Current Configuration Management Inspection Issues “Continued Vigilance” Presented by: Chuck Casto Director, Division of Reactor Safety 8th Configuration Management Benchmarking Conference October 29 – 31, 2001 Raleigh, NC

Inspection Issue Topics Why continued vigilance? History of Design Basis configuration NRC’s focus today NRC’s vigilance Summary

Why Continued Vigilance? Myth: All the big events are in the past Expect the unexpected Expect the expected When all else doesn’t fail, humans may

VIGILANCE “If constant vigilance is the price of liberty, then perpetual unease is the price of safety” -J.P. Reason

History of Design Basis Configuration Davis Besse incident NUMARC 90-12 NUREG 1327 Assessment of DBR 1990 FSAR update Rule GL 91-18 1992 Commission Policy Statement 1992 Regulatory Review Group

History of Design Basis Configuration (cont’d) 1993/1995 National Performance Review August 1995 plant events July 1996 Commission Policy on Voluntary Industry Initiatives Risk Informed Regulation Special Treatment

Source: NUREG 1275, Vol 14

Source: NUREG 1275, Vol 14

Source: NUREG 1275, Vol 14

NRC’s Inspection Focus Today Reactor Oversight Program Engineering Inspections Maintenance Inspections Maintenance Rule

ROP Engineering - Inspection Findings: Risk significant issues Awareness of Design Basis Modifications (including temp mods) and material review

Engineering LERs “Awareness or Attention to Requirements” Modifications, design, test/maintenance Others, e.g., work package quality, non-conservative decision-making, untimely actions

Maintenance Inspections Findings: Inadequate decision-making Inadequate evaluation of test Conducting 2 evolutions resulted in SI Failure to follow MWO for taking system out of service Use of flammable paint thinner not evaluated

Maintenance LERs Inadequate work practice Awareness/Attention to detail Inadequate self checking Independent verification Inadequate supervision

NRC’s Vigilance Our focus: Is the plant configured safely now Maintenance Rule: It’s here to help Configure Assess Manage risk NRC inspection Emergent conditions PMT’s

NRC’s Vigilance (cont’d) The Maintenance Rule What does the NRC focus on with (a)(4)? Is there a configuration change? Was it assessed? Does assessment match the configuration? Were key safety functions maintained? Normal work controls/risk management actions?

NRC’s Vigilance (cont’d) The Maintenance Rule Risk issues associated with the MR Adequate evaluation of emergent conditions Last minute schedule changes Configurations not analyzed Documenting “availability” Crediting manual actions Logging burden

NRC’s Vigilance (cont’d) Maintenance Rule Scoping Accident mitigation functions not included Turbine runback circuit not included RHR room sump level switches not included

NRC’s Vigilance (cont’d) Maintenance Rule Implementation Breaker not placed in A(1) Failure to classify functional failure of SG PORV CREV not placed in A(1) Drywell pressure switch not classified Failure to set goals for backup Nitrogen system

NRC’s Vigilance (cont’d) Maintenance Rule Assessment Test of EDG concurrent with HPCI not assessed Maintenance made EDG inop, not assessed Planned RPS troubleshooting and AFW test assessment tool input did not represent AFW as unavailable

CONTINUED VIGILANCE “Getting the job done is not success. Getting the job done with the proper behavior is.” -Unknown

Continued Vigilance Summary Big events can still happen Humans will be involved Maintenance Rule is here to help NRC’s inspection focus is on today’s configuration