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Current Configuration Management Inspection Issues

This presentation by Chuck Casto, Director of the Division of Reactor Safety, discusses the importance of continued vigilance in configuration management. It covers topics such as the history of design basis configuration, the NRC's focus on safety, and the Maintenance Rule. The presentation highlights the need to expect the unexpected and emphasizes the role of humans in maintaining safety.

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Current Configuration Management Inspection Issues

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  1. Current Configuration Management Inspection Issues “Continued Vigilance” Presented by: Chuck Casto Director, Division of Reactor Safety 8th Configuration Management Benchmarking Conference October 29 – 31, 2001 Raleigh, NC

  2. Inspection Issue Topics • Why continued vigilance? • History of Design Basis configuration • NRC’s focus today • NRC’s vigilance • Summary

  3. Why Continued Vigilance? • Myth: All the big events are in the past • Expect the unexpected • Expect the expected • When all else doesn’t fail, humans may

  4. VIGILANCE “If constant vigilance is the price of liberty, then perpetual unease is the price of safety” -J.P. Reason

  5. History of Design Basis Configuration • Davis Besse incident • NUMARC 90-12 • NUREG 1327 Assessment of DBR • 1990 FSAR update Rule • GL 91-18 • 1992 Commission Policy Statement • 1992 Regulatory Review Group

  6. History of Design Basis Configuration (cont’d) • 1993/1995 National Performance Review • August 1995 plant events • July 1996 Commission Policy on Voluntary Industry Initiatives • Risk Informed Regulation • Special Treatment

  7. Source: NUREG 1275, Vol 14

  8. Source: NUREG 1275, Vol 14

  9. Source: NUREG 1275, Vol 14

  10. NRC’s Inspection Focus Today • Reactor Oversight Program • Engineering Inspections • Maintenance Inspections • Maintenance Rule

  11. ROP Engineering - Inspection • Findings: • Risk significant issues • Awareness of Design Basis • Modifications (including temp mods) and material review

  12. Engineering LERs • “Awareness or Attention to Requirements” • Modifications, design, test/maintenance • Others, e.g., work package quality, non-conservative decision-making, untimely actions

  13. Maintenance Inspections • Findings: • Inadequate decision-making • Inadequate evaluation of test • Conducting 2 evolutions resulted in SI • Failure to follow MWO for taking system out of service • Use of flammable paint thinner not evaluated

  14. Maintenance LERs • Inadequate work practice • Awareness/Attention to detail • Inadequate self checking • Independent verification • Inadequate supervision

  15. NRC’s VigilanceOur focus: Is the plant configured safely now • Maintenance Rule: It’s here to help • Configure • Assess • Manage risk • NRC inspection • Emergent conditions • PMT’s

  16. NRC’s Vigilance (cont’d)The Maintenance Rule • What does the NRC focus on with (a)(4)? • Is there a configuration change? • Was it assessed? • Does assessment match the configuration? • Were key safety functions maintained? • Normal work controls/risk management actions?

  17. NRC’s Vigilance (cont’d)The Maintenance Rule • Risk issues associated with the MR • Adequate evaluation of emergent conditions • Last minute schedule changes • Configurations not analyzed • Documenting “availability” • Crediting manual actions • Logging burden

  18. NRC’s Vigilance (cont’d)Maintenance Rule • Scoping • Accident mitigation functions not included • Turbine runback circuit not included • RHR room sump level switches not included

  19. NRC’s Vigilance (cont’d)Maintenance Rule • Implementation • Breaker not placed in A(1) • Failure to classify functional failure of SG PORV • CREV not placed in A(1) • Drywell pressure switch not classified • Failure to set goals for backup Nitrogen system

  20. NRC’s Vigilance (cont’d)Maintenance Rule • Assessment • Test of EDG concurrent with HPCI not assessed • Maintenance made EDG inop, not assessed • Planned RPS troubleshooting and AFW test assessment tool input did not represent AFW as unavailable

  21. CONTINUED VIGILANCE “Getting the job done is not success. Getting the job done with the proper behavior is.” -Unknown

  22. Continued VigilanceSummary • Big events can still happen • Humans will be involved • Maintenance Rule is here to help • NRC’s inspection focus is on today’s configuration

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