preparation is performed onsite. During these three weeks, no time should be assigned to inspection. d.Documentation ChargesDuring the inspection, any time spent documenting items which have been reviewed isto be charged to BID. Also the time spent on the exit meeting is to be charged to BID.
If the inspector has no findings, documentation time should be between 6 and 15 hours0.625 days <br />0.0893 weeks <br />0.0205 months <br />.
Documentation of findings should take about 20 hours0.833 days <br />0.119 weeks <br />0.0274 months <br />, depending on their complexity.
These hours may be adjusted, dependent upon the number and extent of findings.
Please note that this does not change the time period over which the input is due: It still will be five working days following the exit. e.Checking E-mail and Other Such ActivitiesFor planning purposes, the lead inspector has assumed that each inspector will spend amaximum of 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> each on-site week of the inspection, maximum of 8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br />, checking e-mail, HRMS, or doing other activities not directly related to the inspection.
This time, if used, should be charged to general administration. f.Travel ChargesAll travel time is to be charged in HRMS to an IPE code of "AT", including travel duringnon-regular hours (see below). For planning purposes, a total of approximately 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> travel is allotted to each inspector (6 per week). This is based on nominal driving travel time to the site. g.OvertimeBased on the number of inspectors and the allowed direct inspection hours, overtime foreach regional inspector should be minimal and normally not exceed 3 hours0.125 days <br />0.0179 weeks <br />0.00411 months <br /> per onsite week. The overtime is to only be used to meet the inspection requirements or if an issue comes up at the end of the day that requires resolution. Inspectors need to inform the team leader if overtime will be used. Overtime must be claimed in HRMS if used. Any overtime spent traveling (although there shouldn't be any) also must be claimed inHRMS using the overtime code of "CPETV". h.Trainees and Mentoring Palisades CDBIInspection Plan-12-Trainee time should be charged to ZT0007, "Qualification Training". Time spent mentoring, that is above and beyond normal inspection type assistance, should be charged to W90156, "Safety Professional/Entry Level Development and Coordination."
This would include explaining inspection techniques, discussing how to assess thesignificance of an issue, or accompanying a trainee on a plant tour purely for the purpose of on-the-job training. Qualified inspectors should use their best judgement when charging to this code. i.In-Office WeekIn order to ensure that the maximum inspection hours are not exceeded, it is likely thatinspectors will be asked to perform other tasks during the in-office weeks. As noted in item j. below, inspectors should keep close track of total inspection hours, if working on the inspection during an in-office week. This does not mean that inspection cannot be done, just that the inspector needs to be aware of the time spent and be able to justify the work product. j.Tracking of TimeBecause of this inspection could come close to the maximum allotted hours, it isimperative that each inspector keep close tabs on their hours and not exceed the number of hours listed in Item b., above. If it appears that the inspection cannot be completed within the time limitations described above, the lead inspector should be notified as soon as possible. The lead inspector will then consult with the branch chief as to available options, which might include reassignment of tasks.IXInterface and Coordination Meetings a.Entrance MeetingThe team will conduct the entrance meeting on Monday, November 13, 2006, tentativelyscheduled for 1:00 p.m (est). Team members are expected to arrive onsite to attend the entrance meeting. b.Licensee DebriefingsDaily debriefings with the licensee will start Wednesday, November 15 th at 8:00 a.m. These daily meetings will normally be between the lead inspector, or her designee, and the licensee, with team member attendance on an as-needed basis. c.Routine InteractionsThroughout the inspection, team members are expected to have routine interactionswith licensee employees. It is expected that these interactions will be professional in Palisades CDBIInspection Plan-13-nature and will normally be conducted without the lead inspector present. Inspectors should keep track of any questions or requests for further information arising from these meetings. d.Team MeetingsTeam meetings during the information gathering week will be held on Tuesday,Wednesday, and Thursday at 3:00 p.m. The intent of these meetings is to discuss the selection of components, operator actions, and operating experience that will be reviewed during the inspection. An additional team meeting may be held, if necessary during the in-office preparation week on November 9, 2006, to finalize selection of components. Team meetings during the onsite inspection weeks will be held starting Tuesday,November 14, at 3:00 p.m. The meetings will last approximately 40 minutes. The intentis to allow each inspector, including the lead inspector, to briefly discuss the day's activities/issues, status of inspection activities, and any administrative or logistics items. An extensive team meeting will be held on Wednesday, December 13, 2006, to discussthe team's findings and determine what issues will be mentioned at the exit. This meeting will probably begin at 2:00 p.m. and will probably run longer than normal team meetings. e.Final De-briefThe final de-brief with the licensee will be held on Thursday, December 14, 2006,around 2:00 p.m. Inspectors should be ready to discuss in some detail the areas they inspected, observations, and any potential violations/findings. f.Exit MeetingThe team will conduct the exit meeting on Friday, December 15, 2006, tentativelyscheduled for 11:30 a.m. Team members are expected to attend the final exit meeting and to be prepared to present any of their findings to the licensee.XLogistics a.TravelAccording to the RIII travel web page, Palisades is approximately 150 miles away. Thelead inspector has allotted approximately 3 hours0.125 days <br />0.0179 weeks <br />0.00411 months <br /> driving time for both the first and last days of the onsite weeks for Region III inspectors. Additional travel time needed shouldbe discussed with your branch chief. There is no need for Sunday travel. Additionally,the lead inspector requests that everyone use good judgement in all travel Palisades CDBIInspection Plan-14-arrangements. If severe weather conditions arise, it is expected that inspectors will take sensible precautions during traveling. b.HotelsPer diem for Palisades is 63/39/102. There are a number of hotels in South Haven, withadditional hotels in the St. Joseph/Benton Harbor area. Carlson Travel, which should be used by all NRC inspectors, was able to arrange a rate of $59 at the South Haven Holiday Inn Express. When speaking with Carlson (John), remind them that this is a team inspection and that other inspectors are staying in South Haven MI. Contractors should call the hotel and ask to speak to either Jessica or Jenny to get at least the government rate of $63. Let them know you are with the Palisades NRC inspection team. c.Inspection LocationThe inspection team will be located in the main building outside the fence (second floor). d.Badging and DosimetryThe licensee is checking on badging for everyone. An e-mail will be sent out to all teammembers with the Palisades "read and sign" site access information. It is recommended that all team members take this opportunity to refresh their site access. e.Hours of WorkInspectors are expected to generally adhere to their normal working hours. Significant changes should be coordinated with the lead inspector but will be accommodated to the extent possible. However, compressed days off should be changed to a non-onsite week. Inspectors desiring to work overtime on their compressed days off need to individually coordinate this with their branch chief prior to the inspection. f.Work at HomeIt is acceptable to the lead inspector for inspectors to have perform work-at-home forany of the in-between weeks, the documentation week, and for parts of the preparation weeks, dependent upon the hours limitations discussed above. The lead inspector is willing to work with other inspectors to develop specific activities and work products to provide to the branch chief for approval. Please note that work-at-home must be approved by the appropriate branch chief.
Attachment ADESIGN REVIEW QUESTIONS-15-During the design review, inspectors should consider the following questions:Valves1.Are the permissive interlocks appropriate?
2.Will the valve function at the pressures that will exist during transient/accidentconditions?3.Will the control and indication power supply be adequate for system function?
4.Is the control logic consistent with the system functional requirements?
5.What manual actions are required to back up and/or correct a degraded function?
Pumps1.Is the pump capable of supplying required flow at required pressures undertransient/accident conditions?2.Is adequate net positive suction head (NPSH) available under all operating conditions?
3.Is the permissive interlock and control logic appropriate for the system function?
4.Is the pump control adequately designed for automatic operation?
5.When manual actions are required, do the operating procedures appropriately describenecessary operator actions?6.What manual actions are required to back up and /or correct a degraded function?
7.Has the motive power required for the pump during transient/accident conditions beencorrectly estimated and included in the normal and emergency power supplies?8.Do vendor data and specifications support sustaining operations at low flow rates?
9.Is the design and quality of bearing and seal cooling systems acceptable?
Instrumentation1.Are the required plant parameters used as inputs to the initiation and control system?
2.If operator intervention is required in certain scenarios, have appropriate alarms andindications been provided?
Attachment ADESIGN REVIEW QUESTIONS-16-3.Are the range, accuracy, and setpoint of instrumentation adequate?4.Are the specified surveillance and calibrations of such instrumentation acceptable?
Circuit Breakers and Fuses1.Is the breaker control logic adequate to fulfill the functional requirements?
2.Is the short circuit rating in accordance with the short circuit duty?
3.Are the breakers and fuses properly rated for the load current capability?
4.Are breakers and fuses properly rated for DC operation?
Cables1.Are cables rated to handle full load at the environments temperature expected?
2.Are cables properly rated for short circuit capability?
3.Are cables properly rated for voltage requirements for the loads?
Electrical Loads1.Have electrical loads been analyzed to function properly under the expected lowest andhighest voltage conditions?2.Have loads been analyzed for their inrush and full load currents?
3.Have loads been analyzed for their electrical protection requirements?
As-built System1.Are service water flow capacities sufficient with the minimum number of pumps availableunder accident conditions?2.Have modified equipment components falling under the scope of 10 CFR 50.49 beenthoroughly evaluated for environmental equipment qualifications considerations such as temperature, radiation, and humidity?3.Are the modifications to the system consistent with the original design and licensing bases?