1. NRC CM Pilot Inspections Methodology and Results
John Reddington /Bill Kline
FENOC
September 19, 2018
Cleveland 2005

2. What Are We Talking About?
NRC Margin Management Pilot Inspections
NRC Temporary Instruction (TI) 2515/158
Functional Review of Low Margin/Risk Significant Components and Human Actions
Four Pilot Inspections Completed
Vermont Yankee -- 8/9-9/3/ Region I
V. C. Summer -- 10/4-11/19/ Region II
Diablo Canyon -- 1/3-2/15/ Region IV
Kewaunee -- 1/24-2/18/ Region III
September 19, 2018
Cleveland 2005

3. NRC Pilot Objectives Reactor Oversight Process (ROP)
Possible replacement methodology for SSFI
SSFI findings often very low safety significance
Extent of conditions were therefore not investigated
Focus design and engineering inspection effort
Areas with high safety significance
Areas most susceptible to design errors
Assess results of pilot inspections
Determine whether changes to ROP are warranted
Improve inspection effectiveness in design/engineering area
September 19, 2018
Cleveland 2005

4. Pilot Methodology Focus on Risk and Margin
Components w/ high PRA worth and low margin
Include non-safety related system components
Review key operator actions credited in PRA
Investigate design and operating margins
Impact of recent plant modifications
Extended power uprate challenges (where applicable)
Effect of Operating Experience (OE)
Look at integrated effects from multiple areas
September 19, 2018
Cleveland 2005

5. Pilot vs. SSFI Differences
Pilot Inspection Activities
Not limited to one or two plant systems
Significant effort focused on relevant OE
Sample not limited to mitigating system components
Extent -of-condition reviews for deficiencies
Inspection report includes integrated assessment of performance weaknesses
More resource intensive - approx. 700 Insp. Hrs.
September 19, 2018
Cleveland 2005

6. Pilot Scope Selection
September 19, 2018
Cleveland 2005

7. Review - Design Configuration
Calculation Adequacy
Design Assumptions
Analysis Boundary Conditions
Models
Interfaces w/ non-safety related systems
Modifications
Design elements verified through testing
September 19, 2018
Cleveland 2005

8. Review - Operational Configuration
Physical configuration matches
Including alignments of components
Procedures direct proper operation
Surveillance testing adequate
Use of OE to address vulnerabilities
Degraded conditions addressed
Effective maintenance
September 19, 2018
Cleveland 2005

9. Review - Operator Actions
Component operation not restricted by temporary configurations
Procedure adequacy
Operator training
Action Initiators (alarms, etc.) functional
Ingress/egress paths maintained
September 19, 2018
Cleveland 2005

10. Pilot Inspection Findings
28 “GREEN” Findings across four sites
24 represent Non-Cited Violations (NCVs)
All categorized very low safety significance
26 associated w/ Mitigating Systems Cornerstone
General Categories/Classifications
Inadequate procedures
Inadequate translation of design basis
Untimely corrective action for long-standing issues
September 19, 2018
Cleveland 2005

11. Qualitative Rigor Assessment
Engineering Programs
Calcs, GL 91-18, IST, Configuration Mgmt.
Design Bases Information Retrieval
Control/Translation of Design Assumptions
Maintenance Rule Compliance
Procedural Adequacy
CAP effectiveness in resolving problems
Use of applicable Operating Experience (OE)
September 19, 2018
Cleveland 2005

12. CM Model Functions #1 Protect the Design Basis #2 Modify the Plant #3
Design Basis Configuration #2
Modify the Plant
Engineering Change Control #3
Operate the Plant
Operational Configuration Control #4
Maintain the Plant
Configuration of SSCs not in service #5
Test the Plant
Plant Design Validation
September 19, 2018
Cleveland 2005 25

13. Protect the Design Basis
Pump low pressure trip not adequate to protect from air entrainment
Inadequate relay setpoint tolerances
Did not perform & control battery sizing calcs
Incorrect/non-conservative voltage values
Failure to establish design limit in calc
Inadequate electrical coordination
Had not completed “coping” analysis
September 19, 2018
Cleveland 2005

14. Operate the Plant
Failure to correct long-standing problem w/ automatic operation of a valve
Poor coordination of procedure revisions
Failure to verify minimum flow settings
Lack of procedure to cross-tie trains
Manual action timeframe not achievable
Removal of critical procedural steps
Increase likelihood & duration of SBO
September 19, 2018
Cleveland 2005

15. Test the Plant Lack of proper testing methodology
Procedures did not include acceptance limits
Inadequate procedures for demonstrating operability
Failure to perform adequate review of procedure changes adverse effects
Failure to demonstrate load sequencing requirements
September 19, 2018
Cleveland 2005

16. Programmatic Concerns
Weak control of design products
Electrical system analyses not retrievable or inadequate
Operability evaluations incorrect
Control of calculations
Superceded calcs supplied to inspectors
Resolution of long-standing issues
Retrieval of design basis information (DBI)
September 19, 2018
Cleveland 2005

17. Insights Know your design margins
Basis for what is adequate
Where it is eroded or challenged
Be able to validate assumptions from the past
Control of calculations and revision history
Capitalize on existing employee knowledge
Identify eroded/missing information
Identify links between calcs, drawings, procedures
September 19, 2018
Cleveland 2005

18. Conclusions DBI Integrity Issues
Know where your gaps are
Prioritize resolution based on risk insights
Quantify extent of condition
Identify and resolve programmatic issues
Ensure what we are testing validates what we designed
Integrate knowledge/experience derived from CAP and OE Programs
September 19, 2018
Cleveland 2005

19. Questions/Discussion
September 19, 2018
Cleveland 2005