ML20149M175

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Forwards Ltr Which Requires Info That Will Provide NRC Added Confidence & Assurance That Plant Operated & Maintained within Design Bases
ML20149M175
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 10/11/1996
From: Blanch P
AFFILIATION NOT ASSIGNED
To:
NRC
Shared Package
ML20149M049 List:
References
NUDOCS 9612130019
Download: ML20149M175 (9)
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Text

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. From: PAUL M. BLANCH <PMBLANCH91x.netcom.com>

To: WND2.WNP3(jaz,awd),TWD1.TWP4(gam)

Date: 10/11/96 II:34am

Subject:

50 54 f to all utilities and NEI NRC 50.54f Letter on Design Bases Information Similar Letters Addressed to Chief Executive Officers of NRC-licensed Utilities (Slightly different letter sent l to Haddam Neck Nuclear Power Plant). l

SUBJECT:

REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) -

REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION 4

Dear ------- :

l The purpose of this lette'.- is to require information that will - provide the U.S. Nuclear Regulatory Commission (NRC) added = confidence and assurance that your plant (s) are operated and = maintained within the design bases and any deviations are - reconciled in a timely manner.

) Background i

In the mid- to late 1980s, NRC safety system functional inspections -

(SSFIs) and safety systems outage modifications inspections -

(SS0 mis) identified concerns that design bases information was not - being properly maintained and plant modifications were being made = without the licensee having an understanding of the plant design - bases. The NRC's findings heighten:'d the nuclear industry's - awareness of the need to improve the adequacy and availability of - design documentation, and many t licensees voluntarily initiated - extensive efforts to improve the design bases information for their - plants.

]

To assist the industry in performing design bases improvement - programs, the Nuclear Management and Resources Council (NUMARC)[1] = developed a e guidance document, NUdARC 90-12, " Design Basis Program -

Guidelines." These guidelines were intended to provide a standard =

framework for licensee programs to improve plant design bases =

information.[2] The NRC staff reviewed the guidelines and provided =

comments to NUMARC in November 1990. In emphasizing the importance - of validating the facility against current design information, the - staff stated that the goal of any program should be to establish - confidence that the existin3 Scility is in accordance with the - current design documents and that any deviations will be reconciled. -

The staff concluded that the NUMARC guidelines would provide = worthwhile insights to utilities undertaking design reconstitution - programs and that 4 the guidelines appeared to provide sufficient - flexibility for licensees to structure their programs to respond - most efficiently to any unique needs and circumstances of a - particular licensee. The staff requested NUMARC to consider making - design reconstitution a formal NUMARC initiative and commented that - design documents that support technical specification values and - that are necessary to support operations or to respond to events - should be regenerated if missing. NUMARC subsequently concluded -

that a formal initiative was not necessary because most of its - members 9612130019 961210 PDR ORG NRRA PDR ,

i

) were already conducting or evaluating the need to conduct = design reconstitution programs, and agreed to forward the - guidelines, with the ,

i NRC's comments, to its members for use on a = voluntary basis, i

To provide more information to the industry on this topic and to = provide 4

~

an independent view of the design control issue, the staff = conducted a survey of six utilities and one nuclear steam supply = system vendor to  ;

4 determine the status of design control problems - and the strengths and  !

j weaknesses of the sample utility programs. = t i The results were published in February 1991 in NUREG-1397, "An =  ;

, Assessment of Design Control Practices and Design Reconstitution =

i Programs in the Nuclear Industry." The survey observations were as =

l follows:

L

' -85 The need for a design documentation reconstitution program was = directly proportional to the age of the plant.

-85 The general intent of the program should be to provide a central =

l location for design bases information, with emphasis on the design - intent j (the "why" of the design).

4

85 The design bases documents should be a top-level directory that

l defines the current plant configuration.

] -85 Reestablishment of design bases without reconstitution of the =

supporting design documents, as necessary, may not provide a = sufficient level of information for future modifications or current = plant operation, or

to quickly respond to operating events.

. =85 Minor changes to the design should be tracked to support the =

l conclusion that-the changes in the aggregate do not affect the - validity of ,

j existing calculations and the ability of a system to = perform its design l

functions.

i

85 Some common weaknesses of licensee programs identified during the

i survey included the following:

i =85 Design reconstitution programs had not identified in advance the =

2 documents that are necessary to demonstrate that a structure, a - system, or a j~

component will function properly.

=85 The process for regenerating missing design documentation was not -

4 always proceduralized so that it could be handled in a systematic = manner.

=85 Validation of the content of specific output documentation was = not j

always thoroughly carried out.

In late 1991, the NRC staff evaluated whether rulemaking, guidance, = or a i

policy statement was needed to address the issue of licensees = retaining accurate design bases information. It concluded that the = existing regulatory requirements for design control were adequate; = however, it 3 determined that the publication of a policy statement - addressing design 1

bases information and publication of a generic = letter requesting licensees to describe their design reconstitution = programs would be beneficial . .

Additionally, the staff stated its = intention to continue to evaluate design control adequacy during = its performance-based inspections such as SSFIs and SSOMIs. The = staff also expected that the enforcement policy i guidance to provide = greater opportunities for enforcement discretion [3]

) would encourage - voluntary identification of past design, engineering, and

! = installation issues by licensees. With the Commission's approval, - the j staff proceeded with this approach.

, y ...- , _ _ , , _ _ . . _ . , _ _ _ - - . . . _ _ . , , , , _ _ _ , . . .

I l

, In August 1992, the NRC issued a Comission policy statement =

j " Availability and Adequacy of Design Bases Information at Nuclear -

i Power Plants" (57 FR 35455) (Attachment 1). This policy statement =

stressed the importance of maintaining current and accessible - design documentation to ensure that (1) plant physical and = functional characteristics are maintained and consistent with = design bases, (2) systems, structures, and components can perform = their intended functions, i and (3) the plant is operated in a manner - consistent with the design bases. In the policy statement, the =

l Commission recommended that all power reactor licensees assess the =

l accessibility and adequacy of their design bases information and = that they be able to show that there is sufficient documentation to = conclude that the current facility configuration is consistent with = the design bases.

L The policy statement outlined the additional - actions the NRC would take to keep apprised of the industry's - design reconstitution activities

! previously discussed.

i Following review by the Comittee To Review Generic Requirements =

(CRGR) and the Comission, a draft generic letter was issued for = public comment on March 24, 1993. The proposed generic letter = requested i licensees, on a voluntary basis, to submit information = and schedules for  !

! any design bases programs completed, planned, or = being conducted, or a  ;

i rationale for not implementing such a = program. All but one of the.  :

i commenters concluded that the generic = letter was unnecessary and l

{ unwarranted. NUMARC responded that it - believed the NRC's request for

descriptions, schedules, and dates - would have a negative impact on ongoing design efforts and that =

l

{ NRC's focus on schedules would undermine the licensees' ability to = manage  !

the activities. In SECY-93-292, " Generic Letter on the =

Availability and Adequacy of Design Bases Information," dated =

October 21, 1993, the staff recommended that the generic letter not - be 1 issued. The staff stated that publication of the policy - statement and the i proposed generic letter conveyed to the industry = the Comission's concern

! and that publication of the generic letter = would not further licensees' importance of the = activities. The staff proposed to

, awareness of the '

continue performing - design-related inspections and to gather information and insights as - to how well the licensees' design-related programs were being - implemented. The Comission issued a staff requirements memorandum =

l that agreed with the staff's proposal.

i t

In response to the findings relating to the regulatory burden of = team

, inspections identified in the 1991 Regulatory Impact Survey, = during the past several years the staff has reduced its effort on = specific, 4

resource-intensive, design-related team inspections, and = followed the issue of accurate and accessible design documentation = at plants principally as an element of inspection and followup of = ope ations-related activities. The issuance of the NUMARC = guidelines and ongoing industry efforts to improve and maintain - design bases information also f, contributed to this decision.

j Current Problem 2 Over the past several months, NRC's findings during inspections and =

j reviews have identified broad programatic weaknesses that have = resulted

~.~, - _.

- ~. .- - -- . . . - . . - - - - - . - - - - _ . - - _ - - _ -

3 9

i in design and configuration deficiencies at some plants, = which could j

impact the operability of required equipment, raise - unreviewed safety questions, or indicate discrepancies between the = plant's updated final safety analysis report (UFSAR) and the = as-built or as-modified plant or

!' plant operating procedures. These = inspections and reviews have also highlighted numerous-instances in - which timely and complete implementation of corrective action for = known degraded and nonconforming conditions and 3 for past violations = of NRC requirements has not been evident. Overall,

{ the NRC staff = has found that some licensees have failed to (1)

] appropriately = maintain or adhere to plant design bases,[4] (2)

appropriately = maintain or adhere to the plant licensing basis,[5] (3) 4 comply with - the terms and conditions of licenses and NRC regulations, and j

(4) = assure that UFSARs[6] properly reflect the facilities. Attachment =

2 provides examples of some of the deficiencies recently identified = by the

, staff. As a consequence of this new information, the NRC = believes that i the industry's voluntary efforts to improve and - maintain design bases

, information for their plants, consistent with -

NUMARC 90-12, the staff's comments on the industry guidelines, and = the

! Commission policy statement, have not been effective in all - cases.

J The magnitude and scope of the problems thht the NRC staff has = identified raise concerns about the presence of similar design, - configuration, and operability problems and the effectiveness of = quality nsurance programs

.! at other plants. Of particular concern = is whether licensee programs to l maintain configuration control at = plants licensed to operate are j sufficient to demonstrate that plant = physical and functional 4

characteristics are consistent with and are - being maintained in accordance

! with their design bases. The extent - of the licensees' failures to j maintain control and to identify and = correct the failures in a timely 1

manner is of concern because of = the potential impact on public health and safety should safety - systems not respond to challenges from off-normal and j accident = conditions.

} It is emphasized that the NRC's position has been, and continues to - be, that it is the responsibility of individual licensees to know - their i licensing basis, to have appropriate documentation that = defines their design bases, and to have procedures for performing = the necessary 1 assessments of plant or procedure changes required by =

I NRC regulations. Attachments 3 and 4 are a recent exchange of =

correspondence between J. Colvin, NEI, and Chairman S. Jackson, =

j NRC, regarding these subjects.

j Action I i The NRC has concluded that it requires information that can be used - to i verify compliance with the terms and conditions of your = license (s) and NRC regulations, and that the plant UFSAR(s) = properly describe the facilities, l as well as to determine if other = inspection activities [7] or enforcement l action [8] should be taken. =

1 Therefore, you are required, pursuant to Section 182(a) of the -

4 Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f), to = submit a ,

i response to this letter within 120 days of its receipt. = I

Your response must be written and signed under oath or affirmation.

j l

] I

4 i

i 1

Please submit the original copy of your response to the NRC -

Document Control Desk, and send a copy to the Director, Office of -

Nuclear Reactor Regulation and to the appropriate regional - administrator.

) The following information is required for each - licensed unit:

?

(a) Description of engineering design and configuration = control processes, including those that implement 10 CFR 50.59, =

10 CFR 50.71(e), and Appendix B to 10 CFR Part 50; l

j (b) Rationale for concluding that design bases requirements - are translated into operating, maintenance, and testing - procedures; (c) Rationale for concluding that system, structure, and = component

[ configuration and performance are consistent with the - design bases; i

(d) Processes for identification of problems and - implementation of corrective actions, including actions to - determine the extent of problems, action to prevent recurrence, - and reporting to NRC; and i

(e) The overall effectiveness of your current processes and =

. programs in concluding that the configuration of your plant (s) is -

, consistent with the design bases. ,

! In responding to items (a) through (e), indicate whether you have -

1 undertaken any design review or reconstitution programs, and if not, - a

{ rationale for not implementing such a program. If design review - or

reconstitution programs have been completed or are being - conducted, j provide a description of the review programs, including = identification of the systems, structures, and components (SSCs), = and plant-level design j attributes (e.g., seismic, high-energy line - break, moderate-energy line
break). The description should include - how the program ensures the-4 correctness and accessibility of the - design bases information for your plant and that the design bases - remain current. If the program is being
conducted but has not been - completed, provide an implementation schedule j for SSCs and - plant-level design attribute reviews, the expected completion j date, - and method of SSC prioritization used for the review.

f This request is covered by the Office of Management and Budget -

(OMB) clearance number 3150-0011, which expires July 31, 1997. The -

i reporting burden for this collection of information is estimated to -

I average 400 hours per response, including the time for reviewing -

i instructions, searching existing data sources, gathering and - maintaining

! the data needed, and completing and reviewing the - collection of information. Send comments regarding this burden - estimate or any other aspect of this collection of information, = including suggestions for reducing this burden, to the Information = and Records Management Branch j (T-6 F33), U.S. Nuclear Regulatory -

1 Commission, Washington, D.C. 20555-0001, and to the Desk Officer, =

i Office of Information and Regulatory Affairs, NE0B-10202 -

2 (3150-0011), Office of Mknagement and Budget, Washington, D.C. 20503. -

The NRC may not conduct or sponsor, and a person is not required to =

respond to, a collection of information unless it displays a - currently

! valid OMB control number.

i l

i

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a - copy of this letter and your response will be placed in the NRC -

Public Document Room (PDR), the Gelman Building, 2120 L Street, -

N.W., Washington, DC, and in the local public document room (s) for - your facility or facilities.

If you have any questions about this matter, please contact the = staff members listed below, or the appropriate Office of Nuclear -

Reactor Regulation (NRR) project manager.

Sincerely, James M. Taylor Executive Director - for Operations Docket Nos. STN 50-528, STN 50-529 & STN 50-530 Attachments: 1. Policy Statement on Availability and Adequacy of =

Design Bases Information at Nuclear Power Plants 2. =

Background Information on Recently Identified Problems 3. Letter = from J.

Colvin (NEI) to Chairman S. Jackson (NRC) dated =

8/2/96 4. Letter from Chairman S. Jackson (NRC) to J. Colvin (NEI) =

dated 8/14/96 Contacts: Kristine M. Thomas, NRR (301) 415-1362 Internet: = kmt9nrc. gov Eileen M. McKenna, NRR (301) 415-2189 Internet: = emm9nrc. gov Notes:

1. NUMARC was consolidated into the Nuclear Energy Institute (NEI) - on March 23, 1994.
2. As discussed in NUMARC 90-12, these programs or efforts would - emphasize collation of design basis information and the supporting - design information, not the identification or re-creation of the - licensing basis for a plant or the regeneration of missing analyses - and calculations.
3. NRC would refrain from imposing civil penalties for violations up = to Severity Level II if the violations were identified and corrected - as a result of systematic voluntary initiatives
4. As described in 10 CFR 50.2, design bases is defined as, " Design - bases mean that information which identifies the specific functions - to be performed by a structure, system, or component of a facility, = and the specific values or ranges of values chosen for controlling - parameters as reference bounds for design..." The design bases of a - facility, as so defined, is a subset of the licensing basis and is = contained in the FSAR.

l i . .

i Information developed to implement the design - bases is contained in other i documents, some of which are docketed and - some of which are retained by the j licensee.

5. The licensing basis for a plant originally consists of that set - of information upon which the Commission, in issuing an initial - operating {

license, based its comprehensive determination that the - design, '

} construction, and proposed operation of the facility - satisfied the

Commission's requirements and provided reasonable - assurance of adequate i

protection to public health and safety and - common defense and security. The )

licensing basis evolves and is - modified throughout a plant's licensing term I i as a result of the =

Commission's continuing regulatory activities, as well as the - activities of 4

the licensee.

6. The FSAR is required to be included in, and is one portion of, an -

application for an operating license (OL) for a production or = utilization facility. 10 CFR 50.34(b) describes the information = which must be included in an FSAR. The FSAR is the principal = document upon which the Commission bases a decision to issue an OL = and is, as such, part of the licensing basis of a facility. It is - also a basic document used by NRC inspectors to determine whether the - facility has been constructed and is operating within the license - conditions.

7. A number of design bases inspections are being planned, and your -

response will be used in the planning process.

8. A number of design bases inspections are being planned, and your -

response will be used in the planning process. recently approved - changes that would modify this policy to encourage licensees to - undertake voluntary initiatives to identify and correct FSAR - noncompliances by (I) the exercise of discretion to refrain from - issuing civil penalties for a two-year period where a li.censee - undertakes a voluntary initiative in this area and (2) the exercise - of discretion to escalate the amount of civil penalties for -

violations associated with departures from the FSAR identified by the -

NRC subsequent to the two-year voluntary initiative period.

THE FOLLOWING IS IN RESPONSE TO NEI-89S OBSTRUCTIONIST ACTIVITIES NRC Letter to Nuclear Energy Institute August 14, 1996 Mr. Joe F. Colvin President and Chief Executive Officer Nuclear Energy Institute Suite 400 1776 I Street, N.W. 1 Washington, D.C. 20006-3708

Dear Mr. Colvin:

I am responding to your letter of August 2,1996, concerning industry =

- ~ -- - - . - - . - . - - - .

4 i

! actions for assessing programs in place to reaffirm that nuclear - power plants are operated in conformance with their licensing basis. -

. Your letter also identified three issues that, in your view, require = mutual i

agreement between the industry and the Nuclear Regulatory =

Commission (NRC) before the industry would proceed with the - initiative. (1) i the legal standing of the Updated Final Safety =

Analysis Report (FSAR) and the NRC's Safety Evaluation Reports; (2) = the j scope of what constitutes the current licensing basis; and (3) = the adequacy

of NSAC-125, " Guidelines for 10 CFR 50.59 Safety =
Evaluations," for performing 10 CFR 50.59 evaluations. ,

We believe that resolution of the issues you identified is not a =

] prerequisite to reviewing, on a retrospective basis, whether existing -

2 programs are sufficient to ensure that licensees know their licensing = bases, i

whether licensing bases have been properly maintained, and - whether licensing bases are accurately described in each facility's - updated FSAR or other documents. The significant issues recently = identified by licensee reviews and NRC staff inspections relate to = failures to address degraded and I

nonconforming conditions properly, = failures to perform reviews required by 10 CFR 50.59 before making = changes to facilities, and failures to update

facility Final Safety =
Analysis Reports in accordance with 10 CFR 50.71(e). In our view, - industry initiatives can proceed notwithstanding that ongoing NRC = activities under the 10 CFR 50.59 Action Plan will consider, in a = broad sense, issues such as

+50se you raise, j Existing regulations and guidance are sufficient to conduct a - retrospective 4

review for conformance to existing regulatory = requirements. These. include:

l (1) NRC regulations 10 CFR 50.2, 50.34, -

4 50.54,50.59,'50.71(e),50.72,50.73 and Appendix B; (2) NRC's policy =

statement - Availability and Adequacy of Design Bases Information at =

Nuclear Power Plants, 57 FR 35455 August 10, 1992; (3) " Design Bases =

Program Guidelines," NUMARC 90-12 and NRC letter dated November 9, =

3 1990; and (4) Generic Letter 91-18, "Information To Licensees =

i Regarding Two NRC Inspection Manual Sections On Resolution Of =

1 Degraded And Nonconforming Conditions And Operability."

The staff is concerned, however, that the proposed initiative may not - be of sufficient scope and depth to identify the types of design and = openbility problems recently identified at several operating plants. =

Specifically, it is not sufficient to perform a process / procedural = based review. An in-depth vertical slice review of actual design - basis  !

documentation and comparison of "as built" and "as operated" = safety systems

is more appropriate.

For example, reviews similar to safety system functional inspections = l (Inspection Procedure 93801, " Safety System Functional Inspections"), = may be  :

used to evaluate a licensee's program effectiveness to = maintain the licensing and design bases. These reviews should - include: (1) an in- depth ,

i review of selected systems' design and - design basis since issuance of the

facility operating license; (2) = risk- and safety-based criteria for

! selection of systems for review; = and, (3) a method to ensure that licensee i problem identification and = corrective action on the selected systems are i representative and = consistent with other systems. The in- depth review

1 l

l should examine: -

(1) engineering design and configuration control; (2) verification of -

as-built and as-modified conditions; (3) translation of the design - bases requirements into operating procedures, maintenance, and - testing; (4) verification of system performance through review of - tes t records and observations of selected testing; (5) proposed and - implemented corrective actions for licensee-identified design - deficiencies; and, (6) modifications made to the systems since - initial licensing.

In short, the NRC position has been, and is, that it is the - responsibility of individual licensees to know their licensing basis, - to have appropriate documentation that defines their design basis, - and to have procedures for performing the necessary assessments of - plant or procedure changes required by NRC regulations. Until such - time that any regulation changes are made as a result of NRC action - plan activities, we will continue inspection and oversight activities - related to the design basis to ensure compliance with existing - regulations.

Sincerely, Shirley Ann Jackson Paul M. B1anch Energy Consultant 135 Hyde Rd.

West Hartford CT 06117 Voice 860-236-0326 Fax 860-232-9350 I

, .

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