ML20128L109

Staff Requirements Memo Re,Issuance of 10CFR50.54(f) Letters on Availabilty & Adequacy of Design Basis Info

ML20128L109
Person / Time
Issue date:	10/02/1996
From:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
REF-10CFR9.7 SECY-96-189-C, NUDOCS 9610110297
Download: ML20128L109 (7)

Text

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/,. re%*o RELEASED TO THE PDR UNITED STATES o

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6 October 2, 1996 i

OFFICE OF THE j

4 SECRETARY I

MEMORANDUM TO:

James M. Taylor Execy *v Dir tor for Operations M

FROM:

John

. Hoy

,/ ec etary

SUBJECT:

STA REQUIREMENTS - SECY-96-189 - ISSUANCE i

OF 10 CFR 50.54(f) LETTERS ON THE AVAILABILITY AND ADEQUACY OF DESIGN BASIS I

INFORMATION 1

l The Commission has approved issuance of the proposed letters under the signature of the EDO subject to the changes indicated i

1 in the attached revisions to pages 4, 5,

6, and enclosure 2, page 2 of the draft and the comments below.

j 1.

The staff should clearly articulate in the body of the letter the relationship among design basis, licensing l

basis, and UFSAR conibrmance.

I 2.

The staff should include additional examples related to the design basis in attachment 2 to the proposed letter.

Ensure the examples cited focus on design basis versus licensing basis and conformance with the updated final safety analysis report (UFSAR)

(See modifications to Enclosure 2, page 2)

Attachment:

As stated cc:

Chairman Jackson Commissioner Rogers Commissioner Dicus Commissioner Diaz Commissioner McGaffigan OGC OCA OIG Office Directors, Regions, ACES, ACNW, ASLBP (via E-Mail)

SECY NOTE:

THIS SRM, SECY-96-189, AND THE VOTE SHEETS OF ALL fy COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 5 WORKING DAYS FROM THE DATE OF THIS F'M.

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In SECY-93-292 " Generic Letter on the / /ailability and Adequacy of Design i

Bases Information," dated October 21. 1993, the staff recommended that the 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 l

i proposed to continue performing design-related inspections and to gather i

information and insights as to how well the licensees' design-related programs were being implemented.

The Commission issued a staff requirements memorandum 4

that agreed with the -

ff's proposal.

In response to the fina ngs relating to the regulatory burden of team 4

inspections identified in the 1991 Regulatory Impact Survey, during the past several years, the staff has reduced its effort on specific, resource-intensive, design-related team inspections, and followed the issue of accurate and accessible design documentation at plants principally as an element of inspection and followup of operations-related activities.

The i'.suance of the NUMARC guidelines and ongoing industry efforts to improve and maintain design i

j bases information also contributed to this decision.

Current Problem 4

Over the past several months. NRC's findings during inspections and reviews have identified broad programmatic weaknesses that have resulted in design and configuration deficiencies. at a number 4 some plants. which could impact the operability of required equipment, raise Jnreviewed safety questions, or i

indicate discrepancies oetween the plant's updated final safety analysis report (UFSAR) and the as-built or as-modified plant or plant operating i

procedures.

These inspections and reviews have also highlighted numerous instances in which timely and complete implementation of corrective action for known degraded and nonconforming conditions and for past violations of NRC 3

requirements has not been evident. Overall, the NRC staff has found that some licensees have failed (1) to appropriately maintain or adhere to plant i

licensing and desigrj bases information. (2) to comply with the terms and J

conditions of licenses and NRC regulations, and (3) to assure that UFSARs i

properly reflect the facilities. 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's 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 aimilar design, configuration, and operability problems and the effectiveness of quality assurance programs at other plants throughout the industry.

Of particular concern is whether licensee programs to maintain configuration control at plants licensed to operate are sufficient to demonstrate that plant physical and functional characteristics are consistent with the design bases and whether 0; crating plants are being maintained in accordance with their design b s w 3ases.

The extent of the licensees

• failures to maintain control and to identify and correct the failures in a timely manner is of concern because I

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5-of the potential impact on public health and safety should safety systems not respond to challenges from off-normal and accident conditions, 1

It is emphasized that the NRC position has been, and continues to be, that it is the responsibility of individual licensees to know their licensing basis, 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, Attachments 3 and 4 are a recent exchange of correspondence betw en J. Colvin, NEI, and Chairman S. Jackson.

NRC, regarding these subjects, Action j

The NRC has concluded that it requires information that can be used to verify i

compliance with the terms and conditions of your license (s) and NRC

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regulations, and asere that the plant UFSAR(s) 3roperly describe the i

facilities, and ;Aich may be used to decide ;teticr to modify, suspend, Or revoke the Operating licensc(s) for your facility or facilitics, or teether as i

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6 we1U asTto determinelif other inspection activities' or enforcement action should be tak'en, 'Therefore, you are required, pursuant to Section 182(a) of the Atomic Energy Act of 1954, as amended, and 10 CFR 50,54(f), to submit a J

response to this letter within 120 days of its receipt, Your response must be j

written and signed under oath or affirmation.

4 4

Please submit your response to the Director, Office of Nuclear Reactor i

Regulation, with a copy to the appropriate regional administrator and to the NRC Document Control Desk.

The following information is required for each j

licensed unit:

(1)

A description of any design revicW Or reconstitution programs, including identification of the systems, structurcs, and c090nents, and plant level design attributes (c.g., Sci =fc-higi energy line break, modcrate energy line break), that have already been co pleted, are planned, Or are being conducted to ensure the correctnc : and accc Sibility of the design bases efor= tion for your plant and to ensure that it 1: =intained current.

If the program is planned or being conducted but has not

'. A numbsrLofide~signTbasis71nspectionfare tieilig planned @ rid ljogresponis will; be;used in;the; planning; process.

• SectionWlIlBWofIthelNRC[ Enforcement!PolicyJaddressesThoFoldidesign issues; involving!pastiproblemsMn engineeringMdesignfordinstallationiaresto be handl ed :L fromfan e enforcementi standpoi ntDI_n c a irel ated imatter e thel Ccmi ssion recentlyfa) proved changestthat would:modifyhthistpolicystolencourageMicensees to undertacesvoluntarylinitiatiVes tosidentifyland; correct!FSAR!noncompliances by c(1bthej exerciseLoffdiscretion :to' t'efrainl from11 ssui ng : ci vil? penaltiesiforsa two: year periodiwhere aL11censeefundertakes :a voluntary? initiatives 1njthiCarea and (2) the? exercise ofidiscretionito escalate:theTamounttof ciM1 penaltiesifor violations withJdepartures;from the FSARxident.ified.bycthe NRCLsubsequent:tofthe two;yearLyoluntaryXinitiative) period;

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(a)

Description of engineering design and configuration control processes, including those that implement 10 CFR 50.59,10 CFR 50.71(e), and Appendix B to 10 CFR Part 50v :

(b)

Selection and prioritization of systems, structures, and co ponents for review (item (1) Only).

4c4 Rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures (cd) Rationale for concluding that system, structure, and component configuration and performance are consistent with the design bases (de) Processes for problem identification of problems and implementation of corrective actions, including actions to determine the extent of problems, actions to prevent recurrence, and reporting to NRCr ; and (ef) The overall effectiveness of your current processes and programs in concluding that the configuration of your plant (s) is consistent with the design bases.

In responding:to. items :(a) through (e),iindicate whether:you haveTundertaken any design. review or reconstit': tion programs, and ifinot,xa rationale forinot implementing such a program,' _'I.f design review or: reconstitution

?rograms:;have been completed or are being:conductedarovide a description.of tielreview '

programs.dncluding: identification of tie; systems,1: structures.Jandicomponents (SSCs),f and plant-level design attributes '(eig.L,; seismic? high? energy /line" break.: moderate-energy:line! break). 2Theidescriptioncshouldfinclude h.ow!the programensures;thecorrectnessiandaccessibility.of1the/designLbases informationifor your/ plant and that:the design: bases:Tremain/currentt lIf the programJis.beingconductedbut-hasunot:beencompleted,provlideani.f;

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implementation schedule:for. SSCs~ and' plant-leve1Ldesign attribute;reviewsCthe expected completion:. ate ;and method of;SSC.prioritization1usedLfor the d

review, This request is covered by the Office of Management and Budget (OMB) clearance number 3150-0011, which expires July 31, 1997.. The re]orting burden for this collection of information is estimated to average 400 lours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

Send coments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (T-6F33), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs NE0B-10202 (3150-0011), Office of Management and Budget Washington, D.C. 20503. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of this letter and your response will be placed in the NRC Public Document Room (PDR), the Gelman Building 2120 L Street, N.W., Washington, DC. and in the local public document room (s) for your facility or facilities.

4

Maine Yankee On January 10. 1996, the NRC issued a Confirmatory Order Suspending Authority for and Limiting Power Operation and Containment Pressure and a Demand for Information to the Maine Yankee Atomic Power Company. The order was based, in part, on the NRC's determination that Maine Yankee did not apply a computer code, proposed to demonstrate compliance with the emergency core cooling system (ECCS) requirements of 10 CFR 50.46, in a manner conforming to the requirements of 10 CFR Part 50. Appendix K. nor in conformance to the conditions specified in the staff's safety evaluation dated January 30, 1989.

Specifically, the licensee did not demonstrate that the RELAP5YA code will reliably calculate the peak cladding temperature for all break sizes in the small break LOCA spectrum for Maine Yankee, nor has the licensee submitted the justification for the code options selected and other justifications and sensitivity studies to satisfy conditions in the staff's safety evaluation.

In addition, the licensee assumed an initial containment pressure of 2.0 psig for calculating peak design-basis accident pressure, even though the plant's technical specifications allow a maximum operating pressure in containment of 3.0 psig.

Assuming an initial containment pressure of 3.0 psig results in a calculated peak accident pressure in excess of the containment design pressure i

described in the UFSAR.

Refuelina Practices Survey In fespon30 to recent problem encountered at Mil ttone Unit I regarding conformance of the facility with the UFSAR. during the spring of 1995, the NRC conducted a survey of licensee refueling practices.

During the cour:0 of this survey. the "RC determined that ninc site (15 unitO needed to modify their licensing basic cr punt practices to ensure that their reload practices werc in com^11ance with their licensing bas h conducted'during the spring of 1996, the NRhidentified d9eficiencies in the management of design bases assumptions were ah o noted in the survey. Many plants were found to have aspects of their design and licensing bases that were only loosely proceduralized or not proceduralized at all. Typical of this kind of discrepancy was the identification of a lack of procedures for controlling the assumptions regarding hold-up time before beginning fuel transfer.

The NRC found a number of instances in which other design bases assumptions were not captured in procedures.

In addition, it'was necessary for licensees at 12 et-hee sites (23 unitd to upgraded 3rocedures 'to direcMy implement the design bases assumptions.

In otaer cases, the licensee performed engineering analyses, documented pursuant to 10 CFR 50.59, as necessary, to ensure that the planned activities would not exceed design bases assumptions.

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