NRC CM Pilot Inspections Methodology and Results

1. May 19, 2012 Cleveland 2005 1 NRC CM Pilot InspectionsMethodology and Results John Reddington /Bill Kline FENOC

2. May 19, 2012 2 Cleveland 2005 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 -- 8/9-9/3/2004 - Region I V. C. Summer -- 10/4-11/19/2004 - Region II Diablo Canyon -- 1/3-2/15/2005 - Region IV Kewaunee -- 1/24-2/18/2005 - Region III

3. May 19, 2012 3 Cleveland 2005 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

4. May 19, 2012 4 Cleveland 2005 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

5. May 19, 2012 5 Cleveland 2005 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.

6. May 19, 2012 6 Cleveland 2005 Pilot Scope Selection

7. May 19, 2012 7 Cleveland 2005 Review - Design Configuration Calculation Adequacy Design Assumptions Analysis Boundary Conditions Models Interfaces w/ non-safety related systems Modifications Design elements verified through testing

8. May 19, 2012 8 Cleveland 2005 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

9. May 19, 2012 9 Cleveland 2005 Review - Operator Actions Component operation not restricted by temporary configurations Procedure adequacy Operator training Action Initiators (alarms, etc.) functional Ingress/egress paths maintained

10. May 19, 2012 10 Cleveland 2005 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

11. May 19, 2012 11 Cleveland 2005 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)

12. May 19, 2012 12 Cleveland 2005 CM Model Functions

13. May 19, 2012 13 Cleveland 2005 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

14. May 19, 2012 14 Cleveland 2005 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

15. May 19, 2012 15 Cleveland 2005 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 - 50.59 adverse effects Failure to demonstrate load sequencing requirements

16. May 19, 2012 16 Cleveland 2005 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)

17. May 19, 2012 17 Cleveland 2005 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

18. May 19, 2012 18 Cleveland 2005 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

19. May 19, 2012 Cleveland 2005 19 Questions/Discussion