Overview of a Training Program Produced by LeBlond & Associates, LLC

1. Overview of a Training Program Produced by LeBlond & Associates, LLC • Thanks for taking the time to view this presentation • It’s about ten minutes long • This presentation will advance automatically • until you see this symbol • which means “click to advance” Click on this when you are ready to proceed

2. Regulatory Treatment of Compensatory Measures Developed and Presented by LeBlond and Associates, LLC

3. Contents of This Presentation(color coded by topic) • What is the intended student population? • How is the course structured? • What is the current delivery schedule?

4. What is the intended student population? • This course is intended for personnel who are currently qualified to perform: • Operability Determinations and • 10 CFR 50.59 Screenings • These individuals use these skills to: • Identify the need for Compensatory Measures in support of interim operation and • Implement the Compensatory Measures • This course is not intended as an introduction to either Operability Determinations or 10 CFR 50.59 Screening • Course could be used as part of an Operability or 10 CFR 50.59 requalification program

5. Overall Course Goal • The course is intended to create the ability to analyze various combinations of: • A Degraded/Non-Condition • A proposed Compensatory Measure (CM) taken in response to the D/NCC • This analysis will allow the students to make two basic decisions • What is the role of the CM in the Operability of the SSC? • Is the SSC Operable without the CM? • Will the CM “Screen in” or “Screen out”? • The course slide introducing the Course Learning Objectives is provided next

6. Major Course Objectives • The student shall define the fundamental concepts associated with: • Corrective Action Process as required by 10 CFR 50, Appendix B, Criterion XVI and industry standards. • The requirements of 10 CFR 50.59 as described in NEI 96-07, Rev.1. for: • The Screening process as applied to physical and procedural alterations • The Evaluation process associated with 10 CFR 50.59 c(2) ii. • The Operability Determination process as described by Generic Letter 91-18. 2. When provided with a technical description of a Degraded or Non-Conforming Condition (D/NCC), and a proposed Compensatory Measure (CM), the student shall define and identify: • Accurate versus inaccurate descriptions of D/NCCs • The effect of D/NCC versus the effect of the proposed CM • The application of the 10 CFR 50.59 process, and NEI 96-07, to the two effects identified in Objective 2.b above • This includes identification of CMs that: • “Screen in” versus “Screen Out” • Require prior NRC approval before implementation • The use of CMs in support of the Operability Determination Process. This includes the use of : • Manual Actions • Maintenance/Surveillance Activities

7. How is this course structured? • The course is one day in length • The course consists of three segments • First segment is an overview of the fundamentals of: • Corrective Action Process • 10 CFR 50.59 Screening • Operability Determination Process • This segment lasts about two hours • Reviews/Establishes the fundamentals that will be relied upon in the rest of the class • Excellent treatment for review and/or requalification • Not intended for initial exposure to these three processes

8. How is this course structured?(Cont.) • Second segment establishes a common method of analyzing situations • A standardized set of questions • A graphic to allow the class to keep track of progress as the examples become more complex • Segment length is less than one hour • Third segment is the analysis of nine examples • Major segment of the course, lasting about five hours • The standardized questioning pattern is used • Examples range from simplistic to complex The next slide is the course’s graphical presentation of the three segments.

9. Format of Course Review the Basics Corrective Action 10 CFR 50.59 Operability Determinations Develop a Model to Analyze Situations Standard Set of Questions Graphical Depiction Practical Application Analyze Nine Examples of Varying Characteristics

10. Selected Course Slides • Segment #1 • Review the fundamentals required for the course • The slides that follow are extracted from the overview of 10 CFR 50.59 • This segment could also be credited as part of 10 CFR 50.59 requalification Click here to view a few selected course slides from Segment #1

11. Definition of “Affects” • As with “Design Function”, proper application of this concept is crucial • “Affects” is written into the regulation • Following presentation will illustrate the meaning of this term as it applies to: • Design function • Method of performing or controlling a design function

12. “Affects” • From NEI 96-07, Section 4.2.1 on page 31 An activity must be “adverse” to “Screen in” “A 10 CFR 50.59 evaluation is required for changes that adversely affect design functions, methods used to perform or control design functions, or evaluations that demonstrate that intended design functions will be accomplished (i.e., “adverse changes”). Changes that have none of these effects, or have positive effects, may be screened out because only adverse changes have the potential to increase the likelihood of malfunctions, increase consequences, create new accidents or otherwise meet the 10 CFR 50.59 evaluation criteria.”

13. “Affects”(cont.) • From NEI 96-07, Section 4.2.1 on page 31 Screening determinations include “indirect effects” “Consistent with historical practice, changes affecting SSCs or functions not described in the UFSAR must be screened for their effects (so-called “indirect effects”) on UFSAR-described design functions. A 10 CFR 50.59 evaluation is required when such changes adversely affect a UFSAR-described design function, …”

14. 10 CFR 50.59 Major Points • Purpose of 10 CFR 50.59 is to determine if prior NRC review and approval is required • Definition of “Design Function” must be understood • Consult definition and use provided aids • Included in the meaning of “Affects” • An activity must be “adverse” to “screen in” • The magnitude of the “adverse effect” does not matter • Screening determinations include “indirect effects” • “Adverse effect” for “method of performing or controlling” means: • “Adverse” in the same manner as for “design functions” • Fundamentally alter (replace) the existing means of performing or controlling design functions These points are emphasized on classroom posters. A similar set of Major Points are developed for Corrective Action and Operability Determinations.

15. Selected Course Slides(Cont.) • Segment #2 • Establish a framework for analyzing combinations of: • Degraded and/or Non-Conforming Conditions • Proposed Compensatory Measures • The framework consists of: • A set of six questions designed to repetitively solicit the correct information from the class • A graphic to illustrate the regulatory treatment of the proposed CM as the examples become more complex • The slide that follows presents the graphic described above Click here to view the graphic developed as part of Segment #2

16. Start with two elements: • D/NCC • Proposed Compensatory Measure • D/NCC descript. • CM purpose • CM effect • Sect 4.4 • Major Pts for: • 10 CFR 50.59 • Corrective Action • Major Pts for: • ODs • 10 CFR 50.59 • Screening • Major Pts for: • 10 CFR 50.59 • Screening • Evaluation • Major Pts for: • 10 CFR 50.59 • Evaluation Temporary Change Involved • Required for Operability • “Screens Out” “Screens in” LAR Required

17. Selected Course Slides(Cont) • Segment #3 • Illustrates course’s learning objectives with nine examples • Utilizes the previously established framework for analyzing combinations of: • Degraded and/or Non-Conforming Conditions • Proposed Compensatory Measures • Examples are heavily based upon industry experience • Examples begin as simplistic and end with complicated industry events • The graphic on the next slide illustrates how the nine examples progress from relatively simple to complex • The slide that follows presents the graphic with the nine examples superimposed Click here to overview the nine examples graphic illustrated as part of Segment #3

18. Start with two elements: • D/NCC • Proposed Compensatory Measure • D/NCC descript. • CM purpose • CM effect • Sect 4.4 • Major Pts for: • 10 CFR 50.59 • Corrective Action • Major Pts for: • ODs • 10 CFR 50.59 • Screening • Major Pts for: • 10 CFR 50.59 • Screening • Evaluation • Major Pts for: • 10 CFR 50.59 • Evaluation #1 Temporary Change Involved • Required for Operability • “Screens Out” #2 #4 #7 #6 #3 #5 “Screens in” LAR Required #9 #8

19. The nine examples elicit classroom discussion to ensure a more complete understanding of the learning objectives. Click here to advance to “What is the current delivery schedule?”

20. What is the current delivery schedule? • This class typically can be delivered at your site within five weeks of a decision to proceed.

21. Closure • Thanks again for your interest and time • For any questions or further details, contact Peter LeBlond at: • 847-549-8775 or • LeBlond@Prodigy.net Just click anywhere to end the show