ML20134C997
| ML20134C997 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/09/1996 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | May T BOSTON EDISON CO. |
| References | |
| NUDOCS 9610110255 | |
| Download: ML20134C997 (28) | |
Text
{{#Wiki_filter:. _ _ ~ - . . _ - _ _ . - fn p $ UNITED STATES s# j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001 k...../ October 9, 1996 Mr. Thomas J. May Chairman and Chief Executive Officer Boston Edison Company 800 Boylston Street Boston, MA 02199 I
SUBJECT:
REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION l
Dear Mr. May:
The purpose of this letter 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. , l Backaround ! In the mid- to late 1980s, NRC safety system functional inspections (SSFIs) I 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 heightened the nuclear industry's awareness of the need to improve the adequacy and availability of design documentation, and many 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) developed a guidance document, NUMARC 90-12, " Design Basis Program Guidelines." These guidelines were intended to provide a stanpard framework for licensee programs to improve plant design bases information. 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
'NUMARC was consolidated into the Nuclear Energy Institute (NEI) on March 23, 1994. yG\g i 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. 110017 ' 9610110255 961009 PDR ADOCK 05000293 P PDR j
. Mr. Thomas J. May stated that the goal of any program should be to establish confidence that the existing facility 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 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 were already conducting or evaluating the need to conduct design reconstitution programs, and agreed to forward the guidelines, with the NRC's l comments, to its members for use on a voluntary basis. To provide more information to the industry on this topic and to provide an ' independent view of the design control issue, the staff conducted a survey of six utilities and one nuclear steam supply system vendor to determine the status of design control problems and the strengths and weaknesses of the sample utility programs. The results were published in February 1991 in l NUREG-1397, "An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Industry." The survey observations were as follows: 1
. The need for a design documentation reconstitution program was directly proportional to the age of the plant. '
. The general intent of the program should be to provide a central location for design bases information, with emphasis on the design intent (the "why" of the design).
- The design bases documents should be a top-level directory that defines the current plant configuration.
- 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.
Minor changes to the design-should be tracked to support the conclusion that the changes in the aggregate do not affect the validity of existing calculations and the ability of a system to perform its design functions. i 1
l Mr. Thomas J. May ' 1 1 Some common weaknesses of licensee programs identified during the survey I included the following: l
- Design reconstitution programs had not identified in advance the '
documents that are necessary to demonstrate that a structure, a j system, or' a component will function properly. !
- The process for regenerating missing design documentation was not
! always proceduralized so that it could be handled in a systematic manner. !
- Validation of the content of specific output documentation was not always thoroughly carried out. l In late 1991, the NRC staff evaluated whether rulemaking, guidance, or a ;
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 determined that the publication of a policy statement addressing design 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 expectedthattheenforcempntpolicyguidancetoprovidegreateropportunities for enforcement discretion would encourage voluntary identification of past design, engineering, and installation issues by licensees. With the Commission's approval, the staff proceeded with this approach. In August 1992, the NRC issued a Commission policy statement " Availability and Adequacy of Design Bases Information at Nuclear 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, and (3) the plant is operated in a manner consistent with the design bases. In the policy statement, the Commission recommended that all power reactor licensees assess the 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. The policy statement outlined the additional actions the NRC would take to keep apprised of the industry's design reconstitution activities previously discussed. Following review by the Committee To Review Generic Requirements (CRGR) and the Commission, a draft generic letter was issued for public comment on March 24, 1993. The proposed generic letter requested licensees, on a 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.
Mr. Thomas J. May voluntary basis, to submit information and schedules for any design bases programs completed, planned, or being conducted, or a rationale for not implementing such a program. All but one of the commenters concluded that the generic letter was unnecessary and 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 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 issued. The staff stated that publication of the policy statement and the proposed generic letter conveyed to the industry the
- Commission's concern and that publication of the generic letter would not
- further licensees' awareness of the importance of the activities. The staff proposed to continue performing design-related inspections and to gather information and insights as to how well the licensees' design-related programs were being implemented. The Commission issued a staff requirements memorandum that agreed with the staff's proposal.
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, 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 operations-related activities. The issuance of the NUMARC guidelines and ongoing industry efforts to improve and maintain design bases information also contributed to this decision. ! 1 Current Problem i Over the past several months, NRC's findings during inspections and reviews ; have identified broad programmatic weaknesses that have resulted in design and l configuration deficiencies at some plants, which could impact the operability j of required equipment, raise unreviewed safety questions, or indicate l 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 I timely and complete implementation of corrective action for known degraded and j nonconforming conditions and for past violations of NRC requirements has not , been evident. Overall, the NRC staff has found that some licensees h ' failed to (1) appropriately maintain or adhere to plant design bases,pve
'As described in 10 CFR 50.2, design bases is defined as, " Design bases mean that infomation 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. Information developed to implement the design bases is contained in other documents, some of which are docketed and some of which are retained by the licensee.
. . i
. Mr. Thomas J. May (2) appropriately maintain or adhere to the plant licensing basis,5 (1) comply with the teps and conditions of licenses and NRC regulations, and (4) assure that UFSARs 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 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. The magnitude and scope of the problems that the NRC staff has identified raise concerns about the presence of similar design, configuration, and operability problems and the effectiveness of quality assurance programs at other plants. Of particular concern is whether licensee programs to maintain configuration control at plants licensed to operate are sufficient to demonstrate that plant physical and functional characteristics are consistent with and are being maintained in accordance with their design bases. The extent of the licensees' failures to maintain control and to identify and correct the failures in a timely 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 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 licensing basis, to have appropriate documentation that defines their design bases, and to have procedures for performing the necessary assessments of plant or , procedure changes required by NRC regulations. Attachments 3 and 4 are a recent exchange of correspondence between J. Colvin, NEI, and Chairman S. Jackson, NRC, regarding these subjects.
'The licensing basis for a plant originally censists 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 protection to public health and safety and common defense and security. The licensing basis evolves and is modified throughout a plant's licensing term as a result of the Commission's continuing regulatory activities, as well as the activities of the licensee.
Dhe 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.
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1 Mr. Thomas J. May Action l The NRC has concluded that it requires information that can be used to verify compliance with the terms and conditions of your license (s) and NRC regulations, and that the plant UFSAR(s) properly dpscribe the facilities g as well as to determine if other inspection activities or enforcement action should be taken. Therefore, you are required, pursuant to Section 182(a) of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f), to submit a > response to this letter within 120 days of its receipt. Your response must be written and signed under oath or affirmation. 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; (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; (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 7 A number of design bases inspections are being planned, and your response will be used in the planning process. sSection VII.B.3 of the NRC Enforcement Policy addresses how old design issues involving past problems in engineering, design, or installation are to be handled from an enforcement standpoint. In a related matter, the Commission recently approved changes that would modify this policy to encourage licensees to undertake voluntary initiatives to identify and correct FSAR noncompliances by (1) the exercise of discretion to refrain from issuing civil penalties for a two-year period where a licensee 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.
. Mr. Thomas J. May (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 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, provide a description of the review programs, including identification of the systems, structures, and components (SSCs), and plant-level design attributes (e.g., seismic, high-energy line break, moderate-energy line break). The description should include how the program ensures the 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 for SSCs and plant-level design attribute reviews, the expected completion date, and method of SSC prioritization used for the revicw. This request is covered by the Office of Management and Budget (OMB) clearance ' number 3150-0011, which expires July 31, 1997. The reporting burden for this collection of information is estimated to average 400 hours per response, including the time for reviewing 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 l Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs, NE0B-10202 (3150-0011), Office of Management 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. 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. a a
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, Mr. Thomas J. May l i
If you have any questions about this matter, please conte t toe staff members listed below, or the appropriate Office of Nuclear Reactor xt:gulation (NRR) project manager. Sincerely, i / L "
- >[
es M. la r xecutive D rector for Operations Docket Nos. 50-293 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 i Contacts: Kristine M. Thomas, NRR l (301) 415-1362 Internet: kmt0nrc. gov Eileen M. McKenna, NRR (301) 415-2189 Internet: emm@nrc. gov cc w/atts: See next page 1 l
Pilgrim Nuclear Power Station cc: Mr. Leon J. Olivier Mr. David F. Tarantino Vice President of Nuclear Nuclear Information Manager Operations & Station Director Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station RFD #1, Rocky Hill Road RFD #1 Rocky Hill Road Plymouth, MA 02360 Plymouth, MA 02360 Ms. Kathleen M. O'Toole Resident Inspector Secretary of Public Safety U. S. Nuclear Regulatory Commission Executive Office of Public Safety Pilgrim Nuclear Power Station One Ashburton Place Post Office Box 867 Boston, MA 02108 Plymouth, MA 02360 Mr. David Rodham, Director Chairman, Board cf Selectmen Massachusetts Emergency Management 11 Lincoln Street Agency Plymouth, MA 02360 400 Worcester Road P.O. Box 1496 Chairman, Duxbury Board of Selectmen Framingham, MA 01701-0317 Town Hall Attn: James Muckerheide 878 Tremont Street Duxbury, MA 02332 Chairmen, Citizens Urging Responsible Energy Office of the Commissioner P. O. Box 2621 Massachusetts Department of Duxbury, MA 02331 Environmental Protection [ One Winter Street Citizens at Risk l Boston, MA 02108 P. O. Box 3803 l Plymouth, MA 02361 ' Office of the Attorney General One Ashburton Place W. S. Stowe, Esquire 20th Floor Boston Edison Company Boston, "A 02108 800 Boylston St., 36th Floor Boston, MA 02199 Mr. Robert M. Hallisey, Director i Radiation Control Program Chairman Massachusetts Daprtment of Nuclear Matters Committee Public llealth Town Hall 305 South Street 11 Lincoln Street Boston, MA 02130 Plymouth, MA 02360 l i Regional Administrator, Region I Mr. k.<liam D. Meinert l U. S. Nuclear Regulatory Commission Nuclear Engineer 1 475 Allendale Road Massachusetts Municipal Wholesale King of Prussia, PA 19406 Electric Company P.O. Box 426 Ms. Jane Fleming Ludlow, MA 01056-0426 8 Oceanwood Drive Duxbury, MA 02332 Mr. E. Thomas Boulette, Ph.D. Senior Vice President - Nuclear Mrs. Nancy Desmond Boston Edison Company l Manager, Reg. Affairs Dept. Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road RFD #1 Rocky Hill Road Plyr.outh, MA 02360 ' Plymouth, MA 02360 l
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i ' i, Mr.' Jeffrey Keene i Regulatory Affairs Department i ! Manager i Boston Edison Company , 600 Rocky Hill Road , j Plymouth, MA 02360-5599 i j j i l 1 i 1 f 1 4 k J 8, i 0 1 , i 1 1 I i 1 1 4
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0 ; i l 35453 1 l 1 Rules and Regulations r d =i a sta' l Vol. 57. No 154 I l I Monday. August 10. 1992 This section of the FEDERAL REGtSTER Program Cuidelines." NUMARC W12. functional characteristics are contains regulatory documents having While developing these guidelines, maintained and are consistent with the general apphcabety and legal effect, most NUMARC discussed them at several design bases as required by NRC of which are keyed to and codiried in public meetings held with the NRC. The regulation. (2) systems. structures, and the Code of Federal Regulations, which is staff has concluded the NUMARC components can perform their intended hed under 50 tities pursuant to 44 guidelines provide a useful standard functions, and (3) the plaht is operated framework for implementing design in a manner consistent with the design The Code of Federal Regulatons is sold by the Suoenntendent of Documents reconstitution programs.The staff also bases. The Commisalon believes the Pnces of new books are listed in the agrees no single approach would enable regulatory framework already exists to l first FEDERAL REGISTER issue of each utilities to best accomplish the address the need for accessible design i week reconstitution task. The NUMARC bases and control of design information. ! guidance appeared to provide sufficient The availability of current design and flexibility for individual utilities to licensing bases will also expedite the NUCLE AR REGULATORY vructure their programs to respond most license renewal process. COMMISSION efficiently to their unique needs and The Commission believes. as a result circumstances. of NRC inspections and licensees'self-10 CFR Part 50 The staff sent comments on the assessments that all power reactor guidelines to NUMARC on November 9. licensees should assess the accessibility Avallability and Adequacy of Dealgn 1990. Commission paper SECY-90-365 and adequacy of their design bases Bases information at Nuclear Power Plants; Policy Statement informed the Commissioners in advance documentation.The results of this self. about the staff response to NUMARC. assessment should form the basis for a AOENCv: Nuclear Regulatory The staff requested NUMARC licensee's decision whether a design Commission. consider making the design bases effort reconstitution program is necessary and i I ACTION: Policy statement. a NUMARC initiative. NUMARC the attributes to be included in the concluded they would not pursue a program. The Commission recognizes I suMMaRv: The Nuclear Regulatory formalinitiative, but would forward the the need for a design reconstitution Commission is issuing this policy guidelines to their members to use on a p ogram to be tailored to meet the statement on availability and adequacy voluntary basis. Their reason for not unique needs of a particular utility.The of design information at nuclear power pursuing an initiative was that most of structure and content of the design : I plants. This policy statement describes their members were already conducting document reconstitution program will be the Commission's expectations and or evaluating the need to conduct design influenced by various factors, such as fuiure actions with regard to the bases reconstitution programs. the utility's organizational structure, the availability of design information and The Commission's evaluation of the availability or unavailability of design emphasizes the Commission's view that status of reconstitution programs clearly documentation, and the intended users facilities should not be modified without indicates the licensees' substantial of the documentation.The Commission a clear understanding of the applicable investment in these programs should expects that after completing a engineering design bases. yield positive safety benefits for a reconstitution program, or as a basis for EFFECTIVE DATE: August 10.1992 majority of sites.The NRC commends concluding that such a program is FOR FuRTHER INFORM ATION CONTACT: those licensees that are actin 8 to ensure unnecessary, the licensee will have Eugene V. imbro. Office of Nuclear technically adequate and accessible current design documents and adequate Reactor Regulation. U.S. Nuclear design bases dccumentation is technical bases to demonstrate that the Regulatory Commission. Washington, maintained. plant physical and functional DC 20555. telephone (301) $04-2967. However, the Commission is characteristics are consistent with the SUPPLEMENT ARY INFORM ATION: NRC concerned some situations exist where design basis, the systems, structures. licensees have ne critically examined and components can perform their inspection findings have demu.. trated that some licensees have not adequately the. ir design enntrol and configuration intended functions and the plant is being maintained their design bases management processes to identify operated in a manner consistent with information as required by NRC requisite measures to ensure the plant is the design basis. regulations. Both the problems identified operating within the deugn bases . . NUMARC has developed guidance for during the NRC inspections and those envelope. Therefore, the Commission is the conduct of desPn beses identified by licensees have prompted articulating its expectations with regard reconstitution programs. The guidance niost power reactor licensees to initiate. !o design information and elaborating on outlines a framework to organize and over the past several years. design its planned activities to confirm the collate nuclear power plant design bases integrity of the as configured plant with information. This information provides bases reconstitution programs. To respect to the plant design bases. the rationale for the design bases implement a reconstitution program. consistent with the definition of design licensees week to identify missing design Policy Statement documentation and to selectively bases contained in to CFR $0.2. Po8i' ion NUMARC 90-12. " Design Basis Program regenerate missing documentat%n as required. The Commission has concluded that Guidelines." was issued in October 1990 in 1989. Nuclear Utilities Management maintaining current and accessible for voluntary use by NUMARC memb:r and Resources Council. Inc.. (NUMARC) design documentation is important to organizations as a reference point from began developing their " Design Basis ensure that (1) the plant physical and which licensees would review their s-3ioo++ nooinmunwo 92 i:nn:,, Attachment 1
35456 Federal Rsgister / Vol. 57, No.154 / Monday, August 10, 1992 / Rules cnd Regulations existing or planned efforts to collate ensuie their validity for the life of the DEPARTMENT OF THE TREASURY supporting design information. The facihty. including any renewal period. in order to ensure the Commission is Office of Thrift Supervision , Commission believes NUMARC's approach provides a useful framework appraised of mdustry's activities. the 12 CFR Part 584 1 and worthwhile insights to those utilities NRC will take the following actions. l undertaking design basis programs (1) The staff willissue a generic letter is2-ts51 The Commission believes a licensee requesting alllicensees to describe the should be able to show that it has programs that are in place to ensure htN 1550- AA38 sufficient documentstion, including design information is correct. accessible. Registration, Examination and calculations or pre. operational. startup and maintained current.Those licensees Reports; Statements, Applications, or surveillance test data to conclude the that are not implementing a design Reporte and Notices To Be Filed current facility configuration is reconstitution program will be requested consistent with its design bases.The to provide their rationale for not doing AotNcy: Office of Thrift Supervision. Commission further believes the design so. lf a reconstitution program is under l're a s ury. bases must be understood and way. the schedule for implementation Action: Final ru'e. documented to support operability and completion will be requested. determinations and 10 CFR 50 59 suuMAny:The Office of Thrift (2) The staff will prioritize NRC Supervision (OTS)is hereby amending evaluations that me) need to be made quickly in responding to plant events. inspections of licensee'a management of its regulations pertaining to holding The design bases related information design and configuration using SSF1- company reporting requirements. In should be retrievable within a type techniques based upon responses updating existing forms to reflect reasonable period of time. however. it is to the generic letter and other plant changes necessitated by the Financial not necessary for all design basis specific information known to the NRC. Institutions Reform. Recovery. and documentation to be organized in one Additionci staff guidance will be Enforcement Act of 1989. the OTS has place. The information used solely to developed. where needed.for the desi F n combined several forms to streamline support the developmerit of a bases aspects of these inspections. the reporting process and ease the modification package would not need to regulatory burden on savings and loan be able to be retrieved as expeditiousiv (3) The NRC systematic assessment of holding companies. In particular, the as information needed to support an - licensee perf rmance (SALP) process reporting requirements set forth in will be modified to explicitly address Forms H-(b)3. H-(b}4. H-{b)5 and H-operabihty determination. assessment of licensee prostems t (b)10 Registration Statements are now
, in the event the design bases control design bases information that contained in one body of instructions for mformation is found technically reflect NRC inspection activity in this all Registrants, the H-(b)10. In addition.
inadequate or not accessible, licensees area and assure consistent evaluations. the H-(b)11 Annual Report and the H-should consider whether remedial action (b)12 Current Report have been merged is warranted. A methodology should be (4) The staff will continue t nto one set of instructions requiring an . developed and implemented to ensure encourage self. identification of design l annual filing with quarterly updates licensee resources are focused un design bases issues through application of the informing the OTS of any changes.The l information regeneration in a timeframe provisions of the Commission's I enforcement policy.The staff will. H-(f) Dividend Notification has been commensurate with the safety renc nded, since the requirements significance of the missing or erroneous however. pursue enforcement actions for contained in the Capital Distributions mformation. engineering deficiencies whose root regulation are sufficient for the OTS's cause lies in the inadequacy or monitoring and supervision purposes. The Commission also emphasizes it is unavailability of design bases gFncTive oATE: September 9.1992. very important that modifications to a facility be made after a thorough review information and which are identified during NRC inspections. Michael P. Scott. Program Manager, has been conducted and an understanding of the applicable (202) 906-5748. Supervision Policy, Paperwork Reduction Ad Statement Office of Thrift Supervision.1700 G underlying design bases has been gained in order to ensure appropriate This final polic) statement does not Street NW., Washington. DC 20552. design margins are preserved. contain a new or amended information sUPPLEM ENT ARY INFORM ATION: collection requirement subject to the Future Acfions 1. Background Paperwork heduction Act of 1980 (44 U.S C. 3501 et seq.). Existing The OTS is today issuing a final rule The Commission will continue t . requirements were approved by the amending its holding company reporting inspect routinely the adequacy of design Office of Management and Budget requirements. This amendment affects , control program effectiveness. The approval number 3150-0011. the registration. annual. and current l Commission concludes that ensuring the reporting requirements. ' design bases and configuration of a Daied at Rockvilie. Maryland. this 4th day facility are well understood and of August.1992. controlled in plant documents will also As previously structured. holding ensure that those parta of the current For the Nuclear Regulatory Commission. companies were required to choose from licensing bases of most safety four separate registration statements. significance are understocd and Sa muel l. Chilk. These separate statements were controlled. Other aspects of the current Secretary of the Commission. originally deemed necessary to licensing bases, such as emergency accommodate special types of holding preparedness and security plans. should lFR Doc 92-18895 Filed 6-b92. 8 45 ami companies (i.e., companies that become also be appropriately examined to * * * * ' ' ' " savings and loan hold;ng companies as S-310999 0002(00x07. A UG.92 12 00 32) 470n NT .116 anL 4an.02 , 1
l BACKGROUND INFORMATION ON RECENTLY IDENTIFIED PROBLEMS i l Over the past several months, design a- Sngineering information has been ! obtained that indicates that design ba. at certain plants have not been
- appropriately maintained or adhered to. Specific examples follow
l Millstone Units 1. 2. and 3 i An NRC inspection team recently found examples in which design bases information and the Updated Final Safety Analysis Report (UFSAR) did not agree 4 with the as-built plant, operational procedures, and maintenance practices. The team found inconsistencies that required analyses, procedure changes, and design changes to resolve. For example, the Millstone Unit 3 operating i ! procedures required isolation for the turbine-driven auxiliary feedwater pump 4 during certain plant conditions, in conflict with technical specification j requirements for operability. The team found that certain protective relays i at Millstone Unit 3 were not set in accordance with the design bases j information. This required re-analyses and resetting of certain relays. j Based on the team's findings, the licensee initiated design changes to correct i nonconforming conditions between the UFSAR and the as-built plant, including changes to the design of the Millstone Unit 2 reactor protection system to i meet the design bases with respect to physical separation of redundant channels and changes to the design of the Millstone Unit 2 )l (post-loss-of-coolant accident (LOCA)) hydrogen monitors to meet the design i bases for single failure vulnerabilities. 4 ! Haddam Neck i An NRC inspection team found examples in which the design bases information i and the UFSAR did not agree with the as-built plant, operational procedures, } and maistenance practices. The team identified a number of deficiencies in i engineering calculations and analyses that were relied upon to ensure the 4 adequacy of the design of key safety systems. Deficiencies were identified in i the caleviations and analyses supporting the station batteries, emergency 1 diesel generators, containment cooling system, and other key safety systems. l In some cases, the inspection findings were resolved by revising the calculations and analyses. In other cases, procedure and design changes were I required to resolve the issues. For example, the team identified that the l design bases calculations supporting the size of the station batteries were inconsistent with the design bases stated in the FSAR. Field measurements and j design modifications were required to resolve this issue. l Other issues were identified by the NRC and the licensee following the
- 1ssuance of this special team inspection report that led the licensee to enter l l a refueling outage earlier than originally s,cheduled. Discrepancies included l inadequate configuration management of the containment sump design and i as-built conditiors; a lack of detailed analysis and technical justification l
for the reliance on post-accident back pressure inside the containment to j assure adequate net positive suction head for the residual heat removal pumps;
- inadequate inspection and verification of the sump as-built and material 4
i Attachment 2 j d i
4 l . conditions; and the lack of aggressive action in response to generic communications of industry events, which contributed to an inadequate operability determination regarding the sump screen design and mesh size. These issues impacted the operability of the emergency core cooling systems (ECCSs) under certain postulated design basis events. li Maine Yankee 1 On January 10, 1996, the NRC issued a Confirmatory Order Suspending Authority
- for and Limiting Power Operation and Containment Pressure and a Demand for ,
i Information to the Maine Yankee Atomic Power Company. The order was based, in l i part, on the NRC's determination that Maine Yankee did not apply a computer code that was proposed to demonstrate compliance with the ECCS requirements of 10 CFR 50.46 in a manner that conforms to the requirements of 10 CFR Part 50, 1 Appendix K, nor to the conditions specified in the staff's safety evaluation )
. dated January 30, 1989. Specifically, the licensee did not demonstrate that '
the RELAP5YA code will reliably calculate the peak cladding temperature for all break sizes in the small-break LOCA spectrun for Maine Yankee, nor has the licensee submitted the justification for the code options selected and other , justifications and sensitivity studies to satisfy conditions in the staff's ! safety evaluation. ! In addition, the licensee assumed an initial containment pressure of 2.0 psig i for calculating peak design-basis accident pressure, even though the plant's technical specifications allow a maximum operating pressure in containment of 3.0 psig. Assuming an initial containment pressure of 3.0 psig results in a calculated peak accident pressure in excess of the containment design pressure described in the UFSAR. ._- Refuelina Practices Survey l \ j In a survey of licensee refueling prv.tices conducted during the spring of i 1996, the NRC identified deficiencies i., the management of design bases i assumptions. Many plants were found to tave aspects of their design bases i that were only 1;osely pruceduralized or not proceduralized at all. Typical of this kind of discrepancy was the identification of a lack of procedures for cor. trolling the assumptions regarding hold-up time before beginning fuel 1 transfer. The I:RC found a nuober of instances in which other design bases ! assumptions were not captureu in procedures. In addition, it was necessary l for licensees at 12 sites (23 units) to upgrade procedures to directly l ) implement the design bases assumptions. In other cases, the licensee i performed engineering analyses, documented pursuant to 10 CFR 50.59, as necessary, to ensure that the planned activities would not exceed design bases l l assumptions. j i i i i I l 4 1 ; l 1
,s .
El . .
.. :e i.!;. -
Joe F. Colvm August 2.1996 The Honorable Shirley A. Jackson Chairman U.S. Nuclear Regulatory Commission Washington DC 20555 0001 l l l
Dear Chairman Jackson:
On July 23.1996. the Nuclear Strategic Issues Advisory Committee (NSIAC) held a special meeting to discuss industry actions for ensuring the licensing basis of nuclear plants is being maintained consistent with the regulations. The chief nuclear officers of the nuclear utilities approved an initiative to provide additional assurance and conSdence that existing programs are adequate to ensure that-
. Licensees are operating their plants in conformance with their licensing l
basis:
. Licensees are adequately maintaining their licensing basis:
. There are no differences between operating practices and the licensing basis that could result in a significant public health and safety concern: and
. Degraded or non-conforming conditions are captured on tracking systems and resolved in a timely manner.
Under the initiative. each licensee will conduct an assessment of the programs in place to reaffirm that plants are operated in conformance with their licensing basis. The program assessment is accomplished by sampling (1) FSAR information. (2) J programs in place for processing changes to procedures and the plant that may impact the FSAR and (3) changes that may not be governed by licensee programs. Many licensees have already commenced or recently completed similar program assessments. Differences identiSed through the sampling process will be evaluated to assess the overall effectiveness and adequacy of programs. Programmatic enhancements will be made if needed. The overall significance of any differences will be characteiized to determine if additional sampling is warranted. Differences that represent degraded or nonconforming conditions will be captured on a tracking system and resolved in a timely manner. Each licensee will notify the NRC of any differences that are subject to reportHg requirements per the regulations. Attachment 3
i l The Honorable Shirlev A. Jackson
'e l August 2,199G 1 j Page 2 i
l The results of the indmdual plant assessments wdl be provided to NEl for compilation in an industry summary report. The summary report wal be provided 4, to the NRC for information 1 i t j The industry has developed a draft guidehne to assist utihties in performing the l programmatic assessment. The guidehne wtl1 be Snabzed subsequent to resolution j of the issues discussed below. Enclosure 1 provides a copy of NEI 96 05 fDraft) Rcvision D. "Guidehnes for Assessing Programs for Maintaining the Licensing Basis." for your information. l There are a number of related issues that require a mutual agreement between the ! Industry and the NRC before the industrv can proceed with the initiative in a consistent manner These include-l
. The legal standing of the Updated Final Safety Analysis Report and the l
i NRC's Safety Evaluation Reports.
- . The scope of what constitutes the current been<ing basis
- and j . The adequacy of SSAC 125 for performing 10 CFR 50 59 safety evaluations 1
The industry is committed to completing the initiative within six months of the resolution of these issues. Initial progress in resoldng these issues was i accomphshed dunng the NRC pubbe meeting also held on July 23.1996. We l appreciate very much the participation of your senior staffin this meeting and the j opportunity to discuss these issues Expedited closure on these fundamentalissues i is needed to minimize confusion within the NRC regions and the plants and focus j our resources on addressing the programmatic issues. t 2 i We look forward to a continuing dialogue with the Commission and NRC staff to achieve timely resolution of this matter. j Sincerely. i g4AL
! Jge F Colvin i -
'I ,,
Enclosure c Con:nussioner Kenneth C. Rogers. NRC f Commissioner Greta .I. Dieus NRC
.\1r . lame. .\1 Taylor NRr
NEI 96-05 (DRAFT) Revision D NUCLEAR ENERGY INSTITUTE GUIDELINES FOR ASSESSING PROGRAMS FOR MAINTAINING THE LICENSING BASIS l l JULY 25,1996
i
1.0 INTRODUCTION
Licensees have implemented various programs / processes over the period of thetr licenses for ensuring that the licensing basis is known. is mamtained current and is accurately described in the FSAR and associated referenced documents. The NRC. through a review deuribed in SECY 94 066. determined that licensees were adequately maintaining the licensing basis of their facilities. As a result of events that have occurred over the last several months. the NPC has increased attention on hcensee compliance with the plant's bcensing basis. Differences can occur due to problems in those processes / programs intended to effect changes in the license basis. missing programmatic controls to translate changed operational activities ' into the licensing basis. or a lack of awarenes.5 oflicensing basis features. Licensees employ various programmatic mechanisms for identifying, evaluating and/or processing changes in plant activities that could affect the licensing basis or that are intended to make changes to the licensing basis. These include:
. Final Safety Analysis Report (FSAR) updates per 10 CFR 50.71(e)
. Safety Evaluations per 10 CFR 50.59
. Changes to Quahty Assurance. Security and Emergency Plans per 10 CFR 50.54
. License amendments per 10 CFR 50.90
. ASME Code rehef requests per 10 CFR 50.55a
. Procedure changes (not subject to 50.59)
. Design changes (not subject to 50.59)
. Regulatory commitment changes .
. Degraded or non conforming conditions
. Configuration management changes (e.g., operator workarounds, extended operation of equipment in manual mode rather than automatic operation modes. and Technical Specification positions / interpretations) 1
I a 4 2.0 PURPOSE AND SCOPE 2 2.1 Purpose j This document provides guidance for performing a self assessment of the adequacy l of programmatic controls for maintaining the licensing basis in order to identify l missing or incorrectly apphed programmatic elements that can lead to licensing l , basis differences. j f 2.2 Scope The assessment approach consists of a data ga:hering phase and an evaluation 1 phase. The data gathering phase employs a three tiered sampling technique. The i first tier involves in process sampling for the programmatic elements intended to l effect a change in the licensing basis. Since programmatic elements may be missing i or incorrectly applied. the next two sampling tiers involve a search for differences ; by sampbng for potential operational changes that could be made without j l procedure changes, and samphng backwards by comparing selected FSAR l 4 statements with operational practices. The purpose of the data gathering phase is ' to identtfy a set of potential differences between the operational practices and the l bcensing basis.
- 1 The evaluation phase determines if potential differences are vahd. Vahd l
! differences are categorized in order to draw conclusions about the adequacy of particular programmatic controls for maintaining the licensing basis. The 4 signtficance of the findings are used to develop recommendations for programmatic enhancements. j lt is recognized that many beensees have performed safety system functional
; inspections (SSFIs) and other reviews that have assessed the adequacy of their i
programs to maintain the licensing basis of their plants and to ensure the accuracy i ofinformation in the FSAR. These completed activities can be credited, as l apprcpriate, in meeting portions of the assessment described below. The assessment methodology described below represents only one way of performing the assessment of the adequacy and effectiveness of programs for ; maintaining the licensing basis. Although the methodology contains a reasonable l amount of detail. it is not intended to be prescriptive. Other approaches that provide an equivalent scope of review can also meet the intent of this assessment. l 2
i 3.0 ASSESSMENT METHODOLOGY 3.1 Data-Gathering Phase The data gathering phase of the assessment employs three sampling techniques. Each sampling technique is discussed separately 3.1.1 FSAR Sampling *
- Extract the relevant FSAR sections for the system (s) being evaluated
- Highlight those FSAR statements that meet the following criteria:
0 Descriptive phrases regarding frequencies for tests, calibrations. etc.
- Con 5guration descriptions Descriptions of system operation in different modes (e.g.. normal. abnormal. accident / emergency)
- Operating limits
- Descriptive functional performance statements
- NOTE: The intent is to identify a range of FSAR statements associated with operational practices that could be changed and, in the presence of programmatic weaknesses, are not adequately reflected in the FSAR.
. Compare the highlighted FSAR statements with current operational practices using individuals cognizant of the operation of the system and associated engineering problems. Document the following:
0 Is the FSAR statement accurate with respect to operational practices (procedures, operating philosophy, standing orders, workarounds, etc.)? If not, identify the differences. O Is the FSAR statement clearly understood or in need of clariScation? 3.1.2 Programmatic Sampling
. Select three unrelated examples of each of the following types of changes:*
- 50.59 ( at least one procedure chance evaluationi 3
i , i I I
) 50.54 (one each from QA, EP and Security 1
- Outstanding corrective action for a matarial condition greater than one j year old i
I Operating procedure change not evaluated under 50.59
> FSAR change request j
1 j 0 50.90/50.55a change and associated SER (where NRC approval has been received) 0 Regulatory commitment addition or change j 0 Design change not evaluated under 50.59 i !
- NOTE: The chances selected should have been completed in sufScient time l
to have been reDected (if required) in the most recent licensing basis update of the FSAR. QA program. etc. i t
- Review the change to determine if the change should have appeared in the bcensing basis and, if so. if the licensing basis accurately reDects the change.
l For changes that are not accurately reDected in the licensing basis. ) 1 determine the programmatic step or missing programmatic step) that j would have ensured its accurate incorporation into the licensing basis.
- Document the results of the programmatic sampling.
3.1.3 Sampling for potential changes that may occur separate from ! programmatic or procedure changes 2
. Compile the following:
i 0 Workaround bst l 0 Operations standing orders 0 Technical SpeciBcations positions / interpretations (if any)
- Sample of documents that may show potentially routine "NA*ing" of
! procedure steps (e.c. last completed startup procedure, recently completed system operating instructions. shift supervisor loc entries for deviationsi
.e*
4
S
- List of equipment being operated in manual
- Old* temporary alterations
- Old' non conformances
- Old* tag outs
* "Old" refers to current items that should be reDected (if requtred)in the last FSAR update per 10 CFR 50.71(e)
. Select a sample from each of the above categories based on the number of
'tems compiled.
. Review the item selected to determine if the item represents a change to the bcensing basis and, if so. If the licensing basis accurately reDects the change.
For changes that are not accurately reDected in the licensing basis, determine the programmatic step (or missing programmatic step) that would have ensured its accurate incorporation into the licensing basis.
. Docu:nent the results of the samphng.
3.2 Evaluation Phase At this point in the assessment. the changes to operating practices that should have been reDected in the licensing basis have been identified. Those not accurately reDected in the licensing basis are differences that must be resolved and categorized. The evaluation phase cannot be precisely structured. However, the following broad steps should be undertaken.
. Categorize differences in accordance with the following criteria:
o Proeram/ process which should have ensured licensmg basis accuracy 0 Significance
- Safety signiScant
- Regulatory significant (i.e. noncomphance or missed commitment)
- Low .e tentScance te.g., the oritinalinformation was not requtred to be included in the FSAR. or the information could not have been 5
d i
- rehed upon by the NRC in reaching a safety conclusion)
J ! [ NOTE: Section V of SDIARC 9012. " Design Basis Program I i Guidelines." provides guidance for assessing the safety signincance of differences and for determining if operability and/or reporting issues exist.] l 1 z 0 50.59 was correctly / incorrectly applied 1
. Licensing basis information has always been inaccurate u.e. there
, was no change in operating practice) 1 j
. Identify areas of programmatic weakness or missing programmatic controls.
If uncertain, pursue additional assessment investigation for the l programmatic area in question.
- Characterize overall signtScance of the 6ndings. Based on this i characterization. determine the need to broaden the assessment scope to obtain the necessarv conndence that the programs are adequate and are being effectively implemented i l
. If appbcable. generate necessary quality de6ciency documents and identify any reportable situations.
. Prepare recommendations to address programmatic weaknesses.
. Document the results and brief appropriate management.
4.0 STIREPORT 4.1 Purpose of Report NEI will compile the overall industry results to assess the composite adequacy and effectiveness of programs designed to maintain the licensing basis of tha plants. The overall industry results will be reported to the NRC by NTI. 4.2 Report Format The report format follmvs the steps contained in Section 3.0 of this report. Part 1 - FSAR Sampline
. Identify the FSAR systems reviewed under Section 31.1
. Indicate the number of FSAR differences identined G
l s . l l l Part 2 - Programmatic Samoline ' l , 1 Indicate the total number ofitems reviewed. l
- Indicate the number ofitems where the change was not accurately reDected in the bcensing basis.
Part 3 -Samoling for notential changes that mav occur seoarate from programmatic or orocedure changes Indicate the total number ofitems reviewed.
. Indicate the number ofitems where the enange w.-i not accurately reflected in the licensing basis. if required.
Part 4 - Evaluation Phase
. Indicate the number of differences that were characterized as being safety sign 15 cant.
Indicate the nutnber of differences that were characterized as beine regulatory signtScant.
- Indicate the number of differences where 50.59 was incorrectly applied.
. Indicate the number of differences where the licensing basis information has always been inaccurate. l
. Provide a brief summary of the programmatic deSciencies identined if any. l
. Indicate whether the assessment scope is being broadened based on the ;
identt5ed differences. l l
. Describe any departures from the methodology of this guideline.
l 5.0 DEFINITIONS 5.1 Regulatory Commitment NEI" Guideline for Managing NRC Commitments." endorsed by NRC in SECY 95 300, deEnes a regulatory commitment as follows: l "Rerulatorv Commitment means an explicit statement to take a spect5c action agreed to or volunteered by a licensee that has been submitted in writing on the docket to the Commission." 5.2 Licensing Basis 1 10 CFP. Part 54 de5nes the current " licensing basis as followc. 7
]
3
- / l i
f
" Current licensing basis o LBiis the set of NRC requirements applicable
) to a spectSc plant and a licensee's written commitments for ensuring l
- compliance with and operation within applicable NRC requirements and l
the plant specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and l in effect. The CLB includes the NRC requirements contained in 10 CFR l parts 2,19. 20, 21. 30, 40, 50, 51, 5 4, 55. 70, 72, 73, and 100 and appendices thereto: orders: license conditions: exemptions: and technical i
- spectScations. It also includes the plant speciSc design basis i j information de6ned in 10 CFR 50.2 as documented in the most recent j final safety analysis report (FSAR) as requtred by 10 CFR 50.71 and the l j heensee's commitments remaining in effect that were made in docketed l l
licensing correspondence such as licensee responses to NRC bulletins. generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event i reports." l NOTE: Responses to NRC bulletins. generic letters and beensee event l reports contain sorne commitments that are outside the scope of the CLB in that they are not necessarv to ensure comphance with applicable NRC , t e p an .pec ic Uest basi. } a l-t I
}
s i j 4
/gansc,u **'e UNITED STATES
.:' - . NUCLEAR REGULATORY COMMISSION W AS 60 N GT O N D C 2055ko001 e !
, g s.s j August 14, 1996 a.... , CHA@ MAN Mr. Joe F. Colvin i President and Chief Executive Officer Nuclear Energy Institt.te Suite 400 1776 I Street, N.W. Washington, D.C. 20006-3708
Dear Mr. Colvin:
I am responding to your letter of August 2, 1996, concerning industry 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 agreement between the industry and the Nuclear Regulatory Commission (NRC) before the industry would proceed with the initiative: (1) the legal standing of the Updated Final Safety Analysis Report (FSAR) and the NRC's Safety Evaluation Reports; (2) the 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 programs are sufficient to ensure that licensees know their licensing bases, 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 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_those you raise. .
)
Existing regulations and guidance are sufficient to conduct a retrospective ) review for conformance to existing regulatory requirements. These include: l (1) NRC regulations 10 CFR 50.2, 50.34, 50.54, 50.59, 50.71(e), 50.72, 50.73 ! f 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; I (3) " Design Bases Program Guidelines," NUMARC 90-12 and NRC letter dated j November 9, 1990;' and (4) Generic Letter 91-18, "Information To Licensees Regarding Two NRC Inspection Manual Sections On Resolution Of Degraded And Nonconforming Conditions And Operability." Attachment 4 i
1 2 The staff ts cor.cerned, however, that the proposed initiative may not be of sufficient scope and depth to 1dentify tha types of design and operability problems recently identified at several operating plants. Specifically, An in-depth it is not sufficient to perform a process / procedural based review. 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 (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 review of selected systems' design and design basis since issuance of the facility . l operating license: (2) risk- and safety-based criteria for selection of systems for review; and, (3) a method to ensure that licensee problem identification and corrective action on the selected systems are representative and consistent with other systems. The in-depth review should exa-ine: (1) engineering design and configuration control; (2) verification cf as-Duilt and as-modified conditions; (3) translation of the design bases recu1retents into operating procedures, maintenance, and testing; (4) ver'f1 cation of system performance through review of test records and 00ser5ations of selected testing; (5) proposed and implemented corrective acticns for licensee-identified design deficiencies; and, (6) modifications ade to the syste s since initial licensing. In sh rt. the NRC position has been, and 15, that it is the responsibility of individual licensees to know their licensing basis, to have appropriate docu-entation 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, S-Shirley Ann Jackson 1
.. .. l l
Distribution for 50.54(f) letter to utility CE0s dated: October 9, 1996 Docket File PUBLIC
, J. Taylor EDO Rdg File F. Miraglia/A. Thadani R. Zimmerman DRPW/DR?E/DRPM Directors DRPW/DRPE/DRPM Deputy Directors J. Lieberman J. Goldberg
' W. Dean G. Tracy , B. McCabe l J J. Mitchell l D. Matthews 1 i E. McKenna ! K. Thomas l F. Akstulewicz OGC i ACRS l' OPA ! DRPW/DRPE PDs i NRR PMs i . NRR LAs PD Rdg File l 1 R.W. Cooper, RI E. Merschoff, RII ! W.L. Axelson, RIII J. Dyer, RIV K. Perkins, RIV/WCF0 1 e { l}}