ML080850613
| ML080850613 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 04/10/2008 |
| From: | Frederick Brown, Christiana Lui NRC/NRR/ADRO/DIRS, NRC/RES/DRA |
| To: | Roe J Nuclear Energy Institute |
| Persensky J, RES, 415-6759 | |
| References | |
| Download: ML080850613 (4) | |
Text
April 10, 2008 Jack W. Roe Director, Security and Operations Support Nuclear Energy Institute 1776 I St. N.W., Suite 400 Washington, DC 20006
SUBJECT:
RESOLVED AND OPEN ISSUES REGARDING NEI-O6-11, REVISION B, MANAGING FATIGUE AT NUCLEAR POWER REACTOR SITES
Dear Mr. Roe:
At the February 21, 2008, public meeting regarding implementation guidance for 10 CFR Part 26, Subpart I, the U.S. Nuclear Regulatory Commission (NRC) staff and Nuclear Energy Institute (NEI) identified a few high level issues that should be resolved prior to issuance of final guidance documents. These issues are: (1) the definition of on-site; (2) the definition of maintenance, including predictive maintenance; and the determination of when a structure, system or component is considered risk significant; (3) acceptable methods for implementing the minimum day off (MDO) requirements described in Section 26.205(d)(4) during unit outages at multi-unit facilities; and (4) acceptable methods for implementing the MDO requirements during transitions between work schedules and duties, including NEIs proposal for periodic overtime.
Our positions on these issues are:
- 1. Definition of On-site NEI has proposed to define on-site as within the owner-controlled area. This resolution addresses the staff comment.
- 2. Definition of Maintenance, applicability of work hour provisions to predictive maintenance, and determining the risk-significance of SSCs for the purpose of implementing Subpart I work hour controls The final rule provides the following definition of maintenance:
Maintenance means, for the purposes of §26.4(a)(4), the following on-site maintenance activities: modification, surveillance, post-maintenance testing, and corrective and preventive maintenance.
We would find acceptable guidance that excludes the following predictive maintenance activities from the scope of duties subject to work hour controls: Predictive maintenance activities that are neither required by technical specifications nor change the condition or state of the structure, system, or component (SSC).
We understand that NEI will revise NEI-06-11 such that maintenance on risk-significant SSCs will be subject to work hour controls if the work is performed on-site, regardless of whether the component is installed in a system. The staffs position remains that for the purposes of Part 26, Subpart I, the determination regarding the risk-significance of an SSC is based upon the function that the SSC is intended to serve, not an instantaneous assessment of risk.
- 3. Implementation of the MDO requirements described in Section 26.205(d)(4) during unit outages at multi-unit facilities We understand the guidance in NEI-06-11, Revision B to effectively allow all personnel at a multi-unit site to work in accordance with the work hour limits applicable to individuals working on outage activities, including individuals at the controls of an operating unit. The staff considers this guidance to be inconsistent with the rules limitation of the outage work hour relaxation to individuals while working on outage activities.
- 4. Implementation of the MDO requirements during transitions between work schedules and duties The applicability of MDO requirements of Section 26.205(d)(3) is based on the duration of a shift schedule (i.e., whether an individual is working an 8, 10, or 12-hour shift) and the duties that an individual is performing (i.e., whether an individual is performing the operations, health physics, chemistry, or fire brigade duties described in Section 26.4(a)(1) through (a)(3), the maintenance duties described in Section 26.4(a)(4), the security duties described in Section 26.4(a)(5), or not performing any of these covered duties). Both of these factors must be considered to appropriately determine which MDO requirements are applicable to an individual. Accordingly, when an individual changes either job duties or the duration of his or her schedule, both factors must be considered. Implementation guidance for these requirements should be consistent with ensuring that individuals who are transitioning to duties with more stringent MDO requirements are fit to assume those duties. Determinations regarding shift schedule changes should be based on actual hours worked and the definitions of shift durations provided in Section 26.5.
We believe that the above resolves the outstanding issues from the February 21, 2008, meeting. We await your final version of NEI-06-11. We have begun drafting the Regulatory Guide endorsing NEI-06-11. Depending on your changes to the guidance relative to Issues 3 and 4, we will either endorse the guidance as written or with exceptions that can be addressed during the public comment period.
Sincerely
/RA/
/RA/
Christiana Lui, Director Frederick D. Brown, Director Division of Risk Analysis Division of Inspection and Regional Office of Nuclear Regulatory Research Support Office of Nuclear Reactor Regulation
We believe that the above resolves the outstanding issues from the February 21, 2008, meeting. We await your final version of NEI-06-11. We have begun drafting the Regulatory Guide endorsing NEI-06-11. Depending on your changes to the guidance relative to Issues 3 and 4, we will either endorse the guidance as written or with exceptions that can be addressed during the public comment period.
Sincerely
/RA/
/RA/
Christiana Lui, Director Frederick D. Brown, Director Division of Risk Analysis Division of Inspection and Regional Office of Nuclear Regulatory Research Support Office of Nuclear Reactor Regulation DISTRIBUTION:
DRA r/f BSheron JDyer WBorchardt RZimmerman MJohnson JMonninger DDesaulniers DDiec TMcCune HBenowitz NSalgado JIbarra YIvanchev NHughes VBarnes KMartin ADAMS Accession Number: ML080850613 OFFICE RES NRO/DCIP NSIR/DSP OGC RES/DRA NRR/DIRS/D NAME JPersensky GTracy PHolahan (S.Morris for)
HBenowitz CLui FBrown DATE 03/26/08 03/27/08 04/03/08 04/08/08 04/10/08 04/10/08 OFFICIAL RECORD COPY