ML20202J408
| ML20202J408 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/08/1997 |
| From: | Olivier L BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-293-97-06, 50-293-97-6, BECO-2.97.128, NUDOCS 9712110145 | |
| Download: ML20202J408 (7) | |
Text
a Boston Edison Pilgrim Nuclear Powr S': lion RocAy Hill Road Plymouth. Massachusetts 02360 L.J. Olivier
%ce President Nuclear and Station Director December 8,1997 BECo Ltr. 2.97.128 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-293 License No, DPR 35 Eupolemental Response to NRC 50.54(f) Letter Reaardina Adeauacy and Availability of Desian Bases Information in response to the NRC's request for information about the adequacy and availability of design basis information requested under 10 CFR 50.54(f), Pilgrim Station responded on February 10,1997 (BECo letter 2.97 014). On June 24,1997 (BECo letter 2.97-067), we supplemented this response to provide the preliminary scope of our evaluation of the UFSAR as committed in the first response. This letter is a second supplement that provides docketed commitments made in an enforcement conference on November 21,1997, and requests the NRC to reschedule an Architect-Engineer (A E) inspection currently scheduled for January 20,1998.
As described in the June 24,1997 letter, changes were enacted to our corrective action program such as the lowering of the threshold for the identification of potential problem areas, in relation to the UFSAR, these lowered thresholds identified discrepancies in the UFSAR and design bases documents that warranted the performance of root cause analyses to ensure timely and comprehensive corrective actions were prescribed and enacted, in addition, root cause analyses conducted as a result of design control issues identified in NRC Special Inspection Report 97-06, dated October 21,1997, showed the lack of a clearly documented design basis as a major contributor.
Accordingly, among the corrective actions planned are a design basis and licensing basis documentation program. The scope and schedule of these and other related planned efforts are desenbed in the enclosure.
We presented the scope of the corrective actions planned, in part, during an enforcement conference at Region 1 Headquarters on November 21,1997. Elements of the planne corrective actions for the design controlissue include:
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documenting the design basis documenting the licensing basis e
'e upgrading the UFSAR quality of information to distinguish design basis documentation from design information strengthening management attention on the corrective action program backlog open items and their completion reviewing operating procedures to ensure they contain correct design e
information and operating instructions.
Due to the magnitude of these corrective actions, we request NRC consideration for rescheduling the A E inspection currently schedulert to take place at Pilgrim commencing January 20,1998. Our rationale for this request is summarized.
An inspection of this proportion at this point in time would create an approximate 3 5 month schedule impact on the already underway design basis and licensing basis information documentation projects.
The same Pilgrim resources now working on these projects would need to support the rigorous information and documentation retrieval demands associated with the A E inspection.
For the most part, we believe such an inspection would duplicate the findings of the recently conducted NRC SpecialInspection Report 97 05, which underscored our corrective action program findings relating to the need to upgrade our UFSAR and conduct an in-depth design basis and licensing basis documentation effort.
Therefore, we request the NRC consider rescheduling the A E inspection until at least mid-year 1999. This will afford us time to complete a major pnrtion of the initial effort which, according to industry sources and peers, is considered to be the most labor intensive aspect of the project.
We appreciate your consideration of this request and intend to keep the NRC abreast of our progress with an update letter and/or presentation during the first quarter of 1998 and to provide periodic updates thereafter.
This letter contains the following commitments.
Document as design bases reports, the design and licensing bases for Pilgrim Station. Complete on or before the fourth quarter 2001.
Retrieve and review the licensing correspondence docket file and identify UFSAR discrepancies or omissions. Complete on or before the fourth quarter 1998.
Update the UFSAR as appropriate as each design basis report is completed.
Update the status of this effort with a letter and/or presentation during the first quarter 1998.
Update the Standard Technical Specification conversion project schedule in accordance with the committed design and licensing bases documentation efforts.
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. J. Olivier
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Mr. Alan B. Wang, Project Manager 1
Pro}ect Directorate 13 Office Of Nuclear Reactor Regulation Mail Stop: OWF 1482 l
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11555 Rcckville Pike i
I-Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region i 475 Allendale Road King of Prussia, PA 19406 o
Senior Resident inspector -
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Enclosure In our June 24,1997,50.54(f) supplementalletter, we discussed the formation of a team to perform a root cause analysis of discrepancies identified in the UFSAR. The discrepancies were the result of a focused UFSAR self assessment. This root cause and others performed to address the design controlissues identified in NRC Special Inspection 97 05 identified the lack of a reasonably retrievable and clearly documor.ted design and licensing basis as major contributors to the problems under evaluation. As a corrective action, Pilgrim Station has committed to a formal design and licensing basis program that willinclude an update of the UFSAR information quality. The program consists of several parts: retrieving formal design basis documents; upgrading, updating, and consolidating design information in calculations, reports, and studies; reviewing existing technical specifications and converting them to Improved Standard Technical Specifications; retrieving the entire Pilgrim Station docketed correspondence file and assessing for impacts on the design basis, licensing basis, and UFSAR; reviewing plant operation procedures against the design and licensing basis to ensure procedures contain accurate design basis and licensing basis information.
The objectives of the above activities are to organize, verify, and validate the Pilgrim design basis, document information as appropriate, ensure plant procedures contain complete and accurate des!gn information, and create a living document suppoited by a sound document maintenance program.
Desian Basis Documents To address issues conceming retrievability and clarity of design basis information, Pilgrim developed a proceduralized approach to the collection and organization of the current design basis in a control'ed document. System design basis reports (DBRs) will be created for specified systems containing a consolidated summary of design basis values with explanations of the basis and relationship to design functions. The DBR will also provide the list of supporting references. Special DBRs will be developed for topical areas not associated with a specific system such as the accident analysis, fire protection, and equipment qualification. The Special DBRs will state the design and licensing basis and explain the inputs, assumptions, and evaluations used to address the topical issue for Pilgrim Station.
The DBR program was developed based on guidance from a self assessment team chartered to identify the current condition of design basis information and develop a vision for its management and use from an end user viewpoint. The team used information gathered from industry peers as well as NUREG 1397 and NEl 97 04 as guidance. Information being gathered for the development of the above DBRs includes, but is not limited to :
Applicable industry codes and standards Licensing documents (regulations, current licensing basis, other e
correspondence)
Engineenng files 1
Architect Engineer files Nuclear Steam Supply System vendor files Equipment specifications / drawings / calculations Dunng the process of developing these design documents and reviewing station operating procedures against this information, discrepancies are expected to be identified. Discrepancies will be entered into the Pilgrim Station corrective action program for assessment and resolution. Generic Letter 91 18, Revision 1, will be utilized in operability determinations.
The design basis documentation effort is currently in process for 2 systems and 2 topical areas. The scope includes independent review and approval of the products.
Our expectation is the program will be completed on or before the fourth quarter 2001.
The scope includes approximately 50 systems and 13 topical reports. System and topical reviews are priontized based on risk significance in accordance with our Maintenance Rule program and IPE studies. The following systems and topical reports are presently in the initial two year scope of the DBR. The listing is preliminary and will be treated as a living task list. Other systems might replace an identified system because of an emergent issue.
Systems Emergency Diesel Generator (currently in process)
Residual Heat Removal (currently in process)
Automatic Depressurization Core Spray Reactor Protection Pnmary Containment isolation High Pressure injection Reactor Core Isolation Cooling Nuclear Boiler Vessel Instrumentation Recirculation Control Rod Drive Neu'~on Monitoring System Primary Containment Pressure Suppression Reactor Water Cleanup Standby Liquid Control Standby Gas Treatment Main Steam Feedwater
. HVAC AC/DC Distribution TBCCW RBCCW Instrument Air Containment Atmospheric Control Salt Service Water l
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LOCA ECCS [ vessel only/not containment) (currently in process) e DC End Devices (currently in process)
Anticipated Operational Occurrences (minus control rod withdrawa!)
Control Rod Withdrawal / Drop e
e ATWS Containment Response e
Miscellaneous (other FSAR events)
Radiological Consequences of Accidents e
EQ Rcensina Basis /UFSAR Review The increased industry focus on how licensees have been maintaining their UFSARs in accordance with 10 CFR 50.71(e) caused Pilgrim Station to assess its past and current methods for UFSAR maintenance. Many of the discrepancies identified during our self assessments of the UFSAR pointed to confusing and limited information in some sections with profuse information in others. As part of the data collection and review activities associated with the design and licensing bases efforts, the UFSAR will be updated to incorporate or eliminate information to be consistent with this documentation. The objective of this effort is to ensure consistency with the plant design, operation, the UFSAR, and design values, and determine if there are unknown unreviewed safety questions that have not been identified and addressed. Standards for the level of detail and type of information to be included in UFSARs are under development by the NRC and industry as part of the Millstone Lessons Leamed and will be factored into the UFSAR updating effort.
A task planned to be completed in 1998 is to confirm compliance with the UFSAR licensing basis. In order to accomplish this, the licensing correspondence docket file will be retrieved in its entirety and reviewed for consistency with the UFSAR.
Improved Standard Technicaljoecifications Pilgrim Station intends to convert the current customized technical specifications to the extent practical to the NUREG 1433, Standard Technical Specifications. General Electric Plants BWR/4, also known as improved Siendard Technical Specifications (ITS). The Pilgrim improved technical specifications and technical specification bases will be verified against the UFSAR, plant procedures, system design and operation, accident analysis calculations, and other sources such as design calculations, drawings, and operational practices as appropriate. The bases for each technical specification will be enhanced to reflect the significant accident analyses that credit the requirements in the specification.
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The objective of converting to ITS is to improve operational safety by allowing operators l
to focus on those requirements which are most important, in addition, the improved i
. Bases will provide a clearer understanding of the LCOs and Surveillance Requirements, as well as provide references to additional or more in depth bases documents.
l This item is already included in the Pilgrim Station Long Term Program report submitted to the NRC on a semi annual frequency. The schedule for completion of this activity will be re structured in accordance with the design and licensing bases documentation efforts discussed above.
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