Specific Application of Graded Approach: Design Reconstitution cont'd

DOESTD107393

remaining facility lifetime is 5 years or more, the full design requirements reconstitution should be

implemented; if the remaining facility lifetime is less than 5 years, the searches should be reduced.

Retrieving and regenerating safety requirements should have top priority. This guideline is warranted

because of the fundamental importance of design requirements to facility operations. Design

requirements reconstitution will contribute substantially to a better understanding of the important

aspects of facility SSCs, and thus will have a positive impact on operating procedures, training

programs, and maintenance programs.

Moreover, the activities involved In the development of DISs enable them to remain in use for a period

of facility operation equal to or greater than the period estimated for their development. For example, if

the desired/remaining facility lifetime is 10 years, an adjusted DR program that can be accomplished In

5 years is appropriate. In adjusted DR program activities, safety SSCs and safety requirements should

receive top priority. Additional discussion of approaches and methods to developing adjusted DR

program is provided below.

For facilities that are currently operating and expect lo continue operating for a significant period, it

would not be appropriate to adjust the general program criteria according to operational status.

Operating facilities that have been directed to change their operational status within the near future

should consider the impact of the change on their program scope. For example, a facility that will enter

standby status in I or 2 years may be able to provide a technical basis for conducting only a smart

search for safety systems and refraining from the regeneration of missing design requirements.

For facilities that are in standby status (i.e., not operating but maintaining the ability to operate), DR

program planning is appropriate, but further implementation activity should be withheld pending the

announcement of plans to resume operations. Facilities in shutdown status (i.e., not operating and not

maintaining any ability to resume operations) should forgo DR adjunct activities altogether.

Facilities in the design and construction phases of their life-cycle should take steps to ensure that

complete and accurate design requirements, design basis, and as-built drawings are established prior

to turnover and operation, so that no design reconstitution will be needed after turnover. Special

emphasis should be placed on accelerated completion of DISs. Clearly, the most complete, accurate,

and cost-effective approach is to establish the facility design requirements and design basis in the

design and construction phase and maintain them throughout the operational phase. Facilities in the

major renovation and redesign phase should accelerate DR reconstitution, establishing firm milestones.

For example, completing the smart search might be appropriate before returning to the nominal

operational phase. For facilities in the deactivation phase, no actions are necessary to reconstitute

design requirements or basis.

Where facility importance or other considerations (particularly remaining facility lifetime) call for an

adjusted DR program, the following adjustment strategies may be considered:

Perform only the most important system and topical DISs. If the DR program scope has to

be limited, it might be best to complete DISs for the most important systems only.

Provide the design basis only for safety requirements. For a program of limited scope,

emphasis should be placed on the most important design basis. This option call be used in

conjunction with the option above.

Reduce the scope of searches in favor of regeneration. The program might be adjusted to

provide for skipping or limiting searches, particularly the comprehensive search, in favor of

an aggressive regeneration program. It may be more cost-effective to go ahead with the

regeneration without pursuing every possible source of existing design information.

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