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, 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 Vigilance Our 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 Vigilance Summary
Big events can still happen
Humans will be involved
Maintenance Rule is here to help
NRC’s inspection focus is on today’s configuration