ML20137C697
| ML20137C697 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, Rogers K, The Chairman NRC COMMISSION (OCM) |
| References | |
| FACA, NUDOCS 9703250090 | |
| Download: ML20137C697 (11) | |
Text
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4 UNITED STATES s
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20555-0001
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March 19, 1997 4
MEMORANDUM T0: Chairman Jackson Commissioner Rogers Commissioner Dicus Commissioner Diaz Commissioner McGaffiga FROM:
L. Joseph Callan Executive Director fo Operations
SUBJECT:
UPDATE ON 10 CFR 50.54(f) RESPONSE REVIEW EFFORTS: PILOT PROCESS RESULTS In a February 25, 1997, memorandum to the Commission, the staff described the plans and efforts underway to review the licensee resoonses to the agency's October 9.
1996, 10 CFR 50.54(f) letter on the adequacy and accuracy of design basis information and provided a draft review guideline to be used as part of a pilot review effort. In that memorandum the staff also outlined a pilot review process that would be conducted to test and refine the proposed review approach. This memorandum reports the results of the pilot review process.
During the week of February 10, 1997, the staff and regional representatives selected one facility per region to undergo the pilot review process. The facilities chosen to test the review process were Ginna (Region I), Farley (Region II). Fermi (Region III), and Fort Calhoun (Region IV). The pilot reviews were performed by the facility's NRR project manager, an engineering specialist from the region, and except for one region, a resident inspector.
The recommendations for followup inspection activities that resulted from the pilot reviews varied. In one case, the review team recommended modifications to near-term engineering inspections that would require the inspectors to also focus on certain aspects of the licensee's corrective actions taken as the result of previous design bases reconstitution efforts. In another case, the review team recommended the facility as a high priority site for a design inspection.
On March 3, 1997, headquarters and regional staff discussed in a telephone conference call the results of the 10 CFR 50.54(f) pilot reviews and identified improvements and refinements to the review guidance and process. Although the overall format for presenting the results varied slightly among the regions, the review process yielded similar results. The pilot process results did not highlight the need for immediate regulatory actions at any of the facilities; however, the
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need for additional inspection in the design area was evident.
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I The Commissioners The pilot reviews demonstrated that project managers, resident inspectors, and the regional engineering staff would be an effective review team. These pilot review teams (1) recommended modifications to the review guidance that enhanced the review process to facilitate Agency decisionmaking, and (2) prepared additional guidance to 3e used in developing documentation of review results.
Specifically, Section 2 of the review guidance was modified to require the review teams to discuss the following areas: (1) inconsistencies between the licensee's response and the NRC's understanding of the licensee's regulatory history, (2) major new information from the licensee that needs clarification or confirmation, (3) unexplained topics or missing information in the licensee's response. (4) significant items or trends observed in the past 1 to 2 years, and (5) other significant observations.
Section 3 of the review guidance was also modified to require the review teams to discuss recommendations in the following areas: (1) the need for an architect-engineer (AE) design inspection at the facility and its priority. (2) any near-term changes to the facility's current master inspection plan for the facility on the basis of the review, (3) changes to the focus of currently planned engineering inspections based on the response review, and, (4) other recommended actions that should be taken to clarify information or obtain additional assurance that a licensee is operating in accordance with its design bases.
The changes made to the review guidance are intended to provide more consistent reviews by the regions and facilitate decisionmaking during the upcoming Screening Meetings. A revised version of the review guidance is attached to this memorandum.
The NRC has received 10 CFR 50.54(f) responses from all licensees. Each project manager has reviewed its licensee's response and either issued an acknowledgement letter or is preparing one. Headquarters and regional staff have begun the reviews described as Phase 3 in the February 25, 1997, memorandum using the revised guideline. The Phase 3 reviews will be completed in March or early April 1997 to support providing the results at the upcoming Screening Meetings in April 1997.
Phase 3 will culminate in May 1997. The staff will develop a status report to the Commission on the results of the initial reviews of the responses to the 10 CFR 50.54(f) letter, identification of any insights gained to date, and the recommendations for Phase 4 of the staff's review initiative.
Attachment:
As stated cc: SECY 0GC OCA OPA
L P_ra-decisionallnformation 4
Response Pursuant to 50.54(f) on Facility Design Basis Information Review and Plan Summary i
Facility Operating License Date Docket Number Plant Type i
Purnnam and Prne maa-i e
2 This document summarizes the results of the staff's initial review of the licensee's response of to the 10 CFR 50.54(f) letter of October 9,1996, that requested l
currently licensed nuclear generating facilities to submit specific information pertaining to their programs and processes for ensuring operation in accordance with design, ensuring the avai! ability and adequacy of design basis information, and assessing the effectiveness of i
such programs or processes for maintaining operation within the design basis. The j
licensee's response was reviewed by both regional and program office personnel. The i
i results of this review were presented to and discussed with regional management, inspection specialists, and program office representatives who were knowledgeable of the l
facility's regulatory performance and history as they relate to the availability and use of j
design basis information. On the basis of integration of the review results with regulatory 3
information specific to the facility, these same individuals then determined the need for l
near term regulatory followup activities.
a The ram"Its_nf_the_raview_are_ presented as follows; i
l 1.
Statement of Facts Gained From Review of Response i.
2.
Analysis of Facts Integrated With Available Regulatory Information
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3.
Conclusions and Recommendations for Followup Activities j
4.
Attachments (optional) 1 2
j.
1.
Statement _of_Facta n= Mad FromRaview.af_Rasponsa 4
i in this section of the summary, provide factualstatements extracted from the licensee's l
response that might be usefulin focusing the analysis and formulation of conclusions on the status of a licensee's design basis programs andprocesses. Insights such as highlighting new information about the licensee's design controlprocesses or information you have l
reason to believe needs to be tested, based on your experience with the facility, would be
. especially useful. As a minimum, factualstatements should address the following:
i s' ~
Did the licensee provide the required information? On what basis did it conclude that its processes were effective in maintaining conformance of its facility and operations.
with its design basis?
b.
. Did the licensee perform a design basis reconstitution or some other similar design y
basis documentation effort? If so, what were its attributes? If not, what was the rationale for not performing it?
c.'
What did the licensee do about problem areas identified through the above-
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mentioned efforts? Is the followup complete or, if not, are followup actions being l
' tracked and appropriately prioritized?
j d.
What has the licensee done to evaluate the effectiveness ofits ability to operate in a.
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4 i
4 accordance with its design? Are these assessments ongoing and appropriate in
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scope?
What additional actions has the licensee taken or planned as the result of preparing i
e.
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its response to the to CFR 50.54(f) request or any other previously initiated effort related to maintaining or verifying operation within its design basis?
f.
Has the licensee validated the finalsafety analysis report (FSAR) and the technical
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specification (TS) (i.e., recent FSAR review or Improved TS Program)? If not, on what basis does it believe these documents appropriately reflect its design basis?
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Other information you deem noteworthy in light of your regulatory experience with the facility.
1 if any of the infom Ation necessary for answering these questions is not available, it should be so noted. Additiondy, in this section, the subject headings should be formatted in according to these questions.
2.
Analysis af Facts tritsgratad_With_Awallabla Regulatory _Information Include relevant inspection and licensing insights in the design basis area from a facility's regulatory history. These insights are derived from NRC inspections of procedures, TS l
interpret?tions, operability evaluations,10 CFR 50.72 reports, licensee event reports (LERs),
quality assurance programs and audits, onsite and offsite safety committee evaluations, and training; NRC inspections of maintenance, modifications and engineering (including safety system functionalinspections, safety system outage modification inspections, and architect-(
engineer (AE) design inspections); NRC reviews of updated FSARs,10 CFR 50.59 evaluations, requests for enforcement discretion, exemption requests andlicense
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amendment requests; NRC enforcement correspondence related to 10 CFR 50.59, 50. 71(e),
v and 10 CFR Part 50, Appendix B, Criteria Ill and XVI violations; and NRC performance data i
captured in the Office for Analysis and Evaluation of OperationalData performance mdicators, systematic assessment oflicensee performance (SALP) and the Plant Issues Matrix (PIM).
Use the PIM as a starting point. During these preliminary reviews, the staff willnot be required to retrieve historicalinformation on the licensee's use of design bases information, i
except as necessary to support the normalplant performance review process (PPR). The i
major objective for discussing an integratedperspective of the licensee's response with available regulatory information in a PPR-like meeting is to draw out and document insights i
from seniorpersonnel with historicalperspectives on a facility's performance in the design basis arena, o
l' From your analysis of the licensee's response, present the results of your review under the following headings:
a
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- a. '
inconsistencies between the licensee's response and the NRC's understanding of the i
. licensee's regulatory history.
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- b.
Major new information from the licensee that needs clarification or confirmation.
Unexplained topics or missing information in the licensee's response.
c.
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d.
Significant items or trends observed in the past 1 to 2 years (source documents:
SALPs, PIMs, enforcement histories, and LERs),
e.
Other significant observations.
Questions about or iiisagreements with the licensee's assertions wiH require some level of active research to ensure proper characterization of contradictory statements.
3.
Cancipalans and Recommandatlans for Folinwup Activitias The purpose of this section is to determine the near-term activities necessary to establish confidence in the licensee's appropriate use of design basis information. FoHowup activities
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should develop or clarify information needed to establish this confidence or identify areas of the licensee's performance that need improvement.
l FoHowing presentation of information in Sections 1 and 2 above to regional management in a PPR-like meeting, a decision regarding near-term foHowup activities should be made. For i
the purpose of efficient use of management time, the individuals responsible for reviewing I
the licensee's response should develop preliminary recommendations to be used as a starting point for the meeting. At this time, it is envisioned that foHowup recommendations i
could range from assigning the resident staff under the current core engineering module to y
assess the licensee's performance of a particular aspect of a facility's design basis control l
process, to recommending a large engineering team inspection (Headquarters or region-i based), such as the current AE inspection initiative. In addition, although currently less than
).
a dozen inspection modules focus on aspects of the design bases controlprocess, inspection procedures developed for initiallicensing of the facilities to determine whether i
system configurations were in accordance with design specifications and the preliminary safety analysis report could be utilized. If recommendations take additionalresources to accomplish or would affect ongoing operations, so state.
?
In developing your conclusions and recommendations, you should respond in each of the I
areas listed below; Is there a need for an AE design inspection at the facility and what is its priority?
a.
b.
Are there any near term changes to the current MIP for the facility that you would make on the basis of the review?
c Is there a need to change the focus of currently planned engineering inspections based on the basis of the review?
d.
Other (any other recommended actions that should be taken to clarify information or obtain additional assurance that a licensee is operating in accordance with its design bases).
4.
AttaclimentajQptionau PIM
- Inspection / activity plan, as modified by insights gained from this process.
3
, ~ _ -. - - - - -. -.. - - - -.
i' Th3 Commission 2rs t Ths pilot rsvi:ws d:monstrat:d that proj3ct minigsrs, residsnt inspsetors, and ths r;gional
,c engineering staff would be an effective review team. These pilot review teams (1)/
recommended modifications to the review guidance that enhanced the review pr6 cess to facilitate Agency decisionmaking, and (2) prepared additional guidance to
{ sed in developing documentation of review results.
)
i Specifically, Section 2 of the review guidance was modified to requir the review teams to discuss the following areas: (1) inconsistencies between the licen,e's response and the NRC's understanding of the licensee's regulatory
}
history, (2) major new information from the licensee that nee clarification j
or confirmation, (3) unexplained topics or missing informat' in the licensee's response, (4) i significant items or trends observed in the past 1 to 2 ye
, and (5) other significant a
observations.
^
Section 3 of the review guidance was also modifie to require the review teams to discuss recommendations in the following areas: (1) the ed for an architect-engineer (AE) design inspection at the facility and its priority, (2) any ear-term changes to the facility's current master inspection plan for the facility on the b sis of the review, (3) changes to the focus of currently planned engineering inspections b ed on the response review, and, (4) other recommended actions that should be take to clarify information or obtain additional assurance that a licensee is operating in ccordance with its design bases.
The changes made to the review guid ce are intended to provide more consistent reviews i
by the regions and facilitate decision aking during the upcoming Screening Meetings. A i
revised version of the review guida is attached to this memorandum.
i' The NRC has received 10 CFR 5.54(f) responses from all licensees. Each project manager i
has reviewed its licensee's resp nse and either issued an acknowledgement letter or is j
preparing one. Headquarters d regional staff have begun the reviews described as Phase 3 in the February 25,1997, morandum using the revised guideline. The Phase 3 reviews will be completed in March early April 1997 to support providing the results at the upcoming Screening Meeti s in April 1997.
l Phase 3 will culminate in ay 1997. The staff will develop a status report to the Commission on the results of the initi i reviews of the responses to the 10 CFR 50.54(f) letter, identification of any insi nts gained to date, and the recommendations for Phase 4 of the i
staff's review initiative.
i
Attachment:
As stat d 4
cc: SECY-OGC OCA' OPA DISTRIBUTION:
See attached pa e
- See Previous Concurrences j
Document Name: a:\\5054f
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OFFICE PGEB:DRifM SC:PGEB:DRP BC:PGEB:DRP D:DRPM:NR D:NRR*
EDO i
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- of NAME DSolorio:sb FAkstulewicz DMatthews*
TTMartin*
SCollins LCa\\dn DATE 03/13/97 03/13/97 03/7/97 03/7/97 03/13/97 03N97 OFFIC AL RECORD CORY
. DISTRIBUTION: Memo to Commission fm L. Callan Dated March 19, 1997 Central Ejiq (w/ incoming) (WITS 96000179)
PdR~
EDO r/f (w/ incoming) (WITS 96000179)
PGEB r/f (w/ incoming) (WITS 96000179)
NRR Mailroom (w/ incoming) (WITS 96000179)
ClO CFO JBlaha H. Thompson E. Jordan P. Norry SCollins FMiraglia RZimmerman AThadani TMartin DMatthews FAkstulewicz MMalloy JBirmingham DSolorio KThomas JGallo WBorchardt EKelly, R1 HCristensen, Ril MRing, Rlll CVandenburg, RIV Regional Administrators Regional DRP DDs Regional DRS DDs
I The Commissioners P The pilot reviews demonstrated that project managers. resident inspectors, and
{
the regional engineering staff would be an effective review team. These pilot
/
review teams (1) recommended modifications to the review guidance that
/;
a j
enhanced the review process to facilitate Agency decisionmaking, and (2) prepared additional guidance to be used in developing documentation of review results.
j 4
i Specifically, Section 2 of the review guidance was modified to require the review teams to discuss the following areas: (1) inconsistencies between he licensee's response and the NRC's understanding of the licensee's regu tory e
history (2) major new information from the licensee that needs clar ication or confirmation, (3) unexplained topics or missing information in e
e licensee's response. (4) significant items or trends observed in e past 1 to
-2 years, and (5) other significant observations.
i Section 3 of the review guidance was also modified to requir the review teams to discuss recommendations in the following areas: (1) the eed for an i
architect-engineer (AE) design inspection at the facility and its priority.
(2) any near-term changes to the facility's current mas r inspection plan for i
the facility on the basis of the review, (3) changes t the focus of currently planned engineering inspections based on the respons review, and. (4) other i
recommended actions that should be taken to clarify nformation or obtain i
additional assurance that a licensee is operating 'n accordance with its design bases.
I The changes made to the review guidance are in ended to provide more consistent reviews by the regions and facilit/te decisionmaking during the upcoming Screening Meeting. A revised vers 16n of the review guidance is
[
attached to this memorandum.
The NRC has received responses from all icensees.
Each project manager has reviewed its licensee's response and ei her issued an acknowledgement letter or is preparing one.
Headquarters an regional staff have begun the reviews described as Phase 3 in the February
- 5. 1997, memorandum using the revised guideline. The Phase 3 reviews wil be completed in March or early April 1997 to support providing the results a the upcoming Screening Meetings in April
- 1997, i
Phase 3 will culminate in May 1 7.
The staff will develop a status report to the Commission on the results o the initial reviews of the responses to the 10 CFR 50.54(f) letter, identi ication of any insights gained to date, and the recommendations for Phase 4 o the staff's review initiative, cc:
SECY OGC-OCA 0PA DISTRIBUTION:
See attached page j
- See Previous Concurrences l
Document Name: g:\\5054 ile\\ pilot.mem 0FFICE PGEB:DRPM*
SC:hEBiDRPM* BC:PGEB:DRPM D:DRPM:NRR D:NRR*
EDO NAME DSolorio:sw FAkdtulewicz DMatthews*
TTMartin*
SCollins LCallan DATE' 03/13/97 03/13/97 03/7/97 03/7/97 03/13/97 03/ /97
/
OFFICIAL RECORD COP (
'/
/
i L. Call (
Phase 3 will culminate in May 1997 with a status report o the Commission on the results of the initial reviews of the responses t the 10 CFR 50.54(f) letter, identification of any insights gained to dat, and the recommendations for Phase 4 of the staff's review initiative.
l cc: SECY l
See attached page Document Narn/ } g:\\S054 file \\ pilot.me,
- See Previo Concurrences e:
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OFFICE PGEBtIRM/h SC:PGEB:DkPMfk Sd:PGEB:DRPM*
0:DRPM:NRR* DM
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ED0 NAME DSolorkdsw FAkstuldcz I)Matthews TTMartin
[SchIid LCallan 03/13/b 03/lb/97
/ 03/7/97 03/7/97 N h3/)I/97 03/ /97 DATE 0FF CIAL RECORD COPY
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4 DISTRIBUTION: Memo to Commission fm L. Callan Dated Central File (w/ incoming) (WITS 96000179)
EDO r/f (w/ incoming) (WITS 96000179)'
PGEB r/f (w/ incoming) (WITS 96000179)
NRR Mailroom (w/incomir.g) (WITS 96000179)
CIO
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j CF0 JBlaha H. Thompson E. Jordan P. Norry SCollins FMiraglia RZimmerman AThadani TMartin DMatthews FAkstulewicz MMalloy j
JBirmingham DSolorio KThomas JGallo WBorchardt EKelly, RI HCristensen, RII l
MRing, RIII i
CVandenburg, RIV j
Regional Adminis ators Regional DRP DDs Regional DRS DDs j
l i
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The Commissioners !
Phase 3 will culminate in May 1997 with a status report to the Commission on the results of the initial reviews of the responses to the 10 CFR 50.54(f) letter, identification of any insights gained to date, and the recommendations for Phase 4 of the staff's review initiative, cc:
H. Thompson 4
E. Jordan P. Norry OCA l
OPA i
i DISTRIBUTION:
f See attached page 1
i i
i i
DocumentNak: sg:\\50Mfilo\\ pilot.mem ((
p 0FFICE PGEB:N LCIhaIb DRPM BC:M kh D:DRdNRR D:NRR EDO NAME DSolokibw Ns$dAwicz DM$tthews[
TTMIrtin
. _SCollins LCallan
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DATE 03/ 7 I97 0 /1 /97 03/'//97' 03/ /3 /97 02/ /97 02/ /97 0FF.lCIAL RECORD COPY 4
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