ML20137K005

Forwards Hypothetical Questions & Staff Replies Re SECY-96-189 & 50.54(f) Ltr Staff Proposes to Send to All Licensees to Gather Info About Design Basis Reconstruction Efforts

ML20137K005
Person / Time
Issue date:	09/05/1996
From:	Blaha J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Ader C, Fleishman M, Slosson M NRC COMMISSION (OCM)
Shared Package
ML20137J929	List: ML20137J922 ML20137J964 ML20137K005 ML20137K020 ML20137K026 ML20137K031 ML20137K044
References
FOIA-96-466 SECY-96-189-C, NUDOCS 9704040208
Download: ML20137K005 (20)

Text

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fasta st UNITED STATES j

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NUCLEAR REGULATORY COMMISSION  !

WASHINGTON. D.C. 20555-4001 '

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% . . . . . ,o September 5, 1996 ,

NOTE TO COMMISSIONER ASSISTANTS '

l OCM/SJ OCM/KR OCM/GJD i L Marylee Slosson _ Myron Karman

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_ Annette Vietti-Cook L Mort Fleishman

_ Brad Jones L Terence Chan

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i _ Mitzi Young _ Jack Sorensen _ Anthony Markley i i

_ James Johnson _ Seth Coplan _ Joel Lubenau

_ Brian Holian Lynn Deering _ Keith McDaniel Regis Boyle _ Lil Vancise _ Donna Smith

! _ Bob Mc0sker _ Ann Haikalis

_ Joanne Field

_ Jackie Silber

_ Janice Dunn Lee

_ Chris Miller 0CM/ND OCM/EM Scott Moore i _ Gerry Schuetze _ Maria Lopez-Otin L Joe Gray

Evelyn Williams L Charlie Ader _ Cathy Grimes i _ Judy ledbetter

_ _ Vicki Bolling _ Linda Lewis l _ Pat Celenza

_ Leslie Hill FROM: James L. Blaha Assistant for 0 e ations, OED0

SUBJECT:

BACKGROUND INFORMATION FOR SECY-96-189 t

Attached are some hypothetical questions and the staff's replies

regarding SECY-96-189 and the 50.54(f) letter the staff proposes to send to i all licensees to gather information about design basis reconstruction efforts.  !

Several of these responses were provided in the briefing package for the forthcoming Congressional Hearings. l

Attachment:

As stated 1

]' cc: J. Taylor, EDO (w/ attachment)

J. Milhoan, DEDR (w/ attachment) i J. Blaha, A0/0ED0 (w/ attachment) l V. McCree, OEDO (w/ attachment)

W. Dean, OED0 (w/ attachment)

SECY (w/ attachment)

OGC.(w/ attachment) 9704040208 970331 PDR FOIA WILLIAM 96-466 PDR

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i 4 Design Basis Issues w/ 50.54f

} Q: At which plants has the NRC identified programmatic weaknesses j which could impact the operability of required equipment or raise 4

unreviewed safety questions?

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{ At Operability concerns were identified at the Nillstone units l and at the Haddam Neck plant; these facilities are presently shut

down and will remain so until these concerns are resolved. Other

{ design issues were identified as a result of NRC inspections of

{ refueling practices and as part of other recent inspections. The l accumulated findings of these inspections are the basis for NRC's

, concern that the problems may not be limited to the Nillstone and i

j Haddam Neck facilities.

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j Q: In light of the inspection findings and NRC's concern as j demonstrated by issuance of letters to CEOs under 50.54(f), what l is the basis for continued operation of these facilities?

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As The issues noted reveal problems in implementation of j processes that warrant increased NRC and licensee attention.

i l However, the extent and significance of the findings to date do j not demonstrate immediate concerns about equipment operability

] except at the few plants which are presently shut down. The 1

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information obtained in the licensees' responses will be used by  !

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the NRC to prioritlau and better focus its continuing oversight, 4

l such as through design inspections, as well as other engineering inspection activities. The NRC believes it is prudent to pursue l

j this area to determine whether extensive problems exist at other 1

facilities.

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Q: Why did four years pass between the issuance of the l Commission's policy statement and the Commission's recognition of I i these broad programmatic weaknesses? How could NRC have

identified these weaknesses and taken action sooner? ,

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.. 1 1 I f At The NRC had intended to continue design-related inspections ,

after the policy statement was issued. Over the next several  ;

) years, in response to findings relating to the regulatory burden l

of team inspections identified in the 1991 Regulatory Impact  !

i survey, the staff reduced its effort on specific, resodrce-  !

intensive, design-related team inspections and refocused its  !

inspection program on operational safety and performance. The refocused inspection activities provided only limited insight into the maintenance and use of design basis information as )

compared to the design-related team inspections.

i Recent NRC inspections and reviews have identified broad )

programmatic weaknesses in licensee design programs at a few sites and indications of potential problems at some others. One of the purposes of these letters ~is to understand to what extent design basis programs were implemented, and how effective they  !

were. The weaknesses might have been recognized earlier if the staff had continued its more intense focus on design-related team inspections or had followed the implementation of industry plans for design basis reconstitution programs more closely. As part of its response to Millstone, the staff is conducting a lessons-learned review of NRC programs and processes to identify needed improvements.

Q: How will the information requested by the NRC in these 50.54(f) letters be used to give the Commission added confidence and assurance that plants are being operated and maintained within the plant design basis?

At NRC has asked for informat :on about design basis reconstitution activities, or licensee reasons for concluding that such activities are not needed. These activities have as their objective ensuring the correctness of design basis information and that it is being maintained current and used in plant modifications and operations. Knowledge of the design basis is needed to maintain consistency of the plant physical and

functional attributes with the design basis when modifications are made to the plant or procedures. Licensees are also being asked to address how their programs and processes:

(i) address translation of design basis requirements into I procedures, (ii) address problem identification and corrective actions, and (iii) address overall effectiveness of processes in keeping the configuration of the plant consistent with its design basis.

The responses will enable NRC to understand the measures taken by licensees to improve design basis information accuracy and accessibility. The NRC will use the information provided to help l

prioritize and focus our inspection activities on those plants, l

or in those areas, where weaknesses in plant design basis j information and related processes are identified. )

I Q: What kind of design-related inspections does the NRC intend to perform? How will the NRC determine at which plants to perform these inspections and how many inspections are being planned?

A: The NRC plans to conduct a number of design-related i

inspections such as safety system functional inspections and safety system outage modification inspections. These inspections will assess selected licensee activities to determine whether regulatory requirements for maintenance and utilization of design basis information are correctly implemented, and whether design control processes are effective in maintaining the plant configuration consistent with the design basis. Contractor assistance with specialised knowledge of engineering design will supplement NRC staff inspectors. Resources have been budgeted to support at best 12 inspections per year. In addition, other j inspection activities have been undertaken which include  !

" vertical slice" activities, that is, to review in detail individual systems with respect to design requirements,  ;

calculations, procedures and other information. Decisions on i

which plants will be inspected will be made based on the responses to the 50.54(f) letters; assessment of the engineering support to operations through periodic Systematic Assessment of Licensee Performance (ShLP) evaluations; events or conditions reported by licensees; and other inspections being performed at a site.

Q: The 50.54(f) letters discuss an industry guidance document for licensee programs for design basis information. Would the NRC conclude that implementation of.a design reconstitution program conducted using this guideline is an acceptable response to this letter?

A: The NRC will base its judgment on program success on its independent inspections of the results of the programs. The NRC will use the program informs. tion to focus and prioritize these inspections but will not approve particular licensee programs.

The industry document, NUMARC 90-12, provides guidelines for design basis programs that licensees may undertake on a voluntary basis to organize and collate a plant's design basis information to support plant activities. .The guidelines also address validation of information, that is, whether the information is consistently reflected in the plant and documents used to control plant operations, and integration with configuration management and design control. In 1990, the NRC noted that NUMARC's approach provided a useful framework and worthwhile insights to those utilities undertaking design basis programs of various scopes. Further, NRC provided comments to NUMARC about the guideline document that indicated areas where further guidance might be useful; for example, NRC noted that the program should include a technical review of the design parameters, calculations and analyses.

The Commission Policy 8tatement of August 10, 1992, Policy Statement on Availability and Accessibility of Design Basis I

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I Information, provides NRC expectations that after completing a design basis reconstitution program, the licensee will have 4

current design documents and adequate technical bases to demonstrate that the plant physical and functional a

characteristics are consistent with the design basis, the j systems, structures and components can perform their intended

! functions and the plant is being operated in a manner consistent with the design basis. As noted above, the success of licensee efforts will be sampled and evaluated through independent NRC inspections..

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S i . "- .i //7 AVAILABILITY AND ADEO.UACY OF DESIGN BASES INFORMATION i NEED FOR 50.54(f) LETTER TO LICENSEES-gpS RGn 4 4h '

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NRR STAFF  !

SEPTEMBER 18,1996 Q - .

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., NEED FOR STAFF PROPOSED ACTION 4

INFORMATION REQUESTED IN 50.54(f) LETTER IS NECESSARY

o TO ESTABLISH A CONSISTENT AND. LOGICAL APPROACH TO ADDRESSING STAFF FOLLOW-UP (AS REQUIRED BY SRM OF 7/11/96) ON THE VOLUNTARY INDUSTRY PROGRAM j

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i e EVALUATE WHETHER ADDITIONAL REGULATORY ACTIONS ARE NECESSARY TO l 4

ENSURE THAT EXISTING REGULATIONS ARE BEING MET e GAIN ADDITIONAL CONFIDENCE THAT LICENSEES ARE OPERATING THEIR PLANTS UNDER THE TERMS AND CONDITIONS OF THEIR LICENSES 4

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Design Basis Chronology A National Performance Review #1 A National Performance

" Review #2 A Regulatory Review Group A Regulatory

" Unnecessary Regulations" Impact Sumey A GAO repod on South Texas

~ A Revised Enforcement A FSAR inspection

' P "' A Poli Statement: Adequacy & Availability ident pera i n f Design Bases information outside license A NUREG 1397: Assessment of A Maine Yankee A----------A Design Reconstitution Programs SBLOCA Analysis A Generic Letter 91-18 A NUMARC 90-12 Design A Millstone i Basis Documentation SFP issues

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HISTORY OF ISSUES l

MID-TO-LATE NRC TEAM INSPECTIONS IDENTIFY POTENTIAL PROBLEMS WITH DESIGN 1980's BASES DOCUMENTATION AFFECTING SAFETY SYSTEM FUNCTIONALITY / OPERABILITY l

EARLY 1990 INDUSTRY RESPONSE - NUMARC 90-12 AND VOLU ARYINDUp,IBY EFFORT TO IMPROVE DESIGN BASES INFORMATIO / d y f ,JL LATE 1990 NRC ENDORSES NUMARC 90-12 WITH COMMENTS

.LiL91 REGULATORY IMPACT SURVEY IDENTIFIES REGULATORY BURDEN OF l NRC TEAM INSPECTIONS ON LICENSEES l 1922 STAFF CONSIDERS OPTIONS FOR ADDRESSING ISSUE OF ACCURATE DESIGN BASES INFORMATION l

STAFF CONCLUDES THAT CHANGES TO REGULATIONS WERE NOT NEEDED. RECOMMENDS ISSUANCE OF A POLICY STATEMENT TO OUTLINE NRC EXPECTATIONS AND GENERIC LETTER THAT WOULD REQUEST LICENSEES TO DESCRIBE THEIR PROGRAMS FOR ADEOUACY AND AVAILABILITY OF DESIGN BASIS COMMISSION ISSUES POLICY STATEMENT ENFORCEMENT POLICY REVISED TO ALLOW ENFORCEMENT DISCRETION FOR SELF-IDENTIFIED DESIGN BASES DEFICIENCIES 1(L92 DRAFT GENERIC LETTER ISSUED FOR COMMENT. INDUSTRY STATES THAT GENERIC LETTER IS UNNECESSARY. STAFF CONCLUDES THAT GENERIC LETTER WOULD NOT F ER LICENSEpS' AWARENE F THE IMPORTANCE OF THE ISSUE dun"> ' W 19.91 ENGINEERING CORE INSPECTION OGRAM E E TO EMPHASIZE OPERATIONS. INSPECTIONS REFOCUSED TO EVALUATE HOW WELL ENGINEERING SUPPORTED OPERATIONS AND MAINTENANCE i TOWERS-PERRIN REPORT PRESENTED REGULATORY BURDEN ISSUES 1921 COMMISSION SRM DIRECTS STAFF TO MONITOR AND TRACK VOLUNTARY INDUSTRY PROGRAMS

! STAFF DETERMINES THAT TOTAL ENGINEERING EFFORT FOR DESIGN-RELATED TEAM INSPECTIONS DECREASED SINCE ISSUANCE OF THE POUCY STATEMENT, WITH MOST HOURS BEING DEVOTED TO l OPERATIONALLY ORIENTED SERVICE WATER INSPECTIONS LICENSEES ARE RESPONSIBLE FOR MAINTAINING THEIR DESIGN BASIS. WHEN NRC REDUCED DESIGN INSPECTIONS FOLLOWING POLICY STATEMENT, SOME LICENSEES STOPPED IMPLEMENTING DESIGN RECONSTITUTION PROGRAMS.

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. 1 i RECENT EVENTS I

• EVIDENCE IS BUILDING THAT PROBLEM WITH ACCURACY OF DESIGN BASIS

INFORMATION IS NOT LIMITED TO MILLSTONE AND HADDAM NECK f

• DESIGN AND ENGINEERING INFORMATION HAS NOT BEEN APPROPRIATELY '

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(SPENT FUEL POOL COOLING - YNh - DRESDEN - MAINE YANKEE -

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< QUAD CITIES -E ALEM - zinm ye f) j L%to (LcWAust%d [k, k gg,4'NdT f BEEN SUFFICIENT T@

• ~ RELIANCE ON INDUSTRY- MTARY EFFUMIb NA

, MAINTAIN CONFIGURATION CONTROL AT SOME PLANTS i

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• AUGUST 1996, NEl PROPOSES LICENSING BASES INITIATIVE, CONDITIONED ON RESOLUTION OF THREE ISSUES. INITIATIVE IS SIGNIFICANTLY LESS THAN

NUMARC 90-12 IMPROVEMENTS. CHAIRMAN JACKSON INFORMS NEl THAT lNITIATIVE MISSES THE MARK i

• CONSISTENT WITH CHAIRMAN'S RESPONSE TO NEl'S INITIATIVE, STAFF i DETERMINES THAT INSPECTIONS ARE NECESSARY IN THE AREA OF DESIGN j BASES DOCUMENTATION TO ESTABLISH CONFIDENCE THAT DESIGN BASES ARE BEING MAINTAINED AND THAT PLANTS ARE BEING OPERATED WITHIN THE i DESIGN BASES

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BENEFITS OF PROPOSED ACTION e TO APPROPRIATELY PLACE THE BURDEN ON LICENSEES OF TELLING NRC WHERE THEY STAND ON IMPLEMENTING THE VOLUNTARY EFFORT TO IMPROVE -

THE DESIGN BASES INFORMATION FOR THEIR PLANTS S

1 e INFORMATION WILL PROVIDE A BETTER MEANS OF SELECTING AND PRIORITIZJQG PLANTS FOR INSPECTIONS

• NRC DOES NOT HAVE SUFFICIENT RESOURCES TO PERFORM INSPECTIONS AT l EVERY FACILITY IN A TIMELY MANNER. (AT A MAXIMUM OF '

3 INSPECTIONS /OUARTER, IT WOULD TAKE NRC ~ 8 YEARS TO COMPLETE INSPECTIONS AT ALL OPERATING PLANTS)

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. l l . l FOLLOW-UP ACTIONS  !

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AFTER COMMISSION APPROVAL TO ISSUE THE 50.54(f) LETTERS, THE STAFF WILL  ;

ESTABLISH:

e INTERNAL REVIEW GROUP TO EVALUATE THE RESPONSES 1

e SCHEDULE FOR INSPECTIONS AT PLANTS i

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NEED FOR STAFF PROPOSED ACTION INFORMATION REQUESTED IN 50.54(f) LETTER IS NECESSARY:

e TO ESTABLISH A CONSISTENT AND LOGICAL APPROACH TO ADDRESSING STAFF FOLLOW-UP (AS REQUIRED BY SRM OF 7/11/96) ON THE VOLUNTARY INDUSTRY PROGRAM e EVALUATE WHETHER ADDITIONAL REGULATORY ACTIONS ARE NECESSARY TO ENSURE THAT EXISTING REGULATIONS ARE BEING MET

• GAIN ADDITIONAL CONFIDENCE THAT LICENSEES ARE OPERATING THEIR PLANTS UNDER THE TERMS AND CONDITIONS OF THEIR LICENSES Y

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Design Basis Chronology A National Performance Review #1 A National Performance o

Review #2 A Regulatory Review Group AR " Unnecessary Regulations" ma S ey A GAO report on South Texas ,

" A Revised Enforcement A FSAR inspection Policy Statement Refocus Design inspections' A Policy Statement: Adequacy & Availability identify operation f Design Bases Information outside license A Maine Yankee  ;

A NUREG 1397: Assessmentof A ---- --- ---- A Design Reconstitution Programs SBLOCA Analysis  !

A Generic Letter 91-18 A NUMARC 90-12 Design A Millstone Basis Documentation SFP issues  ;

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• h HISTORY OF ISSUES i MID-TO-LATE NRC TEAM INSPECTIONS IDENTIFY POTENTIAL PROBLEMS WITH DESIGN

! 1980's BASES DOCUMENTATION A.FFECTING SAFETY SYSTEM I

FUNCTIONALITY / OPERABILITY  ;

EARLY 1990 INDUSTRY RESPONSE - NUMARC 9012 AND VOLUNTARY INDUSTRY j EFFORT TO IMPROVE DESIGN BASES INFORMATION 1

l LATE 1990 NRC ENDORSES NUMARC 90-12 WITH COMMENTS 191.1 REGULATORY IMPACT SURVEY IDENTIFIES REGULATORY BURDEN OF NRC 'lEAM INSPECTIONS ON LICENSEES l 1922 STAFF CONSIDERS OPTIONS FOR ADDRESSING ISSUE OF ACCURATE j

DESIGN BASES INFORMATION h STAFF CONCLUDES THAT CHANGES TO REGULATIONS WERE NOT i NEEDED. RECOMMENDS ISSUANCE OF A POLICY STATEMENT TO l OUTLINE NRC EXPECTATIONS AND GENERIC LETTER THAT WOULD i REQUEST LICENSEES TO DESCRIBE THElR PROGRAMS FOR ADEQUACY

AND AVAILABILITY OF DESIGN BASIS h

j COMMISSION ISSUES POLICY STATEMENT l ENFORCEMENT POLICY REVISED TO ALLOW ENFORCEMENT DISCRETION FOR SELF-IDENTIFIED DESIGN BASES DEFICIENCIES

! 1922 DRAFT GENERIC LETTER ISSUED FOR COMMENT. INDUSTRY STATES 1 THAT GENERIC LETTER IS UNNECESSARY. STAFF CONCLUDES THAT GENERIC LETTER WOULD NOT FURTHER LICENSEES' AWARENESS OF TF'E IMPORTANCE OF THE ISSUE 4

l [$ 1921 ENGINEERING CORE INSPECTION PROGRAM REVISED TO EMPHASIZE

} p j. OPEF1 ATIONS. INSPECTIONS REFOCUSED TO EVALUATE HOW WELL j- ,p -

ENGINEERING SUPPORTED OPERATIONS AND MAINTENANCE l \, p TOWERS-PERRIN REPORT PRESENTED REGULATORY BURDEN ISSUES 1291 COMMISSION SRM DIRECTS STAFF TO MONITOR AND TRACK VOLUNTARY INDUSTRY PROGRAMS i

STAFF DETERMINES THAT TOTAL ENGINEERING EFFORT FOR DESIGN-

! RELATED TEAM INSPECTIONS DECREASED SINCE ISSUANCE OF THE i

POLICY STATEMENT, WITH MOST HOURS BEING DEVOTED TO j OPERATIONALLY ORIENTED SERVICE WATER INSPECTIONS

LICENSEES ARE RESPONSIBLE FOR MAINTAINING THEIR DESIGN BASIS. WHcN NRC REDUCED DESIGN INSPECTIONS FOLLOWING POLICY STATEMENT, SOME LICENSEES STOPPED IMPLEMENTING DESIGN RECONSTITUTION PROGRAMS.

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i RECENT EVENTS e EVIDENCE IS BUILDING THAT PROBLEM WITH ACCURACY OF DESIGN BASIS  !

INFORMATION IS NOT LIMITED TO MILLSTONE AND HADDAM NECK ,

e DESIGN AND ENGINEERING INFORMATION HAS NOT BEEN APPROPRIATELY ,

MAINTAINED OR ADHERED TO AN R OF OTHER PLANTS l (SPENT FUEL POOL COOLIN e AL R - DRESDEN - MAINE YANKEE -

QUAD CITIES - SALEM ION) 4s e RELIANCE ON INDUSTRY VOLUNTARY EFFORTS HAS NOT BEEN SUFFICIENT TO MAINTAIN CONFIGURATION CONTROL AT SOME PLANTS l

e AUGUST 1996, NEl PROPOSES LICENSING BASES INITIATIVE, CONDITIONED ON RESOLUTION OF THREE ISSUES. INITIATIVE IS SIGNIFICANTLY LESS THAN NUMARC 90-12 IMPROVEMENTS. CHAIRMAN JACKSON INFORMS NEl THAT )

INITIATIVE MISSES THE MARK l e CONSISTENT WITH CHAIRMAN'S RESPONSE TO NEl'S INITIATIVE, STAFF  !

l DETERMINES THAT INSPECTIONS ARE NECESSARY IN THE AREA OF DESIGN BASES DOCUMENTATION TO ESTABLISH CONFIDENCE THAT DESIGN BASES ARE BEING MAINTAINED AND THAT PLANTS ARE BEING OPERATED WITHIN THE DESIGN BASES v

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b BENEFITS OF PROPOSED ACTION

• TO APPROPRIATELY PLACE THE BURDEN ON LICENSEES OF TELLING NRC WHERE THEY STAND ON IMPLEMENTING THE VOLUNTARY EFFORT TO IMPROVE THE DESIGN BASES INFORMATION FOR THE:R PLANTS h INFORNIATION WILL PROVIDE A BETTER MEANS OF SELECTING AND PRIORITIZING PLANTS FOR INSPECTIONS e NRC DOES NOT HAVE SUFFICIENT RESOURCES TO PERFORM !NSPECTIONS AT EVERY FACILITY IN A TIMELY MANNER. (AT A MAXIMUM OF

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3 INSPECTIONS / QUARTER, IT WOULD TAKE NRC ~ 8 YEARS TO COMPLETE INEPECTIONS AT ALL OPEGATING PLANTS) 5 i

FOLLOW-UP ACTIONS AFTER COMMISSION APPROVAL TO ISSUE THE 50.54(f) LETTERS, THE STAFF WILL ESTABLISH:

e INTERNAL REVIEW GROUP TO EVALUATE THE RESPONSES e SCHEOULE FOR INSPECTIONS AT PLANTS l

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