1 CDBI Inspection Insights for 2008 Kelly Clayton Senior Reactor Inspector Engineering Branch 1 Region IV

2 Preview Clarity on “Margin” concept, other issues with this inspection Selection of items and Types of Margin Use of Operator Actions and Plant-Ref. Simulator Use of Operating Experience Plant Modification Impacts PIR impacts Summary

3 Clarity on “Margin” concept Example: A pump purchased with 5000 gpm capacity to met an initial design requirement of 4000 gpm would have a 1000 gpm margin. However, after plant changes, the actual requirement may be 4200 gpm. IST results show a decrease in pump performance to 4100 gpm leaving a negative margin. Inspectors seeing arguments that there is still a 200 gpm margin from original design.

4 Other “issues” with this inspection Licensee representatives not always effective at ensuring proper personnel are available to address inspector issues. Numerous occasions in locating/identifying design basis for systems and components. Sometimes weeks from time of initial requests without results.

5 Selection of items Follow IP , which specifies to: “Select risk-significant and low design margin samples in the following categories: components, operator actions and operating experience. Usually pick approximately 20/5/5 for final selections (components/OA/OE).

6 Types of Margin Analytical margin Operations margin Maintenance margin Complexity margin

7 Use of Operator Actions and Plant-Ref. Simulator Screen risk-significant Operator manual actions Operations Engineer on the CDBI team will develop the “high-risk” scenarios (with licensee training staff) to run on one or two crews (selected randomly) to verify manual actions selected are achievable. Use HRA worksheets Verify other actions thru plant walk-downs using plant procedures Operator work-arounds

8 Use of Operating Experience Includes items selected and generic issues Evaluate how licensee dispositions the OE Acquire objective evidence that OE issue is resolved (beyond a written evaluation)

9 Plant Modification Impacts Verify that design bases, licensing bases, and performance capability of components have not been degraded through modifications (IP , section a) Verify proper considerations for screening of issues and various conclusions are correct. Verify post-mod test operability

10 PIR impacts Review significant corrective action documents for the last four years, including degraded/deficient conditions Review adequacy of technical evaluation, corrective actions, operability determinations Follow IP for additional guidance

11 Summary To have a successful CDB Inspection: 1. Review the IP and plan accordingly 2. Have a strong design margin program 3. Have a strong Corrective Action program 4. Review OE and implement as necessary