ML20147H961

Requests Answers to Listed Questions in Order to Assist in Evaluation of Commission Paper Re SECY-96-189, 10CFR50.54(f) Ltrs on Availability & Adequacy of Design Basis Info. Commissioner Diaz Comments on Paper Encl

ML20147H961
Person / Time
Issue date:	09/13/1996
From:	Dicus G NRC COMMISSION (OCM)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20147H952	List: IA-96-466, Submits Followup to Earlier Conversation ML20147H945 ML20147H961 ML20147H975 ML20147H981 ML20147H986
References
FOIA-96-466 SECY-96-189-C, NUDOCS 9704100057
Download: ML20147H961 (12)

Text

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• September 13,1996 a

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,A MEMORANDUM TO:

James M. Taylor

..: i i 4A gg Executive Director for Operations FROM:

Greta J. Dicus Co3&

g Commissioner YO;.

SUBJECT:

SECY-96-189,10 CFR 50.54(f) LETTERS ON THE Q, p AVAILABILITY AND ADEQUACY OF DESIGN BASIS cc_:

INFORMATION To assist irt my evaluation of the action requested by this paper, I request that the following questions be addressed:

1.

The paper seems to base the need for information from all licensees primarily on the findings from Millstone and Haddam Neck, all of which are operated by Northeast Utilities. How was the staff able to conclude that similar types of deficiencies and the associated safety significance or regulatory significance are also likely to exist at other NRC licensed plants to the extent that 50.54(f) letters i

to alllicensees are warranted. Wss supplementalinformation also used in making such a determination?

2.

What are the anticipated staff resource implications involved in the review of licensee responses, and the schedule or time table in which the staff will complete its reviews? How does staff plan to respond to the licensees once the reviews have been completed?

3.

The staff, through Requests Nos.1 and 2 of the proposed 50.54(f) letter, strongly implies that NRC wants licensees to implement a design review or design basis reconstitution program that contain the various elements of Subitems (a) and (b).

It also appears that information relating to several separate and distinct administrative programs or processes are being requested in subitems (a) through (e) of the letter Corrective Action, design change, configuration control, i

quality assurance, problem identification and resolution, operability determinations, and 50.59 evaluation procedures.

These all appear to be programs of which the NRC has been conducting inspections in order to assess licensee performance and program effectiveness.

If this information is available through inspection reports, what is the purpose of requesting this information from each licensee now?

970410o057 970400 PDR FOIA WILLIAM 9,6-466 PDR

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Since the questions seem to relate more to process than results, how will the information that is requested by the 50.54(f) letters allow the staff to determine l

whether a particular licensee or plant is performing well or poorly with respect to maintaining their plants in accordance with their designs and design documents, or whether they have an effective design basis management program, which in l

tum, would help the staff better prioritize and focus its future design-related insp)ection activities? -

WMaltematives to a 50.54(f) letter were considered (i.e., limited number of team inspections)? -

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i (EDO Suspense - 9h96) l t

SECY, please track.

cc:

Chairman Cmr. Rogers l

l Cmr. Diaz Cmr. McGaffigan SECY i

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l-1 AVAILABILITY AND ADEO.UACY OF DESIGN BASES INFORMATION NEED FOR 50.54(f) LETTER TO LICENSEES i

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SEPTEMBER 18,1996 i

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NEED FOR STAFF PROPOSED ACTION i

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 e

GAIN ADDITIONAL CONFIDENCE THAT LICENSEES ARE OPERATING THEIR.

PLANTS UNDER THE TERMS AND CONDITIONS OF THEIR LICENSES

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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 Survey A GAO reporton South Texas A Revised Enforcement

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A FSAR inspection A Polic Statement: Adequacy & Availability ident o

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f Design Bases Information outside license A NUREG 1397: Assessmentof A Maine Yankee E------~~--A Design Reconstitution Programs SBLOCA Analysis A Generic Letter 91-18 A NUMARC 90-12 Design A Millstone Basis Documentation SFP issues i

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HISTORY OF ISSUES' MID-TO-LATE NRC TEAM INSPECTIONS IDENTIFY POTENTIAL PROBLEMS WITH DESIGN 1980's BASES DOCUMENTATION AFFECTING SAFETY SYSTEM FUNCTIONALITY / OPERABILITY a ggp.f]J ' 53o g fj.J EARLY 1990 INDUSTRY RESPONSE - NUMARC 9012 AND VOLUNTARY INDUSTRY EFFORT TO IMPROVE DESIGN BASES INFORMATION 1

LATE 1990 NRC ENDORSES NUMARC 9012 WITH COMMENTS 1

.1221 REGULATORY IMPACT SURVEY IDENTIFIES REGULATORY BURDEN OF NRC TEAM INSPECTIONS ON LICENSEES i

l 1122 STAFF CONSIDERS OPTl'ONS FOR ADDRESSING ISSUE OF ACCURATE DESIGN BASES INFORMATION STAFF CONCLUDES THAT CHANGES TO REGULATIONS WERE NOT

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NEEDED. RECOMMENDS lSSUANCE OF A POLICY STATEMENT TO NW

'l OUTLINE NRC EXPECTATIONS AND GENERIC LETTER THAT WOULD REQUEST LICENSEES TO DESCRIBE THEIR PROGRAMS FOR ADEOUACY M4I M %/.4

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AND AVAILABILITY OF DESIGN BASIS

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COMMISSION ISSUES POLICY STATEMENT

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pk ENFORCEMENT POLICY REVISED TO ALLOW ENFORCEMENT DlS p

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FOR SELF IDENTIFIED DESIGN BASES DEFICIENCIES DRAFT GENERIC LETTER ISSUED FOR COMMENT. INDUSTRY STATES g' p.g 1222g sytJuJM THAT GENERIC LETTER IS UNNECESSARY. STAFF p gjbep-GENERIC LETTER WOULD NOT FURTHER LICENSEES' AWARENESS OF gMHE IMPORTANCE OF THE ISSUE 1915.

ENGINEERING CORE INSPECTION PROGRAM REVISED TO EMPHASIZE OPERATIONS. INSPECTIONS REFOCUSED TO EVALUATE HOW WELL

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Uf TOWERS PERRIN REPORT PRESENTED REOULATORY BURDEN ISSUES I

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COMMISSION SRM DIRECTS STAFF TO MONITOR AND TRACK VOLUNTARY INDUSTRY PROGRAMS l

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STAFF DETERMINES THAT TOTAL ENGINEERING EFFORT FOR DESIGN-RELATED TEAM INSPECTIONS DECREASED SINCE ISSUANCE OF THE 7

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

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

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EVIDENCE IS BUILDING THAT PROBLEM WITH ACCURACY OF DESIGN BASIS e

INFORMATION IS NOT LIMITED TO MILLSTONE AND HADDAM NECK 4

DESIGN AND ENGINEERING INFORMATION HAS NOT BEEN APPROPRIATELY e

MAINTAINED OR ADHERED TO AT A NUMBER OF OTHER PLANTS (SPENT FUEL POOL COOLING - CRYSTAL RIVER - DRESDEN - MAINE YANKEE -

QUAD CITIES - SALEM - ZION)

~ ELIANCE ON INDUSTRY VOLUNTARY EFFORTS HAS NOT BEEN SUFFICIENT TO R

e MAINTAIN CONFIGURATION CONTROL A1SOME PLANTS AUGUST 1996, NEl PROPOSES LICENSING BASES INITIATIVE, CONDITIONED ON e

RESOLUTION OF THREE ISSUES. INITIATIVE IS SIGNIFICANTLY LESS THAN NUM, ARC 90-12 IMPROVEMENTS. CHAIRMAN JACKSON INFORMS NEl THAT INITIATIVE MISSES THE MARK d

CONSISTENT WITH CHAIRMAN'S RESPONSE TO NEl'S INITIATIV5, STAFF e

DETERMINES THAT INSPECTIONS ARE NECESSARY IN THE AREA OF DESIGN BASES DOCUMENTATION TO ESTABLISH CONFIDENCE THAT DESIGN BASES ARE BEING Malt'TAINED AND THAT PLANTS ARE BEING OPERATED WITHIN THE DESIGN BASES i

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BENEFITS OF PROPOSED ACTION l

TO APPROPRIATELY PLACE THE BURDEN ON LICENSEES OF TELLING NRC e-WHERE THEY STAND ON lMPLEMENTING THE VOLUNTARY EFFORT TO IMPROVE.

THE DESIGN BASES INFORMATION FOR THElR PLANTS i

e INFORMATION WILL PROVIDE A BETTER MEANS OF SELECTING AND.

PRIORITIZ4NG PLANTS FOR INSPECTIONS e

NRC DOES NOT HAVE SUFFICIENT RESOURCES TO PERFORM INSPECTIONS AT 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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7-FOLLOW-UP ACTIONS 1

AFTER COMMISSION APPROVAL TO ISSUE THE 50.54(f) LETTERS, THE STAFF WILL ESTABLISH:.

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. lNTERNAL REVIEW GROUP TO EVALUATE THE RESPONSES e-SCHEDULE FOR INSPECTIONS AT PLANTS d$10 W ano 9Y2% ?

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Comissioner Diaz' Comments on SECY-96-189

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'I approve issuance of the proposed 50.54(f) letter under the signature of.the i

EDO with the following coments:

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1) 1: agree with the modifications to the letter sug Jackson and Commissioners McGaffigan and Dicus. gested by Chairman p

W 2)

I understand that the primary use 'of.the information gained from the

' responses to these letters will'be to select and prioritize slants for upcoming inspections.

I also understand that the need for t.1ese 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 phrase on page 5 "to decide whether to-modify, suspend, or revoke the 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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of the potential impact on public health and safety should safety systems not i

respond to challenges from off-normal and accident conditichs.

l It is emphasized that the NRC posities has been, and continues to be, that it is the responsibility of. Individual licensees to know their licensing basis, i

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. Attact,ments 3 and 4 are a recent exchange of correspondence between J. Colvii., NEI, and Chairman S. Jackson, NRC. regarding these subjects.

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

l compliance with the terms and conditions of your license (s) and NRC regulations,and assure.that the plant UFSAP(s) pigerly desr. ribe the

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i you are required, pursuant to Section 182(a) of the Atomic tr,ergy 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 respense must be written and rigned under oath or affirmation.

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Please submit your response to the Director, Office of Nuclear Reactor Regulation, with a copy to the appropriate rsgional administrator and to the NRC Document Control Desk. The following in.'ormation is required for each j

licensed unitt

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(1)

A description of any design review or reconstitution programs, 5

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 i

ensure the correctness and accessibility of the design bases infonnation for your plant and to ensure that it is maintained current.

at the program is planned or being conducted but has not i

been completed, prov<de an implementation schedcle for systems, structures, and components, and plant-level desigr. attribute reviews and the expected completion date.

i (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 ef particular interest, as expressed in NUMARC 90-12, the staff's comments on the industry guidelines, and the Commission policy statement:

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In SECY-93-292, " Generic Lettier on the Availability and Adequacy of Design F

Bases:Inforuation " 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 c

further licensees' awareness of the importance of the activities.

The staff q

proposed to continue performing design-related inspections and to gather-i Information.and insights as to how well the licensees' des 13n-related programs were being 'aplemented. The Commission issued a staff requ resents memorandum that agreed with the staff's proposal.

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In response to the findings relating to the regulatory burden of team i

inspections identified in the 1991 Regulator 2 Impact Survey, during the past several years, the staff has reduced its effort on specific, resource-intensive, casign-related team inspections, and followed the issue of accurate i

and accessille~ design documentation at plants principally at an element of inspection and followup of operations-related activities.

.'he issuance of the NUMARC guidelines and ongoing industry efforts to improve a nd maintain design i

l bases information also contributed to this decision.

Current Prollag-gg Over the past several months, NRC's fin ings during inspections and reviews have' identified broad programmatic wea esses that have resalted in design and configuratica deficiencies at : " r ;f plants which could impact the 1

operability of required equipment, raise unreviewed safety questions, or indicate distrepancies between the plant's updated final sa ety analysis r

report (UFS/R) and the as: built or as-modified plant or plant operating procedures. These inspections and reviews have also highlighted numerous i

instances in which timely and complete implementation of corrective action for known degraded and nonconforming conditions and for past violations of NRC 1

requirements has not been evident. Overall, the NRC staff has found that some i

l licensees have failed (1) to appropriatel licensing and design bases information, (y maintain or adhere to plant 2)'to comply wi conditions of licenses and NRC regulations, and (3) to assure that UFSARs properly reflect the faci 1%s. Attachment 2 provides examples of soc:e of l

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 presen:e of similar design, configuration, and 4

eperabilityproblemsandtheeffectivenessofqualityassuranceprograms, jog #fg

^ --- 3 :t * - C.,. Of particular concern is whether licensee programs i

to manntain configuration control are sufficient to demonstrate that plant physical and functional characteristics are con # stent with the design bases and whether operating plants are being maintal in accordance with their j

L design basis. The extent of the licensee's ilures to maintain control and to identify and correct the failures in imely manner is of concern because dallplads

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