ML20217L010

Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions

ML20217L010
Person / Time
Site:	Waterford
Issue date:	10/18/1999
From:	Ewing E ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-99-0152, NUDOCS 9910270047
Download: ML20217L010 (8)

Text

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Entergy = c = " " "c-Kiuona, LA'70066 Tel 504 739 G242 Early C. Ewing lit or f4 dear Safety Assurance 4

W3F1-99-0152 A4.05

, PR October 18,1999 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES

. Docket No. 50-382 License No. NPF-38 Fidelity of Updated Final Safety Analysis Report (UFSAR)

Gentlemen:-

This letter provides an update of the Waterford 3 effort for the review of the UFSAR.

The information is presented in the following format: (1) Background,

. (2) Management Expectations, (3) Review Status and Results, (4) Clarifications Regarding Review, and (5) Conclusion.

1. Background '

The fidelity of the UFSAR is a vital aspect of our responsibility to ensure the safe )

L operation of Waterford 3 (W3) and regulatory compliance. In the past years, there

' have been various assessments of the UFSAR. These assessments have included, 4 for example, Safety System Functional Inspections (SSFI's), Quality Assurance j

- audits, NRC Inspections, and specific assessments of the UFSAR. Also, there have

' been a number of activities that have improved the fidelity of the UFSAR. These ,

activities.have included, for example, reconstitution of Design Basis Documents l (DBD's), reconstitution of calculations, and other recent design basis initiatives.

' Collectively, these efforts have confirmed the overall integrity of the UFSAR and conformance with regulatory requirements. These efforts also identified 1 discrepancies and the need to enhance the fidelity of the UFGAR. In this context, as

. part of the EOl response to the NRC Staff's 10 CFR 50.54(f) ietter on Design Basis O h EOI, on behalf of W3, made a commitment to review certain sections of the UFSAR, Reference EOl letter No. W3F1-97-0025, dated February 6,1997. The last schedule '

. 050^34 991'0270047 991018 PDR- ADOCK 05000382 K PDR

Fidelity of Updated Final Safety Analysis Report (UFSAR)

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.Page 2 October 18,1999 '

communicated to the NRC Staff for completing this review is December 31,1999,

. Reference EOl letter No. W3F1-98-0009,' dated January 15,1998.

Subsequent to the EOl response to the NRC Staff's 10CFR 50. 54(f) letter on Design Basis, we undertook a number of broad initiatives to improve the fidelity of the ,

UFSAR. Initially, we analyzed historical UFSA'R problems, reviewed past -  !

assessments, and benchmarked the programs of other utilities in order to target specific improvements. The specific improvements that have been achieved include:

o ? A new program plan that specifies the various elements for maintaining the fidelity of the UFSAR.

l c A new' procedure for maintaining the fidelity of the UFSAR.

o' A new guide that contains fidelity and content guidelines, o _ A new electronic responsibility matrix that identifies the responsible departments for each section of the UFSAR.

o Training of Waterford 3 personnel for maintaining the fidelity of the UFSAR.

i o Enhanced integration of the design basis review and the UFSAR review efforts.

These broad initiatives' have enhanced personnel awareness of the need to maintain the fidelity of the UFSAR. These initiatives also provided a framework for proceeding with a dedicated review of selected sections of the UFSAR.

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'2.. Management Expectations Maintainir,g the fidelity of the UFSAR is a crucial element of our responsibility to ensure the safe operation of Waterford 3, demonstrate regulatory compliance, and

- operate economically.' We have implemented both broad initiatives that address cultural and process improvements and specific review initiatives that address

UFSAR historical discrepancies. We are continually adjusting the elements of the

. review to gain optimum results.

A new project instruction has been prepared which reflects the experience gained from the ongoing review of the UFSAR and industry experience. The management I

4 Fidelity of Updated Final Safety Analysis Report (UFSAR)

. .W3F1-99-0152 Page 3 October 18,1999 i expectations in the project instruction are:

o The UFSAR must be accurate and complete to support the safe operation of the

. plant and the operability of structures,' systems, and components, o The UFSAR must be consistent with the operations, design, and licensing basis of Waterford 3. This means the UFSAR must be consistent with the following:

. The. actual operation of the plant, procedures, and the configuration of  !

structures, systems, and components.

. The design assumptions, design inputs, analyses, and codes and standards that establish the design for the operation and configuration of structures, systems, and components, e Applicable regula'tions and other documents that demonstrate compliance with regulations, such as the operating license, technical specifications, NRC Staff safety evaluation reports, docketed commitments, and the Quality Assurance Program Manual.

o The UFSAR 'must reflect a high standard of fidelity to ensure the information is accurate and complete.

' Management and the project personnel maintain a strong communication to ensure

- management expectation issues are effectively addressed.

3. ' Review Status and Results We commenced the review of the UFSAR'in July 1998. The review was held in abeyance during Refuel 9. The reviews of Chapters 6,7,8,9,10,11, and 12 have been_ completed. No discrepancies have been found that adversely affect the safe

. operation of the plant or that would prevent safety systems from performing their safety function. No discrepancies have been found that affect the operability of l

equipment or which constitute unreviewed safety questions.

!: Generally,- the discrepancies found can be characterized as: 1.) Information lacking a L

definitive design basis,2.) Differences between the UFSAR and other operations, ,

design,' or licensing basis documents like procedures, calculations, or technical 1 specifications, 3.) Incorrect or incomplete data or statements about equipment performance or configuration, and 4.) Editorial errors.

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Almost all of the discrepancies did not require the generation of a Condition Report because they did not meet the threshold of an adverse condition. The discrepancies are input into an ACCESS database for tracking and correction.

Although the discrepancies have not been safety or operationally significant, some UFSAR sections, including tables and figures, have historically not been well i maintained. The measures previously discussed address the underlying causes. j

\ l l One major shift we have implemented is that EOl personnel rather than contract personnel are now perfomling the review. This shift has allowed us to dedicate a more diverse team to ensure a strengthened technical review. l l Also, as part of the review effort, we are holding discussions with key personnel and management to ensure an understanding of fidelity concepts and requirements, developing fidelity tools, such as a plan for maintaining figures, and assessing needs for additional training, The remainder of the review is planned, prioritized, and scheduled. The current goal l for completing the review is October 31,2000 rather than December 31,1999 as )

previously communicated to the NRC Staff. The new projected completion date has changed as a result of holding the project in abeyance during Refuel 9, dedicating  ;

EOl personnel to the review effort, adjusting the scope and basis of the review, and the Entergy Renewal Initiative. The new projected completion date is a target date for managing goals, and the date is subject to change.

4. Clarifications Regarding Review One of the important elements of our UFSAR fidelity focus is to keep abreast of industry achievement and regulatory initiatives relating to UFSAR fidelity. These achievements and initiatives include, for example, the promulgation of the Nuclear Energy Institute (NEI) document NEl 98-03, Revision 1, " Guidelines for Updating Final Safety Analysis Reports," and the NRC Staff Safety System Engineering inspection at the Grand Gulf Nuclear Station Facility documented in NRC Staff Inspection Report No. 50-416/99-02.

NEl 98-03 is expected to be a valuable tool in applying guidance for updating the UFSAR.' We have carefully reviewed and applied NEl 98-03 in our review effort

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W3F1-99-0152 i L Page 5 October 18,1999 throughout its development. _ However, we also note, based on NRC Staff Inspection j Report 50-416/99-02 that some aspects.or details of licensee review efforts may ,

vary from NRC Staff perceptions. Accordingly, we would like to highlight some {

" aspects and details of our review effort.

l The first priority of the review is to identify information which is suspect and could potentially affect the safe operation of the plant, the ability of structures, systems, or components to perform their safety function, or the operability of equipment.

1 The second priority of the review is to identify any information which is suspect and )

may not be consistent with the operations, design, and licensing basis of the plant.

The third priority of the review is to identify information that is suspect and may need to be reconstitute'dto improve the accuracy and completeness of the UFSAR. l The review objectives are to ensure: 1 o The information has a supporting and definitive design basis, o Information is consistent with the operations, design, and licensing documents, o Information is consistent with the actual performance, design' data, or configuration of st uctures, systems, and components.

o The classificaticos for structures, systems, and components are correct.

~a The description of the implementation of codes, standards, and commitments is correct.

o The information is consistent with the information in other sections of the UFSAR, tables, and figures.

1 o : The information is clear, unambiguous, and sensible.

The review attempts to find editorial errors because they could be misinterpreted and lead to more serious errors.

- The review is not intended to verify all information. Rather, the reviewer, based on

- expertise and judgment, confirms select information if it is suspect or has safety or risk significance.

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L ' The review does not entail a verification of the configuration of the plant. The UFSAR l

information regarding the performance capabilities of structures, systems or components or plant configuration is reviewed based on the expertise and judgment of the reviewer. The information is verified only if the accuracy or completeness of the information in the UFSAR is suspect.

Although the review entails a comparison of the UFSAR with operations, design, and licensing documents, the intent is not to verify the adequacy of the source documents. There are processes in place to ensure documents such as calculations, operations procedures,' or technical specifications are complete and accurate. The j adequacy of the source document is evaluated only if the information in the source document is suspect, and the information could constitute a potential UFSAR fidelity problem.

The review assesses the information in the UFSAR describing how codes and standards are implemented.' The intent of the review is to confirm the information has a supporting and definitive design basis; agreement with operations, design, and licensing bases; and the information is accurate and complete based on the expertise

.and judgment of the reviewer. However the intent of the review is not to verify the adequacy of the design or analyses, including whether the necescary exceptions or clarifications have been identified.

Figures in the UFSAR are reviewed to ensure the figure revision in the UFSAR matches the current revision of the figure. The figures receive a cursory review.

l However, the design details and configurations depicted in the figures are not verified since the design control process ensures the adequacy of the design. Additional l

reviews are performed to the extent suspect information is found in the text sections ,

or if the figures contain critical design basis or analytical information' corresponding to or supporting the text sections.

The review is not intended to verify plant configuration or the adequacy of the design, analyses, or source documents. However, the reviewers look for such discrepancies based on judgment and expertise? Once suspect information is identified, the reviewer will review all aspects associated with the suspect information, including l plant configuration, design, analysis, or source documents as necessary to establish

' the scope and basis of the discrepancy.

Historicalinformation is not' reviewed. NEl 98-03 is used in determining what information is historical. Basically, historical information is

'(1) information not intended to be updated for the life of the plant,

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i Fidelity of Updated Final Safety Analysis Report (UFSAR) l W3F1-99-0152 )

Page 7 I October 18,1999 l

(2) information not affected by changes to the plant or its operation, or (3) information that does not change with time. Specific examples are meteorological information, i description of original factory testing of equipment, or description of start-up or . l preoperational tests.

Although not analytically structured, the foregoing approach places emphasis on safety-related, risk significant, or suspect information. The review focus and l l confirmation is adjusted based on the Chapter or section being reviewed and also on  ;

the types of discrepancies being identified. The effectiveness of the review is highly i dependent on the expertise and judgment of the reviewers. . Therefore, we have dedicated a highly diverse and experienced EOl % terford 3 team to the UFSAR Fidelity Project.

5. Conclusion l

The fidelity of the UFSAR is vital for the safe operation, regulatory compliance, and the economic viability of Waterford 3. Various assessments over the past years have  ;

confirmed the overallintegnty of the UFSAR. However, these assessments have l also identified the need to enhance the UFSAR. We have carefully evaluated the historical record and instituted broad and specific initiatives to enhance the UFSAR.

Management expectations for maintaining the fidelity of the UFSAR have been carefully considered and documented. One initiative currently ongoing is the review of the UFSAR.To date, this review of the UFSAR has not identified any discrepancies that adversely impact safety or the operability of equipment.

Certain UFSAR sections, tables, and figures have not been well maintained, but recent and ongoing initiatives address this issue. Some aspects and details of our review have been highlighted to provide a more visible picture of our effort.

The current review, although not analytically structured, focuses on safety-related, risk significant, or suspect information. The effectiveness of our review is achieved by virtue of the diversity and experience of our review team.

This submittal does not contain any commitments.

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Fidelity of Updated Final Safety Analysis Report (UFSAR)

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, October 18,1999 1

Please contact E.P. Perkins at (504) 739-6379 or myself should there be any l l

question regarding this letter.  !

I Very truly yours,  ;

U ' M If e EC.b'g')

E.C. Ewing .

Director Nuclear Safety Assurance l

ECE/RJM/rtk cc

E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR

. J. Smith N.S. Reynolds NRC Resident inspectors Office t.

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