ML20198M846
| ML20198M846 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/15/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-98-0009, W3F1-98-9, NUDOCS 9801200137 | |
| Download: ML20198M846 (5) | |
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..f Ent Operations, Inc. -
KHlona LA 70060 Tel 504 739 6242 Early C. Ewing. he a afety & Regulatory Affairs --
W3F1-98-0009 A4.05 PR-January 15,1998 U.S. Nuclear Regulatory Commission A1TN: Docun,nt Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 UFSAR Review initiatives Gentlemen:
Entergy Operations, Waterford 3, on October 23,1997, via letter W3F1-97-0244 committed to provide to the NRC by January 15,1998, a schedule for completing a review of the UFSAR. This letter provides the schedule and describes our program for completing a review of the Waterford 3 UFSAR. Tlie letter provides the background for our program, briefly describes the program and elements, and identifies the overall schedule for the completion of the UFSAR review initiatives.
Background
Entergy Operations, Waterford 3, has placed significant importance and closely followed industry efforts and issues regarding the fidelity of the UFSAR. In the past few years, we have undertaken many initiatives and programs which have helped us to better understand the problems associated with the UFSAR and to improve the UFSAR. Some of these initiatives and programs include the development of Design Basis Documents (DBDs), upgrade and reconstitution of calculations, upgrade and validation of procedures, self assessments, design basis evaluations, inspections, and a corporate and multi-site review of the UFSAR. Some of the current initiatives and programs include design basis review; development of additional basis
' documents like Containment Isolation DBD, Tomado Design Criteria Document, and Inservice Testing (IST) Basis Document; and development of safety analysis DBDs.p
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W3F1-98-0009 Page 2, LJanuary.1S,1998 3
- These efforts have given us objective evidence substantiating the overall adequacy
- of the UFSAR and of the processes and programs for maintaining the fidelity of the UFSAR. These efforts have also substantiated the need for improvement. We have identified UFSAR discrepancies, acquired an understanding of the reasons for F
- the discrepancies, and gained a better insight for developing initiatives for:
-improving the fidelity of the UFSAR.
In response to the NRC 10CFR50.54(f) on design basis information, Waterford 3
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made a commitment to perform a review of selected sections of the UFSAR. We have since been reviewing certain sections of the UFSAR and have also evaluated possible options for completing the review of the UFSAR. Most importantly, we
. have evaluated the experience gained from ongoing design basis and UFSAR
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review work resulting from the 10CFR50.54(f) commitments.
We are pursuing a multi-faceted approach for completing the review of the UFSAR.
The important elements of our program are an effective review approach, the inclusion of past history and ongoing review experience, and the integration and
. application of organizational processes, standards, and functions in maintaining the
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'idelity of the UFSAR.
Description of UFSAR Review Initiatives The pro 0 ram for reviewing and maintaining the fidelity of the UFSAR is comprised of various ongoing programs and special scope initiatives which include design basis work, the enhancement of the Quality Assurance audit program, now training initiatives, a read through review of the UFSAR, the finalization cf n new site procedure for maintaining the fidelity of the UFSAR, the finalization and use of a Fidelity and Content Guide, and the revitalization and application of a responsibility matrix.
Design Engineenng is implementing a number of initiatives to review selected sections of the UFSAR. The goal of the Design Engineering program for the UFSAR is to achieve a high level of awareness, understanding, and standards for
- Design Engineering elements which are essential to maintaining the accuracy of the UFSAR. These elements include maintaining the accuracy of the information for structures,' systems, and components described in the UFSAR; establishing a firm i
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5 LUFSAR. Review initiatives L
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January 15,1998-
- understanding.in Dasign Engineering of the operating, licensing, and ' design basis.
of Waterford 3; and. continuing or instituting new specific Design Engineering _
initiatives, commensurate with identified deficiencies and needed performance.
standards. The review of selected sections of the UFSAR are being, and will be :
. achieved, by one of the following Design Engineering initiatives:~ The DesQn Basis Review Program, the Safety Analysis DBD program, and the previous and planned
? safety system functional inspections.'
- The QA audit program will be enhanced to include a review of the applicable
- UFSAR section commensurate with the scope and basis of the specific audit being.
performed.
Additional training initiatives will be implemented for the UFSAR. The goal of the
- training program is to achieve a high level of awareness, understanding, and..
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. standards for maintaining the accuracy and completeness of the UFSAR. The training program will convey management expectations for the accuracy and 4
- completeness of the UFSAR, ensure personnel maintain a robust understanding of the operating, licensing, and design basis of Waterford 3; and institute specific training initiatives which address identified deficiencies and needed performance standards.'
L A road through review of the UFSAR will be performed. The objective of the L
UFSAR read through is to provide a defense in depth evaluation of the accuracy and completeness of the UFSAR by reviewing the UFSAR by highly experienced i=
personnel. The primary focus of the review is to identify discrepancies or to identify l
. areas that may require further detailed evaluation or verification.
. A new site procedure will be finalized for maintaining the fidelity of the UFSAR. The objectives of the new procedure will be to:- Re-define basic terms necessary for maintaining an understanding of the UFSAR, delineate responsibilities for
. maintaining the fidelity of the UFSAR, describe a process for identifying and processing discrepancies, communicate management expectations for maintaining
- the fidelity of the UFSAR, and communicate revised guidelines for the scope and
' content of the information which should be included in the UFSAR.-
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4-UFSAR, Review initiativn W3F1-964009 Page4-
- January 15l1996 ~
A Fidelity and Content Guide has been developed and will be finalized. The purpose of this Fidelity and Content Guide is to serve as a guidance document for Waterford 3 personnel in maintaining the fidelity of the UFSAR and determining the con *ent of the information which should be included in the UFSAR. The guide contains management expectations for maintaining the fidelity of the UFSAR, a
. characterization of the discrepancies which have historically been found with the UFSAR, and general standards for the type of information which should be included in the UFSAR.
ii A responsibility matrix will be revitalized. The responsibility matrix is a bre&down of the UFSAR sections and the corresponding primary and secondary departments responsible for maintaining the fidelity of me respective UFSAR sections.
' Overall Program Schedule We plan to complete the process improvement initiatives by April 30,1998. The review initiatives are planned for completion by the end of 1999. Some review initiatives like SSFls will continue on an ongoing basis as needed.
Suremary Remarks We have carefully evaluated the possible approaches for cornpleting a review of and maintaining the fidelity of the UFSAR. The important elements of our program are an effective review approach, the inclusion of past history and ongoing review experience, and the integration and application of organizational processes, standard, and functions in maintaining the fidelity of the UFSAR. A program plan has been prepared to define the objectives, attributes, and specific tasks and schedules of our program. A program manager hes been assigned to ensure these n
tasks and schedules are pursued with vigor. We are collectively committed to achieving high standards of fidelity for the UFSAR.
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UFSAR, Review initiatives W3F1-98-0009 Page5-January 15,1998 t
Please contact Tim J. Gaudet at (504) 739-6666 or myself at (504) 739 6242 should there be any questions regarding this letter.
j Very truly yours, a
E.C. Ewing
- Director, Nucleyr Safety & Regulatory Af' airs ECE/RJM/ lad -
cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR J. Smith N.S. Reynolds NRC Resident inspectors Office 1
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