ML20195H068
| ML20195H068 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/1998 |
| From: | Spessard R NRC (Affiliation Not Assigned) |
| To: | Grobe J, Mallet B, Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9811230243 | |
| Download: ML20195H068 (6) | |
Text
p % UNITED STATES -
j NUCLEAR REGULATORY COMMISSION n WASHINGTON, O,C. 2066H001
% ~ ~ A u tu si a u l
- g g [N: h, m8 MEMORANDUM TO: pl y gsJgWiggsp,gcqqtor tvision of Reactor Safety, RI Bruce S. Mallet, Director Division of Reactor Safety, Ril John A. Grobe, Director Division of Reactor Sa' 'y, Rlli Arthur T. Howell, Director Division of Reactor Safety, RIV Kenneth A. Raglin, Director Technical Training Division Office for Analysis and Evaluation of Operational Data FROM:
gj R. Lee Spessard, Director h Division of Reactor Controls (
and Human Factors "
Office of Nuclear Reactor Regulation
SUBJECT:
NRC MAINTENANCE RULE WORKSHOP
SUMMARY
SEPTEMBER 16-17,1998 The subject workshop, an output from DRCH's operating plan, was hosted by the Quality Assurance, Vendor inspection, and Maintenance Branch (HQMB), at NRC headquarters, Rockville, Maryland. NRC staff members from all four regions and headquarters representatives from organizations associated with and responsible for the maintenance rule (MR), enforcement, technical training and probabilistic safety assessments were in attendance for discussions on certain issues and items of common interest to ensure continued consistency between inspections and enforcement actions. MR lessons learned and significant issues were I highlighted during this MR workshop. These discussions are part of the feedback process that enables HOMB to provide the programmatic oversight of the maintenance rule implementation. [
Significant MR issues that were discussed included:
Evolving enforcement policy on NRC violations in general and 10 CFR 50.6o violations in particular.
Status of rule changes to 10 CFR 50.65(a)(3) and (a)(4).
[ Review of methods used for inspecting shutdown plants using 10 CFR 50.65(a)(1).
Discussion of milestones reached in the MR training turnover to TTD and the purposes and objectives to be used in future MR training.
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Multiple Addressees 2 Discussion of lessons learned from NRC Maintenance Rule Baseline Inspections (MRBI), MRBI Followup inspections and closure of Followup items, conduct of training and tentative schedules for proposed Maintenance Rule Core inspections, inspection and PRA resources, and recent industry initiatives.
Additional topics of discussion included the positive experiences with the NRC MR Web page, changes to inspection procedures, closeout of MRBI After Action Reports, frequency and timeliness of the MR-required (a)(3) periodic evaluation and the staff position on counting SSCs in the (a)(1) category, concluding with comments on measuring the efficacy of the MR.
The agenda for the September 16-17,1998, NRC MR Workshop is identified as Attachment I i and the list of attendees is included in Attachment II. The workshop commenced with a request l for regional support of the proposed Maintenance Rule Core Inspections; it included sessions on numerous technical areas and inspection methodologies for decommissioning status facilities as I well as operating plants. It was a very productive workshop during which very candid and open dialogue on lessons learned during the overall MR program were emphasized. These types of interactions have helped ensure consistency ofinspections throughout each of the regions and enabled us to continue our work toward a standard approach for inspections for future risk-informed, performance-based regulations. '
1 During the workshop several items were discussed that will be addressed by the upcoming revision to Regulatory Guide 1.160. Among them were the revised supplemental PRA guidance and supplemental inspection guidance, as was a revision of the definition for unavailability.
Clarification of (a)(3), periodic evaluation, is also under consideration for commentary in the revised regulatory guide. '
The workshop presentation on Decommissioning Status Plants pointed out that while the rule applies to those plants as well as the operating plants, the scope of the SSCs under the rule is reduced and could continue to reduce as spent fuel radioactivity decay heat decreases over time. It was noted that a final OGC interpretation on rule applicability to the Decommissioning Status Plants will be forthcoming and that the OGC draft position supports applicability of the entire rule to those plants. Regional training for this category of plant has been incorporated into the training program as has Maintenance Rule Core Inspection training for site resident inspectors.
Our appreciation is conveyed to you and your staff for your support and efforts during this and previous NRC MR Workshops. As a demonstration of our appreciation, we awarded certificates of appreciatior, a those who participated in the MRBis during the two year period from July 15,1996, through July 10,1998. The next MR workshop is tentatively scheduled for May 1999 subsequent to the issuance of (a)(4) of the rule.
Attachments: As stated cc w.attchs: S. J. Collins F. J. Miraglia B. Sheron G. Holahan F. Gillespie R. Zimmerman B. Boger G. Tracy (OEDO) J. Lieberman (OE)
J. Goldberg (OGC) B. Prato (PDLR) C. Grimes (PDLR)
L. Miller (TTD) R. Borchardt
c u
l Attachment l l
Final Update: September 15,1998 2:00pm C:\worksep2.dft NRC Maintenance Rule \/forkshop Agenda September 16-17,1998 h em f >O Location: T-10A1
+,
1 Wednesday, September 16,1998: l 1:00 Session 1 Onening Sess]DD Welcome
. Speaker: Rich Correia l J
l
Introduction:
Request for Regional Support of Maintenance Rule Core Inspections l
. Speaker: Lee Spessard
)
Industry Perspectives and Statements on NRC and the MR: Favorable Reviews for MR
. Speaker: Suzie Black l
1.30 session 2 Mainjossion! Part 1 - The Realons Panel Discussion on NRC Baseline Inspection Results and NRC Lessons Leamed NOTE: The following are the lessons leamed selected by each region for discussion. The selection has been based on the greatest contribution to lessons learned and experience gained from the MRBis. Approximately 10 minutes per speaker was allotted for planning purposes.
Region I: Theme - Enforcement Threshold and Maintenance Rule Performance
. Calvert Cliffs - Reliability Index and Enforcement (R. Conte or designate)
Pilgrim, IP-2 SusquehannafMRBI Late Bloomers" and Enforcement (R. Conte or designate)
. Limerick: Plant Decisions and Compliance (R. Conte or designate)
Region II:
. TS Surveillance and Unavailability (B. Crowley)
Threshold for Programmatic Violations in Era of Performance-Based inspections (P. Fredrickson)
. Status of Brown's Ferry Unit i MR Complianm (P. Fredrickson)
Region Ill:
. Shutdown Plant inspections (M. Farber)
. Followup inspections (M. Farber)
. Program vs. Product . . the disconnect between the written word and implementation (M. Farber)
Region IV:
. Solid State Protection System (C. Johnson)
. Controversial Structures, Systems and Components (C. Johnson)
. Coordination and Support crom the Program Office (C. Johnson)
. Additional Lessons Leamed
~3:00 Break i
e,
~ ,
3:15.caantan 3 Main nession: Part11 Headauarters Changes to the MR and Training:
(a)(3) and (a)(4)
(Scott, NRR)
. Training for (a)(4)
(Scott, NRR)
. Tumover of Training to TTD (Ford, NRR/ Miller,TTD)
Schedules:
. MRFU inspections (Wilcox, NRR)
Closure of FUls (Wilcox, NRR) i e Onsite training of residents (Correia, NRR)
Training for Maintenance Rule Core inspections (MRCl), IP62707 (Correia, NRR) 4:30 Wednesday Wran unnalCinsa Speaker Rich Correia e
2
4 . . -
l l
Thursday September 17,1998:
8.00 s===In= 4 - Around tha atR World b
)Q
. PRA Funding and Use of SRAs (Pete Wilson, et al)
(,
V 4 g .,
't -
. Re nt Industry initiadves # -
l (Latta. NRR) c /
Decornmissioned Status Plants (DSPs) and the Maintenance Rule: An Overview (Ford. NRR)
Experiences with arnended (a)(1);"The Demmmissioning Status Plants
- Big Rock Point, Lacrosse, Zion (Region til representative; SSM: Ford) .
~QM Break
. Enforcement issues:
(Mark Satorious or other OE representative)
. Experience with MR Web Page (Donnie Ashley, NRR)
. Changes to inspection Procedures (Pete Balmain, NRR)
- Closecut of After Action Reports (Frank Talbot, NRR) i Frequency and Timeliness for (a)(3) Periodic Evaluation (Scott, NRR) l
. - Policy on Counting SSCs in (a)(1)- don't (Scott, NRR) l
. MR Efficacy (Black, Correia) jJLQasino Remarks and Adjourn Speaker Rich Correia l
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ATTACHMENT 11
' ATTENDEES OF THE NRC MR WORKSHOP (JANUARY 21-22,1998) .
l- RI: Rich Conte, Herb Williams-L Rll: Paul Fredrickson, Billy Crowley l- ^
, Rlil: Marty Farber l
l RIV: Dale Powers, Claude Johnson NRR/DRCH: Lee Spessarc t
- NRR/DRCH/HOMB: Donnie Ashley, Pete Balmaln, Suzie Black, Rich Correia, Ed Ford,
! Bob Latta, Wayne Scott, Frank Talbot, J.D. Wilcox, Jr,
' OE: Mark Satorius j '. NRR/DSSA/SPSB: Pete Wilson
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l TTD: Lee Miller -
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