ML19330D027
| ML19330D027 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Dresden, Davis Besse, Palisades, Perry, Fermi, Kewaunee, Point Beach, Byron, Braidwood, Prairie Island, Callaway, Duane Arnold, Clinton, Cook, Quad Cities, Big Rock Point, Zion, LaSalle, 05000000 |
| Issue date: | 10/25/1989 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | CLEVELAND ELECTRIC ILLUMINATING CO., COMMONWEALTH EDISON CO., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), DETROIT EDISON CO., IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT, ILLINOIS POWER CO., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG, NORTHERN STATES POWER CO., TOLEDO EDISON CO., UNION ELECTRIC CO., WISCONSIN ELECTRIC POWER CO., WISCONSIN PUBLIC SERVICE CORP. |
| Shared Package | |
| ML19330D028 | List: |
| References | |
| NUDOCS 8910310243 | |
| Download: ML19330D027 (5) | |
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October 25, 1989 Those on Attached List Gentlemen:
Enclosed is a document which describes the Region III Oversight of Licensee Self-Initiated Configuration Management Programs.
I believe that these licensee programs are very important, since both licensee and NRC inspections under these programs have identified significant safety findings.
I am forwarding the enclosed document to you so that you will be aware of Region III's approach relative to this important subject.
If you have any questions or comments on this approach, I would be pleased to discuss them with you.
Sincerely, OrJginal n?cnod by A. Eart Davra A. Bert Davis Regional Administratoc
Enclosure:
As stated cc w/ enclosure:
E. G. Greenman, RIII H. J. Miller, RIII C. E. Norelius, RIII P
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Multiple ~ Addressees 2
October 25, 1989 i
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Distribution Attached'1etter was sent to the following licensees:
Perry:
50-440';50-44f Braidwood:
50-456'; 50-457 50-454';' 50-45s/;50-24d Byron:
j Dresden:
50-10 50-23 i
50-373;; 50-37#
.LaSalle:
Quad Cities:
50-25(;50-26$
Zion:
50-296; 50-304' Big Rock Point:
Sp-155' Palisades:
50-255 Fermi:
50-34f Clinton:
50-46f D.C. Cook:
50-31515p-316 Duane Arnold:
50-3)I Moaticello:
50-267 -
a Prairie Island:
50-J82';50-308 Davis-Besse:
50-)46 Callaway:
50-483 Point Beach:
50-266';50-30I Kewaunee:
50-305' i
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REGION III OVERSIGHT OF LICENSEE SELF-INITIA1ED I
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CONFIGURATION MANAGEMENT PROGRAMS BY H. J. MILLER T. O. MARTIN, M. P. PHILLIPS, I. S. YIN DIVISION OF REACTOR SAFETY, REGION III l
In 1985 a new NRC inspection approach called a Safety System Functional Inspection (SSFI) was developed by the Office of Inspection and Enforcement.
This inspection was intended to be a comprehensive
- vertical slice" review to evaluate whether a particular safety system had been designed, constructed, maintained, tested, and operated in a manner that would ensure it met its required safety function. These resource intensive inspections, that typically involve 3 weeks of field time for up to 10 inspectors. have proven to be very effective in identifying major design, modification, maintenance, and operational deficiencies that could impact safe plant operation. SSFIs have continued to be performed, on a limited basis, by NRC headquarters and the regional offices.
The depth of review conducted as part of an SSFI inspection in many cases l
yielded findings that exposed major shortcomings in configuration management programs -- configuration management being the process of ensuring that plant systems and components are maintained within their intended design bases.
It was disecvered that in many cases equipment was maintained or modified without meeting original margins of safety often due to missing or inappropriate use of design basis documentation.
SSFIs quickly received national recognition as a valuable diagnostic tool. Given the safety payoff of these inspections and limited NRC inspection resources. licensees were encouraged by NRC to conduct their own SSFI inspections. This encouragement took many forms, including participation in a special American Society for Quality Control (AS00) industry seminar on SSFIs in 1986 to review the process and the experience of licensees that had been throuch an UDC led SSFI. Utilities that had received such inspections reinforced the r W age being sent to the industry at large that i
such inspections were likely to identify weaknesses at most plants and that it was desirable for licensees to find and correct their own weaknesses before they i
became significant problems. The industry through the auspices of the Electric Power P.esearch Institute, developed NSAC-121, " Guidelines for Performing Safety System Functional Inspections", which was issued in November 1988.
j of 1987 With this encouragement and regional management emphasis, by the end, form of nearly all of the nuclear plants in Region III had implemented some self-initiated SSFI and configuration management review. This has involved a significant comitment of engineering oriented resources for most licensees.
In several instances, these programs will take up to 5 years and encompass all safety-related systems as well as selected, nonsafety-related systems.
These programs, which have been developed to suit what each licensee has perceived to be its own needs have included the following elements:
reconstitution of design basis information and documentation; detailed walkdown I
of electrical and mechanical systems to assure as-built conditions match design; and detailed evaluation of selected systems to confirm that they remain functional.
In addition to gaining operator confidence in system design and eliability, the end product of such efforts is a better set of reference
.naterials and tools for design engineers who will continue to modify plants and deal with equipment aging issues, i
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the self-initiative of licensees may reduce so'newhat the need for NRC to conduct SSFI's, the scope and potential safety significance of these efforts l
dictate some form of NRC oversight. The two principal objectives of this
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oversight are: (1) to understand the depth and effectiveness of licensee l
reviews as well as the findings that are being made; and (2) to assess the i
promptness and effectiveness of licensee corrective actions and the accuracy of licensee reports of significant findings. The former is important if NRC l
1s to give appropriate credit to licensees for their efforts and to identify l
where such initiatives might be weak, making NRC inspection arudent. The challenge facing the Region has been to conduct such oversigit without discouraging licensee initiative. To accomplish this, the Region has emphasized direct communication with senior licensee officials regarding NRC's expectations and views on these self-initiatives and how we will treat licensee f
findings. While the kind of costly and intense scrutiny that is a part of these reviews can be painful, we have emphasized the safety and other benefits i
that accrue from competent efforts. For example, licensees have been made aware that selection of candidate sites for NRC led SSFIs would be based partly on whether the facility had a credible self-initiated SSFI and configuration management program. Consistent with changes made to the NRC enforcement policy, Region III licensees have been told that enforcement discretion would se granted whenever possible for licensee identification of violations.
l As a result of the level of licensee activity in this trea, Region III reduced l
the number of SSFIs actively performed by the region and shifted resources
'1 instead to tronitoring performance of licensee programs. This effort includes periodic meetings with licensees including senior management and on-site reviews of self-initiated SSFI reports.
The on-site review has consisted of approximately one to two person-weeks of effort devoted to reviewing the licensee's report, conducting staff interviews, and evaluating corrective action taken as a result of the SSFI findings.
In some cases, licensees have been reluctant to release off-site the results of their self-initiated reviews making it necessary to conduct the NRC review of this material at the t
licensee's facility. These reviews have shown that significant safety issues i
are often identified. The region has also found that while licensee, corrective action has been acceptable in most cases it has sometimes been less aggressive l
than warranted. There appears to be a tendency on the part of licensees to treat the findings of an SSFI differently than when NRC performs the inspection even when the findings are just as significant.
On a selecteo basis, the Region expects to assess licensee efforts by actually performing SSFIs on the same systems reviewed by the licensee. Region III has recently completed an SSFI of the High Pressure Core Spray (HPCS) system at one utility to evaluate the utility's own SSFI of the same system. Based on the findings, the Region III team concluded that the utility initiated SSFI had seme limitations in that it did not challenge original design or construction where warranted nor did it adequately verify that all Tech Spec required conditions were being monitored for conformance.
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Currently, most Region III liceasees have active configuration management improvement programs and many conduct system evaluations patterned directly i
after the NRC SSFI model. We have seen sianificant safety mayoff from these efforts. For example, one licensee conducting an SSFI of t1e instrument air system identified a design deficiency that could render both station diesel generators inoptrable. Another licensee identified a potential for complete loss of component cooling wter during a postulated high energy line break.
These and other findings h r.*sulted in the submission of many voluntary LERs. However, sone of t,,t. atiSems and limitations that the NRC has identified with these prop ms, particularly with respect to corrective action, have strengthened the Region's perception of the need for continued oversight.
Ve have also found that our continued interest and involvement has helped senior licensee managers see the benefits of these often costly, difficult i
programs.
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