ML20147H093
| ML20147H093 | |
| Person / Time | |
|---|---|
| Issue date: | 09/23/1996 |
| From: | Pulley D NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Conran J NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| Shared Package | |
| ML20147H050 | List: |
| References | |
| FOIA-96-466 NUDOCS 9704020148 | |
| Download: ML20147H093 (1) | |
Text
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From:
Deborah Pulley /.# 6 #
4 To:
TWD1.TWP4(JHC). M/64#
Date:
9/23/96 10:53a t
Subject:
Meeting re: 50.54(f) letters -Reply -Reply i
4 Are you available to meet with Steve Burns regarding above subject in his office on Tuesday. Oct. 2: 1996 at 10:00am.
Please - e-mail me back a reply.
Thanks.
2 l
Yes.
I'll be there. Thank you.
Jim Conran i
iiteely 2 Thanks for your prompt reply.
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I 9704020148 970327 PDR FOIA WILLIAM 96-466 PDR
- a NOTATION VOTE l
RESPONSE SHEET TO:
John 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 Disappreved Abstain Not Participating Request Discussion COMMENTS:
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Release Vote
/ V/
9/.1[/9 S DATE l
Withhold vote
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Entered on "AS" Yes No f
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Commissioner Diaz' Comments on SECY-96-189 I approve issuance of the proposed 50.54(f) letter under the signature of the E00 with the following cpmments:
1)
I agree with the modifications to the letter suggested by Chairman Jackson and Commissioners McGaffigan and Dicus.
2)
I understand 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 tiese inspections is based, in part, on staff's findings that some licensees have failed to maintain configuration control and the concern that industry's voluntary efforts have not been effective in all cases.
3)
I recommend deletion of the 3hrase on page 5 "to decide whether to modify. suspend, or revoke t1e operating license (s) for your facility or facilities. or whether other inspection activities 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 the attached pages.
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O Mr. [Name),
1 of the potential impact on public health and safety should safety systems not respond to challenges from off-normal and accident conditions.
4 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 between J. Colvis, NEI, and Chairman S. Jackson,
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NRC, regarding these subjects.
j Action 2
i The NRC has concluded that it requires information that can be used to verify compliance with the terms and conditions of your license (s) and NRC
- i regulations,nd.J,LL ay k c
- d te-deciWc7 h!t:.e. iv W ffyand. assu facilities
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r a fer:--.t utier. 5heind 6 W.! Iherefore, you are required, pursuant to Section 182(a) of the Af5mTE ERErgy Act of 1954, as amended, and 10 CFR 50.54(f), to submit a response to this letter within 120 days of its receipt.
Your response must be written and signed under oath or affirmation.
Please submit your response to the Director, Office of Nuclear Reactor Regulation, with a copy to the appropriate ragional administrator and to the NRC Document Control Desk.
The following information is required for each i
licensed 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 industry guidelines, and the Commission policy statement:
4
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Mr. [Name) !-
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i In SECY-93-292, " Generic Letter on the Availability and Adequacy of Design Bases Information," dated October 21, 1993, the staff recommended that the
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generic let'.er not be isrued.
The staff stated that publication of the policy statement and the propo',ed generic letter conveyed to the industry the
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Commission's concern and that publication of the generic letter _would not
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further-licensees' awareness of the importance of the activities. The staff proposed to continue performing design-related inspections and to gather i
i informatinn.and insights as to how well the licensees' desijn-related programs were being 'aplemented.
The Commission issued a staff requirements memorandum l
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
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i several years, the staff has reduced its effort on specific, resource-i intensive, cesign-related team inspections, and followed the issue of accurate and accessille design documentation at plants principally as an element of inspection a nd followup of operations-related activities.
The issuance of the i
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NUMARC guidtlines and ongoing industry efforts to improve aid maintain design
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bases information also contributed to this decision.
f.
Current Prot].gg gg Over the pas t several months, NRC's fin ings during inspect ons and reviews i
have identified broad programmatic wea esses that have res.lted in design and I
configuratic i deficiencies at : % M plants which coule impact the I
operability of required equipment, raise unreviewed safety buestions, or indicate dis repancies between the plant's updated final sa ety analysis j
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 y
known degraded and nonconforming conditions and for past violations of NRC requirements has not been evident. Overall, the NRC staff has found that some licensees have failed (1) to appropriately maintain or adhere to plant licensing and design bases information, (2) to comply with the terms and i
conditions of licenses and NRC regulations, and (3) to assure that UFSARs i
properly reflect the facilities. Attachment 2 provides examples of some of i-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 i
with NUMARC 90-12, the staff's comments on the industry guidelines, and the l
Commission policy statement, have not been effective in all cases.
i The_ magnitude and scope of the problems that the NRC staff has identified raise concerns about the presence of-similar desi n, configuration and operability problems and the effectiveness of qua ity assurance pro, grams [g i
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.M-d n t +% C...j.
Of particular concern is whether licensee programs to maintain configuration control are sufficient to demonstrate that plant i
physical and functional characteristics are cont /istent with the design bases l
and whether operating plants are being maintal in accordance with their i
design basis.
The extent of the licensee's ilures to maintain control and
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to identify and correct the failures in imely manner is of concern because d
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