ML18153A136
| ML18153A136 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 05/14/1997 |
| From: | Belisle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 9705290345 | |
| Download: ML18153A136 (29) | |
Text
.
May 14, 1997 Virginia Electric and Power Company ATTN:
Mr. J. P. O'Hanlon Senior Vice President - Nuclear Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060
SUBJECT:
MEETING
SUMMARY
- VIRGINIA ELECTRIC AND POWER COMPANY (VEPCO)
CONFIGURATION MANAGEMENT AND UPDATED FINAL SAFETY ANALYSIS REPORT REVIEW PROGRAM FOR SURRY UNITS 1 & 2 - DOCKET NOS. 50-280, 50-281 AND NORTH ANNA UNITS 1 & 2 - DOCKET NOS. 50-338, 50-339
Dear Mr. O'Hanlon:
This refers to the meeting conducted at your request at the NRC Region II office in Atlanta, Georgia on May 7, 1997.
The purpose of the meeting was to discuss VEPCO's Configuration Management and Updated Final Safety Analysis Report Review Program for your North Anna and Surry facilities.
It is our opinion that this meeting was beneficial in that it provided us with a better understanding of this program. Specific topics discussed included the current regulatory environment, the Design Basis Document Process, the Design and Licensing Basis Integration Review Process, the Updated Final Safety Analysis Review Process and the Improved*Technic, 1 Specifications Process. There was also a brief discussion on the Improved Safety Analysis Report.
The enclosures contain a list of attendees, a copy of the Integrated Configuration Management Project presentation, and a copy of the Improved Safety Analysis Report presentation.
In accordance with Section 2.790(a) of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
No reply to this letter is required; however, if you have any questions concerning this matter, please contact us.
9705290345 970514 PDR ADOCK 05000280 P
PDR Sincerely, Original signed by George A. Belisle George A. Belisle, Chief Reactor Projects Branch 5 Division of Reactor Projects I llllll lllll lllll llllll 11111111111111111
- &&2C26*
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j VEPCO Docket Nos. 50-280, 50-281 50-338, 50-339 License Nos. DPR-32, DPR-37 NPF-4, NPF-7
Enclosures:
- 1.
List of Attendees 2
- 2.
Integration Configuration Management Project
- 3.
Improved Safety Analysis Report cc w/encls:
M. L. Bowling, Manager Nuclear Licensing and Operations Support Virginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060 W.R. Matthews, Manager North Anna Power Station P. 0. Box 402 Mineral, VA. 23117 D. A. Christian, Manager
. Surry Power Station Virginia Electric & Power Company 5570 Hog Island Road Surry, VA 23883 Ray D. Pea~e. Chairman Surry County Board of
- Supervisors P. 0. Box 130 Dendron, VA 23839 Executive Vice President Old Dominion Electric Cooperative 4201 Dominion Boulevard Glen Allen, VA 23060 Dr. W. T. Lough Virginia Corporation Commission Division of Energy Regulation P. 0. Box 1197 Richmond, VA 23209 J. Jeffrey Lunsford County Administrator Louisa County P. 0: Box 160 Louisa, VA 23093 Michael W. Maupin, Esq.
Hunton and Williams Riverfront Plaza, East Tower 951 E. Byrd Street Richmond, VA 23219 Attorney General Supreme Court Building 900 East Main Street Richmond, VA 23219 Robert B. Strobe, M.D., M.P.H.
State Health Commissioner Office of the Commissioner Virginia Department of Health P. 0. Box 2448 Richmond, VA 23218 Distribution w/encls:
See page 3
VEPCO Distribution w/encls:
G. Edison. NRR N. Kalyanam, NRR R. Gibbs. RII P. Fillion, RII D. Jones. RII W. Stansberry, RII R. Aiello, RII PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Commission Surry Nuclear Power Station 5850 Hog Island Road Surry, VA 23883 NRC Resident Inspector U.S. Nuclear Regulatory Commission 1024 Haley Drive Mineral, VA 23117 3
I 97 05 /
/ 97 05 /
/ 97 NO YES NO YES NO
LIST OF ATTENDEES NRC Attendees:
J. R. Johnson, Director, Division of Reactor Projects (DRP), Region II (RII)
F. M. Reinhart, Acting Director, Project Directorate II-1, Office of Nuclear Reactor Regulation G.. A. Belisle, Chief. Reactor Projects Branch 5, DRP. RII L. W. Garner, Project Engineer, Branch 5, DRP, RII P. C. Hopkins, Project Engineer, Branch 5, DRP. RII H. 0. Christensen, Chief, Engineering Branch, Division of Reactor Safety, RII Licensee Attendees:
R. M. Berryman, Project Manager, Integrated Configuration Management Projects, Virginia Power J. D. Hegner, Project Supervisor, Integrated Configuration Management Projects. Virginia Power D. A. Sommers, Supervisor, Corporate Licensing, Virginia Power ENCLOSURE 1
Integrated Configuration
. Management Project May 7, 1997 Meeting with NRC Region II VIRGINIA POWER ENCIDSURE 2
.)
.I
Purpose
+
To describe Virginia Power;s continuing effort.to improve the adequacy and availability of design and licensing bases information
+
To describe Virginia Power's efforts to validate the current content of the Surry and North Anna Updated*Final Safety Analysis Reports, and to improve their format and.content to better support operating nuclear facilities Integrated Configuration Management Project
.)
The Current Regulatory Environment
+
The current regulatory environm.ent is a significant factor in Virginia Power business decisions. That environment includes:
- An expectation of strict compliance with information in the Technical Specifications and the UFSAR *
- An NRC enforcement policy that encourages near-term licensee initiatives to focus on resolving departures from the current UFSAR
- The various regulatory concerns expressed by the NRC in its October 9, 1996 letter requesting information pursuant to IO CFR 50.54(£) regarding the adequacy and availability of design bases information
- Current NRC policy issues involving the design basis, *current licensing basis, UFSAR, and 10 CFR 50.59 as a result of recent industry events Integrated Configuration Management Project
- ~
- ~
Virginia Power Strategy in*the Current Regulatory Environment
+ Perform additional verification and validation activities to demonstrate compliance with the design and licensing bases
+ Take advantage of recetjt NRC Enforcement Policy change that encourages licensee initiatives in discovering "departures from I
the FSAR" over a speci 11ed interval (a two-year period that began in October 1996)
+ In~e~rate_ se:~ral ongoin~ desi~ a~d licensing base_s activities w1th1n V1rg1n1a Power bty establ1sh1ng a Configuration Management Project Integrated Configuration Management Project
An Integrated Approach to the Management of Related Design and Licensing Bases Activities
+ Virginia Power has established an Integrated Configuration e,
iv1anagement Project to manage ongoing programs intended to improve design and licensing bases documentation and validate compliance
+ The overall approach is to complete verification and validation of plant configurations, operations documents, UFSARs, and ITS on a system-by-system basis following issuance of the design basis documents e
+ Integration review teams led by Configuration Management Project engineers and comprised of engineering, operations, and licensing personnel will conduct the reviews and initiate
- change documents, as required Integrated Configuration Management Project
Work Breakd*own Structure Tasks will be organized by major program elements:
Task I Complete design basis docum.entation program Task 2 Complete design and licensing bases integrated review prograrn Task 3 Complete UFSAR Improvement program
- Phase.I - Validate current UFSAR sections Phase II - Upgrade UFSAR document Task 4 Convert to Improved Technical Specifications Task 5 Develop and maintain electronic design and li¢ensing bases information systems Task 6 Review and enhance current processes to maintain design and licensing bases Task 7 Develop project controls and perform project management, project control, and administrative support functions Tasks will be integrated to the extentpractical to account for program dependencies while meeting schedule constraints Integrated Configuration Management Project
DBD Complete
~
Resolve DBD -
Revise Program DBDs Open Items DBDs Integrated*
Design and Revise Design Operating
~
and Operations Review Information Conduct Documents Design &
Resolve IR
. Licensing Open Items*
Bases Revise Integrated UFSAR UFSAR UFSAR Reviews Phase I Improvement andNRC
~
u Correspondence Program Develop Format Revise and Content I
~
Conversion Prepare ITS a
I NRC Review Implement Wark Packages and Approval ITS Program Information Update
- Develop Configuration Evaluate and Conduct DBDLS
~ Electronic improve
~
Assessments Systems Documents*
Mgmt.
processes and Training Integrated Configuration Management Project INTEGRATED PROJECT APPROACH
System Design Basis Document Status by Group Group I -- Issued Auxiliary Feedwater Emergency Power Emergency Diesel Generator D.C.Power Instrument and Service Air Containment/Quench Spray Recirculation Spray Safety Injection Service Water Group 2 -- Issued Component Cooling Water Condensate Station Service Power Feed water Main Steam Group 3 -- Partially Issued Chemical and Volume Control*
NSSS Control System Nuclear Instrumentation Reactor Coolant*
Residual Heat Removal Reactor Protection
- Working Group 4 - Issued Power Generation Vital Bus Group 5 - Working Chilled Water Gaseous Waste Aux. Building Ventilation Control Room Air Conditioning Service Building Ventilation Miscellaneous Building Ventilation Fuel and Decon Building Ventilation Containment Air Cooling*
Turbine Building Ventilation Group 6-Working Circ Water and Vacuum Priming Fire Protection Radiation Monitoririg Integrated Configuration Management Project Group 7 - Working Bearing cooling SIG Blowdown and Recirc Boron Recovery and PG Water Condensate Polishing Containment Vacuum and LM Communication Systems Plant Gas Supplies Post Accident Monitoring and Hydrogen Removal Primary Vents and Drains Sampling System Secondary Drains Group 8 - Planned Electrical Instr. and Plant Computer Station Lighting Fuel Pool Cooling and Purification
Design Basis Document Process Prepare Group 8 ~
Review Group 8._
ResolveDBD
~
Draft SDBDs SDBDs Open Items Complete Review &
Issue Complete Publish Final Preliminary ~ Information ~
Revise 1--
~
Development of Draft DBDs DBDs SDBDs DBDs Assessments Review Design &
Licensing Basis Changes Complete Prepare Draft Review Plant Accident,...
Plant DBDs I-Anaiysis DBDs DBDs Integrated Col!figur_ation Management Project
Design and Licensing Bases Integration Review Process
~
Verify System Revise Design Configuration and/or Drawings Review Design Basis Documents'""
Validate Revise L--.
Operating Operating Procedures Procedures Review UFSAR Validate Revise
~
~
Maintenance Maintenance Section(s)
Procedures
. Procedures Review Identify Licensing Prepare DLBIR Validate Revise Test
~ Technical Basis
~ Validation System I
Procedures j
Specificaton(s)
Commitments Package Testing L.. Review Licensing Validate Revise Training Documents &
~
~ Sections Sections (Phase I)
(Phase I)
Review Draft Validate Prepare ITS ITS Bases Improved Package(s)
Technical Documentation Specifications Sections Integrated Configuration Management Project
UFSAR Improvement Process Implement prompt corrective action Review DBD Open Items associated -
with the UFSAR Defer to integrated -
review
~
Conduct Assemble Conduct pilot integrated UFSAR review of Revise work reviews to Review UFSAR
- design, instructions, as Sections
& docketed validate design correspondence operations. and necessary
& licensing (Phase I) licensing bases bases Conduct RCE to identify root cause of UFSAR inconsistencies Define UFSAR
~
Develop detailed Develop a Issue Revised Apply Guidance usage in support UFSAR format &
methodology for
& Complete Annotated UFSAR of operating content guidance applying the in Electronic Validation facilities document guidance Format (Phase II)
Integrated Configuration Management Project
Improved Technical Specifications Process Develop Criteria Application Reports Prepare Individual work packages Conduct operations &
safety reviews Integrated Configuration* Management Project Verify &
validate ITS packages in concert with integrated
- reviews Assess training
& procedure impacts Conduct safety committee &
management reviews Submit proposed Surry &
North Anna ITS change toNRC Support NRC review &
....._ ___ ~ Implementation 1------i Implementation Plan Plan
Information Systems Development Process Deploy UpdateDBD Engineering Library Workstations Series (DBDLS)
Specify Document Evaluate Software Automation
& Hardware Requirements Applications Integrated Configuration Management Project Install DBDLS as Networked Application Maintain
.-~-1.i MIND/DBDLS Applications Load MIND System Documents (UFSARs, TS,
- Dwgs.,
Procedures)
Convert DBDs t Electronic Fonnat Prepare Improved UFSARin Electronically Publishable Fonnat Prepare Improved TS in.
Electronically Publishable.
Fonnat Install DBDs on Intranet Server Install Improved UFSARon Intranet Server Install Improved TS on Intranet Server Maintain Electronic DBD Applications Maintain Improved UFSAR Application
, Maintain Improved TS Application
Configuration Management Process Improvement Evaluate Current Processes that Impact Design &
Licensing Bases Develop Safety System Functional Assessment Methodology Assess Process Training Requirements Prepare Process Flow Charts Mobilize Independent SSFA Team Prepare Training Modules Integrated Configuration Management Project Conduct RCE of UFSAR Deficiencies Conduct SSF A on One or More Systems Conduct Process Training Identify Process Improvements Revise Procedures
& Documents
Project Management and Controls Process Develop Evaluate Budget Budget Variance Develop Track Cost Costs Plans Develop Staff Task Task Management Project Project Assignment Evaluation Reporting &
Plan Interface Develop Monitor Task -
Schedule Status Develop Procedures &
Maintain Work Procedures & -
Instructions Documents Integrated Configuration Management Project
Key Project Milestones
+ Review and validation of the North Anna and Surry UFSARs will be completed by October 18, 1998
+ Improved Technical Specifications for North Anna and Surry will be submitted in February and April 1999, respectively
+ Design basis documents will be completed and issued by June 30, 1999 Integrated Configuration Management Project
TaskName 01 DBD Program SDBD Develapment PDBD Develapment SDBD Annual Revision PDBD Annual Revision
()pen Item Dispcsition Issued Category 'M' ()pen Items Workin* SDBD Goen Items DBDLS Update LicensinR Correspondence Other DBDLS Document Types DBDLS Maintenance DLBIR ProKram Conduct Pilot DLBIR Conduct DLBIRs for Safetv Related Svmms Conduct DLBIRs for Non-Safetv Svstems UFSAR Program Disoosition UFSAR Ooen Items UFSAR Phue I Enhancement UFSAR Phase 2 Enhancement ITS Program Pr~nare 'Draft' ITS Work Packaees Validate ITS Bases via DLBIR Preoore 'Final' ITS Work Pacmes Submit NAPS ITS to NRC NRC Review of NAPS ITS Submit SI'S ITS to NRC NRC Review of SI'S ITS Implement ITS IMS ProKram Install DBDLS on VP Network SDBD ComDUterization UFSAR/CTS Computerization ITS ComDUteriution Trainin* Module INCRODPl ComDuterization Process Pro11ram Evaluate Maier Processes Evaluate Other Processes Conduct UFSAR Root Cause Evaluation Conduct Svstem Self Assessment ConductTrainin2 Project Manaaement
- b. Milestone c=:J St nmary Integrated Configuration Management Project Proposed Project Schedule Configuration Management Project 1997 1998 1999 02 OJ 04 01 02 OJ 04 01 02 OJ 04
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Project Resources
+ The Integrated Configuration Management Project is a new organization, led by a Project Manager, within Virginia Power's Nuclear Engineering & Services department
- At its peak, the project staff will consist of nearly 50 full-time (Virginia Power and contract) positions, augmented at different times with substantial A/E, consultant, or vendor support
+ Composition of the project's integrated re*view teams is dynamic and \\vill vary based on the technical expertise required to review a particular system or topic. That level of effort is estimated to require an additional 20 FTE's drawn from the Virginia Power organization
+ The estimated project cost going forward is $24 Million Integrated Configuration Management Project
Organization & Staffing Project Manager (I)-Va. Power Controls Admin.
Engineer Support (1)-Va. Power (I )-Va. Power DBD Integration UFSAR/ITS Process/IS Team Leader Review Team Leader Team Leader (1)-Va. Power Team Leader
(!)-Va. Power (1)-Va. Power (I )-Va. Power I
I CAD Word IR Lead UFSAR/ITS ITS Process Operator Processor Engineers Lead Engineer Coordinator Engineer
( I )-Contract
( I )-Contract (6)-Va. Power (1)-Va. Power (I )-Va. Power (I )-Va. ~ower I
Existing Organizati '
un I
--i I
I I
Nuclear Licensing North Anna Surry DBD DBDLS Engineers Licensing Licensing RCE/SSFA Information Engineers Administrator Existing Organization (4)-Va. Power Engineers Engineers Consultant Tech.
(6)-Va. Power (1)-Va. Power m
( 4 )-Contract (1)-Va. Power (I )-Va. Power (5)-Contract I
(2 )-Contract (3 )-Contract
. I I
l Architect/
DBDLS s
UFSAR Document Administrative Administrative Software Engineer Contractor Coordinators Support Support Development (2)-Contract
( I )-Contract
( I )-Contract Contract *
,--- -------~ ------,- --- ---,
Existing Organization Project Manning I
- Va. Power= 29 North Anna Surry
- Staff Contract = 20 ITS Review ITS Review RCE/SSFA Team Team Team Integrated Configuration Management Project
Improved Safety Analysis Report
+ The present Updated Final Safety Analysis Report is founded in the past and needs improvement*.
- The format and content of an Improved Safety Analysis Report should be established based on a set of objective criteria
- The goal would be to create a document that meets the current needs of both NRC and licensees, and that better supports operating nuclear facilities
+ The NRC and industry should work together in a cooperative effort similar to that which resulted in the Improved Technical
- Specifications Integrated Configurat~on Management Project
-- -- 1 Conclusions
- Virginia Power has developed comprehensive design basis e
documents to support configuration control process
+ Substantial additional activities are planned to validate that operations and licensing documents are consistent with design basis and licensing commitments
+ The Integrated Configuration Management Project will effoctively manage Virginia Power's resources associated with design and licensing bases activities in uupport of the continued safe operation
- of Surry and North Anna Power Stations
, Integrated Configuration Management Project
The Improved Safety Analysis Report Consider this for a moment: An important licensing document whose format and content has been re-established based on objective criteria. The focus on safety has been restored. The format and content reflect knowledge and experience gained by both NRC and industry over several decades.
Unnecebsary information has been removed. The document meets the current needs of both the NRC and industry and will be used and useful, not only in support of current operation, but in any license renewal period.
Sound. familiar? It should. We've been there and done that. The product of a decade-long cooperative effort between NRC and industry. The document is the Improved Technical Specifications. The conversion is underway.
Why not the FSAR?
Current concerns regarding the Final Safety Analysis Report are analogous to those in the mid-BO's regarding the Technical Specifications.
Format and c.ontent varied widely.
Plants utilized different versions of standard technical specifications. A number of plants had customized specifications.
Numerous requirements had b~en added over the years, some of dubious value. A not uncommon view within the NRc* staff was that the optimum solution for most regulatory issues was to resolve the issue by adding a new technical specification. In a sense, the technical specifications had become the "dumping ground" for regulatory issues.
Both NRC and the industry re:ilized that the Technical Specifications needed a fundamental overhaul.
The old Technical Specification format and content models had been created before most plants were even operated. There were 1
ENCWSURE 3
too many variations in format, content, and level of detail. Something needed to be done. And it was.
Where are we today? The large majority of plants are committed to converting to the Improved Technical Specifications. In the not too distant future; there will essentially be one set of standard specifications (with plant-specific details).
Roughly a third of the former Technical Specification requirements will have been relocated to licensee controlled documents, an acknowledgment that many of the current technical specification requirements did not have a nexus to safety.
With the industry's conversion, the right information will be in tha
- documents. The right level of detail for operations. For enforcement. W_hy not the FSAR?
The present Updated Final Safety Analysis Report is founded in the past. The format and content was established with a primary goal being to obtain an operating license. Much of the information was written before the plants the document supported were ever built or operated. When an update rule, 10 CFR. 50.71(e), was published in the early 1980's, it failed to rec~gnize that a fundamental change had occurred: The format and content requirements (or in other words, the information needed by NRC from licensees) to support its regulation of operating plants were different from those needed to issue an operating license.
However, rather than require a new document, a more modest strategy was implemented: The requirement was to build on the original FSAR content--update it-and add or revise information as changes occurred.
The update rule was characterized at the time as a reporting requirement to keep NRC apprised of changes to the facility.
A rule that, admittedly, even in its limited scope we have been less than effective in implementing.
But the appropriate regulatory strategy for addressing FSAR issues today is not more of the same. The proposed NRC staff action (Action 16 of the Millstone 2
Lessons Learned, Part 2) to continue to verify FSAR accuracy through inspection is misguided. There are substantial portions of the current FSAR content that simply have no place being there, let alone that warrant verification. Proposed NRC staff action (Action 17 of the Millstone Lessons Learned, Part 2) to identify information to be added to the FSAR is premature.
The document's infrastructure (i.e., format and content guidance) requires* overhaul before information is added.
What needs to be done? Certainly format and content guidance needs to be revised. Action 18 of the NRC staff's Millstone Lessons Learned part 2 report is on the right track, but doesn't go far enough. Action 18 proposes to revise RG 1.70 to include format, content, and level of detail guidance for updates to the FSAR. That action is necessary, but not sufficient. First, the NRC and industry have to again work together to establish objective criteria to specify the content
- of the Safety Analysis Report in support of operating 1 nuclear plants:
(In concept, this is analogous to the four criteria developed and codified in 10 CFR 50.36 for the Technical Specifications.) Then, format and content guidance for the entire Safety Analysis Report, not just for updates, needs to be developed.
Finally, and most important, the NRC needs to offer an incentive to licensees to undertake the effort, and licensees have to respond with an initiative to convert to the Improved Safety Analysis Report.
The current NRC incentive in the NRC Enforcement Policy on departures from the FSAR has the right idea, but the wrong focus. It drives licensees to focus on validating current FSAR content in a limited timeframe-regardless of its value--
because the potential liability for not taking such action appears substantial to licensees in the current regulatory environment. The focus of any NRC incentive 1 The current regulation applicable to FSARs, IO CFR 50.34(b), provides some specificity on FSAR
- content. However, it is clear from a reading of the section that it was drafted from the perspective of an applicant for an operating license.
3
should be shifted from validating the "old" updated FSAR, to encouraging licensees willing to expend the re$ources required to improve the FSAR and willing to work with both NRC and industry to accomplish that goal.
In summary, the actions needed are simple: Develop objective criteria for FSAR content to support both NRC and industry needs in the regulation of operating nuclear facilities, develop improved format and content guidance for the entire document, and develop incentives for licensees willing to expend the resources required to convert from the current document to an Improved Safety Analysis Report.
4