ML20134M661
| ML20134M661 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 11/21/1996 |
| From: | Donohew J NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9611250222 | |
| Download: ML20134M661 (65) | |
Text
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. _ Nr$6$6 3E l p ,, UNITED STATES g) /
l g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2066&C001
.g\ November 21, 1996 LICENSEE: ENTERGY OPERATIONS, INC.
FACILITY: Arkansas Nuclear One, Units.1 and 2 i
Grand Gulf Nuclear Station, Unit 1 River Bend Nuclear Power Station Waterford Steam Electric Station, Unit 3 4
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SUBJECT:
SU M RY OF NOVEMBER 14, 1996, MEETING ON AN ASSESSMENT OF !
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THE FINAL SAFETY ANALYSIS REPORTS FOR THE FACILITIES A meeting was held on Thursday, November.14, 1996, between the' Nuclear-4 Regulatory Commission (NRC) staff and the licensee to discuss the results of the licensee's self assessments of the accuracy of the information in the 1 Final Safety Analysis Reports (FSARs) for the four nuclear reactor sites. The :
! meeting was held at the request of the license _at NRC headquarters in l Rockville, Maryland. A notice of this meeting was issued on October 8, 1996. i f
Attachment 1 is the list of attendees' .
Attachment 2.is the licensee's handout i entitled " License Basis Assessments at Entergy Operations." There were no handouts by the staff. The meeting was for the staff to understand how the
! licensee conducted its self assessment of the FSARs and the results of the j self assessment. No decisions were made during the meeting.
MEETING SU R RY:
L The agenda for the meeting is on page 2 of Attachment.2. The licensee's i
presentation was divided into (1) a discussion on the license basis assessments, including the methodology, the findings for the four facility sites, and the general observations from the assessments, and (2) the future design basis evaluation plans. The presentation by the licensee is discussed below and there are references made to pages in Attachment 2.
The licensee stated that.the key elements describing the plant which affect l j the operating license for a nuclear power plant are the license basis, the design basis, and the operating basis for the plant. The key element that was new to the staff is the licensee's concept of the operating basis of the
. plant. The licensee defined the operating basis as the current operating procedures, practices, and processes for the plant. These elements were shown j on page 7. The FSAR provides information on all three bases for the plant. l 1
- The licensee discussed changes to the license basis, design basis, and
- operating basis on pages 8 to 15. The licensee stated that the sequence of
- change is important in that a change to the license basis must be evaluated j ~before implementing a design basis change, and a change to the design basis must be ovaluated before implementing a operating basis change. .The i-regulations require this and enforcing the sequence preserves the integrity of 4
the license basis. The summary of the different change pathways is shown on
- page 11.
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On page 14, the licensee stated that its purpose for the self assessments was to determine if reasonable assurance existed to conclude that the licens basis for each plant was sound. I i
The approach taken by the licensee in the self assessments are shown on pages 16 to 25. The assessments were in three phases: (1) review of the change processes defined in the regulations, including'10 CFR 50.54, 50.59, and 50.90; (2) review of the site change processes, including work-around lists, operations standing orders, and temporary alterations; and (3) a search for ,
unknown change processes. The latter search was conducted by selecting four '
plant systems for each site and determining if the statements in the FSARs are accurate with respect to the current operating and design bases, l
The staff asked why only four systems were chosen for review at each plant. ;
The licensee stated that the four systems were not the same systems for each ,
plant and four systems were sufficient to determine the weaknesses in the I processes at the plants. The systems reviewed were listed on pages 30 (Arkansas Nuclear One), 33 (Grand Gulf), 37 (River Bend),. and 41 (Waterford).
The licensee stated that these assessments were not conducted in a vacuum by I themselves.and there are numerous other activities being conducted at the plants that provide additional confidence in the license and design bases. '
These other activities are the following:
- The corrective action program for the plants
- The safety system functional inspections (SSFIs) and assessments (SSFAs) that are conducted at the plants !
- Design basis documentation (DBD) efforts at the plants !
- Responses to industry and NRC experience and events in terms of the !
design and operation of the plants A list of SSFIs-(conducted by the NRC) and SSFAs (conducted by the licensee) for each of the four plants from 1984 were shown on pages 21 and 22. The licensee's DB0 efforts at each plant were listed on page 23. !
How and when the assessments were conducted is shown on page 25. The licensee stated that the following were the overall results of the assessments:
- No safety significant discrepancies or operability issues were identified.
- With minor exceptions, existing site-specific license basis change processes are effective in maintaining the license basis.
- Non-traditional site change processes or mechanisms deserve additional.
controls to ensure accurate reflection in the-license basis.
- The assessments created an enhanced site sensitivity to license basis changes for the plant.'
- The three phase assessment process, in conjunction with previous efforts, is sufficient to' determine reasonable assurance of license basis integrity for the plant.
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3-I The programmatic insights from the assessments, shown on page 27, were the following:
- Temporary changes (alterations, tag-outs, work-arounds) need to be periodically re-evaluated to determine if a permanent facility change should be proposed.
- Short-term operating basis changes (i.e., operations standing orders) need better controls to ensure screening under 10 CFR 50.59.
-. Screening to identify potential changes to the license basis documents is not sufficiently comprehensive in all cases.
The plant-specific findings of the assessments for the four plants are shown on pages 28 to 42, in alphabetical order, from Arkansas Nuclear One (ANO) to Waterford 3. The acronym LBD means license basis determination and it is described in the FSAR.
The-licensee briefly discussed the 10 CFR 50.54(f) letter sent by NRC to all licensees on October 9, 1996, regarding the adequacy and availability of design basis information at the nuclear power plants. The licensee stated that the self assestments were planned before June 1996, when the assessment for ANO began, in advance of the letter, and were not conducted to be a response to the 50.54(f) letter. The slide on this letter is page 45.
The presentation on the licensee's design basis evaluation plans are shown on pages 46 to 56. The licensee stated that the wide range of inputs to improve the DBD at the plants are the following: corrective actions program, self- _'
assessments, NRC inspections and generic correspondence, Institute of Nuclear Power Operations (INPO) evaluations, industry experience, the licensee's peer groups, and plant walkdowns. The licensee stated that the DBD at the plants provides a sound basis for operations of the units; however, the upgrading of the DBD is an on-going process as the licensee's standards contir e +o rise, NRC expectations change, and current business plans reflect areas for-enhancement at each plant. However, to gain greater confidence'in the design basis integration at each plant, the licensee is planning teem evaluations at each plant to evaluate each design area and develop recommendations. The team make-up and the target schedule for the evaluations are on pages 55 and 56. l The questions to be explored at each plant are on page 53. i The licensee ended its presentations and the meeting was adjourned.
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N. Donohew, Senio~r' Project Manager
( Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.: 50-313, 50-368, 50-382, l 50-416, and 50-458 Attachments: As stated cc w/atts: See next page
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November 21, 1996 l The programmatic insights fro:. the assessments, shown on page 27, were the l following:
Temporary changes (alterations, tag-outs, work-arounds) need to be l periodically re-evaluated to determine if a permanent facility change should be proposed.
Short-term operating basis changes (i.e., operations standing orders) need better controls to ensure screening under 10 CFR 50.59.
- Screening to identify potential changes to the license basis documents is not sufficiently comprehensive in all cases.
The plant-specific findings of the assessments for the four plants are shown on pages 28 to 42, in alphabetical order, from Arkansas Nuclear One (AN0) to Waterford 3. The acronym LBD means license basis determination and it is described in the FSAR.
i The licensee briefly discussed the 10 CFR 50.54(f) letter sent by NRC to all licensees on October 9, 1996, regarding the adequacy and availability of l
design basis information at the nuclear power plants. The licensee stated that the self assessments were planned before June 1996, when the assessment l for ANO began, in advance of the letter, and were not conducted to be a response to the 50.54(f) letter. The slide on this letter is page 45.
The presentation on the licensee's design basis evaluation plans are shown on
! pages 46 to 56. The licensee stated that the wide range of inputs to improve the DBD at the plants are the following: corrective actions program, self-assessments, NRC inspections and generic correspondence, Institute of Nuclear i
Power Operations (INPO) evaluations, industry experience, the licensee's peer groups, and plant walkdowns. The licensee stated that the DBD at the plants provides a sound basis for operations of the units; .however, the upgrading of the DBD is an on-going process as the licensee's standards continue to rise, l NRC expectations change, and current business plans reflect areas for enhancement at each plant. However, to gain greater confidence in the design basis integration at each plant, the licensee is planning team evaluations at each plant to evaluate each design area and develop recommendations. The team make-up and the target schedule for the evaluations are on pages 55 and 56.
l The questions to be explored at each plant are on page 53.
l 'The licensee ended its pr se a on meeting was adjourned.
i ac N. Donohew, Senior Project Manager Project Directorate IV-1 9
'*50039 htisi n nf Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.: 50-313, 50-368, 50-382, 50-416, anc 50-458 l Attachments: As stated /J cc w/atts: See next page DISTRIBUTION PHarrell, RIV JDyer, RIV EWang 19ecketJ11e;*/ PUBLIC PD4-1 r/f" JDonohew JRoe EAdensam (EGA1) CHawes WBeckner OGC * .
- CPatel DWiggington ,
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Document Name: GG111496.MTS *
- HARD COPY OFC PM/904 1/n (A)LA:PD4-1 NAME JD h h[cf CHawesd[TM DATE II /D/96 Il/M/96 g % hh COPY h (YE/N0 YES/i10 SFFICIAL RECORD COPY
I t Entergy Operations, Inc. Arkansas Nuclear One, Units 1 & 2 l
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! CC:
1 Executive Vice President Vice President, Operations Support
& Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc. P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995 Jackson, MS 39286-1995 Director, Division of Radiation Wise, Carter, Child & Caraway Control and Emergency Management P. O. Box 651 Arkansas Department of Health Jackson, MS 39205 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Vice President Operations, AN0 Entergy Operations, Inc.
Winston & Strawn 1448 S. R. 333 1400 L Street, N.W. Russellville, AR 72801 l
Washington, DC 20005-3502 Manager, Rockville Nuclear Licensing l
Framatone Technologies l 1700 Rockville Pike, Suite 525 l Rockville, MD 20852 Senior Resident Inspector l U.S. Nuclear Regulatory Commission
- P. O. Box 310 l London, AR 72847 l
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission l 611 Ryan Plaza Drive, Suite 400 i Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse i Russellville, AR 72801 l
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1 Entergy Operations, Inc. Grand Gulf Nuclear Station cc:
Executive Vice President General Manager, GGNS
& Chief Operating Officer Entergy Operations, Inc. ,
Entergy Operations, Inc. P. O. Box 756 l P. O. Box 31995 Port Gibson, MS 39150 l Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Department of Justice P. O. Box 651 State of Louisiana -
Jackson, MS 39205 P. O. Box 94005 l Baton Rouge, LA 70804-9005 l Winston & Strawn 1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi ,
P. O. Box 10385- Jackson, MS 39201 '
l Jackson, MS 39209 Attorney General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi Port Gibson, MS 39150 P. O. Box 22947 Jackson, MS 39225 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Vice President, Operations Support 611 Ryan Plaza Drive, Suite 1000 Entergy Operations, Inc.
Arlington, TX 76011 P.O. Box 31995 l Jackson, MS 39286-1995 Senior Resident Inspector U. S. Nuclear Regulatory Commission Director, Nuclear Safety Route 2, Box 399 and Regulatory Affairs Port Gibson, MS 39150 Entergy Operations, Inc.
P.O. Box 756 Nuclear Operating Plant Services Port Gibson, MS 39150 Bechtel Power Corporation 9801 Washington Boulevard Gaithersburg, MD 20878 Vice President, Operations GGNS Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150
O Entergy Operations, Inc. River Bend Station cc:
Winston & Strawn Executive Vice President and ,
1400 L Street, N.W. Chief Operating Officer l Washington, DC 20005-3502 Entergy Operations, Inc. 1 P. O. Box 31995 i Manager - Licensing Jackson, MS- 39286 Entergy.0perations, Inc.
River Bend Station General Manager - Plant Operations P. O. Box 220 .
Entergy Operations, Inc.
St. Francisville, LA 70775 River. Bend Station P. O. Box 220 Director :St. Francisville, LA 70775 Joint Operations Cajun 10719 Airline Highway Director - Nuclear Safety ,
P. O. Box 15540 Entergy Operations, Inc. l Baton Rouge, LA 70895 River Bend Station P. O. Box 220 Senior Resident Inspector St. Francisville, LA 70775 P. O. Box 1050 1 St. Francisville, LA 70775 Vice President - Operations Support Entergy Operations, Inc.
President of West Feliciana P. O. Box 31995 Police Jury Jackson, MS 39286-1995 P. O. Box 1921 St. Francisv111e, LA 70775 Attorney General State of Louisiana Regional Administrator, Region IV P. O. Box 94095 U.S. Nuclear Regulatory Commission Baton Rouge, LA 70804-9095 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Wise, Carter, Child & Caraway P. O. Box 651 Ms. H. Anne P1ettinger Jackson, MS 39205 3456 Villa Rose Drive Baton Rouge, LA. 70806 Vice President & Controller Cajun Electric Power Cooperative Administrator 10719 Airline Highway Louisiana Radiation Protection Division P.O. Box 15540 P. O. Box 82135 Baton Rouge, LA 70895 Baton Rouge, LA 70884-2135 Vice President - Operations Entergy Operations, Inc.
River Bend Station
-P.O.-Box 220-St. Francisv111e, LA 70775
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Entergy Operations, Inc. Waterford 3 l
l cc:
Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington, TX 76011 Vice President, Operations Resident Inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc. Killona, LA 70066 P. O. Box 31995-Jackson, MS 39286 Parish President Council St. Charles Parish Director P. O. Box 302 Nuclear Safety Hahnville, LA 70057 Entergy Operations, Inc.
P. O. Box B Executive Vice-President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.
Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Service Commission 1 Entergy Operations, Inc. One American Place, Suite 1630 l P. O. Box B Baton Rouge, LA 70825-1697 Killona, LA 70066 Vice President Operations Licensing Manager Entergy Operations, Inc.
Entergy Operations, Inc. P. O. Box B P. O. Box B Killona, LA 70066 Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 l
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ATTENDEES AT MEETING 0F NOVEMBER 14. 1996 ASSESSMENT OF FINAL SAFETY ANALYSIS REPORTS M8ME AFFILIATION J. Roe NRC/NRR/DRPW W. Beckner NRC/NRR/PDIV-1 J. Donohew NRC/NRR/PDIV-1 C. Patel NRC/NRR/PDIV-1 D. Wiggington NRC/NRR/PDIV-1 E. Wang _
NRC/NRR/PGEB J. Yelverton E01 F. Titus E0I J. Fisilaro E01 L. England E01 M. Meisner E01 - Grand Gulf D. Mims E0I - ANO R. King E01 - RBS-K. Hughey E01 - Grand Gulf N. Chapman Bechtel - SERCH T. Pietrangelo NEI where: ANO - Arkansas Nuclear One Bechtel- Bechtel-Power Corporation I E0I - Entergy Operations, Inc.
NEI - Nuclear Energy Institute :
NRC - Nuclear Regulatory Commission NRR = Office of Nuclear Reactor Regulation DRPW - Division of Reactor Projects III/IV PDIV-1 --Project Directorate IV-1 PGEB - Generic Issues and Environmental Projects Branch RBS - River Bend Station 1
i ATTACHMENT 1
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l License Basis Assessments !
I et i Entergy Operations m
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November 14,1996
License Basis Evaluation November 14,1996
+ introduction Jerry Yelverton
+ License basis assessments -Mike Meisner
- Elements affecting the license basis
- - Developing an assessment approach
- Assessment findings
- Observations
+ Design basis evaluation plans Fred Titus 2
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Significance of the
- License Basis 1
i The plant license basis establishes the scope of our contract with the public for safe nuclear generation.
While the language of the contract may, at times, be subject ,
__ to interpretation, the responsibility lies with us to maintain or restore public and regulatory confidence in the contract and the integrity of the underlying license basis.
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i License Basis issue f
The key issue today is reduced public and regulatory confidence in the integrity of the license basis due to clear instances of licensees:
- Operating outside the license basis, and
- Failing to maintain the license basis After examining this issue, EOI concludes:
- Current processes (with some exceptions) are effective in maintaining the license basis
- More detailed license basis reviews are warranted in selected areas
i Confidence in the License Basis
+ Understand the elements that can affect / change the license basis i
+ Develop an assessment approach that critically evaluates the process controls necessary to license basis integrity
+ Through assessment, confirm the integrity of the processes governing change
+ Implement process enhancements from lessons learned through assessment 5
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Operating Basis **
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- Referred to as
- Design Basis" ;
in the remainderof the presentation
- Operating procedures, practices and processes 7 j
Changes Allowed by Regulation
+ Regulations allow for numerous means to change facility design / operation (most typical are 10CFR50.54/59/90)
+ Sequence of change is inherent in regulations (e.g., a change to the license basis must be evaluated prior to implementing a change to the operating basis)
+ Enforcing appropriate change mechanisms and sequences is the key to preserving license basis integrity
+ Understanding the charige mechanisms and sequences is the key to effective assessment of license basis integrity l
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i Potential Change Pathways I
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- OB !
If 5 .59 is N/A DB > DB LB DB =
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Summary of Change Pathways ;
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LB = LB Alway acceptable under '
LB = DB appropriate regulation LB OB .
.- OB = OB - Acceptable if there is no effect DB = DB > on the license basis (e.g.,
DB = OB 10CFR50.59 does not apply)
OB = LB -
DB = LB. > Not acceptable OB = DB*
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- Okay by regulation if there is no effect on the license basis, but not good engineering practice 10 f'
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Summary of Change Pathways License Acceptable Basis . --- Not Acceptable i
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I Design w____ Operating ,
Basis i e Basis ) ;
License Basis Assessment Scope Design Basis Evaluation Scope l
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License License ; I Basis Basis j y
Design Operating Design Operating p p l l \ __
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I Developing a License l
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Basis Assessment Approach i
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License Basis Change Subtleties
+ Multiple means are available to change operating practices, some of which seem to be lacking rigorous controls to reflect the change in the license basis
+ Examples
- Configuration changes which do not involve procedure or design basis changes
- Untimely corrective action
- Operator work-arounds 13
License Basis Assessment Purpose Determine if reasonable assurance exists to conclude -
that the license basis is sound.
Reasonable assurance is based upon having a complete set of programmatic controls that ensure thet changes to the operating and design bases are evaluated and reliably reflected in the license basis.
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Assessment Focus Areas i
Are license basis change processes working?
LB '
LB i
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Always acceptable under appropriate regulation
__ LB > OB OB p. OB Acceptable if there is no effect on the IIcense basis (e.g.,
10CFR50.59 does not apply)
DB > DB DB > OB Are there ways to change the facility tuithout triggering license basis changes (i.e., are process controls missing)?
OB > OB q 08 > DB ACCOP able W Were is no eWect on We license bases (e.g.,
DB - OB )> 10CFR50.59 does not apply)
OB > LB DB > LB Not acceptable OB > DB 15
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Assessment Approach A three-phased assessment is necessary to provide reasonable assurance of license-basis integrity (review of the SAR alone is not sufficient). The assessment must cover:
._ + Effectiveness of processes that translate changes in the operating / design bases into changes in the license basis
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+ Confirmation that known means of changing the operating / design bases have appropriate programmatic controls to reflect that change in the license basis
+ A search for unknown means to change the operating / design basis I
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4 Assessment Phase 1 Change Process Review Review examples of the following changes:
+ 50.59 + 50.54
+ 50.90 + 50.55a
+ FSAR changes + Commitment additions
+ Design changes not evaluated under 50.59
_ + Operating Procedure changes not evaluated under 50.59 Review Scope Does the license basis accurately reflect the change?
l If not, what process steps are deficient or missing?
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. l Assessment Phase 2 Known Change Processes Review examples of the following:
- Work-around list
- Operations standing orders
- Tech Spec positions
- Routinely "NAed" procedure steps
- Equipment operated in manual
- Old temporary alterations, non-conformances, tag-outs i
Review Scope is there a change from the license basis?
Are there adequate controls to capture license basis changes?
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Assessment Phase 3 Search for Unknown Change Processes Select four plant systems Excerpt SAR statements associated with operational practices that could be changed and, in the presence of programmatic weaknesses, not be adequately reflected in the SAR Review Scope
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Determine if SAR statements are accurate with respect to current operating and design bases (overlaps the design basis evaluation scope) 4 19 !
l Assessment Development Other Considerations 1 + The license basis assessments are not conducted in a vacuum
+ Numerous previous activities provide additional confidence in both the license and design bases, principally
- Corrective action program
- Safety system functional inspections / assessments .
- Design basis documentation efforts ;
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- Response to industry /NRC experience / events i
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i EOl SSFAs/SSFis i
ANO Grand Gulf U1 EFW (1986) SLCS (1988) i U1 DHR (1989) FPC (1990) !
125 VDC (U1/2,1988) EDSFI (1990)
U2 Elec. Dist. (1991) HPCS/Div Ill EDG (1991)
U2 EDSFl (1991) LPCS/RCIC (1993) l.
U1 Elec. Dist. (1992) SSW (1994) l U1 EDSFI(1992) ADS (1996)
U1/2 SW (1990) RHR (partial) (1996)
U1/2 SW (1994) SGTS (partial) (1996)
U1/2 SWSOPl (1994) PSW (partial) (1996)
Digital FW Control !
(partial,1995) 21 I
i EOI SSFAs/SSFis River Bend Waterford 3 instrument Air (1988;l EFW (1984)
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HPCS (1991;l CCW/ACCW (1988)
LPCS/RCIC (1994) EDG (1990)
SSW (1994;I EDSFl (1991)
CVC/BAM (1992ll Safety inj. (1993)
Software control (1994;l i
EFW (1995)
SSW (partial) (1995)
HPSI(partial)(1996)
EDG (partial) (1996) n
i EOl DBD Efforts ,
ANO Design configuration documentation project (1986-1994);
Upper Level Documents (>120) covering systems, structures and topical areas i
Grand Gulf
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Detailed comparison with NUMARC 90-12 (1992) and selected enhancements and upgrades River Bend Development of System Design Criteria Documents and compilation of Analysis Basis Document m progress j i
i Waterford 3 Design basis documentation project (1988 - 1994) covering systems and structures 23 ;
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Assessment Conduct
+ Single team of knowledgeable representatives with diverse expertise from each EOl site i
+ Consultant knowledgeable in license basis issues
+ Significant preparatory work at each site prior to team arrival
+ Assessment schedule i
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__ - ANO - 6/24-6/28, 7/10-7/12, 8/23
- River Bend - 7/15-18, 8/19 l - Grand Gulf - 7/29-8/2
- Waterford 3 - 8/12-8/16 25
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Overall Results :
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+ No safety significant discrepancies or operability issues were identified
+ Existing site-specific license basis change processes are effective its maintaining the license basis (with some exceptions)
+ Non-traditional change mechanisms deserve additional controls to ensure accurate reflection in the license basis i
! + Enhanced site sensitivity to license basis changes; SAR ownership and review becoming a natural activity
+ The three phase assessment process, in conjunction with previous efforts, is sufficient to determine reasonable '
assurance of license basis integrity 26
Overall Results Programmatic Insights
+ Temporary changes (alterations, tag-outs, work-arounds) need to be periodically re-evaluated to determine if a permanent facility change should be proposed
+ Short-term operating basis changes (i.e., operations standing orders) need better controls to ensure screening
! under 50.59 i + Screening to identify potential changes to license basis
__ documents is not sufficiently comprehensive in all cases i
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-f Overview !
+ Traditional LBD change processes are effective in reflecting plant design / operating bases in the SAR j
- Exception: Cultural factors associated with perceived l _ admin burden led to reluctance to initiate LBD changes in some cases. Reluctance did not appear to extend to safety significant changes.
- Exception: LBD impact determinations have not been consistently comprehensive
+ SAR review will be done for both units to meet current LBD expectations
- Expect substantive SAR updates but not a substantive safety impact
>- Interim confidence in LBD adequacy based on extensive program upgrades such as DBD effort, system trammg l manual upgrades, set point control, EQ, etc. =
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. .i Arkansas Nuclear One Overview
+ 53 SAR discrepancies requiring change
- 22 due to quality of the change process
- 16 operational / design changes at variance with SAR
- 14 original SAR errors / ambiguities t
- 1 other variance
- No safety significant or operability issues
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+ Systems reviewed t i
t Unit 1 Unit 2 !
- Rx Bldg Spray - CVCS
- DHR/LPI - LPSI/SDC i
- Main Steam - Main Steam
- Instrument / Service Air - Instrument / Service Air
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Arkansas Nuclear One -
Programmatic Insights Strengths
+ Use of tagouts (hold cards) to enforce SAR administrative i controls Enhancements
+ Establish site-wide focus on the importance of LBD accuracy
+ Increase comprehensiveness of LBD impact reviews i
+ Formalize system abandonment process under the design change process
+ Incorporate LBD impact review into "use-as-is" dispositions
+ Periodically review longstanding temporary conditions ,
(work-arounds, temp alts, etc.) for LBD impact l
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Overview
+ Traditional LBD change processes are effective in reflecting ;
plant design / operating bases in the SAR >
- Small number of identified discrepancies
+ 11 SAR discrepancies requiring change
- 6 original SAR errors / ambiguities
- 3 operational changes at variance with the SAR 1
- - 2 design changes at variance with the SAR
- No safety significant or operability issues
+ Systems reviewed
-RHR - Combustible Gas Control
- Fire Water - Instrument Air
-l 33 l _
-l Grand Gulf jP Programmatic Insights l Strengths
+ Consistent accurate update of LBDs
+ Comprehensive application of LBD impact screening for a range of engineering documents t
Enhancements
+ Periodically review longstanding temporary conditions (work-arounds, temp alts, etc.) for LBD impact
+ Implement better controls for review of short term operating basis changes such as standing orders
+ Additional enhancements based on design basis evaluation findings ;
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River , Bend Overview
+ Traditional LBD change processes are effective in reflecting plant design / operating bases in the SAR
- Exception: LBD impact reviews are not consistently comprehensive
- Exception: Old tech spec amendments (2 examples) were not reviewed for other LBD impact
+ Most SAR discrepancies are original SAR errors
__ + Additional SAR verification activities planned or in progress include:
- Development of System Design Criteria documents (including SAR validation)
- Analysis (SAR Chapter 15) basis document review
- Engineering SAR review as
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River Bend Overview
+ 32 SAR discrepancies requiring change
- 25 original SAR errors / ambiguities
- 5 due to quality of the change process ,
- 2 other variances
- No safety significant or operability issues
+ Systems reviewed
- Emergency diesels - Instrument Air
-RHR - Main Steam 37
i River Bend e Programmatic Insights ,
Strengths
+ Process controls to evaluate LBD effect if equipment deficiencies are dispositioned "use-as-is" Enhancements
+ Periodically review longstanding temporary conditions ;
(work-arounds, temp alts, etc.) for LBD impact
+ Emphasize LBD impact review should include all SAR .
__ figures
+ implement additional controls to ensure that valid LBD change notices cannot be canceled
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Waterford 3 Overview
+ Traditional LBD change processes are effective in reflecting plant design / operating bases in the SAR
- Exception: Partially completed design changes may not be incorporated in the SAR in a timely manner i
- Exception: While Security Plan changes are evaluated i under 50.54 they do not receive a screening for other LBD impact
- i
+ 20 SAR discrepancies requiring change
__ - 10 design changes at variance with SAR (5 due to partially implemented designs)
- 8 original SAR errors (2) or ambiguities (6) ;
- 2 other variances
- No safety significant or operability issues i i
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_ _ _ _ _ _ _ _ _ _ _ _ _ = _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ - - _ _
o Waterford 3 .
Overview
+ Systems reviewed ,
- DC distribution !
-CVCS !
- Instrument air i'
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Waterford 3 Programmatic Insights Strengths
+ LBD review required for Operations Standing Instructions
+ Broad LBD screening
+ 50.59 training emphasis on operations consistent with SAR Enhancements i
+ Periodically review open temporary alterations, tagouts (clearances) and operator work-arounds for LBD impact
+ Update LBD procedures to reflect current practice and resolve inter-departmental procedure inconsistencies
+ Enhance review of incoming / outgoing regulatory correspondence for LBD effects
+ Additional enhancements based on design basis evaluation findings t
42
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-i FSAR
+ The FSAR was constructed in accordance with the guidance of the SRP and RG 1.70 (or its predecessor documents) [
+ Many subsections of the SAR are narrowly constructed to address specific SRP issues rather than integrated safety scenarios
+ This approach facilitates OL review for the specialist but inhibits understanding or leads to misunderstandings with inspectors
+ Significant NRC and licensee resources are being consumed today in researching, explaining and understanding the SAR in a context, and for an audience, to which it is not well suited
Design Basis 50.54(f) Letter
+ Has had an impact on, and clearly delivered a message to, the industry
+ In practical terms, as with the SAR assessments, we must rely on our conclusions as to the quality of our processes to draw conclusions about the quality of the design basis i
+ " Reasonable assurance" should be the standard
+ Safety performance should be the measure 1
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Design / Licensing Basis Relationship i
Licensing Basis:
~
. Etc*
Regulatory Design Design
- _ _ input Basis Documents (Engineering Design Basis)
Design Analysis Doc:(1)
CALCS Analysis (1) NOTE: Some analysis and output documents are ,
also directly in the Des.ign Output Doc: (1) UFSAR
- Drawings
- EQ List CDB i
i i
47
i I ;
b Entergy Engineering Philosophy j i
t
+ Accountability for the Design Basis !
- No reliance on A/E
- Limited NSSS support
+ Related Actions:
- Turnover of original design cales/ drawings
_ - Technical capability:
+ Selection
+ Training / Development
- Tools (examples):
+ Technical tools i
+ Optical Disk Imaging / Retrieval System i
48
- i What Has Entergy Done to improve Design Basis Documentation?
+ Acted on opportunities for improvement i
+ Wide range of inputs:
- Corrective Action Program
>- Internal Self-Assessments
- NRC Inspections
- INPO Evaluations .
1
- Industry Experience
- NRC Generic Correspondence
- Entergy Peer Groups
- Walkdowns i
I 49
Example:
Vertical Slice Type Assessments
+ EOl Self-Assessments: 30
+ NRC SSFI Type inspections: 6
+ These assessments / inspections have:
- Confirmed safety functions would be performed t
- Identified opportunities to improve documentation l
1 l
In response, Entergy has made a significant commitment to enhance design basis documentation E
i
Significant Upgrades have been Undertaken (Examples)
+ ANO Design Basis Reconstitution Effort
+ All Sites (examples):'
- EQ Documentation
- Seismic Documentation
- Drawing / Configuration Control Upgrades
- Electrical Design Calc Upgrades
- System Level Design Criteria Documents
- Change Process improvements
~
- IST Reconstitution
- Component Data Base Upgrades ;
- Instrument Setpoint Programs -
- MOV Design Basis 51
?
i, Today's Perspective
- + We believe the Design Basis Documentation at EOl provides a sound basis for operation
+ However, upgrading Design Basis Documentation is an
__ on-going process: i
- We continue to raise our standards
- NRC expectations also change
- Current business plans reflect areas for enhancement ,
at each EOl site
+ What can we do to gain even greater confidence in our Design Basis Integration? j i
I EOl Team Evaluation of .
Design Basis Integration at Each Site
$2 r
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Questions ,
, wwv sM e 4 . as,.w. - - , UFSAR (4) Maintain SAR i
~-
Plant: (5) Update Piant (1) Adequate Doc
~
Programs '
Design (2) Retrievable !
- Procedures (6) Review Design s L s L !
(3) Maintained Current Change Change l
(7) Overall design accountability / ownership
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53 !
l
y Approach
+ Team evaluations at each site t
+ Not a typical assessment i
+ Evaluate each design area:
_ - Review discrepancies / findings
- Review prior initiatives .
i
- Review planned initiatives
- Interview subject area experts
+ Develop specific recommendations 1
[
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54
Team Make-Up
+ Core Team:
- Team Lead (Management) ;
- Corporate Assessment
- Mechanical
- Civil / Piping
- Electrical i
- l&C
- Safety Analysis l + Site Team (Supplements):
t
! - Operations i
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- Maintenance f'
- Licensing i I
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Target Schedule i
+ Initial Team Planning November 15,1996
+ Initial Evaluation (Waterford 3) December,1996 March,1997
+ Complete all Evaluations
+ Follow-Up Action Plans April,1997 t
+ NRC Briefing April,1997 !
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_ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _