ML20128K891
| ML20128K891 | |
| Person / Time | |
|---|---|
| Issue date: | 09/24/1996 |
| From: | Diaz NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| SECY-96-189-C, NUDOCS 9610110222 | |
| Download: ML20128K891 (4) | |
Text
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NOTATION VOTE 000000000000000000000000 RELEASED TO THE PDR RESPONSE SHEET :
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TO- J hn C. Hoyle, Secretary .......................
FROM: COMMISSIONER DIAZ
SUBJECT:
SECY-96-189 - ISSUANCE OF 10 CFR 50.54 (f)
LETTERS ON THE AVAILABILITY AND ADEQUACY OF DESIGN BASIS INFORMATION Approved ,jp Disapproved Abstain Not Participating Request Discussion COMMENTS:
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Release Vote / V/ 9/1[!95 DATE Withhold vote / /
Entered on "AS" Yes No )
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CDRRESPONDENCE PDR
Commissioner Diaz' Comments on SECY-96-189 4
I approve issuance of the proposed 50.54(f) letter under the signature of the 4
EDO with the following comments:
- 1) I agree with the modifications to the letter suggested by Chairman Jackson and Commissioners McGaffigan and Dicus.
! 2) I ur.derstand that the primary use of the information gained from the responses to these letters will be to select and prioritize )lants for upcoming inspections. I also understand that the need for t1ese inspections is based, in part, on staff's findings that some licensees
! have failed to maintain configuration control and the concern that j indestry's voluntary efforts have not been effective in all cases.
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- 3) I recommend deletion of the phrase on page 5 "to de.:ide whether to modify. suspend, or revoke the operating license (s) for your facility or facilities. or whether other inspection activitt s or enforcement action should be taken" This phrase restates language from 50.54(f) which is implied. and does not need to be repeated. Other changes are suggested on tne attached pages.
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l of the potential impact on public health and safety should safety systems not i respond to challenges from off-normal and accident conditions, i
l It is emphasized that the NRC position has been, and continues to be, that it i is the responsibility of individual licensees to know their licensing basis, j
to have appropriate documentation that defines their design bases, and to have procedures for performing the necessary assessments of plant or procedure changes required by NRC regulations. AttacLaents 3 and 4 are a recent
- exchange of correspondence between J. Colvis, NEI, <nd Chairman S. Jackson,
- NRC, regarding these subjects.
- Action The HRC has concluded that it requires information that can be used to verify comp
- iance with the terms and conditions of your license (s) and NRC l regulations.,wid assure that the plant UFSAP(s) properly describe the .f
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-i.. ,ati s 5d M tie: r af-:-r:mt utis shC =-eahan. r% fore, you t re required, pursuant to Section 182(a) of the Atomic ~EWrgy Act of 1954, as ar. ended, a.nd 10 CFR 50.54(f), to submit a response to this letter within 120 <ays of its receipt. Your response must be writ:en and signed under oath or ai firmation.
Please submit your response to the Director, Office if Nuclear Reactor Regulation, with a copy to the appropriate ratonal 1dministrator and to the NRC [)cument Control Desk. The following informatioa is required for each licer. sed unit:
(1) A description of any design review or reconstitution programs, including identification of the systems, structures, and components, and plant-level design attributes (e.g., seismic, high-energy line break, moderate-energy line break), that have already been completed, are planned, or are being conducted to ensure the correctness and accessibility of the design bases information for your plant and to ensure that it is maintained current. If the program is planned or being conducted but has not been completed, provide an implementation schedule for systems, structures, and components, and plant-level design attribute reviews and the expected completion date.
(2) A rationale for not implementing such a program, if no design review or reconstitution program has been implemented or planned.
The responses provided pursuant to paragraphs (1) and (2) above should address how current or planned plant processes or programs address the following areas of particular interest, as expressed in NUMARC 90-12, the staff's comments on the indu u ry guidelines, and the Commission policy statement:
Mr. (Name] l l In SECY-93-292, " Generic Letter on the Availability and Adequacy of Design i Bases Information," dated October 21, 1993, the staff recommended that the I generic letter not be issued. The staff stated that publication of the policy
} statement and the proposed generic letter conveyed to the industry the
- Commission's concern and that publication of the generic letter would not further licensees' awareness of the importance of the activities. The staff j proposed to continue performing design-related inspections and to gather
! information .and insights as to how well the licensees' desijn-related programs were being 'aplemented.
i The Commission issued a staff requirements memorandum l j that agreed with the staff's proposal.
l In response to the findings relating to the regulatory burden of team i inspections identified in the 1991 Regulatory Impact Survey. during the past i
several years, the staff has reduced its effort on specific, resource-4 intensive, casign-related team inspections, and followed the issue of accurate and accessille design documentation at plants principally ai an element of i inspection ind followup of operations-related activities. .he issuance of the '
i NUMARC guidtlines and ongoing industry efforts to improve aid maintain design j bases information also contributed to this decision.
Lurrent Prot].g3 g j
Over the pas t several months, NRC's findings during inspections and reviews Iave identified broad programmatic wealphesses that have res:lted in design and
! onfiguratici deficiencies at : "r :f plants which coule impact the (perability of required equipment, raise unreviewed safety questions, or i 11dicate dit repancies between the plant's updated final safety analysis l report (UFS/R) and the as-built or as-modified plant or plant operating
! procedures. These inspections and reviews have also highlighted numerous
- instances in which timely and complete implementation of corrective action for i known degraded and nonconforming conditions and for past violations of NRC requirements has not been evident. Overall, the NRC staff has found that some j licensees have failed (1) to appropriately maintain or adhere to plant
- licensing and design bases information, (2) to comply with the terms and t conditions of licenses and NRC regulations, and (3) to assure that UFSARs properly reflect the facilities. Attachment 2 provides examples of some of the deficiencies recently identified by the staff. As a consequence of this new information, the NRC believes that the industry's voluntary efforts to improve and maintain design bases information for their plants, consistent with NUMARC 90-12, the staff'i comments on the industry guidelines, and the Commission policy statement, have not been effective in all cases.
The magnitude and scope of the problems that the NRC staff has identified raise concerns about the presence of similar design, configuration, and operability problems and the effectiveness of quality assurance programs .
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_ _ _ ;. .--/ . Of particular concern is whether licensee programs to maintain configuration control are sufficient fto demonstrate that plant physical and functional characteristics are con 1 stent with the design bases and whether operating plants are being maintai d in accordance with their design basis. The extent of the licensee's ilures to maintain control and to identify and correct the failures in A imely manner is of concern because
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