1. 1 CDBI Inspection Insights for 2008 Kelly Clayton Senior Reactor Inspector Engineering Branch 1 Region IV

2. 2 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

3. 3 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.

4. 4 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.

5. 5 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).

6. 6 Types of Margin Analytical margin Operations margin Maintenance margin Complexity margin

7. 7 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

8. 8 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)

9. 9 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

10. 10 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

11. 11 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