1 cdbi inspection insights for 2008 kelly clayton senior reactor inspector engineering branch 1...
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CDBI Inspection Insights for 2008
Kelly ClaytonSenior Reactor Inspector Engineering Branch 1 Region IV
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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
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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.
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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.
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Selection of items
Follow IP 71111.21, which specifies to:“Select 20-30 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).
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Types of Margin
Analytical margin Operations margin Maintenance margin Complexity margin
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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
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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)
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Plant Modification Impacts
Verify that design bases, licensing bases, and performance capability of components have not been degraded through modifications (IP 71111.17, section 02.02.a)
Verify proper considerations for screening of 50.59 issues and various conclusions are correct.
Verify post-mod test operability
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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 71152 for additional guidance
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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