ML20249C455
| ML20249C455 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/24/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS980044, NUDOCS 9806300020 | |
| Download: ML20249C455 (3) | |
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P.O. DOX 98 B LL NEB 68321 Nebraska Public Power District
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p NLS980044 June 24,1998 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Revision of Commitments Made In the Performance of the CNS USAR Rebaselining Project Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
1.
Letter from Mr. P. D. Graham (NPPD) to NRC Document Control Desk, dated March 31,1997, regarding the USAR Rebaselining Project Description 2.
Letter from Mr. J. R. Hall (NRC) dated October 15,1997, summarizing the meeting held between NPPD and the NRC on October 8,1997.
3.
Letter from Mr. J. H. Swailes (NPPD) to NRC Document Control Desk, dated April 9,1998, regarding the Strategy for Achieving Engineering Excellence, Revision 1.
As described in References 1 and 2, the Nebraska Public Power District (the District) provided details to the NRC on our commitment to rebaseline the CNS Updated Safety Analysis Report (USAR). A key assumption in the success of the USAR Rebaselining Project (the Project) was for the CNS staff to make a detailed review of the rebaselined USAR. Sections and related
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documentation. The purpose of this was three-fold. Firstly, the appropriateness of the specific USAR changes developed by the Project's consulting engineering firm could be assessed.
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Secondly, this was to provide an additional overall review of the USAR's accuracy, completeness, and clarity. Thirdly, would have provided an opportunity for training and familiarizing the individual CNS staff members who would eventually be tasked as " owners" of /7h/
designated USAR text. The Project has been integrated into the overall Strategy for Achieving Engineering Excellence (Reference 3), and after having reviewed the man-hours being proposed for the Project within the context of the other key activities of the Strategy, the District has reluctantly decided to extend the completion of USAR Rebaseline Project beyond its original end date of October 1998. The scheduled completion date is now in December 1999. Despite this delay, the District believes that there will be several advantages to this approach:
Several other major USAR-impacting initiatives wi.i have been assimilated (Improved Technical Specifientions and the SAFER /GESTR LOCA Analysis).
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NLS980044 Page 2 of 2 4
This will provide an opportunity to assess the lessons learned from the Project to date and to better incorporate them as the Project continues.
A better quality staff review will occur because of the more focused attention that can be applied to the Project in 1999.
The District is closely monitoring the progress being made between the Industry and the NRC in developing guidance for implementing 10CFR50.71(e), and desires to be in conformance with the final document. Although not presently anticipated, the District will inform the NRC of any further delay in Project completion that will accrue in order to comport with those efforts.
The District recognizes that this project extension will put CNS outside of the enforcement discretion window described in Enforcement Guidance Memorandum 96-005. Ilowever, significant efforts have been made in identifying USAR-related discrepancies (and expediting resolution of those with safety or regulatory significance), sensitizing the CNS staff to the importance of USAR accuracy, improving the USAR Change Process so that there is higher assurance of accuracy in proposed USAR changes, and developing USAR standards with regard to significant generic USAR issues that have been areas of prior confusion to the CNS Staff.
With the progress that has been achieved to date, and is expected to be made by October 1998 combined with the District's continuing commitment to proceed with the Project's scope and objectives as outlined in Reference 1, the District requests that continued enforcement discretion be considered by the NRC for the Project's duration.
Should you have any questions please contact my office.
Since l,
ec J. II. Swai s Vice President-Nuclear Energy
/wrv Attachment cc:
Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC - Cooper Nuclear Station NPG Distribution
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LIST OF NRC COMMITMENTS ATTACHMENT 3 Correspondence No:NLS980044 The following table identifies those actions committed to by the District in this document.
Any other actions discussad in the submittal represent intended or planned actions by the District.
They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
l COMMITMENT COMMITTED DATE OR OUTAGE The District is extending the USAR Rebaseline Project 12/31/99 from its original end date of October 1998 to December 1999.
The District will inform the NRC of any further delay in None Project completion that will accrue in order to comport with those [NRC/ Industry 10CFR50.71(e) guidance] efforts.
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l PROCEDURE NUMBER 0.42 REVISION NUMBER 2 PAGE 12 OF 16 l
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