ML20137M555

Forwards Description of Scope of Planned USAR Rebaselining Project

ML20137M555
Person / Time
Site:	Cooper
Issue date:	03/31/1997
From:	Graham P NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS970053, NUDOCS 9704080120
Download: ML20137M555 (11)

Text

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P.O. BOX EB 68321 Nebraska Public Power District Te%T""

NLS970053 March 31,1997 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

USAR Rebaselining Project Description Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

Letter from Mr. G. R. Horn (NPPD) to NRC Document Control Desk, dated February 10,1997 concerning the Request for Information Pursuant to 10CFR50.54(f) Regarding the Adequacy and Availability of Design Bases Information in the referenced letter, the Nebraska Public Power District (the District) committed to provide the NRC with a description of the scope of the planned Updated Safety Analysis Report (USAR)

Rebaselining Project (the Project). The District recognizes that there has historically been a varying degree of rigor in maintaining USAR accuracy, consistency, and completeness. This is contrary both to the District's goals for CNS achieving industry top quartile performance and to the NRC's regulatory expectations.

Attachment I contains the District's detailed voluntary initiative to rebaseline and validate the A

CNS USAR. This effort, of which preliminary activities have already begun, is being performed on a project basis and is scheduled for completion by October 1998. The Project approach Y

described herein will result in the timely resolution of USAR discrepancies, including prompt corrective action for individual issues that are discovered that themselves have significant safety

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or regulatory implications. The District will adjust the Project scope and processes, as appropriate, to reconcile new insights or findings as the Project proceeds, and will also use these results to identify programmatic improvements to assure the rebaselined USAR is properly maintained. With this submittal, the District believes it has met the criteria established by Enforcement Guidance Memorandum 96-005 for discretionary enforcement of USAR-related issues. From conversations with your staff, the District wishes to underscore its understanding that this discretion would be of sufricient breadth to include not only US AR inaccuracy and completeness issues, but also improper implementation of USAR statements in output documents and Station configurations.

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The District looks forward to briefing the NRC staff on this project in the near future. Should you have any questions or require additional detail on this effort prior to that time, please contact l

my office.

Sincerely, pbrLS=

P. D. Graham i

Vice President-Nuclear Energy

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Attachment cc:

Regional Administrator USNRC - Region IV

.j Senior Project Manager USNRC - NRR Project Directorate IV-1 i

Senior Resident Inspector USNRC - CooperNuclear Station l

NPG Distribution I

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Attachmeet I to NLS970053

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Page 1 of 8 F

EXECUTIVE

SUMMARY

This document is a description of the USAR Rebaselining Project at CNS. It describes the Project objectives, scope of effort, and plans for discrepancy resolution. It also defines the key i

Project roles and responsibilities of both Station personnel and the engineering firm that has been -

contracted to assist in this effort, as well as the major milestones in the Project schedule.

l.0 OBJECTIVES The Project scope and methodology are principally designed to:

Capture the facets of the CNS Licensing Basis that are required to be contained in the USAR per 10CFR50.34(b) as updated per 10CFR50.71(e).

Reconcile the USAR text with existing Structures, Systems and Component (SSC) configurations and capabilities, and implementing procedures and activities i.

consistent with the requirements of 10CFR50.59 and 10CFR50 Appendix B.

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Resolve discrepant issues discovered by the Project in keeping with the requirements of 10CFR50 Appendix B Criterion XVI.

An additional Project objective is the development of programmatic means to assure the rebaselined USAR remains up-to-date and consistent with the physical plant and implementing documents. Part of this objective involves making recommendations for improvements in the processes that ensure proper US AR maintenance. Another part is the development of computer-driven linkages between the USAR text and the applicable source and implementing documents along with the procedural infrastructure. The purpose of this is to ensure that when a change is considered for one of these three categories of documents, any potential effects on the other two types will be more readily l

identified and properly updated.

l 2.0 PROJECT SCOPE The following block diagram shows the functional relationship that exists between the USAR, its source documents, and its implementing outputs.

l USAR Outputs Source Document t

Examples: DC's, SER's Examples: Procedures, processes, NRC correspondence plant configuration To achieve the objectives listed previously, the Project incorporates three fundamental processes. First, source documents are collected, evaluated, and incorporated to ensure USAR completeness and accuracy. Conversely, this process evaluates the USAR text i

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against the applicable source documentation to ensure the appropriate information has been accurately transcribed.- Second, an introspective review of USAR content is performed to ensure both accuracy between different USAR sections and consistency in I

the levels of detail. Lastly, comparisons are performed between the USAR text and SSC i

configurations and capabilities, and Station procedures and activities that implement the i

text.

i Tne intent is to rebaseline and validate the USAR in ' his manner on a section-by-section t

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basis using the CNS USAR change process. In keeping with the CNS procedural 1

requirements,10CFR50.59 Safety Evaluations will be performed justifying the deletion, i

addition, or changes ofinformation in the rebaselined USAR Sections.

t A key Project deliverable is a configuration management tool that captures the validated relationships between source documents, the USAR text, and implementing documents l'

through the use of a computer-driven linkage database that is accessible to CNS personnel. Accordingly, when a change is considered for one of these three categories of documents, the potential effects on the other two types will be recognized more easily i

than with the means currently available.

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. 2.1 Source Document Review The Source Document Review encompasses both the evaluation of a broad population of j

documents that could contain source information applicable to the USAR and the capturing of that information, as appropriate, in the USAR sections. These candidate document types include:

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CNS Licendng Docket-A review will be performed of the collected information j

from the CNS licensing docket. The purpose of this review is to identify the baseline documents which define or describe the licensing basis, and to extract the

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I information which should be included in the USAR, as appropriate, based on the established screening criteria contained in the Project procedures. The principal focus is on correspondence that either: 1) changed the Operating License (e.g.,

Orders, Amendments),2) resolved significant new safety issues (i.e., those issues for which an NRC Safety Evaluation Report was issued), and 3) identified additional criteria for meeting existing license requirements based on an industry l

event or recognized design weakness.

b).

Rarety Analyses: The Project will identify and review analyses that have been l

performed in support of the principal licensing basis submittals described above, as j

well as those supporting changes to the facility that provided bases for the j

proposed change not constituting an Unreviewed Safety Question.

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c)

Plant Modifications: A review will be made of plant design changes as well as the applicable 10CFR50.59 Safety Evaluations for the purpose ofidentifying the changes / impact.

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d)

Other 10CFR50 59 Rmfety Evaluationr The CNS Safety Evaluations not associated with plant modifications (e.g., procedure changes or USAR l

clarifications) will be reviewed to identify changes to information contained in the USAR, as they are identified in the CNS Annual Reports.

i e)

USAR Channe Dommentation: The USAR Update Rule was implemented on January 1,1983. Documentation supporting the annual USAR updates since that time will be reviewed.

f)

Other Demion Domments: This category may include documents relevant to the I

SSCs described in the USAR such as design specifications, calculations, codes and standards, etc. The information from such documents will be evaluated on a case-i

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by-case basis and incorporated into the USAR rewrite process, as appropriate.

2.2 USAR Content Review The Project will preserve the current CNS USAR format. Although additional sections l

may be added to describe the resolution of new safety issues developed after initial licensing, the basic structure of the USAR will remain unchanged to facilitate the familiarization of the rebaselined USAR to the CNS staff. The objectives of the USAR content review are: 1) ensure that the rebaselined USAR sections are accurate with

. respect to each other, 2) ensure that there is a consistent level of detail throughout the document for the users to understand the design and licensing bases of SSCs described in the USAR, and 3) streamline the document by reducing duplicate information and identifying historical information that has no current standing in the licensing basis of CNS.

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The Project will not delete current information from the USAR simply to reduce the level of detail. The following principles are being adhered to when eliminating existing information:

The information is inaccurate and is being superseded by correct information; The information no longer has standing in the CNS Licensing Basis but would be retrievable as archived information (e.g., detailed descriptions and analyses of 7x7 fuel bundles, which are no longer being used)

The information is superseded by information that either clarifies the original information or more clearly meets the intended purpose for the original information inclusion. (e.g., replacing the current P&ID drawings with simplified i

. flow drawings).

j The detailed requirements for a given program are superseded by reference to a j

separate stand-alone program or analysis documer? (e.g., Technical Specification i

surveillances, Fire Hazards Analysis, Equipment Qualification program).

2.3

' imnlementation Validation The words in the USAR are implemented in a multitude of ways in the plant. USAR descriptions of SSCs and their functions are manifested through their physical i

to NLS970053 Page 4 of 8 configurations as reflected in' plant drawings. Design functional capability is validated through testing records.' The description of manual manipulations to the normal SSC l

configurations equate to Operations procedures. Descriptions of SSC testing and -

inspection must similarly be traceable to Station procedures or processes. Additionally, i

licensing or design basis SSC analytical information must not be compromised in its l

implementation in Station procedures, processes, and programs.

To meet the above criteria, a detailed validation will be performed for each rebaselined USAR section to ensure the information is being appropriate id:;:bnented. This validation will include, but is not limited to:

1 Station Procedures Testing results j

Program guidance documents j

Plant drawings and/or welkdowns Controlled equipment databases Where it is discovered that the implicit or explicit provisions of the rebaselined US AR are l

not being met, the proper outputs will either be developed or revised, as appropriate, or i

the USAR text will be changed to reconcile the issue, as justified through a 10CFR50.59 Safety Evaluation.

3.0 DISCREPANCY RESOLUTION 1

As described in the previous section, the efforts of the USAR Rebaselining Project are fundamentally to evaluate source documents for design and licensing basis information, to revise the USAR to accurately and consistently incorporate source information, and to verify that outputs properly reflect (or are reconciled with) the US AR text. Therefore, the types of discrepancies that are anticipated as pan of the Project scope are: a) Source Document-to-USAR discrepancies, b) USAR-to-USAR discrepancies, and c) USAR-to-

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Output discrepancies. The effectiveness of the USAR Rebaselining Project will be i

maximized by discrepancies being dispositioned and resolved in an organized, thoughtful, and predictable manner unless there is basis for escalation. The District recognizes that with a project of this nature, subjectivity in discrepancy significance cannot be completely eliminated. However, the Project approach described below attempts to strike a balance between immediate and long term safety interests within the existing regulatory framework.

3.1 Diac=nancv Identifie= tion i

An integrated approach will be used to identify USAR-related discrepancies using bCh the Project team and the CNS staff.

The Project team as part ofits rebaselining and validation process will necessarily raise questions on the USAR section currently under review. These questions are tracked on an internal Project database Because of the investigative nature of the Project (where earlier-

Source Document information may have been superseded by later information not yet

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reviewed), a key area of team focus is deciding on the point where an unresolved question by Project team becomes a documented discrepancy. Once a discrepancy has been identified, the issue enters the CNS Corrective Action Program for disposition and resolution.

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The CNS staff performs an integral role in the identification of USAR-related issues for the Project. Direction has been given to CNS personnel to bring questions or potential 4

discrepancies to the attention of the Project team for assessment and tracking. This includes issues raised from other programmatic efforts that may not currently be captured j

within the Corrective Action Program (e.g., Design Criteria Document development).

l When an issue is believed to be an actual discrepancy (whether corroborated by the j

Project team or not), the issue is documented within the CNS Corrective Action Program.

By encouraging all CNS personnel to identify USAR issues, important information is fed back to the Project team. This feedback can be used to make any adjustments to the Project approach or scope such that there is certainty that the issue would ultimately have j

been Project-identified.

i 3.2 Diacranancy Diannaitinn i

i As discrepancies are identified and entered into the CNS Corrective Action Program, the 1

Project team assists the Station in determining which issues require more urgent resolution than would be corrected by the Project schedule. Fundamentally, the timeliness of corrective action must be commensurate with the safety significance of the issue. Ai stated in Generic Letter 91-18, the design and operation of a nuclear plant are to be consistent with the current licensing basis. Whenever degraded or nonconforming conditions of SSCs subject to Appendix B are identified, Appendix B requires prompt corrective action to correct or resolve the condition. The Generic Letter establishes the expectation that a prompt determination of operability be made to establish a basis for plant operation while the corrective action establishes or reestablishes the design basis / qualification of the safety or safety support system. There is no explicit requirement in the regulations for timeliness of these corrective actions except that the timeliness be I

consistent with the safety significance. The following criteria are being established to help determine when there is sufficient safety significance to warrant expedited efforts over and above the Project timetable:

Operability cannot be established, or Operability can only be established through compensatory measures or new i -

analyses, or Operability is Mode deper. dent or cannot be assured throughout the 18-month life i

of the Project, or Based on qualitative review, it is not clear that the discrepancy does not constitute an Unreviewed Safety Question (or it appears that new analyses are required to demonstrate an Unreviewed Safety Question doesn't exist).

The discrepancy is otherwise reportable per 10CFR50.72 or 10CFR50.73.

If none of these criteria are met, the timeliness of the corrective action is considered to be met by dispositionin3 the discrepancy (via the Corrective Action Program) to the Project

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Attachment I to NLS970053 i

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for action no later than October 1998. This is justified since the relative safety significance will have been demonstrated to be low, and since effective final corrective action will be taken as provided for in the Project Plan. During the period that the discrepancy remains uncorrected, appropriate means will be employed to appraise the CNS staff on the nature j

of the discrepant issue to ensure it will not affect the conclusions of 10CFR50.59 Safety Evaluations or Operability Assessments performed during the interim. This process will be retroactively applied against existing USAR-related discrepancies currently existing in the Corrective Action Program database.

j 3.3 Discrepancy Closure l

l As discussed above, USAR discrepancies will be tracked to closure using the CNS 1

Corrective Action Program. Issues that are documented as having significance, as defined in the previous Section, would be corrected outside of the Project on a schedule commensurate with that increased significance. The District expects that all USAR j

discrepancies would be resolved by the end of the targeted Project completion date of

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l October 1998, 4.0 PROJECT ORGANIZATION The Project has been organized as an integrated site-wide effort, using the existing CNS processes and procedures to the extent practicable. Due to the magnitude of the Project scope, an engineering consulting firm has been contracted to assist in this effort. A full-time NPPD Project Staff has been established to implement the Project through management of Project progress, control and oversight of Project processes, and coordination of activities between the Project team and the CNS Staff.

4.1 Conadtant Resoonsibilities The efforts of the consultant Project staff will be principally performed out of their corporate oflices. However, consultant personnel will also be established at CNS to coordinate these efforts with District personnel and other resources that may be required.

The consultant's main responsibilities are to:

Draft proposed Project instmetions governing the key activities described herein.

Retrieve and review source documents from the CNS archives. Provide disposition of these documents to the NPPD Project Staff with proposed recommendations for information inclusion into the USAR (CNS staff will ultimately decide whether inclusion is appropriate).

Rewrite the proposed rebaselined USAR text for review by the NPPD Project Staff. Resolve comments received from the District.

Prepare detailed 10CFR50,59 Safety Evaluations of USAR text revisions for review and approval by the District that clearly document the bases for information addition, deletion, or other changes.

Perform validation of USAR implementing outputs (including SSC configurations and capabilities) and provide for review and approval by the District.

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Document unresolved questions as Project Open Items in a manner that is subject

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to review by the District. Document USAR-related discrepancies with a CNS Problem Identification Report (PIR) per Station Procedure 0.5 Develop the computer linkage database between the rebaselined USAR text, source documents, and implementing outputs.

Provide assistance to the CNS staff, as required, in resolving USAR-related discrepancies.

J Provide regular status ofProject progress and issues to the NPPD Project Staff.

Provide periodic assessments of USAR discrepancies to the NPPD Project Staff l

with any recommendations for adjusting the scope or methodologies employed by the Project.

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. Periodically compare the existing CNS processes for USAR maintenance against i

the insights gained from the Project and make recommendations for improvements.

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' 4.2 NPPD Prqiect SenF i

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A full-time NPPD Project Staff has been established with personnel from the Engineering and Licensing departments. Their main responsibilities include:

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3 Review and approval of the consultant's dispositions of source documents.

l Control and maintain the Project internal Open Item database.

l Review PIRs resulting from USAR-related discrepancies and provide I

t recommendations to the CNS Corrective Action Program as to their disposition.

Review proposed rebaselined USAR sections with accompanying 10CFR50.59 l

Safety Evaluations and output validations. Facilitate reviews by cognizant i

members of the CNS Staff. Present the packages to the final approval authority.

Provide regular interface with CNS Management and with NRC personnel to l

appraise them of Project progress and issues.

Coordinate with the CNS Staff, as required, on the resolution of USAR-related discrepancies that are outside the consultant scope of work.

Perform retroactive Project disposition of existing USAR issues documented in the Corrective Action Program database and as identified in other programmatic efforts.

Assess recommendations made by the consultant for improvements to the processes that control USAR maintenance and assign actions, as appropriate, to the CNS organization.

4.3 CNS Staff l

1 CNS Management has communicated to the CNS Staff the important goals of the Project.

The CNS Staff will provide full support, where needed, in accomplishing these goals. A 1

general expectation has been expressed that irrespective of the Project's scoped level of effort, individuals bring questions or potential discrepancies on the existing USAR text to the attention of the NPPD Project Staff. Actual discrepancies are to be documented via j

the CNS Corrective Action Program.

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Attachment I to NLS970053 Page 8 of 8 The following specific Project responsibilities are assigned to the CNS Staff-.

a)

Nuclear Licensing & Safetv-Licensing is responsible for incorporating the approved rebaselined USAR sections into the CNS USAR in accordance with Station procedures, as well as submitting to the NRC staff the USAR update per 10CFR50.71(c). Licensing is also responsible for keeping the Project team informed of approved USAR changes (generated from outside of the Project) that will affect the content of the USAR sections being rebaselined.

b)

Engineering-Individual engineers will be assigned ownership of each of the chapters / sections of the USAR. The responsibilities of each of the chapter /section owner will be to provide a technical point of contact with the Project team during the source document review process. Also, this individual will perform a technical review of the rebaselined sections drafted by the Project team with the accompanying 10CFR50.59 Safety Evaluations. Other Engineering personnel will similarly perform, as required, a review of the proposed rebaselined USAR sections to ensure accuracy based on their knowledge of SSC design and function.

Engineering is responsible for resolving USAR-related discrepancies assigned to them.

c)

Operations-Operations personnel will be designated as points of contact with the consultant to help facilitate the validation of the rebaselined USAR sections with their implementing Station procedures. An Operations department review will be performed of the proposed rebaselined USAR section packages. Operations is responsible for resolving USAR-related discrepancies assigned to them.

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d)

Ouality Assurance-Ongoing project activities will be monitored by the Quality Assurance Department.

5.0 PROJECT MILESTONES Preliminary Project activities have already commenced. Following the District's approval of the Project Program Plan the actual scoped level of effort will begin. The Project is scheduled for completion by October 1,1998. The following are some major Project milestones:

April 1997 Source document collection and review begins August 1997 Begin rebaselining USAR Sections Febmary 1998 Begin updating USAR with approved rebaselined Sections / Chapters June 1998 Complete the Linkage Database July 1998 Complete updating USAR with approved rebaselined Sections / Chapters October 1998 Complete resolution of US AR-related discrepancies

O LIST OF NRC COMMITMENTS ATTACHMENT 3 j

i Correspondence No:NLS970053 The following table.4dentifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.

Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE OR OUTAGE As described in the cover letter, the District will 10/21/98 perform a comprehensive rebaseline and validation of the CNS USAR of sufficient breadth and scope to assure compliance with the USAR update requirements of 10CFR50. 71 ( e ) and the implementation requirements of 10CFR50.59 and 10CFR50 Appendix B.

PROCEDURE NUMBER 0.42 REVISION NUMBER 2 PAGE 12 OF 16 s