ML20149M175
| ML20149M175 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/11/1996 |
| From: | Blanch P AFFILIATION NOT ASSIGNED |
| To: | NRC |
| Shared Package | |
| ML20149M049 | List:
|
| References | |
| NUDOCS 9612130019 | |
| Download: ML20149M175 (9) | |
Text
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From:
PAUL M. BLANCH <PMBLANCH91x.netcom.com>
To:
WND2.WNP3(jaz,awd),TWD1.TWP4(gam)
Date:
10/11/96 II:34am
Subject:
50 54 f to all utilities and NEI NRC 50.54f Letter on Design Bases Information Similar Letters Addressed to Chief Executive Officers of NRC-licensed Utilities (Slightly different letter sent to Haddam Neck Nuclear Power Plant).
SUBJECT:
REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) -
REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION
Dear ------- :
4 l
The purpose of this lette'.- is to require information that will - provide the U.S. Nuclear Regulatory Commission (NRC) added = confidence and assurance that your plant (s) are operated and = maintained within the design bases and any deviations are - reconciled in a timely manner.
)
Background
i In the mid-to late 1980s, NRC safety system functional inspections -
(SSFIs) and safety systems outage modifications inspections -
(SS0 mis) identified concerns that design bases information was not - being properly maintained and plant modifications were being made = without the licensee having an understanding of the plant design - bases.
The NRC's findings heighten:'d the nuclear industry's - awareness of the need to improve the adequacy and availability of - design documentation, and many t
licensees voluntarily initiated - extensive efforts to improve the design bases information for their - plants.
]
To assist the industry in performing design bases improvement - programs, the Nuclear Management and Resources Council (NUMARC)[1] = developed a guidance document, NUdARC 90-12, " Design Basis Program -
e Guidelines."
These guidelines were intended to provide a standard =
framework for licensee programs to improve plant design bases =
information.[2] The NRC staff reviewed the guidelines and provided =
comments to NUMARC in November 1990.
In emphasizing the importance - of validating the facility against current design information, the - staff stated that the goal of any program should be to establish - confidence that the existin3 Scility is in accordance with the - current design documents and that any deviations will be reconciled.
The staff concluded that the NUMARC guidelines would provide = worthwhile insights to utilities undertaking design reconstitution - programs and that the guidelines appeared to provide sufficient - flexibility for licensees to 4
structure their programs to respond - most efficiently to any unique needs and circumstances of a - particular licensee. The staff requested NUMARC to consider making - design reconstitution a formal NUMARC initiative and commented that - design documents that support technical specification values and - that are necessary to support operations or to respond to events - should be regenerated if missing. NUMARC subsequently concluded that a formal initiative was not necessary because most of its - members 9612130019 961210 PDR ORG NRRA PDR
i
)
were already conducting or evaluating the need to conduct = design reconstitution programs, and agreed to forward the - guidelines, with the i
NRC's comments, to its members for use on a = voluntary basis, i
To provide more information to the industry on this topic and to = provide 4
an independent view of the design control issue, the staff = conducted a
~
survey of six utilities and one nuclear steam supply = system vendor to determine the status of design control problems - and the strengths and 4
j weaknesses of the sample utility programs.
=
t i
The results were published in February 1991 in NUREG-1397, "An =
Assessment of Design Control Practices and Design Reconstitution =
i Programs in the Nuclear Industry." The survey observations were as =
l follows:
L
-85 The need for a design documentation reconstitution program was = directly proportional to the age of the plant.
-85 The general intent of the program should be to provide a central =
l location for design bases information, with emphasis on the design - intent j
(the "why" of the design).
85 The design bases documents should be a top-level directory that
4 l
defines the current plant configuration.
]
-85 Reestablishment of design bases without reconstitution of the =
supporting design documents, as necessary, may not provide a = sufficient level of information for future modifications or current = plant operation, or to quickly respond to operating events.
85 Minor changes to the design should be tracked to support the
l conclusion that-the changes in the aggregate do not affect the - validity of j
existing calculations and the ability of a system to = perform its design l
functions.
85 Some common weaknesses of licensee programs identified during the
i i
survey included the following:
i
85 Design reconstitution programs had not identified in advance the
documents that are necessary to demonstrate that a structure, a - system, or a 2
j component will function properly.
~
=85 The process for regenerating missing design documentation was not -
always proceduralized so that it could be handled in a systematic = manner.
4
=85 Validation of the content of specific output documentation was = not always thoroughly carried out.
j In late 1991, the NRC staff evaluated whether rulemaking, guidance, = or a i
policy statement was needed to address the issue of licensees = retaining accurate design bases information.
It concluded that the = existing regulatory requirements for design control were adequate; = however, it determined that the publication of a policy statement - addressing design 3
bases information and publication of a generic = letter requesting licensees 1
to describe their design reconstitution = programs would be beneficial.
Additionally, the staff stated its = intention to continue to evaluate design control adequacy during = its performance-based inspections such as SSFIs and SSOMIs. The = staff also expected that the enforcement policy i
guidance to provide = greater opportunities for enforcement discretion [3]
)
would encourage - voluntary identification of past design, engineering, and
= installation issues by licensees. With the Commission's approval, - the j
staff proceeded with this approach.
y
In August 1992, the NRC issued a Comission policy statement
=
j
" Availability and Adequacy of Design Bases Information at Nuclear -
i Power Plants" (57 FR 35455) (Attachment 1). This policy statement =
stressed the importance of maintaining current and accessible - design documentation to ensure that (1) plant physical and = functional characteristics are maintained and consistent with = design bases, (2) systems, structures, and components can perform = their intended functions, i
and (3) the plant is operated in a manner - consistent with the design bases.
In the policy statement, the =
l Commission recommended that all power reactor licensees assess the =
l accessibility and adequacy of their design bases information and = that they be able to show that there is sufficient documentation to
= conclude that the current facility configuration is consistent with = the design bases.
L The policy statement outlined the additional - actions the NRC would take to keep apprised of the industry's - design reconstitution activities previously discussed.
i Following review by the Comittee To Review Generic Requirements =
(CRGR) and the Comission, a draft generic letter was issued for = public comment on March 24, 1993.
The proposed generic letter = requested i
licensees, on a voluntary basis, to submit information = and schedules for any design bases programs completed, planned, or = being conducted, or a i
rationale for not implementing such a = program. All but one of the.
i commenters concluded that the generic = letter was unnecessary and
{
unwarranted. NUMARC responded that it - believed the NRC's request for descriptions, schedules, and dates - would have a negative impact on ongoing design efforts and that
=
{
NRC's focus on schedules would undermine the licensees' ability to = manage the activities.
In SECY-93-292, " Generic Letter on the =
Availability and Adequacy of Design Bases Information," dated =
October 21, 1993, the staff recommended that the generic letter not - be 1
issued. The staff stated that publication of the policy - statement and the i
proposed generic letter conveyed to the industry = the Comission's concern and that publication of the generic letter = would not further licensees' awareness of the importance of the = activities.
The staff proposed to continue performing
- design-related inspections and to gather information and insights as - to how well the licensees' design-related programs were being - implemented.
The Comission issued a staff requirements memorandum =
l that agreed with the staff's proposal.
i In response to the findings relating to the regulatory burden of = team t
inspections identified in the 1991 Regulatory Impact Survey, = during the past several years the staff has reduced its effort on = specific, resource-intensive, design-related team inspections, and = followed the 4
issue of accurate and accessible design documentation = at plants principally as an element of inspection and followup of = ope ations-related activities.
The issuance of the NUMARC = guidelines and ongoing industry efforts to improve and maintain - design bases information also f,
contributed to this decision.
j Current Problem 2
Over the past several months, NRC's findings during inspections and =
j reviews have identified broad programatic weaknesses that have = resulted
~.~,
- ~..-
3 9
i in design and configuration deficiencies at some plants, = which could j
impact the operability of required equipment, raise - unreviewed safety questions, or indicate discrepancies between the = plant's updated final safety analysis report (UFSAR) 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 = known degraded and nonconforming conditions and 3
for past violations = of NRC requirements has not been evident.
- Overall,
{
the NRC staff = has found that some licensees have failed to (1)
]
appropriately = maintain or adhere to plant design bases,[4]
(2) appropriately = maintain or adhere to the plant licensing basis,[5]
(3) comply with - the terms and conditions of licenses and NRC regulations, and 4
j (4) = assure that UFSARs[6] properly reflect the facilities. Attachment
=
2 provides examples of some of the deficiencies recently identified = by the staff. As a consequence of this new information, the NRC = believes that i
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.
J The magnitude and scope of the problems thht the NRC staff has = identified raise concerns about the presence of similar design, - configuration, and operability problems and the effectiveness of = quality nsurance programs at other plants. Of particular concern = is whether licensee programs to l
maintain configuration control at = plants licensed to operate are j
sufficient to demonstrate that plant = physical and functional characteristics are consistent with and are - being maintained in accordance 4
with their design bases. The extent - of the licensees' failures to j
maintain control and to identify and = correct the failures in a timely 1
manner is of concern because of = the potential impact on public health and safety should safety - systems not respond to challenges from off-normal and j
accident = conditions.
}
It is emphasized that the NRC's position has been, and continues to - be, that it is the responsibility of individual licensees to know - their i
licensing basis, to have appropriate documentation that = defines their design bases, and to have procedures for performing = the necessary 1
assessments of plant or procedure changes required by =
I NRC regulations.
Attachments 3 and 4 are a recent exchange of =
correspondence between J.
Colvin, NEI, and Chairman S. Jackson, =
j NRC, regarding these subjects.
j Action I
i The NRC has concluded that it requires information that can be used - to i
verify compliance with the terms and conditions of your = license (s) and NRC regulations, and that the plant UFSAR(s) = properly describe the facilities, as well as to determine if other = inspection activities [7] or enforcement l
action [8] should be taken.
=
1 Therefore, you are required, pursuant to Section 182(a) of the -
4 Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f), to = submit a i
response to this letter within 120 days of its receipt.
=
Your response must be written and signed under oath or affirmation.
j l
]
4 i
i Please submit the original copy of your response to the NRC -
1 Document Control Desk, and send a copy to the Director, Office of -
Nuclear Reactor Regulation and to the appropriate regional - administrator.
)
The following information is required for each - licensed unit:
?
(a)
Description of engineering design and configuration = control processes, including those that implement 10 CFR 50.59,
=
10 CFR 50.71(e), and Appendix B to 10 CFR Part 50; l
j (b)
Rationale for concluding that design bases requirements - are translated into operating, maintenance, and testing - procedures; (c)
Rationale for concluding that system, structure, and = component
[
configuration and performance are consistent with the - design bases; i
(d)
Processes for identification of problems and - implementation of corrective actions, including actions to - determine the extent of problems, action to prevent recurrence, - and reporting to NRC; and i
(e)
The overall effectiveness of your current processes and =
programs in concluding that the configuration of your plant (s) is -
l consistent with the design bases.
In responding to items (a) through (e), indicate whether you have undertaken any design review or reconstitution programs, and if not, - a 1
{
rationale for not implementing such a program.
If design review - or reconstitution programs have been completed or are being - conducted, j
provide a description of the review programs, including = identification of the systems, structures, and components (SSCs), = and plant-level design j
attributes (e.g., seismic, high-energy line - break, moderate-energy line break). The description should include - how the program ensures the-correctness and accessibility of the - design bases information for your 4
plant and that the design bases - remain current.
If the program is being conducted but has not been - completed, provide an implementation schedule j
for SSCs and - plant-level design attribute reviews, the expected completion j
date, - and method of SSC prioritization used for the review.
f This request is covered by the Office of Management and Budget -
(OMB) clearance number 3150-0011, which expires July 31, 1997.
The -
i reporting burden for this collection of information is estimated to -
I average 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> per response, including the time for reviewing -
i instructions, searching existing data sources, gathering and - maintaining the data needed, and completing and reviewing the - collection of information.
Send comments regarding this burden - estimate or any other aspect of this collection of information, = including suggestions for reducing this burden, to the Information = and Records Management Branch j
(T-6 F33), U.S.
Nuclear Regulatory -
1 Commission, Washington, D.C. 20555-0001, and to the Desk Officer, =
i Office of Information and Regulatory Affairs, NE0B-10202 2
(3150-0011), Office of Mknagement and Budget, Washington, D.C. 20503. -
The NRC may not conduct or sponsor, and a person is not required to =
respond to, a collection of information unless it displays a - currently valid OMB control number.
i l
i
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a - copy of this letter and your response will be placed in the NRC -
Public Document Room (PDR), the Gelman Building, 2120 L Street, -
N.W.,
Washington, DC, and in the local public document room (s) for - your facility or facilities.
If you have any questions about this matter, please contact the = staff members listed below, or the appropriate Office of Nuclear -
Reactor Regulation (NRR) project manager.
Sincerely, James M. Taylor Executive Director
- for Operations Docket Nos. STN 50-528, STN 50-529 & STN 50-530 Attachments:
1.
Policy Statement on Availability and Adequacy of =
Design Bases Information at Nuclear Power Plants 2.
=
Background Information on Recently Identified Problems 3.
Letter = from J.
Colvin (NEI) to Chairman S. Jackson (NRC) dated =
8/2/96 4.
Letter from Chairman S. Jackson (NRC) to J. Colvin (NEI) =
dated 8/14/96 Contacts: Kristine M. Thomas, NRR (301) 415-1362 Internet:
= kmt9nrc. gov Eileen M. McKenna, NRR (301) 415-2189 Internet:
= emm9nrc. gov Notes:
1.
NUMARC was consolidated into the Nuclear Energy Institute (NEI) - on March 23, 1994.
2.
As discussed in NUMARC 90-12, these programs or efforts would - emphasize collation of design basis information and the supporting - design information, not the identification or re-creation of the - licensing basis for a plant or the regeneration of missing analyses - and calculations.
3.
NRC would refrain from imposing civil penalties for violations up = to Severity Level II if the violations were identified and corrected - as a result of systematic voluntary initiatives 4.
As described in 10 CFR 50.2, design bases is defined as, " Design - bases mean that information which identifies the specific functions - to be performed by a structure, system, or component of a facility, = and the specific values or ranges of values chosen for controlling - parameters as reference bounds for design..." The design bases of a - facility, as so defined, is a subset of the licensing basis and is = contained in the FSAR.
l i
i Information developed to implement the design - bases is contained in other i
documents, some of which are docketed and - some of which are retained by the j
licensee.
5.
The licensing basis for a plant originally consists of that set - of information upon which the Commission, in issuing an initial - operating
{
license, based its comprehensive determination that the - design,
}
construction, and proposed operation of the facility - satisfied the Commission's requirements and provided reasonable - assurance of adequate i
protection to public health and safety and - common defense and security. The licensing basis evolves and is - modified throughout a plant's licensing term i
as a result of the =
Commission's continuing regulatory activities, as well as the - activities of the licensee.
4 6.
The FSAR is required to be included in, and is one portion of, an -
application for an operating license (OL) for a production or = utilization facility.
10 CFR 50.34(b) describes the information = which must be included in an FSAR. The FSAR is the principal = document upon which the Commission bases a decision to issue an OL = and is, as such, part of the licensing basis of a facility.
It is - also a basic document used by NRC inspectors to determine whether the - facility has been constructed and is operating within the license - conditions.
7.
A number of design bases inspections are being planned, and your -
response will be used in the planning process.
8.
A number of design bases inspections are being planned, and your -
response will be used in the planning process.
recently approved - changes that would modify this policy to encourage licensees to - undertake voluntary initiatives to identify and correct FSAR - noncompliances by (I) the exercise of discretion to refrain from - issuing civil penalties for a two-year period where a li.censee - undertakes a voluntary initiative in this area and (2) the exercise - of discretion to escalate the amount of civil penalties for -
violations associated with departures from the FSAR identified by the -
NRC subsequent to the two-year voluntary initiative period.
THE FOLLOWING IS IN RESPONSE TO NEI-89S OBSTRUCTIONIST ACTIVITIES NRC Letter to Nuclear Energy Institute August 14, 1996 Mr. Joe F. Colvin President and Chief Executive Officer Nuclear Energy Institute Suite 400 1776 I Street, N.W.
1 Washington, D.C.
20006-3708
Dear Mr. Colvin:
I am responding to your letter of August 2,1996, concerning industry =
~ --
4 i
actions for assessing programs in place to reaffirm that nuclear - power plants are operated in conformance with their licensing basis.
Your letter also identified three issues that, in your view, require = mutual i
agreement between the industry and the Nuclear Regulatory =
Commission (NRC) before the industry would proceed with the - initiative.
(1) i the legal standing of the Updated Final Safety =
Analysis Report (FSAR) and the NRC's Safety Evaluation Reports; (2) = the j
scope of what constitutes the current licensing basis; and (3) = the adequacy of NSAC-125, " Guidelines for 10 CFR 50.59 Safety =
Evaluations," for performing 10 CFR 50.59 evaluations.
We believe that resolution of the issues you identified is not a =
]
prerequisite to reviewing, on a retrospective basis, whether existing -
programs are sufficient to ensure that licensees know their licensing = bases, 2
whether licensing bases have been properly maintained, and - whether i
licensing bases are accurately described in each facility's - updated FSAR or other documents. The significant issues recently = identified by licensee reviews and NRC staff inspections relate to = failures to address degraded and nonconforming conditions properly, = failures to perform reviews required by I
10 CFR 50.59 before making = changes to facilities, and failures to update facility Final Safety =
Analysis Reports in accordance with 10 CFR 50.71(e).
In our view, - industry initiatives can proceed notwithstanding that ongoing NRC = activities under the 10 CFR 50.59 Action Plan will consider, in a = broad sense, issues such as
+50se you raise, j
Existing regulations and guidance are sufficient to conduct a - retrospective review for conformance to existing regulatory = requirements. These. include:
4 l
(1) NRC regulations 10 CFR 50.2, 50.34, -
4 50.54,50.59,'50.71(e),50.72,50.73 and Appendix B; (2) NRC's policy =
statement - Availability and Adequacy of Design Bases Information at =
Nuclear Power Plants, 57 FR 35455 August 10, 1992; (3) " Design Bases =
Program Guidelines," NUMARC 90-12 and NRC letter dated November 9, =
3 1990; and (4) Generic Letter 91-18, "Information To Licensees =
i Regarding Two NRC Inspection Manual Sections On Resolution Of =
1 Degraded And Nonconforming Conditions And Operability."
The staff is concerned, however, that the proposed initiative may not - be of sufficient scope and depth to identify the types of design and = openbility problems recently identified at several operating plants. =
Specifically, it is not sufficient to perform a process / procedural = based review. An in-depth vertical slice review of actual design - basis documentation and comparison of "as built" and "as operated" = safety systems is more appropriate.
For example, reviews similar to safety system functional inspections =
(Inspection Procedure 93801, " Safety System Functional Inspections"), = may be used to evaluate a licensee's program effectiveness to = maintain the licensing and design bases. These reviews should - include: (1) an in-depth i
review of selected systems' design and - design basis since issuance of the facility operating license; (2) = risk-and safety-based criteria for selection of systems for review; = and, (3) a method to ensure that licensee i
problem identification and = corrective action on the selected systems are i
representative and = consistent with other systems. The in-depth review
1 l
l should examine:
(1) engineering design and configuration control; (2) verification of -
as-built and as-modified conditions; (3) translation of the design - bases requirements into operating procedures, maintenance, and - testing; (4) verification of system performance through review of - tes t records and observations of selected testing; (5) proposed and - implemented corrective actions for licensee-identified design - deficiencies; and, (6) modifications made to the systems since - initial licensing.
In short, the NRC position has been, and is, that it is the - responsibility of individual licensees to know their licensing basis, - to have appropriate documentation that defines their design basis, - and to have procedures for performing the necessary assessments of - plant or procedure changes required by NRC regulations.
Until such - time that any regulation changes are made as a result of NRC action - plan activities, we will continue inspection and oversight activities - related to the design basis to ensure compliance with existing - regulations.
Sincerely, Shirley Ann Jackson Paul M. B1anch Energy Consultant 135 Hyde Rd.
West Hartford CT 06117 Voice 860-236-0326 Fax 860-232-9350
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