IR 05000336/1997211

Insp Rept 50-336/97-211 on 970825-29,0902-05 & 1201-05.No Violations Noted.Major Areas Inspected:Evaluation of Parson Implementation of Independent CA Verification Program Audit Plan

ML20203E996
Person / Time
Site:	Millstone
Issue date:	02/09/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20203E993	List: IR 05000336/1997211 ML20203E987
References
50-336-97-211, NUDOCS 9802270176
Download: ML20203E996 (53)

Text

- . . .. . -. . . . - - - - . . - - . . - - . . - - . _ .

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION

Docket No.: 50-336

Report No.: 97 211 License No.: DPR 65

Licensee: Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Facility: Millstone Nuclear Power Station, Unit 2 inspection at: Persons Power Group in Reading, PA Dates: August 25-29, September 2 5, and December 1-5,1997 inspectors: Richard P. McIntyre, Team Leader (Team 2B)

Paul P. Narbut, System Lead (Team 2A)

Harold Elchenholz, Operations inspecto, Frank Gee, Instrumentation and Controls Engineer

,

Michael Shlyambcrg, Mechanical Engineer, Contractor *

i Andy du Bouchet, Structural Engineer, Contractor *

Raymond Cooney, Electrical Engineer, Contractor *

James Leivo, instrumentation and Controls Engineer, Contractor *

, * Contractors from Parameter, In Approved by: Eugene Imbro, Deputy Director, ICAVP Oversight

Steven Reynolds, Chief, ICAVP Oversight Branch Ralph Architzel, Unit 2 ICAVP Oversight Team Leader 9802270176 900209

' PDR ADOCK 05000336 G PDR

. - .

_ _ = -_- .- - _. .- . .. .-. -.. -

,

.

TABLE OF CONTENTS i

.

EXECUTIVE SUM MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I Ba c kg r o u nd . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ICAVP Administration. Oversloht. and Manmoement . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Quality Assurance Oversloht . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 R e c ul a t o rv Re vie w . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Technical Advisorv Groun .....................................6 Differino Professional Ooinions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Tier 1 - System Vertical Slice Review insoection Scone , . . . . . . . . . . . . . . . . . . . . . . 9 Tier 1 Backcround and Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 System Boundaries and Identification of the Licensino Basis (Forms 1 and 2)

...........................................................10 Adecuacy of the System Soecific Checklists (Form 3) . . . . . . . . . . . . . . . , . . 14

. Corrective Actions (Form 4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 M odifications (Forms 5. 6. 7) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Ooeratino Procedures (Form 8) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Testino (Form 9) ..............................................29 Tie r 1 S u m m a rv . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Tier 2 - Accident Mitication Systems Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 Tier 3 - Process Review Confiouration Manacement Procram Horizontal Slice . . . . 33 Dis cre na n cy Reoorts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 Exit L eatino S ummarv . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , 46 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 AC R O N Y M S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 8

i l

,

i l

I i

I

_

- . -- . - - . . - . - - . . - - - . - . - _ - -. - - . - - - _ _ -_ - .

i-EXECUTIVE SUMMARY The NRC inspection team conducted the first phase of an inspection of the Parsons Power Group Inc. (Parsons) Independent Corrective Action Verification Program (ICAVP) during the weeks of August 25 29 and September 2 5,1997, and the second phase during the week of December 15,1997. The team evaluated Parsons' implementation of the ICAVP audit plan, as discussed in the Project Manual (PM) and Project Procedures that the NRC reviewed and

,

approved on July 15,1997. The team was tasked to determine if the Parsons ICAVP audit of Northeast Utilities Millstone Unit 2 Configuration Management Plan (CMP) adhered to the audit

' plan and project procedures approved by the staff, if the Persons review was being conducted in a critical and thorough manner, if the threshold for identifying of problems was appropriate, and if the personnel conducting the review were qualifie Critical aspects of the Parsons ICAVP reviewed included the system vertical slice review (SVSR), including the implementation of PP-01, ' System Vertical Slice Review," and Project

!

Instruction PI-01, ' System Vertical Slice Review," Updated Final Safety Analysis Report

' (UFSAR) Chapter 14, design basis event critical design characteristics; the thresholds for writing discrepancy reports (DRs); the DR disposition process; the depth of checklist-driven reviews of the selected systerr.s; and the adequacy of samples selected. Other aspects i

reviewed included quality assurance oversight of the ICAVP, Technical Advisef Group (TAG)

! activities, Regulatory Review activities, the Differing Professional Opinion process, and conduct of ICAVP group meetings.

' During the first phase of the inspection, the team found that only a small part of the Parsons ICAVP had been completed. In several areas, either work had not been started or no completed product was available. This significantly limited the team's ability to draw conclusions about the overall effectiveness of the ICAVP. This lack of completed auditable tasks caused the team to schedule an additionalinspection with the full team for the week of

,

December 15,1997. However, what was inspected during the first phase was found to be

,

'

conducted in accordance with the approved ICAVP audit plan and implementing procedures and NRC staff expectations. During this inspection the team made several observations

'

regarding the ICAVP process and scope. Each observation was discussed with Parsons ICAVP management, and corrective actions and changes to the p'ocess were initiated as necessar During the second phase of the inspection, the team concentrated its review on ICAVP activities performed for the high pressure safety injection system (HPSI) system, since it had the largest amount of completed work and in-process work products of the four systems chosen for review. Activities performed on the auxiliary feedwater (AFW) system were also reviewed ,

d but to a much lesser extent. The teams review included work products from Tier 1,2, and 3 activities. Based on the review of in process and completed work products, the team i

. concluded that Parsons was following the audit plan and project procedures, was providing an

acceptable depth and breadth of review, was using an appropriate threshold of concern when

- -

. . _ _ . . _ _ _ _ . . . _ . . _ _ . . . _ _ _ _ _ _ _ . . . _ .

. - - .

_ . . _ . . _ .

identifying potentialissues, and was providing work products that were readily auditable, in addition, Parsons staff exhibited a questioning attitude and in-depth understanding of the technical areas being reviewed.

4 J

I i

.

4 il

i

-

. - _ . - - _ - . - _ . . _ . -

- . - - - --.--. --

Reoort Details Backgrqund On August 14,1996, the U.S. Nuclear Regulatory Commission (NRC) issued a Confirmatory Order (Order) to Northeast Nuclear Energy Company (NNECO/ licensee) requiring completion of an independent Corrective Action Verification Program (ICAVP) before the restart of any Millstone unit. The Order directed the licensee to obtain the services of an organization independent of the licensee and each facility's design contractor to conduct a multi-disciplinary i review of Milbtone Units 1,2, and 3. The NRC staff approved Parsons Power Group (Parsons)

i as the ICAVP contractor for Millstone Unit 2 on May 28,1997.

L F The Order further stated that an ICAVP audit plan was to be developed by the independent contractor (Parsons) and that the audit plan must describe: (1) the conduct of an in-depth i

review of selected system's design and design basis after issuance of the facilities' operating L

'

. licenses; (2) nsk and safety based criteria for selection of systems for review; (3) the audit plan to assure that the quality of results of the licensee's problem identification and corrective action i programs on the selected system is representative of and consistent with that of other systems; (4) procedures and schedules for parallel reporting of findings of the ICAVP team to both the NRC and the licensee; and (5) procedures for the ICAVP team to comment on the licensee's proposed resolution of the ICAVP team's findings and recommendations. Finally, the Order

stated that the scope of the ICAVP bhall include (1) a review of engineering design and configuration control processes; (2) verification of current, as-modifed, conditions against

design and licensing bases documentation; (3) verification that the design and licensing bases

! requirements have been properly translated into operat;ng procedures and maintenance and test procedures; (4) verification of system performance through review of specific test records and/or observation of selected testing; and (5) review of proposed and implemented corractive

_

actions for licensee-identifed design deficiencies.

i-Three Tier ICAVP Process

,

in a Commission paper (SECY 97-003), " Millstone Restart Review Process," dated January 3, 1997, the staff described the Millstone restart review process. Within SECY-97-003, the staff i: acknowledged that the scope and depth of the independent contractor's effort would be

! determined during the staffs review of the ICAVP. To provide the level of assurance necessary

'

to support a unit restart decision, the staffs expectation, described in SECY-97-003, was that the ICAVP would encompass the aspects of configuration control described in a three-tier

'

approac in Tier 1, four systems were selected to test the thoroughness of the licensee's reviews in -

identifying potential nonconformance with the design and licensing bases. These systems were the high pressure safety injection system and the refueling water storage tank as one system, I

the auxiliary feedwater system and the condensate storage tank as one system, the emergency diesel generator and support systems, which includes six systems as one system, and

radiological release control systems, which includes three systems as one system. The ICAVP

!

,

'

$

non- , - , . , , . , . ~ . . . , - . . . - - . , . , . , . _ . . . , - . - -

_ _ . . . _ __ . _ _ _ . _ _ _ . . _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ . _ _

!

contractor was tasked to conduct a thorough rev ew of all design changes made to these

' systems after the issuance of the operating license, the remaining part of the original system

configuration, and operational aspects of these systems, including maintenar.ce, surveillance i

testing, and training. The ICAVP contractor was also expected to review the licensee's j

corrective actions for previously }dentified design-related deficiencies for the selectd systems,

including the deficiencies discovered during the implementation of the licensee's corrective R

,

action programs, l The objective of Tier 2 was to verify that critical design characteristics of systems relied upo

mitigate the consequences of accidents analyzed in the Final Safety Analysis Report are censistent with those used in the design of the mitigation system and the accident analyses.

i Tier 2 of the ICAVP sudit would review critical aspects of accident mitigation systems that j

Parsons did not examine as part of the Tier 1 reviews. These reviews were more limited in

. scope than those performed on the Tier 1 systems.

t

! Tier 3 of the ICAVP sudit required the review of a sample of changes made to the facility configuration since issuance of the operating license through processes other than the desig

!

change process. These included processes such as calculation changes, proposed Technical Specification changes, temporary modifications, drawing changes, procedure changes, set f

point change requests, and replacement item evaluations. Tier 3 would provide insights into j the effectiveness of the various change processes in controlling the plant's configuration over the lifetime of the plant.

i

,

NRC Review of the Parsons Pe= Pronosal

,

On April 3,1997, Parsons submitted a proposal for the conduct of the ICAVP in the form of a '

.

Project Manual (PM) which included an audit plan and Project Procedures (PPs) goveming specific technical activities. The NRC assembled an inspection team to evaluate the submitted

[ documents and to continue to assess and monitor the implementation of the Parsons ICAVP

' effort. Following the team's review of the PM, working meetings were held with Parsons to disects the team's observations and findings regarding the PM. The team reviewed the

resuraes and interviewed personnel that Parsons had proposed for participation in the audit.

i Based on the results of the review, Parsons submitted Revisions 1 and 2 of the PM and

associated documents on June 9, and again on June 27, igg 7, respectively. The NRC approved the proposed ICAVP in a letter to Parsons dated July 15,1997, i

NRC Oversloht of Parsons'ICAVP

'

Following the review and approval of the Parsons PM, the NRC initiated a plan to monitor the

'

Parsons ICAVP activities for the duration of the effort. The NRC's plan included an inspec by a NRC team of the implementation of the ICAVP. A two-week inspection effort was conducted the weeks of August 25-2g and September 2-5,1997. However, the team's initial assessments during the inspection noted a lack of completed auditable tasks, causing the team to schedule an additionalinspection week with the full team for December 1-5,1997. A i

meeting, open to the public, and attended by a representative from the Nuclear Energy

! Advisory Council (NEAC), was held on December 5,1997, at Parson's offices to discuss the inspection findings ared observation , '

4

g >wy* o-~ + - -,4~"f

_

_ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ . _ _ . _ _ _ _ . _ _ . . _ _ ..-

,

i

4

3 CAVP Admlnietmilon. Overslaht. and Man == ment OumMv Assuranen Overslaht Inspection Scope

The team examined the role of the Parsons Quality Assurance (QA) organization in i

providing independent oversight and in-dspth assessments of the quality of work being

) performed by the Parsons independent Corrective Action Verification Program (ICAVP)

group.

l

,

Observations and Findings

'

Parsons' ICAVP audit plan, Revision 2, dated June 27,1997, Section 3.3, ' Quality

,

Assurance,* described the Quality Assurance that was to be applied. The plan stated that planned end scheduled audits would be performed, the effectiveness of quality services would be assessed, and deficiencies evident in the processes would receive <

,

appropriate corrective action. Parsons had begun its ICAVP technical reviews on July 8,

' 1997. The first Quality Assurance audit was initiated August 5,1997, and was '

scheduled to be completed on September 8,1997. The team examined the audit plan,

i IA 9704, dated July 31,1997, and noted that the plan was prepared and approved by the same individual, the U.unager of Company Quality (MCQ). The team also

,-

observed that the MCQ was conducting the audit (except for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> by a contractor)

{ and was writing the audit report. The team was concemed with the depth of i

independent review. The team also noted the audit attributes being verified were

,

administrative compliance !ype attributes, such as file locations and signature completions, and not measures of the technical adequacy of the ICAVP products. The

! team considered these verifications too superficial to provide independent verification of

! the effectiveness of the ICAVP process.

l

~

The team discussed its concems with Parsons ICAVP management. Parsons noted that the ICAVP products received an intemal technical review in the manner typical of design

.

l output documente; that is, they were reviewed and verified by an independent verifier and approved by a supervisor. Parsons agreed that technical assessments of the

'

quality of its products by an outside organization would aid in producing a quality i product. Parsons management stated they would determine a method to provide

independent technical review of the ICAVP products and implement the method in the project. They also stated that they were considering, among other options, using members of the Technical Advisory Group (TAG) for this effort.

,--

'

. During the second phase of the inspection the team followed up on the above issues

.

and reviewed additional Quality Assurance oversight activities that had been performed by Parsons following the first phase of the inspection. The team reviewed the November 23,1997, Intemal Surveillance Report IA-9705, " Millstone Unit 2 ICAVP Project," and noted that the surveillance team included a technical representative and three members

[ _ of TAG, was technically based, and provided substantive comments and

i l

i I

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

. _ - _ _ . _ _ . . . _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ . . _ _ . . _ _ _

recommendations to enhance implementation of the project. The team also reviewed the ICAVP project responses to the surveillance report recommendations and concluded they were responsive to the comments and recommendation Conclusions During the first inspection, the team concluded that Quality Assurance was not providing l

in-depth technical oversight of the quality of Parsons'ICAVP work prnducts to dat '

However, during the second inspection Quality Assurance was more actively involved in effective technical project oversight than was observed during the initialinspection. The team consider 6d this type of technical oversight an effective way to monNor project performanc !

1. Raoulatorv Review 4 Inspection Scope

'

Parsons' audit plan provided for a review of selected licensing documents to identify the licensee's comrrJtments for subsequent verification during the Tier 1 vertical slice

review, the Tier 2 accident mitigation systems review, and the Tier 3 process revie PP-04, * Regulatory Review Procedure," govemed this activity. Regulatory documents to

.

be considered as sources of commitments on that basis include NRC Bulletins, Generic Letters, Safety Evaluation Reports (SERs), Notices of Violation, and Licensee Event

, Reports (LERs).

!

Parsons had screened the foregoing documents for applicability to the tier reviews, was summarizing the licensee's docketed response or commitment, and was reviewing the

' UFSAR to determine if it had been properly updated pursuant to 10 CFR 50.71. PP-04

! required the resuh* of these reviews to be documented on Regulatory Review Summary Forms.

I Parsons' audit plan stipulated that commitments relating to programmatic areas such as

'

security, fire protection, environmental qualification, operator licensing, emergency planning and response, radweste shipping, and quality assurance would not be i

addressed in the regulatory review, but rather would be included separately in the detailed Tier 1,2, and 3 reviews, supported by appropriate technical specialists,

' Observations and Findings

,

The team reviewed a sample of the Regulatory Review Summary Forms that were

, available and evaluated the following aspects of Parsons' efforts to date:

e conformance to the audit plan and procedures

'

e adequacy of the identification of the commitment

!

I-

~

!- 4

i I -

-_

-- . . _ - - - - . - -._ - _ - - -_. - - - - - _.- - - .

e adequacy of the scoping ef the commitment for disposition in Tor 1,2, and/or 3 i

reviews

!

e adequacy of the UFSAR update review l

, e adequacy of disposition of potential Discrepancy Reports (DRs) resulting directly from the Regulatory Review (for example,10 CFR 50.71 discrepancies)

>

e adequacy of Parsons' verifiestion of the licensee's commitment in the Tot 1,2, l

) or 3 reviews, including Parsons' disposition of potential DRs '

Parsons had begun compiling these types of commitments from publicly availab's information before the systems had been selected. Consequently, an extensive i compilation of commitments had beer, completed for Millstone Unit 2. Parsons had prepared summaries and characterizations of each commitment, and had entered the '

commitments into a database from which reports could be sorted by system, or by ,

l lCAVP Tier 1,2, or 3, or more generically. The work, reviewed in the first phase of this

! l inspection was in accordance with the audit plan and implementing procedures, Based

,

on a programmatic review of reports sorted in this manner for the auxiliary feedwater (AFW) system, the high pressure injection (HPSI) system, and common or generic system applicability, the team concluded in the first inspection phase that the summary reports and the database gave the Tier 1,2, and 3 reviewers good insights into the system history and could also be useful for verifying the FSAR and licensing basi ,

!

During the second phase of the inspection, the team penormed a review of a small i sample of regulatory review summary forms prepared and verified by Parsons. The l team selected licensing commitments associated with LER corrective actions, NRC Generic Communications, and SERs issued by the NRC staff. This sample included i

completed review forms for LER 80-024-00, 'HPSI Pump Seizure"; IEB 86-03, " Potential l Failure of Multiple ECCS Pumps Due to Single Failure of Air Operated Valve in Minimum Flow Recirculation Line"; NRR Safety EvaluaSon for Amendment 185 to OL-FP No.

,

' DPR 65 (PORV and block valve reliability, low temperature overpressure protection, boron dilution, and shutdown risk management); Amendment 205 (charging pumps and l

high pressure safety injection pumps du:ing mode 5 and 6 operation); and LER 4 83-017-01, 'HPSI Cracked Valve Operator.'

i The content of the completed forms for these items provided evidence that Parsons was performing a detailed technical review of regulatory issues considered relevant to HPSI.

in addition. Parsons was verifying, in detall, configuration documents such as FSAR

[ sections, Technical Specifications, operating procedures, and maintenance procedures.

c. Conclusions Based on the team's programmatic review of the Regulatory Review Summary Forms compiled and screened for Tier 1, 2, 3 applicability, the team concluded that the output of this effort was consistent with the audit plan and Project procedures, and provided an effective tool for use by the tier reviewers. For the limited review of verification activities, l

.

E

., , _-4 -

._

m ., - ..

. _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _ _

the team concluded that Parson's was following its audit plan with respect to ,

dispositioning and verifying regulatory review Rems and was providing a sufficient depth of review. The team found that the regulatory database and review proces6 was a y strength of the ICNT ~ .eviews.

, Technical Advisorv Graua

'

e, inspection Scope The team examined the role and activities of the TAG. Section 3.2 of the Person ICAVP Audit Plan, ' Technical Advisory Group," described the TAG and its overall responsibilities as part of the ICAVP review. The TAG is a gioup of industry experts helping Parsons with ICAVP audit plan implementation and other activities as assigned.

The TAG provides advice, expert technical opinions, and review services to the Parsons .

ICAVP group, The TAG is responsible for reviewing the ICAVP final report and the individual reports from the various tiers. The TAG also is responsible for reviewing all discrepancy reports and all differing professional opinions, Observations and Findings

'

During both phases of this inspection, the team discussed recent TAG activities with the chair of the TAG. The TAG held a meeting at the Parsons office on August 25,199 The TAG members attended the project staff meeting and met individually with the management of each tier, Besides meeting and discussing activities and plans, the project had been communicating with the TAG by e-mail. The team was provided

'

copies of selected correspondence addressing issues such as the comments on the Ciltical Design Characteristic submittats to the NRC. The team also examined TAG

, members electronic responses to the ICAVP project. The team noted that the TAG

comments were extensive and in-depth technically.

l During ths, first phase of the inspection, the team observed that correspondence and i activities of the TAG should be better auditable and controlled. For example, the TAG did not prepare meeting minutes for the visit of August 25,1997, in addition, the team noted that correspondence, such as e-mail, was not captured in controlled project

.

i documentation. The team also commented that although the mmmunications contained

!

opinions and responses on the activities of the Parsons ICAVP, involvement planned for the TAG was less than envisioned by the NRC. At the interim status meeting on September 5,1997, Parsons stated that the activities of the TAG, such as, L correspondence and meeting minutes, would be formally documented. Parsons also stated that they would increase the TAG's involvement in reviewing discrepancy reports and consider using TAG members in the Quality Assurance overcight process.

! During the second phase of this inspection, the team observed additional activities of the TAG. Beyond holding routine monthly technical advisory group meetings, the TAG members were involved in a technical quality assurance surveillance audit of the Parsons ICAVP project. The team reviewed the surveillance report, noting it was technically based and provided substantive recommendations and comments to

,

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

--- .- -_. .-.- - - - - . . - - - - . .. .- . . _ - ._ _ _ - _ _ .- .

enhance implementation of the project. The team also reviewed the project's responses to the surveillance report recommendations. In response to prior NRC team comments, the team observed that activities of the TAG were being captured and documented. The team reviewed the following documents detailing activities of the TAG:

Document Autb0f DMS Intemal Surveillance Report G.R. Beldier November 23,1997 lA 3705 - Millstone Unit 2 ICAVP,

conducted October 22 24,1997 TAG Meeting Minutes for W.E. Meek, Document and E-mail November 11,1997 Chair dated Navember 11, 1997 TAG Monthly Report - October W.E. Meek, Document and E-mail

,

=

1997 Chair

,

dated November 11, 1997 TAG Monthly Report - September W.E. Meek, October 12,1997 1997 Chair Group 2 Boundary Diagrams W.E. Meek, E-mail dated October 1,

Review Chair 1997 TAG Monthly Report - July a W.E. Meek, September 6,1997

August 1997 Chair TAG Meeting Minutes for August W.E. Meek, August 18,1997 18,1997 Chair

, Conciusions i

i Overall, the TAG was more actively involved in project oversight during the second phase of the inspection than was observed during the initial phase of the inspectio The team considered that the technical advisory group participation and contribution were effective and represented a project strengt .4 Differino Professional Ooinions

! Inspection Background and Scope Because of the history of employee concems at Millstone, the NRC staff requested that Parsons provide a process to handle differing professional opinions (DPOs) that may arise among the project staff performing the ICAVP, PP-05," Differing

,

Professional Opinion," was included in t% Parsons ICAVP Millstone Unit 2 Audit Plan

.

and had, before this implementation inspection, been reviewed and approved by the

"

NRC. The NRC ensured that the Parsons Project procedures covering the DPO process had allowed an attemate process to raise safety concems outside the normal line organization. As part of the inspection at Parsons, the team conducted an implementation review of the process developed for Parsons' project employees to raise safety concems to their supervisors, NNECO, or the NRC.

.

. 7

,y v - ,. - , - - - ,

_ ._ _ _ _ _ _ _ . - _ _ . _ _ _ _ _ _ _ _ _ _ _

,

! The team reviewed applicable Parsons procedures and project instructiens related to i

this inspection area to confirm prcgram requirements. The team interviewed a i number of Fersons' project personnel to determine their awareness of program I

requirements and their responsibilities and rights in reporting violations and safety (

concems. The team also reviewed a sample of the project staffs indoctrination and j j training focords to confirm that appropriate '. raining was being conducted by Parsons i

in this are l l Observations and Findings  ;

I t

j At the time of the implementatien inspection, Revision 1 of PP-05 was in effect. PP 06

(1) encourages Parst is' project staff to make known their judgments on matters of tech,)lcal and safety significanoe conoeming the Millstone Unit 2 ICAVP even though i their judgments may differ from management's; (2) specifies regulatory protection for employees engaged in nuclear activit4s; (3) provides for informal and formal expressions of a DPO; and (4) allmys for concems to be reported through the formal

, Persons DPO process, the NNECO Employee Core;ms Program as specified in

! NNECO Procedure NGP 2.15, ' Resolution of Employee Concoms,' or directly to the i NRC, as specified in NRC Form 3, ' Notice to Employees.' Persens project

[ management representatives stated that there had been no use of the DPO process by any project staff member to dv t i

i After the issuance of PP 05, Parsons developed the ICAVP Project Administration '

) Manual (PAM). This document states that Parsons' employees may raise safety i concerns and specifies the avenues available for them. Section 4.8, ' Employee  ;

i Concems,' further states 'that all Persons ICAVP project personnel will be I- '

Indoctrinated to NNECO Procedure NGP 2.15." The PAM sets forth an indoctrination

. process by which all personnel assigned to the project will become familiar with the

, Milletone Unit 2 ICAVP project requirements This process requires all Persons ,

, project staff to review the decuments listed and signify their understanding of these t documents on an ICAVP Indoctrination Record. The team noted that the PAM,  :

"

NNECO Procedure NGP 2.15, and PP-05 were included on the indoctrination Roccrd.

j The team selected a sample of ICAVP Indoctrination Records for review. The

'

selection was representative of Parsons' project staff in the different project groups.

i The scords showed that the individ'Jais stated their familiarity with the content and -

) gue ence in the subject documents. Additionally, the team interviewed six project i staff members to confirm their understanding of program requirements. The team noted that these individuals were sufficiently aware of the DPO process, the goveming procedures, and the location of NRC Form 3 (posted on the project area bulletin board). Conclusions

<

The team confirmed that Parsons had implemented an appropriate DPO indoctrination process. Parsons' project staff demonstrated sufficient familiarization with the content l

!

+

.

t

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

___ _ _ _ _ . _ _ _ _ _ _ _ _ ____ _ _ _ _ __ . _ _ ____ _ _ _ _

l l

i l

and guidance included in the relevent Parsons' DPO procedure and the PAM. The ,

teara also confirmed that Parsons' project staff had not initiated any DPO l Tier 1 svatem Ver*nt slice Review Insometion traa.

1 The team assestso Parsons' implementation of the Tier 1 system vertical slice review

, (SVSR) portion of the ICAVP audit plan for Millstone Unit 2. The team essessed (1)

the adequacy of the design and licensing basis checklist, (2) the completeness of the

! system specific checklists, (3) the thoroughness of the corrective action process, (4)

the adequacy of the ICAVP calculation reviews, (6) the adequacy of modification reviews, and (5) the technical adequacy of the DRs that Parsons prepared. The following sections summarize Persons' progress in implementing the Tier 1 SV3R portiors of Parsons'ICAVP audit plan, 1 Tier i Backaround and Statua The Tier i SVSR is govemed in part by PP 01, ' System Vertical Slice Review,' and Project instruction Pl.01, ' System Vertical She Review (SVSR).' Specifically, PI 01 .

provides 11 forms that are to be completed for each system selected. Forms 1 and 2  !

identify the system boundaries and licensing basis. Most of the remaining forms contain a series of questioM thal must be answered to satisfy the scope of the revie For example, Form 3 contains questions about the design and licensing basic of the

system and its components. Form 3 has three major sections: upper tier system.

I related questions, topical area questinns, and component questions or attributes. The component section is divided into mechanical, electrical, instrumentation and control (l&C), and structural areas.

i Form 4 addresses licensee corrective actions. Forms 5,6, and 7 concem modifications. Forms 8 and g concem procedures and testing. Form 10 applies to

! system walkdowns. An eleventh form is used for system closeout when the integrated review is complete At the time of the inspections, Parsons had only issued Form 1 (System Scope and Boundary Definition) and Form 2 (Licensing Basis). Work had progressed in varying degrees for the remaining review areas (including calculations, drawings, specifications, and screening and review of modifications). However, no completed and issued work products in engineering review areas (i.e., Forms 3 through 7) were

, avnilable during the firci phase of this inspection, and only a small portion of work on these forms was even in progress at that tim As of September 4,1997, the mechanical systems discipline had not yet begun to review the system calculations. One of the reasons given for this lack of progress was difficulty in identifving the c'Iculations of record, perticularly for the AFW syste Despite two requests for additionalinformation (RAls), dated August 6 and 13,1997, NNECO had not yet providad the system hydraulic calculations, except the original pump sizing calculation (which was not an as built calculation). The team's preliminary review of NNECO's responses to these RAls !ndicated that NNECO may _

g

_ _ , _ _ - _ _ __. _.__ __.__.____ _ ___ _ . _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ .

still be preparing the system calculation. Therefore, Parsons may not be able to full / l assess the abihty of the AFW system to meet its safety related function untilit receives the rosponse to these RAls.

>

At the component level, the AFW system review had identified 28 types of mechanica! ,

components (pump, motor operated valve, air-operated valve, manual isolation valve, '

vent, drain, etc.), and the HPSI system review had identified approximately 60 types of components. Reviews of six of these components for the AFW system and one component for the HPSI system were in process but not complet During the first phase of the inspection, progress in the electrical, instrumentation and control, and structural disciplines was similar to that in the mechanical systems area Parsons reported that difficulty in retrieving ;alcu'ations of record and other engineering documentt, (for example, documents of record for environmental qualification data, test reports, and instraent specification data) was also hindering progress in these areas.

'

During the second phase of the inspection, the team determined that a significant portion of review required for completion of Form 3 had been accomplished. A major impediment for completion of Form 3 was lack of p+ ogress in the review of topical areas such as environmental quahfication, vencW nanuals, Appendix R, and station blackout. These areas were the subject of s > g remedial efforts by the license After the first phase of the inspection, the team concluded that insufficient work products had been documented and issued to date to draw conclusions about the results or to justify selecting a sample for independent review by the team. Therefore, the staff scheduled the second phase of the inspectio During the second phase, Form 3 products were still incomplete, but a substantial amount of additional work was in progress in all disciplines. Given the extent of this additional work in progress, the team concluded that the available interim work products for the HPSI system could be used to determine whether Parsons was following its audit plan procedures, whether their review scope was of sufficient dopth and breadth, and whether the appropriate threshold of concem and questioning attitude was be;ng maintaine .2 System Boundaries and identification of the Licensinn Basis (Forms 1 and 2)

2.2.1 Adtaunev of the Seone of Tier 1 Review (Form 1) Inspection Scope During the first inspection phase, the tearn reviewed the Millstone Unit 2 ICAVP SVSR

' System Scope and Boundary Definition * (Form 1) checklists, SSBD AFW-01 and SSBD HPSI-01, Revision 0, dated August 21,1997, to assess whether the scope of the Tier 1 reviews was in accordance with Pl 01 and staff expectations. The team also reviewed the Millstone Unit 2 ICAVP SVSR ' Licensing Bases - Current Revision

____

_ _ _ _ _ _ _ _ _ _ . . _ ._ - _ - .

_ . . _ __ __ _ .._ . , _

_ _ _ _ .__ ___._ _ . -

_ _ .. _ __ _ _ . _ . _ _ - _ _ ._ _ _

!

'

of FSAR'(Form 2) documents, LBCD AFW 01 and LBCD HPSI.01, Revisions 0, dated August 21,1997, to assess conformance to PI 01 with respect to identifying r commi'ments related to the systems established by the current UFSAR and docketed j licensing commitments, identification of the scope of the SVSR and identification of the design and licensing

, bases were govemed in part by PP-01 and PI-01. Pl 01 prescribed the use of checklist forms to document the SVSR, including Forms 1 and 2, which had been j completed by Parsons and which the team evaluated as follows.

1 Observations and Findings l

The scope definition for the AFW and HPSI systems was consistent with Pl 01 and i

staff expectations, except that SSBD HPSI 01 specifically excluded pressurizer l pressu's as an initiating variable for safety injection. Containment pressure (the other j variable used to initiate safety injection) had been included.

i Discussions with Parsons indicated that Persons intended to include pressurizer pressure within the scope of the review of the next two systems to be identified by the

staff. Parsons assumed that the next systems selected would be systems that used the se'oty injection signal. Therefore, review of the next two systems would include the pressurizer pressure variable. However, because the additional two systems had

not been selected, the team concluded that to ensure the intended scope was

reviewed, pressurizer pressure should be included in the HPSI review as an

!

engineered safety features actuation system interface. Parsons agreed to include pressurizer pressure in their review of HPS <

,

Form i specified that interface with, and portions of, other systems will be included within the boundary of the selected system to the extent that the other systems are necessary to support the functional requirements of the selected system. Because either pressuriter pressure or containment pressure can be used to initiate safety 3 injection, both variables should be reviewed as a functionalinterface with the HPSI

system. During the second phase of this inspection, the team confirmed that Parsons had revised Form 1 to include review of the pressurizer pressure veriable, in the mechanical, piping, and structural disciplines,26 pipe stress analysis packages qualify for the Tier 1 scope of the HPSI system, and 17 stress analysis packages

, qualify for the scope ::f N AFW system. Parsons had identified approximately 470 pipe supports in the Tier i scope of the HPSI system, and opproximately 240 pipe

supports in the scope of the AFW system. During the fi,st phase of the inspection, the team discussed with Parsons the fact that the staff had evaluated a Sargent and 3 Lundy (S&L) proposal to review 10 percent, instead of the total population, of pipe sunoorts for S&L's ICAVP audit plan review for Millstone 3, because of the repetitive nature of pipe supports. The team informed Parsons that the staff would also consider approving a similar sampling approach for Unit 2 piping and supports if Parsons could provide technicaljustificatio .-- -.-.sw- . . - - - - - - - , - ~ _ - , . , . , r, ,

. . _ . .-.%., , - - .-r ,,~.m,ym ,4 er,.n-- ,7-y,,-,-%---.e e-m--- , - ,-,

_ . _ _ . . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _

in a letter dated January 8,1997, the NRC approved Persons' proposed criteria for the selection and review of analyzed and field routed piping and pipe, tubing, conduit, cable tray, and ductwork supports, as described in the September 29,1997. Parsons'

submitta .

i Conclusions

. Except for the two issues described above, the team concluded that the scopo defined ,

,

,

for the AFW and HPSI systems was consistent with PI 01 and staff expectations, i 2.2.2 Adanumev of the Identmention of Lleanalna maala (Form 21

! inspection Scope PP-04, * Regulatory Review Procedure,' Revision 1, dated June g,1997, and PI 01 stipulate that the Regulatory Review Group (RRG) identified docketed commitments

"

for the Tier 1,2, and 3 reviewom. PP-04 also requires that the tier reviewers verify the commitments appropriate to their review.

,

The team evaluated the completeness of Form 2 for the AFW and HPSI systems by performin,) a programmatic review of the compilation of UFSAR commitments and by

, sampling some products of the RRG to determine whether the commitments had been

captured appropriately in Form 2. The following comments reflect the team's review of the signed off version of Form 2 evaluated during the first phase of the implementation inspection, as well as the proposed revision of Form 2 evaluated during the second phase of the inspection, Observations and Findings l MechanicalSystems i

e During the first phase of the inspection the team determined that Form 2 did

,

not include input from the Tier 2 review. Exhibit 4 2 indicated that the Current l Licensing Basis Review (Form 2) would receive critical design characteristics

'

input from the Tier 2 review, in addition to the Regulatory Review Group inpu Similar1y, PI-01, Section 5.2.2, and Exhibit 3-1 also indicated that Form 2 would

receive critical design characteristic input from the Tier 2 review, in addition to the Regulatory Review Group input. However, the instructions for Form 2, TI CL-l 02, Step 1 A, did not direct the Originating Engineer (OE) to obtain the

' input from the Tier 2 review. The only outside input specifi?/ 6 this instruct.:on was from the Regulatory Review Grou Consequently, the completed and issued Form 2 for the AFW and the HPSI systems did not reflect the Tier 2 input. Interviews of Parsons personnel

,

conducted during the second phase of irspection indicated that the input from Tier 2 was received for the HPSI systerr, and will be included in the next revision of Form 2. The Parsons persor.nel further stated that the instructions

- _ . . _ _ _ _ _ - _ . _ _ _ . _ _ . _ . . _ _ . _ _ . , - _ _ _ _ . _ _ _ . _ . __

_ _ . _ _ _- _ _____._ _ _ _ . _ . . _ . _ _ _ _ _ _ . _ _ _

.

for Form 2, TI CL l 02, Step 1.4 will be revised during the nex' revision of Pl0 e During the first phase of the inspection the team determined that Form 2 did not identify all the applicable commitments to Regulatory Guides. Review of the pending changes for Form 2 performed during the second phase of the

! inspection identifea that applicable commitments to Regulatory Guides were identifed by Parsons, l

e During the first phase of the inspection the team determined that not all licensing requirements were included in Form 2, Revision 0. For example, the

Form 2 licensing basis did not identify the require,nsnt to verify the operability

of the HPSI system by ensuring that the HPSI pump develops a differential pressura of 1231 psi on recirculation flow as stated in Section 4.5.2.a.1.b. of the Technical Specificatiens. Review of the pending changes for Form 2

performed during the second phase of Inspection identifed that tnis

!- requirement was inc"oorsted.

,

o During the first phase of the inspection the team determined that use of the

HPSI system as a backup to the low pressure safety injection (LPSI) system, for the simultaneous hot and cold leg injection for boron precipitation control

'

during post accident recirculation, was identifed as a system function in Form 1, Revision 0, system boundary and scope definition, but was not identifed in Form 2 as a licensing requirement. Similarly, ability to align the HPSI system to the shutdown cooling heat exchanger (not a design basis flow path) was i identified in Form 1, but not in Form 2. The team's discussions with Parsons identifed that the licensing requirements, which were not captured in the 4 UFSAR and related to EOPs, were captured in the EOP review. The team concurred with this approach.

'

Piping and StructuralDischlines c To assess Parsons' compilation of the current licensing bases for the HPSI system in the piping and structural disciplines, the team identifed the fe' lowing FSAR commitments to determine if Ptsrsons had documented thees commitments in Form 2:

.

- Section 5.1.1.1, ' Class i Structures *

- Section 5.2.3.1.5, ' Earthquake Loads,'

- Se: tion 5.2.8.3, 'Difforential Displacement Setween Structures"

- Coction 5.7,"Extemal Class l Tanks'

- Section 5.8.1.1, 'Dealgn Response Spectra'

-

Section 5.8.3.2.2, ' Combination of Vertical and Horizontal Responses *

-

Section 5.8.3.3, * Damping Values,' Section 5.8.4, ' Seismic System Analysis'

! -

Section 5.8.5,' Seismic Equipment Analysis'

- Table 5.81, * Material Damping Values.*

2

_ _ , _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . _ _ _ _ _ _ _ _ _,__ _ . _ . _

_ _ _ _ _ _ _ . . _ . . _ _ _ _ _ . _ . _ _ _

,

!

l l The team confirmed that Persons had documented each of these licensing commitments in Form 2 either directly or by reference to an attemate FSAR section.

i Int, ymentation and Control (l&C)

The team solacted for detailed review, item 44 of the isolated 10 to 50 made outputs from each sonsor provided for main control board indications to venfy the implementation by the licensee of an isolation configuration identified in the FSA FS AR Section 7.3.2.13 states that isolated 10 to 50 made outputs from each sensor of containment pressure and refueling water storag6 tank level are provided for the main control board indication The team verified the implementation of this requirement on the design document The toem reviewed drawings: 25203 28500,SH 53A,53B,54A,54B,56A,56B,57A, 578,400,401,402,403,840,841,842, and 843. The team found the isolators are

'

apparently shown or provided on drawings, but there is no qualification data from NNECO to Parsons to support the venfication of the licensing basis. The team noted that information received to date primarily addressed environmental and seismic qualification, rather than electrical qualification. Parsons stated they will request the electrical qualification licensing basis and qualification data for isolation devices identified within the scope of the ICAV Conclusions The team concluded that Parsons had adequately captured UFSAR commitments and

verified that they were appropriately included in Form 2 per PP 04 requirement .3 Miguacy of the System Soecific Checklists (Form 3)

The tenin reviewed the various parts of the Millstone Unit 2 ICAVP SVSR ' System Design input and Licensing Basis Checklist' (Form 3) and discussed work in progress with Persons personnel. The purpose of Form 3 is to:

'

e Compare the current system design documentation (incluC!ag all modifications)

to the current licensing and design basis e Provide a review of cunent programmatic and topical areas e Verify that system components satisfy their current licensing and design basis None of the Form 3 attributes had been signed off. The team evaluated the adequacy of identification of the design basis and the adequacy of the checklist scop .3.1 Adequacy of Identification of Design Basis and Design inputs During the first phase of the inspection, the team's review of the in progress and incomplete Form 3 documents for the AFW and HPSI systems identified that

.

- , , , - , , - _ _ y__, - - - - - - . - - - - - , - - - - , ,-- -.------,--.---.,-.-,v.--,,_,--, y _-- - --.--,----

_. _ . _ _ . _ _ . - _ _ _ _ _ . _ _ _ . _ _ . _ . _ _ _ . . _ _ _ _ _ _ .

component data sheets were being processed without system Isvol design input Based on this observation, the tem explored three issues with Persons.

'

First, Parsons' reviews should be based on verifiable design inputs and design bases retrieved from the licensee's Ales. Persons indicated that verifiable source references cmlin the licensee's unverified Design Basis Document Packages, as well as calculations of record, would be used as design inputs / bases, j Second, it was not clear to the team whether the reviewers' evaluation against the

-

design input and design basis of record vtuld be auditable unless the design basis for the evaluation were pesented irt summary form and/or explicitly referenced on Form

)

3. Since there were no available examples of sufficient scope, this area could not be reviewed during the first phase of the inspectio Third, it was not clear how the ICAVP would capture the design basis sufficiently early in the review and how retrieval of a complete design basis would be assured for use in the feview. Parsons acknowledged this concem and agreed to identify as much dssign input data as possible, as early as possible, and to add to Form 3 their infomal standard that identifies ANSI N45.2.11 design inputs. This list of generic design inputs would be used as a template of expectations for a complete design basi During the second phase of the inspection, the team confirmed that Parsons had revised Form 3 for the HPSI system to include a design input checklist consistent with ANSI N45.2.11 design input attributes. The checklist was based on Parsons intomal practice and procedures. The team found this to be an acceptable method of assessing the completeness of the design basis to be captured in the Tier 1 revie During the acond phase of the inspection, the team observed that Parsons had gathered the design basis information from the verifiable source references. Also, the majority cf the mechanical systems calculations had been reviewed. Therefore, there was sufficient basis to proceed with the lower tier Form 3 checklists and the other forms requiring input from the design basis revie .3.2 Adequacy of Checklist Scope During the first phase of the inspection, the team reviewed the Form 3 documents in progress. Recognizing that this part of the Parsons effort was in the discovery stage, the team concluded that the system specific checklists appeared complete, with the following observations or scope clarification o The team's inspection revealed that in Form 3, Part C, for the AFW system,68 system level questions were selected from the generic forms of which 7 questions were specific to the AFW system. For the HPSI system,63 system-level questions were selected from the generic forms, of which 2 questions were specific to HPSI. Only one system level questken review was in progress, which was related to minimum flow protection for the HPSI pumps. The team found that the level of review of this item was adequat ._ . _ - _- _

-_ _ - - ___

-

l s e Persons requested clarification of scope with respect to the extent to which it j was necessary to open field instrument enclosures that are boned and a

environmentally sealed (vs. panels designed to be routinely opened for i

, examination). Specifically, Persons had found that redundant divisions entered j several of these common enclosures. Parsons determined that to ensure that j licensing basis requirements for circuit separation are satisfied (by barriers or

, other means consistent with the design and licensing basis), breaching the seals for an intomalinspection would be necessary. Because of the intrusive

, nature of this inspection, the team agreed that a sampling methodology could

) be acceptable. Based on these discussions, Persons stated during the second i~

inspection phase et was still planning to submit a sampling methodolopy to the staff for review. The proposed sampling methodology must provide

,

reasonable assurance that the licensing and design basis is satisfied by the

! existing configuratio e The proposed depth of review of the licensee's retrofit of AFW analog

'

instrumentation with digital instrumentation should be augmented by the review guidance provided by NRC inspection Procedures 52001 and 52002 for digital

) retrofits. This would address concem r61 sed by the staff in Generic Letter g5-02 that unroviewed safety questions may be introduced by the retrofit of i analog instrumentation with digital instrumentation. This would include issues i such as new failure modes and malfunctions, the potential for common-mode

'

failures due to software, increased sensitivity to electromagnetic interference,

control of auxiliary equipment used to modifv software and hardware

configurations, the effect on system diversity, and the adequacy of systems

.

integretion and commercial grade dedication. The team was told by Parsons

that Form 3 would be revised to include or reference this type of guidance,

.

'

During the second inspection, Parsons told the team that they had retrieved ,

the Millstone 3 licensing basis for digital instrumentation and control system '

retrofits. Parsons indicated that the licensee's commitment to RG 1.152, l

[ ' Criteria for Digital Computers in Safety Systems of Nuclear Power Plants *

l l would form the basis of the criteria to be used in the review of digital '

j instrumentation and control systems. Persons was to revise Form : i (Licensing Basis) to identify this commitment as a basis for the review. This ,

i was acceptable to the team, on the basis that the design and quellfication

.

requirements levied by the licensing commitments should be appropriately ,

j identified.

e The l&C Component Review Checklists or another appropriate ICAVP review

guidance should include a review of critical installation attributes for primary elements. This review should include attributes such as unobstructed straight

piping runs upstream and downstream of flow elements, immersion length or l stratification for temperature measurements, and thermal insulation configuration for ir.strumor,ts (for example, insulation of resistance temperature  ;

'

detector interfaces or inadvertent insulation of condensing chambers). In

'

! 16 _ . - - . - . - - - - . . - . - - . _ - - - . - . _ . - . - - . - _ - . - .

,

I

'

response to the above, Persons stated that the Component Review Checklists had been revised to address flow elements and that these types of review attributes could be identified in the specific walkdown instructions that Parsons

was just beginning to prepare during the first inspection.

'

e The design requirements for piping, supports, and equipment in the

,

mechan' cal component and structural areas are documented in lower tier

design criteria documents that incorporate FSAR commitments and system-level design requirements, in discussion with Parsons' Structural Group during i the inspection, the team leamed that Parsons was having difficutty obtaining

] the design criteria documents in the mechanical components and structural i

disciplines for Millstone Unit 2 from NNEC Before the inspection at Parsons, during the week of August 11,1997, the

,

team had obtained a set of design criteria documents from the lead piping

stress engineer at Millstone Unit 2. During the inspection, the staff provided

,

these documents to Parsons to review and to copy, with the proviso that Parsons would formally request these documents from NNECO. Persons i

leamed that Millstone's nuclear records group had provided them with superseded revisions of two of the principal design criter:a documents governing the analysis of piping and supports. The documents provided by nuclear records were not the latest mvision. This example represents the type of problem Parsons encountered when requesting the the latest document of

! record, This problem was discussed on several occasions by Parsons and l NNECO to attempt to ensure that Parsons was receiving the latest revision of documents requeste .3.3 Form 3 Mechanical Systems Checklist Review i

During the second phase of inspection the team noted that although none of the lower

^

,

tier Form 3 checklists were signed off, there was significant progress in the review of HPSI system. A number of discrepancy reports had been generated. The team's evaluation of the significant discrepancy reports identified that the review of HPSI

<

system was .nsightful and thorough. The team also observed that progress in completion of the lower tier Form 3 checklists was hampered by the fact that NNECO is performing remedial actions in a number of the topical areas, such as in the vendor

,

manual program. However, the team had some comments related to completeness and accuracy of Parsons' review. The details of the team's review of sonie Form 3 areas are provided belo Form 3, Part C, item The purpose of this checklist was to identify if the data in t'h e UFSAR is consistent with the plant design calculations and analysis.' The team's review revealed that some values identified in Form 2 as the UFSAR data were not reflected in this checklis Parsons personnel acknowledged these omissions and stated that they will be incorporated in this checklist before to the sign of _ _ _ _ . - - . - - - _ _ _ _ _

.

_ _

. _ _ _ _ _ _ . . .

Form 3, Part C, Hem E.11 i

The purpose of this checklist was to determine if minimum flow protection been

provided for pumps that are subject to operation at zero or reduced flow. During the inspection work concoming this item was still in-progress. Specificolly, the originating

{

a engineer had completed his review, but additional reviews and approval were pendin i The requirement was marked to be considered as satisfying the licensing / design  !

'

! basis.

i

Part D of this form, ' Review Summary /Results,' provided information indicating that i the minimum flow requirement for the unrestricted operation (no time limit) of the HPSI pumps is 135 gpm. Through review, the team determined that Calculation

'

88 RPS 629GM establist,es a minimum flow capacity of at least 135 spm. However, j the team questioned this flow reta. Further review with Parsons' personnel suggested I that this statement is erroneous, in light of the following facts:

j e Review of Ur,!t 2 surveillances revealed that the measured flow through the minimum flow line is approximately 30 pp !

l e The 135 ppm conclusion was based on the size of the minimum flow line

excluding the eMeet of the orifice and, thus, was incorrec I i

Additionall), the review indicated that Emergency Operating Procedure EOP 2532 did j

. not provide any limitation on operation of HPSI pumps for flows below 135 gpm. (The -

_ only minimum flow limitation was 30 gom). This limitation led to a concem regarding l l thi adequacy of the HPSI pumps min.,num flow under certain scenarios (e.g.,

SBLOCA). However, the documentation avflable for review in Persons' offices was

'

not sufficient for the team to reach any definite conclusions. _ Persons' personnel -

stated that they would pursue this issue further with NNECO.

l 2.3.4 Form 3 l&C Checklist Review i

in the l&C area during the first phase of the inspection, the Design input Evaluation

, (Form 3, Part C, item B) had not been documented, nor had the HPSI system level i control system design questions been e7swered (Form 3, Part C, items H.1 through ,

H.23).- However, during the secondphase of the inspection, the team cencluded that  :

Parsons had made the checklist questions (Items H.1 through H.23) more specific to (

the HPSI system. Parsons'sudit plan required that the results of lower tier reviews

(for example, reviews of setpoint calculations, loop components, and detailed 4 walkdowns) as well as topical reviews (for example, evironmental and seismic '

qualification, RG 1.g7) be completed and the results used to perform an overall design

evaluation and to determine conclusions for the system. In some cases, Persons had been unable to complete these lower tier reviews because of pending responses from

,

the Ecersee to requests for additional information (RAls) and because of holds on l certain topical areas being remediated by the licensee, such as environmental i- qualification.

. r

!

I- 18

,

.,._.-.,,-..J.L_,-_,..-. ..

'

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

_ _ . _ _ . _ - _ . . . - _ - ._ _ _ . _ _ _ _ _ .___.

!

Notwithstanding that the system level evaluations were incomplete, the team

'

concluded that substantial lower tier review work was in progress and the interim )

work p'oducts could be used to determine whether Persons was following its audit  :

g procedures and whether the review scope was of sufficient depth and breadt I

~

During the second phase of the inspection, the team evaluated component review l checklists in progress for HPSI. These included three sets of Form 3X IC, ' Millstone

Unit 2 lCAVP SVSR Instrumentation and Control Component Loop Data Sheet.'

These data sheets (IC DS HPSI 01, .02, and 10) included a containment pressure l

transmitter, refueling water storage tank level transmitter, ani vessurizer pressure ,

'

j transmitter, respectively. Although none of these checklists h); seen issued, the team concluded that there were sufficient interim results to asst 4. aisuns

.

compliance with the audit plan, the scope of review, the attention to detail, and the

-

degree of questioning attitude wnen performing the reviews. The team's review of the intenm results and discussions with Parsons concluded that Persons was identifying

,

the following potential issues from the ICAVP HPSI review:

!

e seismic two-over-one concems and seismic qualification with respect to Impulse lines and instruments e discrepanciws in identification and color coding of wiring inside panels e discrept ncies in as built elevation and configuration of field instruments ,

'

e discrepancies in separation of wiring within panels e adequacy of range for RG 1.g7 instrumentation I e material condition and installation of safety related impulse lines i

e undocumented change to a pressurizer pressure indicator

< e quality classification of certain HPSI instruments

e adequacy of certain setpoint calculations Parsons was addressing these potential issues by issuing requests for additional info;mation or preparing discrepancy reports. The team recognized that these issues

might be resolved pending receipt of further information from the license Nevertheless, these interim results demonstrated attention to detail and a questioning attitude for a wide variety of technical attributes. For example, several of the foregoing.

'

'

issues identified by Parsons were supported by in-depth walkdown activities, in addition, Parsons' review of setpoint calculations included a detailed examination of the calculation methodology (as compared to the calibration rrethodology), the as-built configuration, the a6sumptions regarding measurement and test equipment, and the

use of drift data. On the basis of thie review of Parsons' component data sheets and 1g i

. ..__.._.- , -. - . - - . - _ . - - --

.. ___ _ _._ _ _ . __ _ _ _ _. ..___._ _ - _ _ . _ _ _ _ .

supporting documents as well as the interim results, the team concluded that Parsons was following the audit plan and providing an effectivo Tier 1 revie ,

l

The team confirmed with Parsons that the following three review areas that had not i been completed would be include l

i e Regarding licensee commitments to RG 1.11, *lnstrument Lines Penetrating  ;

i Primary Reactor Containment,' Parsons' review should review the basis for 1 maintaining post socident containment integrity with the installed configuratio '

i l 1

o Persons will determine whether maintenance procedures or other means are

available for providing reasonable assurance that the containment pressure impulse lines (atmospheric) are not blocked or restricted; the procedures identifed to date by Parsons in Form g (testing) did not appear to provide this assuranc

, e Persons will request from the licensee the electrical qualification licensing basis

) and qualification data for isolation devices identifed in the scope of the ICAVP.

Information received to date primarily addressed environmental and seismic qualification, rather than electrical qualification.

i 2.3.5 Form 3 Electrical Systems Checklist Review i During the second inspection phase, the team continued the review from the first phase using additionalinformation subsequently generated. As noted earlier in this

! report, Form 1 (System Boundaries) and Form 2 (Licensing Basis Current) had been

-

previously signed off. Form 3 of PI 01, which applied to the system review, contains

,

individual sections on system level questions, topicalissues, and the attributes of

! components in the selected system.

'

For each of the electrical components, approximately 74 attributes must be

addressed. There were component sheets (Form 3XEE) for electricalitems such as HPSI pump motors, various motor operated valves, solenoid valves, and heat tracin The team's review of these documents indicated that approximately 40 percent of the

-

attributes had been addressed and input data had generally been fold verifed. In general, attritwies relating to topical issues had not been completed primarily because the Licensee had not completed the revisions to the fire hazards analysis, equipment i environmental program and station blackout repor . Attributes that required a review of calculations were complete with the exception of

'-

those relating to component protection and coordination and these that rely upon i walkdown responses. Parsons had only iacently tagun to review relay calculations

<

and the responses to the system walkdown packages that they had prepare The team reviewed several of the calculations that Persons had used in responding to

, component attributes, including the following:

-

W

___a_ . . . , ,ww_, ..w.--,.,.~,w,..,,.,, _ , , . , u%,., _ _ ,,,,w._,7 ,.c.wm,._,.m,,.-. ., ,,. - . , <

---

.. - _ .- - - - . . . . - - - . _ _

- . - _ -

l

>

) e PA84 0630 0714 GE, Revision 0, approved July 30,1990, Millstone Unit 2  ;

. Thermal Overload Relays for motor operated valves on safety related

motor control centers -

.

e PA91004 276E2, Revision 0, approved December 20,1995, Millstone Uni' '

Station Service Study, Voltage Pronle

j e PA91-004 286E2, Revision 2, approved October 30,1995, Millstone Unit 2

6.9 KV, 4.16KV, and 480 voit short circuit & equipment duty analysis

o PA791261027 E2, Revision 1, approved May 14,1997, MP2 Emer9ency j Diesel Generator Loading Calculation  !

,

The team concurred with the calculation methodology and input data and with

'

Parsons' responses to component attribute questions that related to the calcuistion, l i

Besides the component data sheets, Form 3 has other sections that pertain to the i system hself, as illustrated by the following:

o Pari C hem B195 relates to design input evaluation

• Part C hem C1 C10 relates to calculat!one and measurements

o Part C item G1 G15 related to electrical system design

! Other Part C items relate to the other technical disciplines. The team's review

Indicated that none of the system level questions had been completed at the time of

, this inspection. Persons indicated that many of the system-level questions rely on

! data recorded on the component data sheets. Parsons did not plan to respond to the

system questions until the component dets sheets were nearly complete. The team  !

concurred with this approach. The team's review of Form 3 and the work in progress i indicated that Parsons was following the ICAVP per PP 01 and Pl 01,

.

2.3.6 Form 3 Mechanical Components Checklist Review

1 To assess the adequacy of Parsons' review in the piping and structural disciplines, the

,

team evaluated a sample of Parsons' work products for the HPSI system. This

! sample included a review of pipe stress analysis packages P48 and P 57, seismic 4 qualification documents for HPSI pumps P-41 A and -C and RWST tank T 41, and a sample of six HPSI pipe supports analyzed by Bechtelin the 19801981 time frame as part of Millstone Unit 2's lE Bulletin 79-02 progra ; P>e Stress Packages No. 48 and No. 67

! Parsons' work product for each pipe stress package consists of a Document Review 4 '

Record and a Piping Analysis Review Checklist. The data that Parsons compiles for-s each piping analysis is additionally documented in portions of Form 3. Parsons had not completed the system level piping and structural portions of Form 3 for the HPSI

,

i

,

,, * . , .- -,w.,, r,-,.,-r,.r.p.,. ,- , ~ - -, - , .,. , m ir

--. - -_ - -

-

- _- -

system. Pipe Stress Packages P-48 and P 57 qualify the piping from the containment sump and the RWST tank to the sucton sides of HPSl pumps P41 A and -C. As noted in the Parsons tabulation entrtled 'HPSI Piping and Support Analyses / Review Status as of December 3,1997', a total of 80 pipe supports are installed in this portion of the HPSI system. During this review, the team leamed that Parsons had not yet received these pipe support calculations from NNECO. On December 4,1997, Parsons noted that NNECO had provided Parsons with 125 of about 500 HPSI pipe support calculations. Parsons initiated DR 0174,'Unavailabiltty of Ca!culations for ASME Code Class 1 and 2 HPSI Pipe Supports,' to document this potential deficienc Parsons' proposed 20 percent sample review of the pipe supports installed in each vertical slice system. Of the 20 percent selected, half will be random sample and the other half will be a ' smart * sample using engineering juogement based on several criterion. The NRC staff approved this sample plan for pipe stress calculations, as well as sample plans for pipe, tubing and conduit supports in a letter dated January 8,1998. Parsons needs to obtain most of the pipe support calculations for each vertical slice system from NNECO to implement this requiremen For Pipe Stress Package P-48, Parsons issued DRs -0041, -0042, -0043; drafted DR-0179; and prepared RAl 0303. For Pipe Stress Package P 57, Parsons drafted DR 0193 and prepared RAl 0856. The team concluded that the review summaries documented in the Document Review Records and the comments documented in the Piping Analysis Review Checklists for Pipe Stress Packages P 48 and P 57 provide reasonable assurance of Parsons' detailed review of the stress package Pipo Support Calculations Pipe support FSK M 015138 H 3 is a structural angle supported by a base plat The angle supports a 2' pipe. Parsons' review Indicated that the structural angle and connecting weld to the base plate were not checked in addition, Parsons' walkdown of the pipe support identified a pipe strap that was not documented in the calculation and was not checked. Parsons documented these discrepancies in DR-016 Pipe support FSK M 015138-H 6 is also a structural angle supported by a base plat Parsons identified similar deficiencies for this analysis that are also documented in DR 016 Pipe support 404009 consists of two parallel structural angles welded to an anchor Dotted base plate that restrain a pipe laterally. Parsons' review indicated that the calculation did not document the loads from the piping stress analysis, and did not document the p! ping thermal movements to determine if friction loads should be considered. Parsons documented these discrepancies in DR-016 Pipe support 506002 is a structural steel saddle welded to an anchor bolted base plate. Parsons' review Indicated that the calculation did not document the loads from the piping stress analysis, and the loads in the calculation did not agree with the loads documented on the pipt support detail sheet, which were higher than the loads used in the calculation. Finally, the local stresses induced in the piping in the vicinity of the

. - - ---__ - - _ - . - - - - - _- - - _ - . _ - - . -. . .-

welded attachment were not evaluated. Parsons documented these discrepancies in DR-016 Pipe support 70058 consists of two pipe struts (approximately 90 degrees) apart and are supported by anchor bolted base plates and laterally restrain a 4* line. Parsons'

review indicated that the load sheet from the pipe stress analysis was not documented in the calculation, and the base plate thickness, bolt diameters, and embedmont lengths qualified in the calculation did not agree with the dimensions shown on the pipe support detail drawing. The calculation also did not check the weld between the rigid strut plate and the base plate. Parsons finally noted that the calculation used an  ;

anchor bolt edge distance tolerance that was unconservative with respect to a detail drawing. Parsons documented these discrepancies in DR 0164, Pipe support 307009 is a structural steel saddle welded to an anchor bolted base plate. Parsons' review noted that the calculation did not document the load sheet fro,n ,

'

the piping stress analysis, and there were differences in the anchor bott spacings and base plate dimensions between two drawings. Parsons documented these discrepancies in DR 016 The team concluded that the review summaries documented in the Document Review Records and the completed Pipe Support Calculation Review Checklists for the above sample of pipe supports provide reasonable assurance of Parsons' detailed review of the pipe supports. However, the team noted that, becausa Parsons has not received ,

the bulk of the pipe supports in the HPSI system, the contractor has not rev..*wed a 10 '

percent smart sample of these pips support Seismic Qualification of HPSI Fumps P-41A C and RWST Tank T-41 The team assessed Parsons' review of the seismic qualification documents for HPSI  !

pumps P-41 A and C and RWST tank T 41 to confirm the adequacy of the design seismic loads specified in the seismic qualification documents. Combustion Engineering Specification No.18767 PE 410, * Project Specification for Safety injection Pumps,' Revision 1, dated September 10,1975, specified the design i requirements for the HPSI pumps. Bechtel Specification No. 7604 C-43,

• Specification for Designing, Fumishing, Fabrication, Delivery and Erection of Field Erected Tanks,' Revision 7, dated September 30,1975, specifies the design requirements for the RWST tank. NNECO has supplanted the original seismic qualification documents for the HPSI pumps and the RWST tank by seismically qualifying the pumps and the tank using A 46 SOUG criteria. NNECO's A 46 review of the pumps and tank is documented on Screening Evaluation Work Sheets (SEWS).

Parsons' review of the SEWS for the HPSI pumps and the RWST tank is documented on Structural Calculat:en Review Checklisis and Document Review Record The team noted that Parsons' Structural Calculation Review Checklist is an adequate template for the structural review of electrical and mechanical equipment. Parsons'

Document Review Records for the HPSI pumps and the RWST tank document Parsons' acceptance of NNECO's A 46 reviews. However, Parsons drafted DR 0200

-

- . . - . . - , - - - , - - - - - - - , - - . - - - - - - - - - - - - - - - - -

. _ . . _ . . _ _ _ _ _ _ .

.

to document the unverified assumption that the HPSI pump nozzle loads are negligible

end issued DR 0099 to document Parsons' concern that the A 46 evaluation for the RWST tank did not consen'atively address the RWST tank anchor botts. Parsons also prepared DR 0172 to note that the FSAR should be revised to document the use of the A 46 methodology as an acceptable attemative to the equipment seismic l qualification requirements of FSAR Section 5. l l

The team concluded that the review summaries documented in the Document Review j Records for HPSI pumps A 41A and C and RWST tank T 41 provide reasonable i assurance of Parsons' detailed seismic review of the HPSI pumps and the RWS ) Corrective Actions (Form di Inspection Scope The team evaluated the thoroughness of the corrective action review being conducted by Parsons. To do so the team reviewed a sample of completed Form 4 System Corrective Action Checklists and assessment of licensee proposed and implemented corrective actions for deficiencies identified during the implementation of the Configuration Management Program (CMP) corrective actio Observations and Findings implementation of the Parsons corrective action review process was originally envisioned to be controlled by T1.CL l 04, System Corrective Action Checklist Instructions Form 4, Revision 2. This checklist provides the System Lead Engineer (SLE) with up to eight questions that could be selected for review o"each cf the corrective actions to be reviewed. Parsons subsequently determined that they needed a 2omputerized data base system to implement their review. This condition resulted f om a number of unsuccessful attempts to use licensee databases related to the CMP and the corrective action proces In response to this situation, Parsons developed a computer Corrective Action Data System version of Form 4, which is required to be populated with corrective action items related to licensee identified Unresolved item Reports (UIRs), Adverse Condition Reports / Condition Reports (ACRs/CRs), and Action Requests (ARs) related to the

'in scope * systems. The system being developed is a customized ' fill-in the blank *

type system. The eight questions contained in the original Form 4 checklist have been converted to a tniversal application of fourteen questions. These questions essentially bound the issues that were to be reviewed in the original Form 4 as part of an appropriate corrective action review (i.e., actions appropriate, timely, and was root cause evaluated,if necessary).

During the inspection, the team determined that Parsons was still developing an understanding of the scope of corrective actions necessitating their review. They perceived that the scope of their review was bounded by those corrective actions that were a condition of plant startup, and to that end, it became apparent to Parsons that

.-

_ _ _ _

_ _ _ - ._ ____- _ - - _ - - - - _ . _ . - - . - _ - - - - _ _ _ - _ - . _

the use of action request data would facilitate retrieval of the scheduler aspects of the

'in scope' corrective actions to be reviewed. However, the team noted that the I questions to be addressed in the new data base system included issues associated with the deferral of corrective actions to a period following plant startup and the appropriateness of this licensee prescribed action. The team held discussions with Parsons on the scope of their review relative to pre and post startup corrective I actions. The team informed Parsons that reviewing ' planned * conective measures for deferred items using the questions contained in their system was an acceptable l approac The team was informed by Parsons that common (i.e., not identifiable to a specific system) ACPJCRs would be screened to determine their applicability to one or more of the 'in scope * systems or topical areas, if Parsons determines that the ACR/CR is within the scope of the Tier 1 effort, the item will be included in the data base and aviewed. However, the team was informed by Parsons that common UlRs would not be treated in the same manner. Specifically, unless the UIR is designated to be applicable to one of the 'in scope * systems by the licensee, the UIR will not be considered for a review of the relevant corrective actions Persons. The team was concerned that this approach would not ensure that all CMP identified deficiency related corrective actions are reviewed if they involve the 'in scope * system The team identified a number of positive attributes ' 'ociated with Parsons'

development of a computerized corrective actiont i base system:

e Screening common,i < _.nassigned ACR/CRs for applicability gains efficiencies to one or more of the 'in scope' systems or topical areas, o The use of a computerized data base system facilitates the application of trending techniques that are usefulin thw identifying performance issues in both technical and programmatic areas, e Once a corrective action item has been reviewed, the system will flag subsequent changes by the licensee in the item's completion schedul Regarding the latter item, Parsons informed the team thet a fing indicating that an item that was originally scheduled for E. pre startup completion date, and which was reviewed as appropriate by Parsons, would necessitate a re review of a change to a post startup commitmen Parsons regarded the corrective actions area of their Tier 1 effort to be formidable, because they estimated that each of the 'in scope * system reviews will contain approximately 3000 discrete corrective action items. Parsons informed the team that following successful verification of the new corrective action data base system, they will revise Frem 4, if necessary. Additionally, Parsons will develop a computerized desktop inuruction for use by their team members as part of indoctrination and training for the use of the new database syste _ _ _ - Conclusions The team determined that the corrective action process was in the ear!y stages and still evolving as Parsons becomes more familiar with the various licensee data bases that input into the corrective action process. The team determined that the systems and actions planned for the corrective action process are consistent with the audit plan and project procedures. The team considered Parsons' plans for revising / enhancing Checklist T1 CL l-04 and developing a computerized desktop instruction to be appropriate. Parsons' plans for indoctrination and training of team members on the corrective .ction review process were also appropriat .5 Modifications (Formt 5 B. 7) Inspection Scope The team performed a cursory review of a small sample of Form 7 (Modification Heview Checklist) work in progress for HPSI modifications. Form 5 (System Modificatien Screening Summary) and Form 6 (System Modification Summary Listing)

were used to choose the Form 7 sample for review, Observations and Findings e Mechanical Systems Modifications The team evaluated Parsons' review of Modification PDCR 219 81 entitled 'HPSI intermediate Impeller Material Change.' Parsons documented this review in Form 5 (Modification Screening): SMSS HPSI 18 and Form 7: RC MODIFICATION HPSI 2 The team concurred with conclusions reached by Parsons, that (1) the modification satisfied licensing basis and configuration control (2) applicable program / topical areas adequately considered in the modification and (3) there were no discrepancies identified by review of this modificatio e l&C Modifications The team reviewed a small sample of Form 7 work in progress for l&C modification The total population of HPSI l&C modifications identified by Parsons was eleven, ranging from 1976 to 1981. The team's sample included PDCR 2 086 76, *RWST Hi/Lo Level Alarm * and PDCR 2 284 77,'RWST Level Transmitters Modification."

Neither of taese reviews was complete, but the draft working document did provide evidence that Parsons was following their procedures. For example, Parsons identified inadequate safety evaluation documentation for these older modifications (1976 and 1977); researched related field changes; noted that one modification did not identify maintenance and test procedure interfaces, and another did not specify post modification testing. Additionally, Parsons identified and reviewed supporting calculations and planned to field check installation and support of rerouted tubin The team also assessed Parsons' review of Modification Number 2 087 75 (completed)'RWST Low Level Alarm,' Modification Number 2 095 76 (in progress),

A

_ _ . --- -- - - .- _ ..

• Engineered Safety Pumps Min Flow Bypass,' Modification Number 2 01179 (in progress), 'SRAS Setpoint Change ' in particular, the team reviewed the form for proper entries, approval signatures, proper responses to the checklist questions, and explanations if provide * Electrical Systems Modifications The team reviewed Modification PDCR 2 098 81, which relates to setting the opening limits of motor operated valve 611647 to eliminate overshooting the desired position on a regular basis. Justification for leaving these valves in an open positi'e is the fact that there are three check valves in series in these lines. The modification was reviewed for technical content and was acceptable to the staff. Form 7 was completely signed of '

The staff also reviewed Modification PDCR 2 065 94 which applies to RWST/PWST heat trace rJrcuits. This modification did not have all of the Form 7 items signed off however its technical content appeared reasonable. As result of a question from the team relating to whether or not there were heaters in the instrumentation enclosures for RWST level transmitters, it was noted that they were not included in the modification. A subsequent review by Parsons indicated that the walkdown group determined that there were heaters in the enclosure, however, they noted that the output cables for all four trains were mounted on common supports for a length of approximately 70 feet. Parsons stated that a DR would be prepared to address this lack of separation, o Mechanical Components Modifications

The team reviewed piping and structural modifications PDCR 212181, PDCR 2 090 81, PDCR 2 272 77, PDCR 2 058 80 and PDCR 2-036 81. Parsons documented the initial screening of each modification on Form 5, the review of each modification on a Form 7, and summarized the review of each modification on a Document Review Record. PDCR 212181 redesigned pipe support 401106 to meet IE Bulletin No. 79-02 requirements. NNECO cannot provide Parsons with the pipe support calculation and Parsons has prepared DR-0165 to document this conce PDCR 2 090 81 replaced Intemational Nuclear Safeguards Company (INC) snubbers installed in the HPSI system to address lE Bulletin No 8101 concems. Parsons did not identify any concems with this modificatio PDCR 2 272 77 replaced tubing with piping and installed new hangers to reduce vibration levels. NNECO could not provide Parsons with the pipe support calculation and Parsons has prepared DR 0168 to document this concem. PDCR 2-058-80 was prepared to control the rework of piping hangers with concrete anchor bolts to IE Bulletin No. 79 02 requirements. Again, NNECO could not provide Parsons with the pipe suppor1 calculations and Parsons has prepared DR-0167 to document this concem. PDCR 2 036 81 removed the snubber from hanger 410082, NNECO could nr t document the technical basis for the elimination of this support and Parsons has prepared DR 0166 to document tnis conce i

_ . . _ . _ _ . . . .

__ _ . _ - . _ _ _ _ _ _ - __ _ _ - ___ - - - __

I

The team notes that the Form 7 Modification Review Checidist is an adequate template for the review of piping and structural modifications. However, the team

could not determine the adequacy of I' arsons' review of a sample of piping and structural modifications to the HPSI system on the basis that Parsons has not received i all required documents to facilitate the review of the calculations that document the l

! technical bases for the modifications.

!

1 Conclusions

'

On the basis of the issues being addressed by Parsons for the work in progress, the {

team concluded that Persons was following its audit plan and project procedures for >

i review of modifications and appeared to be using an appropriate threshold of conoom

when !dentifyleo potentialissues.

+

! Operatina .:eduren (Form B)

i '

i Inspection Sct 1 ( .

l The team evaluated the implementatio 1 of the Parsons' process for the review and assessment of the system-related operating and maintenance procedures. Because j Parsons had not completed Form 3 and Form 7 reviews, the team was informed that

'

none of the Form 8 system procedure checklists could be signed off as complete at .

, this time. As such, the team was only able to review work in process in this Tier 1 I

'

area. However, Parsons performed sufficient work to allow the team to verify that they j were implementing the audit plan appropriately,

.

] Observations and Findings

,  ;

The team examined this Tier 1 area by reviewing Persons' activities associated with

) the implementation of Form 8 System Review Checklist instructions Operating

!

Procedures. This form is described in T1-CL l-08, ' System Review Checklist instructions Operating Procedures Form 8,* of Pl.01.

'

The team's focus was on the Tier 1 activities associated with the HPSI system since ,

i the system review was essentially complete at the time of the inspection. A total of 63 j

operating procedures (i.e.,55 operations, alarm response, abnormal, and emergency

operating procedures; and 8 maintenance procedures) were the subject of Form 8 reviews. The team noted that Parsons improved its audit plan implementation as >

,

' reviews proceeded. An example was the development in the operations area of an expanded checklist set to be used by Parsons operations personnel that provided for both a broadened and more consistent review of the subject procedures. The team l noted that thin enhancement strengthens Parsons' ability to identify licensee

performance insights (both positive and negative).

The team noted some redundancy between Form 7, System Modification Review

Checklist, and Form 8. Because of this t. .mdancy, overlap exists that could affect the identification and impact of operations and maintenance procedures as a result of

1 l

T w n, , - , -- , - . - . , ,,wv-,w-p-,, w-,--,,,,v em,. ., - , -- --m, , - - -., , -,,-.,n

_ _ _ _ _ _ _ _ _ _ . _ . _ -

_

licensee modification efforts. Parsons personnelinformed the team that they would i not sign a Form 8 review for a procedure until the corresponding required Form 7

<

review was completed for the modifications requiring review. The team considered

, this approach apptopriate. A number of DRs have been identified and issued as a J

result of the Form 8 reviews, which the team determined to reflect critical reviews and the appropriate threshold for the identification of problems by Person )

Regarding maintenance procedure reviews, Persons informed the team that while they l were using vendor manual technical information to assess the adequacy of licensee

l

maintenance procedures, they were well aws re of the limits and concoms already )

l identified by the NRC and licensee in this are i Conclusions The team concluded that in the C;wrati .g Procedures area of the Tier 1 review, Parsons implementation of the audit plan appeared to be effective. Parsons personnel j enhanced the audit process by developing expanded checklists that provided for i

'

thorough and consistent reviews. The team concluded that Parsons performance in this regard was positive. Parsons personnel demonstrated good sensitivity to not prematurely consider Form 8 reviews completed while other system review activity was in proces .7 Testina (Form 9)

. Inspection Scope

!

The team evaluated the implementation of the Parson's process for the review and i assessment of testing requirements. Since Form 9 completion was dependent on i both Form 3 and Form 7 efforts being completed, the team was only able to do an in-

.

'

process review in this Tier 1 area. However, Parsons performed sufficient work to allow the team to verify that they were carrying out the audit plan appropriately.

t Observations and Findings The team conducted a review of work in this area of Tier 1 by reviewing Parsons

activities associated with the implementation of Form 9 - System Testing Checklist.

.

This form is described in T1 CL-l-09, ' System Review Checklist instructions Testing -

Form 9,* of PI-01, l

l The teams focus was on the Tier 1 Parsons activities associated with the HPSI t

system, since this system review was essentially complete at the time of the

, inspection. A total of 38 testing-related procedures were the subject of Form 9 reviews. As enumerated above ir, the review of Parsons performance in the area of Operating Procedures Form 8, the team noted the development and implementation

, of an enhanced, or supplemental, checklist; and a similar approach to the inherent redundancy between the review between Form 7 (System Modification Review l

Checklist) and Form 9. Parsons has identified and issued a number of DRs as a result .

( 29 i

. ._ . _ _ _ _ _ _ _ _ . _ _ __ __ _ _ __ __, _ . _ _ _ _ . -

_ _,

-. - - _ _ _ _ _ _ _ _ _ - --_ - - - - _ _ _- - _ - -- - . _ _ __ - -

of the Form 9 reviews, which the team determined to reflect critical reviews and the appropriate threshold for the identification of problems by Parson Cenc u la m The team concluded that in the testing area of the Tier 1 leview, Parsons implementation of the audit plan was effective. Parsons personnel were observed to enhance the audit process by developing expanded checklists that provided for though and consistent reviews. Parsons personnel demonstrated good sensitivity to not prematurely consider Form 9 reviews completed while other system review activity was in process, Tier 1 Summarv e During the first phase of the inspection, the only completed anJ issued work products for the AFW and HPSI system vertical slice reviews were Forms 1 and 2. Form i established a specific review scope and system boundaries; Form 2 identified the licensing bases for the system. Therefore, since the team could not evaluate the technical reviews of calculations, specifications and drawings, and other engineering reviews, no specific conclusions about the overall effectiveness of the Tier 1 review could be drawn at that tim Therefore, a second inspection phase was schedule e in several areas the Tier 1 review scope and process were clarified, as described above. During the second phase of the inspection, the team '

confirmed that Parsons was implementing the scope clarifications identified during the first phase of the inspection, e During the second phase of the inspection, the HPSI review was the most complete, but only Forms 1 and 2 and a small portion of the other forms had been completed and issued. However, there was sufficient work in progress for the HPSI Design and Licensing Basis Review (Form 3) and the reviews performed on forms 4 to 9, such that the team was able to evaluate interim work products and conclude that Parsons was following the audit plan and procedures, was providing an acceptable depth and breadth of review, was using an appropriate threshold of concem when identifying potentialissues, and was providing work products that were readily auditable. In addition, Parsons staff exhibited a questioning attitude and in-depth understanding of the technical areas reviewe .0 Tier 2 - Accident Mitiaation Systems Review Inspection Scope The team assessed Parsons' implementation of the Tier 2 accident mitigation systems review portion of the ICAVP audit plan for Millstone Unit 2 to determine the

l l

l

.- - - - - . -

_ . _ _ _ . . _ . _ _ - _ . _ _ _ . _ _ . - _ __ _

.

i

thoroughness of Persons' accident mitigation systems requirements review and to i

assess the identification of critical design characteristics for systems and components -

i to ensure that they can perform tholt specifed safety functions.

i Observatim and Findings '

. During the second phase of the inspection, the team was briefed on the status of work in the Tier 2 area. Parsons informed the team that development of: (1) Critical Safety

-

Function (CSF) diagrams was 100 percent completed, (2) system boundary diagrams

, was 98 percent completed, (3) Design Basis Events (DBEv) for identifed accident

'

unelyses had various levels of completion, and (4) the database structure was 100 percent complete and was being populated with the system and component erttical characteristics and parameters for each DBEv. Upon completion, this database would

, enable identification of the bounding characteristics and parameters down to the

component leve ,

in reviewing completed and in progress work activities, the team identifed l observations and findings in the following areas:

s e incomplete Review of ' System Level' interlocks for Tier 2 Effort

.

'

During the first phase of the inspection discussions with the Parsons' Tier 2 personnel revealed that current critical function reviews did not incimie effects l of the ' system level' interlocks on the critical design characteristics. An example of such an interlock is the minimum flow recirculation line interiock

,

'

preventing initiation of the emergency core cooling system (ECCS)

recirculation phase before 1.olation of the ECCS pumps' minimum flow refueling water storage tank (RWST) retum isolation valves. Parsons agreed

to review effects of system level interlocks on the critical design characteristics.

l l During the second phase of inspection Parsons informed the team that the system levelinterlocks added were appropriate. The team's review of selected

accident sequences confirmed that the system levelinterlocks were i considere e Lack of Minimum Flow Protection Review

During '5s first phase of the inspection the team's review of the Tier 2 submittal to the NRC revealed that the schematic diagram for the LPSI system failed to i identify the connection for the minimum flow protection for LPSI pumps. The

LPSI pumps share a common minimum flow retum line to the RWST with other

.

ECCS pumps. Discussions with the Parsons' Tier 2 personnel revealed that this function should have been identifed on the schematic diagram and would be added to the system function diagram.

"

During the second phase of the inspection the team confirmed ths addition of this function on the revised schematic diagra f l

_ . . . ._ _ _ _ __ _ _. _ _ _ _ .._ _ _ _ ___ _ . _ _. _ _ , _ _ _ . _ _ _ . . _ _ _ _ .

_... __._._ _ _ _ __ _ _ _____ _ _ _ _ . . _ . _ . _ _

l

.

I

e Rosw of Accident Sequences 3

,

The team reviewed detcils of the in process work related to Large Break LOCA  !

l Tnd Single Control Rod Wehdrawal accident sequences. The team's review identifed that Parsons was performing its review in accordance with ths  !

. approved procedures and appropriately identified the areas of potential >

) conoom !

i e Nuclear inerumentation  !

i j During the first phase of the inspection, in discussions with Persons regarding

^  ;

the scope of Tier 2 activities, the team concluded that for nuclear  :

instrumentation, the Tier 2 development in progress and the forthcoming l j verification effort should include confirmation that the calibration procedures of

'

record reflect the fuel configuration for the next cycle. This would address past industry problems in this area, as identified in INPO SOER 90 3, ' Nuclear  ;

'

instrument Miscalibration.' Parsons agreed to include this effort in Tier Discussions with Parsons during the second phase of the inspection indicated that Parsons had reviewed the licensee's response to INPO SOER 90 3

'ecommendations, including a review of the licensee's procedures goveming calibrs+1on and adjustments for a new fuel cycle. Based on this, the team.

j concluded that Persons was addressing this issue in the scope of the ICAV o Calculations

,

'

Diesel Generator Loading Calculatt, '% 7912e 1027 E2, Revision 1, wen

,

being reviewed by Parsons during the first phase of the inspection. The review

had been completed before the second phase of the inspection. This effort i consisted primarily of reviewing the wnrk described in attached appendices that describe in more detail how the items in the calculation spreadsheet were developed. For example, broke horsepower for each component, using data provided by Mschanical Engineering, was used to verify that the diesel can supply the power required for each mode. The team reviewed this in more detail during the second phase of the inspection and did not identify any problems, i Conclusions - Tier 2 e During the first phase of the inspection, few completed and issued work products existed. Therefore, the team could not evaluate the technical and

engineering reviews and conclusions about the overall effectiveness of the Tier

2 review could not be drawn at that tim ,

o There were several areas where the Tier 2 review scope ant' process were

-

clarifed, as described abov t i

l

, s

_

.--.7 ---,o- ,.,y,. ~,,.,,,,7e, ,,w,-.-. , , , , , , . __,..--,.y.m gw_vr.,.,~,,-r,m,w._- , . . e ._..m,_w.-.a . ~ . - . -+ . - - . * _

_ _ _ _ . _ _ _ - . . __ __ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _

e The review and discussions regarding additional work in progress during the

'  ;

second inspection phare suggested that Parsons was adequately l implementing tha Tier 2 portion of the ICAVP audit plan and procedures  !

previously approved by the NRC staf :

) Tier 3 Process Review. Confiouration Manacement Prooram Horizontal Slice Inspection Scope The team assessed Parsons' implementation of the Tier 3 horizontal slice portion of the ICAVP audit plan for Millstone Unit 2 to determine if the Tier 3 horizontal slice is

,

comprehensive in scope and to assess the thoroughness of Parsons' evaluation of '

past design changes versus the current design and licensing basis, Observations and Findings

.

e Population Identification and Sample Selection J

At the time of the inspection, Parsnns was preparing a horizontal review of the following commodity types:

- setpoint changes 1

- specification revisions, drawing revisions calculation revisions

- licensing document changes nonconformance reports (NCR) ,use as is)

- engineering work requests (EWR)

- vendor technicalinformation

- master equipment parts list (MEPL) safety classification changes commercial grade dedication equivalency substitutions operation and abnormal operations procedures maintenance procedures ,

- emergency operating procedures (EOPs)

surveillance testing ISI, IST, and ASME Section XI repair and replacement temporary changes, including jumper, lifted lead, and bypass control For each commodity, Parsons selected a sample that spans four 5 year periods from 1975 to igg 7, us),'; the following criteria:

(1) Select items categorized as safety related and/or risk significan (2) Select items from systems not chosen for the Tier i revie (3) Select items from within NNECO's CMP (if applicable).

(4) Select changes that have technical significance.

'

l l

._ _ ___ ., ,,

! l

,

(5) Select Rome based on experience with pesi industry problem areas and/or vendor (6) select hems that complement the Tier 1 or Tiar 2 inspedion l

'

'

Attachment 1 to Persons' July 25,1997, submittal letter summarized identification of the population, sample size, and extent of solodion for each ;

} commodity. Persons stated that the selected sample represents the entire 1

, population for each commodity.

!-

e Audit Plan Methodology l

'

3 Persons was conducting the Tier 3 horizontal slice review according to PP 03,

" Process Review, CMP Horizental Slice," Revision 2, dated June 26,1997, and the referenced July 25,1997, lottaf to the staff. Persons had also prepared a !

i new att:chment to PP-03 that we tubmitted for staff review and approval on ;

'

January 12,1998, and a series of commodity checklists that implement the

'

evaluation criteria documented in PP-0 :

e Assessments of Past Design Changes

in discussions with Parsons during the first phase of the inspection, the team leamed that Parsons had not yet reviewed any commodity samples in i accordance with program requirements. During the second phase of the ,

,

inspection, this area was reviewed by sampling the following commodity type !

on a limited basis because few completed work products were available

.

i Satpoint changen i

The team reviewed Parsons' two completed Tier 3 reviews of the licensee's

setpoint change documents. Persons documented these reviews via PP-03 Attachment 8, Package STP 001 for Setpoint Change Request (SCR)

M2 g6-006, * Revision of CRAC Suction Pressure Switch Cut Out Setpoint' and Package STP 005 for Plant Design Change Request (PDCR) 2 45 82, ,

' Thermal Margir / Low Pressure (TM/LP) Pre-Trip Setpoint Change.* -

l

'

Sased on the team's review of the SCR, the PDCR, STP 001 and STP-006, the team agreed with Parsons conclusions and characterizations af the three Significance Level 4 DRs being processed as a result of these Tier 3 reviews (DRs 0201,015g, and 0160). The review packages provided good technical l detail and were readily seC' tabl I Saecification and r rawing revislans

The team reviewed the progress that Persons had made to date in the review

- of Specification changes and Drawing changes. The review indicated that -

i Persons had not progressed very far in their review of specific packages.

L Parsons selected a sample of 32 top level drawings that had been revised i

34 l

l l'

i- .

.-

.

.

_ _ _ . . . . . _ _ _ _ _ _ . _ _ . _ _ _ _ _ . . . . _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _

i

!

'

where a modification did not drive the revision. Parsons identified specification revisions by reviewing the revisions to a sample of parent specification Parsons identified drawing revisions in a similar manner, by reviewing the revision logs of a sample of top tier drawings such as P&lD and one line diagrams and confirming that these changes flowed down to lower tier documents. The team did not assess a sample of drawing revisions during this revie Work in progress reviewed related to a revision to a Main One Line Clagram I documented on Tier 3 Review Package Identifier DWG 005. The drawing is

'

25203 30001 with DCN's DM2-S-023193 & DM2 00 29197. The review is partially complete.

l i A similar procedure was reviewed for Specification revisions. Again the i i contractor selected a sample of 32 Specification revisions. An example of i work in progress rt'ated to a revision of Specification SP EE 308 by DCN

! DM2 S 0213 94 for an inverter. Although the form was not completely signed off, it does indicate that no DR's were identified and that the results of the review are satisfactory, i Although the sample of drawing and specification revisions tuviewed by Persons was very limited, the team was satisfied that the procedure used for

,

the review was being followe Licensina document chenoes Because of the small number of completed samples, the team reviewed onb four packages. However, for the completed packages. Parsons appeared to be following the established procedure and performed the review adequately. The reviews appeatad to have a good questioning attitude and approached their assignment with a critical eye. DRs identified as of the inspection appeared valid and demonstrated a thorough review of the licensee's change processes.

. -

Nonconformance Recorts fuse as is)

,

During the second phase of inspection the team was briefed on Parsons'

review of Nonconformance Reports (NCRs). Parsons stated that population identification and sample selection was in accordance with approved sampling methodology Parsons obtained from NNECO a hard copy list for the period 1975-1985 and an electronic database for the period 1986 to the presen i Parsons then selected a total of 32 NCRs (as numbered below), some of which the team reviewed as described below:

. NCR 19

'

NCR 19 summarizes Parsons' review of NCR 291 173, dated June 22,199 The NCR documented six lug connections with Raychem over braided wire, a

,

. - . . - -, . . , --~- , ~

- . . .. ...- - - .-. - - - - - - .- _ - _ _ _ _ . _ _ - ____- __ - -

!

-

l

missing cover bolt, and cover gasket damage. NNECO dispositioned the NCR l' to replace the cover gasket and to replace the missing cover bolts. NNECO

dispositioned the Raychem that covers the lug barrel "use ofcis," noting that

they did not intend the Raychem to form an EEQ barrier. Rather, the Raychem

, had been installed over the lug and wire to provide added electrical insulation and physical protection. Parsons' review of the NCR determined that the

Raychem heat shrink on the lug barrel did not constitute the EEQ bemer, that 4 motorized valves 2 CS 4.1 AM and 2-CS-4.1B were qualifed volves as  ;

identified on the Environmental Qualification Master List, and that the housing i enclosed the power and position / torque switch casling. Parsons therefore j accepted NNECO's 'use-as is' disposition for the Raychem heat shrin *

NCR 22 l NNECO prepared NCR 292-848 on September 17,1992, to rev!se an incorrect

pipe support number identified during an in-service inspection (ISI) walkdown

of four pipe supports in the RWST trench. Support 30108P was incorrectly labeled as 231090. NNECO dispositioned the NCR 'use-as-is' and revised

work orders (AWO) M29712140 and AWO 29212475 to correct the support j mark numbers. Parsons accepted the disposition of the NCR "use as is' for the i specific scope of the NCR, but identified sever 61 concems. The pipe support i

detail drawing and the piping isometric drawing show different locations for the support. Parsons issued DR-0064 tu document this discrepancy. The ISI j program for the HPSi system may be incomplete. The Tier 3 group's tentative l conclusion is based on a comparison of the scope of the ISI program for the

HPSI system that is documented in "Second Ten Year in Service inspection

.

Program, December 26,1985 to December 26,1995', with respect to the

{. goveming ASME Code requirements. Parsons' Tier 1 review will formally i address the adequacy of the ISI program for the HPSI system. Parsons finally i

noted that AWO M292-12475 was issued to coat support 301088 with

-

Bitumastic, but that the pipe support drawing was not revised to note the

'

addition of the coatin *

NCR 23 NNECO prepared NCR 291225 on September 20,1991, to document that p MEPL evaluation number MP2-CD-674 had upgraded the Safety injection

-

Tank high and low level alarm switches to seismic Category I compo 3 but

that the installed instruments were originally purchased to non-QA snards, i NNECO dispositioned the NCR 'use-as is' based on the rationale that the

MEPL designated the instruments as QA for pressure boundary only, and that i the vendor proof pressure of 4500 psig exceeded the normal 250 psig system

, operating pressure. However, Parsons noted that the NCR did not establish

. that the existing switches were seismically qualified. Parsons concluded that the installed Safety Ir.jection Tank (SIT) low level alarm switches are Category

I components that have aot been seismically qualified as required by MEPL

, evaluation MP2-CD-674, and prepared DR-0139 to document this deficienc i i-

,

r- , , - , _ , - , , . . . - . - - , ,.n-,. , . . - . . . . - - , ,

.. _ _ _ . _ _ _ _ . . _ _ . . _ . _ _ _ _ . _ __ _. _. _ . _ _ _ _ _ __.._

!  !

,

l NCR 24

NCR 2g21026 was prepared on November 17,1992, to note that the

! -

Foodpump 1 A and 18 discharge piping was replaced, and that the pump casing is under the jurisdiction of ASME Section Vill. The NCR notes that the l pump casing-to-pipe welds were welded and inspected to the requirements of

ANSI B31.1, NNECO dispositioned the NCR 'use as-is'since the wolds were radiographed in accordance with appropriate weld procedures, so that the requirements of both ANSI B31,1 and ASME Vill had been met. Persons j concurred with the 'use-as-is' disposition, noting that ANSI B31.1 is the code

of choice at Millstone Unit 2 fe! welding pipe-to-pipe and/or pump casing-to-l pipe. They also noted that this code, combir'ed with radiographic testing, is the j definitive test for acceptability because of its recognized ability to identify voids,

! inclusions, porosity and fusion.

l NCR 27 l l l l NCR 294-085 documented a material discrepancy between the installed and I i design designations for the wedge material for Pacific Valve Model No, i 150-3-WE. The original design drawings specify the wedge material as A-182, l

! F6. The wedges were actually procured as ASTM A 182, FS. An engineering j i evaluation of the material differences was performed under Replacement item  !

! Evaluation (RIE) # PEG MP2E 94-00017, and the installed material was found l

suitable for the application. NNECO dispositioned the NCR 'use-as-is."

j l- Parsons accepted the 'use-as is' disposition for the valves identified, but noted

"

that the NCR incorrectly justified the material substitution for all Pacific Valves of Model 150-3-WE. Parsons noted that for the NCR to properly justify this general material substitution, the NCR needed to identify all of the affected I plant components, evaluate the material change for all of the conditions of l service to which identical valves installed in other plant systems were exposed, and to identify and revise all other valve drawings affected by the vendor

, identified change. Parsons finally noted that NNECO should update the PMMS i database to ensure that they order and use the correct valve wedge material

'

and construction. Pa soas was preparing a DR to document these discrepancie *

NCR-30

,

. NCR 296-197 documented concrete cracks in the vicinity of the baseplate for

support #301080. Design Engineering reviewed the field condition of the d

support, concluded that the cracks were original shrinkage cracks from the

initial curing process that did not affect overall structural integrity, and 3 secommended a disposition of "use-as is." Parsons accepted the "use-as-is'

disposition. but noted that the ISI Program Manual (see NCR 22) does not j reflect a significant portion of the HP31 and Containment Spray Systems in the

'

ASME Class 2 inspection requirement , ,

k 37 r

_ - - - _ _ _ _ . - _ _ , _ . _ _ _ . _ _-- - - . _ -__ - - - . , ,-,-# , ~-,~ ,..- - . - , . . .. .-.- , -

L e

NCR 32 NCR 297117 documented the classification of flow treasmitters FT 3023 and FT.3024 as Non-QA in PMMS, and noted that these instruments form a part of

' safety-related system pressure boundary. A pressure boundary failure of

-

th, 3 instruments could result in exceeding the Technical Specification roc,.. aments on HPSl/ Containment Spray leakage. An engineering evaluation noted that the subject components rweded to be Category I for pressure boundary only. The evaluation concluded that the components could withstand the required pressures, were constructed of compatible materials, and were capable of surviving a seismic event. NNECO dispositioned the NCR 'use as-is.' Parsons accepted the 'ut,e-as-is' disposition, but noted that the PMMS and MEPL databases needed to be update The team concluded that the review of NCRs provided good technical detall and thoroughness and were readily auditable to support the conclusions and DR development as appropriat Commercial Grade Dedication & Eaulvalencv %hstitution The team reviewed Parsons' Tier 3 reviews for several commercial grade dedication package documents completed by NNECO. Parsons documented these reviews via PP-03 Attachment E, and in many cases concluded that the NNECO enort was lacking in the important areas such as identification of safety function, identification and selection of critical characteristics, and acceptance methods and verification of critical characteristics. Parsons was

'

preparing DR 0076 to document their conclusion that many items of indeterminate quality had been installed in safety related applicatioris as a result of weaknesses in conducting dedication of commercial grade items. The team concluded that the review packages provided good technical detail and were readily auditable to support the DR developmen Assessments of NNECO's CMP Corrective Actions Parsons has indicated that the Tier 3 horizontal slice will review corrective actions that NNECO has documented for the commodity samples that Parsons has selected for review. Parsons stated they will review a sample of corrective actions outside the Tier 1 vertical slice review; the staff will select ths sample fer this review. Since Parsons had not yet determined which ICAVP audit plan group will conduct this review, this area was not reviewed during this inspectio Specification Revisions Design Change Notice (DCN) DM2 S-0213-94 revised Section 7.2.8.3 of AC Inverter Specification #SP-EE-308, Revision 1, to relax the extemal frequency synchronization limit from ti to t 2 pe. cent . NNECO noted that operating

.

_

_ . . .

..

__-. - _ - _ _ _ _ _ - _ - _ _ _ _ - _ _ - - - - _ - _ - - _ _ _ -

_ _ _ _ . . _ _ .. _ _ _ __ _ _ _ __ _ _ _ . . _ . _ . _ _ . _ _ _ _ _ _ _ _ _ _ _

experience had shown that the 1 percent limit was too restrictive for the inverter circuitry. A slight drift in the setpoint limits, coupled with noise on the synchronization signal, ceused a loss of synchronization condition in the inverters. This condition would initiate an inhibit signal to the static switch which would disallow a transfer to allemate source if and when required, even -

though the allemate source frequency was perfectly acceptable and within frequency limits. Parsons' review confirmed that the changes as a result of the DCN did not affect the design and licensing basis. Parsons' review also confirmed that the technical requirements were adequately conveyed from the

>

' FSAR and the design basis document into the specification and the design drawings. Partons' review of the UIR database identified UIRs 1454,1529, 1535,1538 and 1638 associated with the vital inverters and determined that none of these UIRs impacted the proposed DCN change. Parsons finally noted that the DCN is posted in the GRITS database as a pending change to

,

'

the specification anche DCN is closed. The DCN should not have been closed prior to revising the specification. Parsons was preparing a DR to document this concem.

'

Calculation Revisiens Parsons reviewed Revision 1 to Calculation No. 2 ENG-077, " Safety injection Tank Volurr) Calculation', dated 10/4/84. As stated in the calculation, NNECO revised the calculation to determine row indicated levels in percent for the then recently issued Technical Specification limits on Safety injection tank volum ' Parsons' review concluded that the Safety injection Tank high/ low levels, as measured in percent and used in various controlled plant documents, were

incorrect and t elow the currently approved Technical Specificat

on limits.

Parsons issued DR-0095 to document this concem. On December 9,1997, i Parsons curtailed review of calculation revisions as part of the Tier 3 review, because of the similarity in findings that the Tier 1 and Tier 2 groups were identifying for calculations. Parsons indicated that Procedure PP-03 will be revised to document this progrom change.

Enaineerina Work Reauests (EWRs)

EWR-033 NNECO issued EWR #M2 97-092, Revision 0, on April 4,1997 to create a DCN to change Drawing No. 25203-20122 SHT 64 to include material for studs and nuts on the 2-SW-62A strainer drain valve flange. Parsons documented several discrepancies for this review. However, NNECO canceled the EWR

, (as noted in the ' Disposition" block of the EWR) on August 8,199 yndor TechnicalInformation As documented in the NNECO document entitled " Engineering Self-Assessment of the Vendor Equipment Technical Information Program

39

-

I

.

,- - - ,~.w -.., --..r -- - - , , + ,,--,.-.._..n - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ - - - - - - _ . _ _ _ _ _ _ - -

._ _ - _ . - - _ - . - ._ _ _ . - . - - - - . _ - - _ ... - - - _ . - .- -

i

i

'

(VETIP)', AR No. 97008418, for Millstone Unit 2 dated June 13,1997. NNECO l

' has determined that the Vendor Equipment Technical information Program for Millstone Unit 2 does not conform to Ms licensing basis. As a conmuence, Parsons has not yet performed a review of a sample of vendor ts 'hnical information as part of Parsons' Tier 3 revie l IST Procedures i *

M2-00539-SWP 'B'

!

!

After a prelimirPf review of SP 2612 A and SP 2612 B Parsons decided to i

'

review Revisions 1 through 7 of Surveillance Procedure ' Service Water Pump Operability and inservice Testing, Facility 2, SP 2612 B. Parsons' selection

, was based on the following factors:

l

-

The 'B' pump's period of operation is shatter than the period of l operation of the 'A' or the 'C' pump, and would therefore be observed for shorter periods of time by plant personne l

,

i

-

When operated, the *B' pump can be aligned to service the safety i related heat sink from either Facility 1 or Fscility I i

-

The 'B' pump, which is installed on the swing bus, is probably subject l to a harsher, stagnant environment than the 'A' pump or the 'C' pum I Parsons also noted that Procedures SP 2612A and SP 2612 B contained instructions for testing three service water pumps along two different flow paths. Since there are two different flow paths invoMng servico water B pump, this was Parsons' pump of choice for review. Parsons reviewed the surveillance procedure by comparing the instructions documented in the procedure to the requ, cements of ASME CodesSection XI,1980 Edition through the Winter 1981 Addenda. Parsons is drafting a DR to document several deficiencies in the current revisions of SP 1612 A and SP 2612 ISI Proceduras

M2-RAl-00471-MT Parsons selected Procedure NU-MP-1, "Magretic Particle Procedure / Dry

- Particle Yoke Method", based on the plant's wide use of this technique for-ASME Code Class 1 and 2 items. As noted in the procedure, the procedure is used to detect discontinuities open to the surface in ferromagnetic materials using continuous magnetization. Parsons reviewed Revisions 2 through 11 of NU-MP-1 with respect to the requirements of ASME CodesSection XI and Section V,1980 Edition through tne Winter 1981 Addenda. Parsons is drafting a DR to document several deficiencies in the current revision of NU-MP- .

I

- . . _ - . - ._ _ _ . - .- - _ _. - . - - - . - - - _ .-. _ _ .---

M2 RAl-00471-PT

'

Parsons selected Procedure NU-LP 1, * Liquid Penetrant Procedure, Color Contrast Solvent Removable", based on the plant's wide use of this technique, for ASME Code Class 1 and 2 items. As noted in the procedure, the procedure is vsed to perform a color contrest solvent removable liquid penetrant

exar,ination to detect discontinuities open to the surface of nonpwous

! materials. Parsons reviewed Revisions 0 through 13 of NU-LP-1 with respect

to the requirements of ASME CodesSection XI and Section V,1980 Edition

through the Winter 1981 Addenda Parsons is drafting a DR to document

{ several deficiencies in the current revision of NU-LP- *

,

M2 RAl 00471 VT  !

!

L Parsons reviewed Procedures NU VE-1, " Visual Examination Procedure

)

'

'

(VT 1)", NU VE 2, ' Leakage Detection Examination (VT 2)', and NU VE-3, ,

" Visual Examinstion Procedure (VT-3)", because of the plant's use of all three !

procedures for ASME Code Class 1 and 2 items Visual examination method - ;

'

VT-1 is used to determine the surface condition of the part, components or

'

'

surface examined. Visual examination method VT 2 is conducted to locate i evidence of leakage from pressure retaining components, or abnormal leakage l

from components with or without leakage collection systems as required during j

the conduct of system pressure tests. Visual examination method VT-3 is performed to determine the general and structumi conditions of components and supports. Parsons performed a detailed review of the current revisions of NU-VE 1, -2 and -3 to determine the adequacy of the present procedures in

performing their intended functions. The previous procedure, which was i

replaced wnh the VE series, and rJ! Its previous retrievable revisions and j changes, was reviewed to determine if significant changes were made and if i weaknesses existed with respect to important interface and program tie Parsons is preparing a DR to document two discrepancies in the current revisions of NU VE-1, NU-VE-2 and NU-VE-3.

.

4 Conclusions - Tier 3

'

The team concluded that Parsons' sample selection for the Tier 3 review is representative of the total population of each commodity type reviewed and conforms with Parsons' program requirements for commodity type and sample size, as documented in PP-03, Attachment A. The team also concluded ti,at the quality of the review checklists that Parsons prepared and the DRs that Parsons hes documented, provide reasonable assurance of Parsons' detailed review of the sample of commodities that Parsons has selected for the Tier 3 revie .

_-__ _ _ _ - .

l Discrenancy Renorts Inspection Scope During the first phase of the inspection the team reviewed the DRs issued to dat The team concluded that the DRs were technically adequate; appeared to be properly categorized; and were identified, evaluated, and submitted within the guidelines and instructions set forth in PP-07, ' Discrepancy Reports.*

During the second phase of the inspection, the team reviewed a number of DRs with respect to technical adequacy, auditabliity, and assignment of significance leve Observations and Findings During the inspection the team reviewed the following DRs in the various disciplines:

DR 0001 incomplete Locked Valve List OPS DR 0010 HPSI System - Manual Operations of the Operator During the Course of a LOCA Mech DR 0015_ HPSI System - Instrument Lines Penetrating Containment l&C DR 001g FSAR Discrepancies l&C DR 0037 Procedural Discrepancy with System Operating Procedure OP 2308, Revision 10, Change 6, 'High Pressure Safety injection System" OPS DR 003g Post Trip immediate Actions conflicts with Those of the FSAR for LOCA Recovery OPS DR 0040 Technical Specification SRAS Actuation Setpoints inconsistent with Analysis Values l&C DR 004g Pressurizer 1600 pst Pressure Setpoint Calculation (FSAR discrepancy determined not valid because it had been previously identified by the licensee) l&C DR 0056 Auxiliary Feedwater initiation with ATWS Event Does Not Meet Licensing Basis (Significance Level 3) l&C DR 0058 AOP 2572," Loss of Shutdown Cooling" Missing Mode 4 Scenario OPS DR 006g No instructions for Performing Auxiliary Feedwater Pump Turbine Tschometer Calibration Provided in Procedure (Significance Lvl 4) l&C

--- - ______ _ -

- - . - . - .. . - _ - . . . - - - - . . -_

l

!

DR 0077 FHA and 10 CFR Compliance Review -Incorrect Emergency Lighting Exemption References Elec DR 0078 FSAR/ FHA incorrect Appendix R Exemption References Elec DR 0079 HPSI NPSHR Not Met During Accident Conditions Mech DR 0084 Procedural Inconsistency in Verifying Valve Positions OPS DR 0089 Drawing and Calculation inconsistencies Elec DR 0102 AFW System FT 5777A&B, FT-5278A&B Document Discrepancies (Significance Level 4) l&C l

DR 0103 AFW System FT 5277A&B and tT 5278A&B Labeling Discrepancies (Significar.co Level 4) l&C DR 0106 AFW System FT 5277A&B and FT-5278A&B Sensing Line issues 1 (Signi5cance Level 3) l&C DR 0115 Non-Class 1E Power Source for RG 1.97 Instrumentation (Gigr.ificance Level 3) l&C DR 0126 Non Conservative Surveillance Criteria Criterion used in T/S 3/4.5.2.a. Mech

.

DR 0127 RPS Analytical Limit Violation with the Existing Setpoint Due to Steam Ge.,erator Narrow Range Low Level Tap Span (Significance Level 1)

,

l&C DR 0135 incomplete Direction in the Fire Protection Procedure for Hot Standby

, Elec e l&C DRs

'

Except for DRs 0015 and 0049, none of the DRs samfed for l&C had been closed during the second phase ofinspection. Based on the information as presented in the foregoing DRs, the team concluded that Parsons was using a proper threshold of concem for identi*ving potential issues, was providing a detailed technical description with appropriate references to configuration documents, and was assigning an

,

appropriate significance level to the discrepancy, based on the information available at the time. The team's conclusion regarding Parsons' threshold of concem was further reinforced by informal review of additional DRs being initiated erd processed by Parsons from the Tier 1,2, and 3 review _ _ _ _ _ _ . . . J

_. - _ _ _ - _ - --

e Electrical DRs None of the DRs sampled for electrical had been closed during the second phase of inspection. A number of DRs in process were reviewed in addition to review of the electrical DRs listed in the table above. The team's review indicated that those DRs in-progress are well documented, as are those previously signed off. The staff agreed with the signi'icance levels assigned by Parson * Mechanical Systems DRs in the mechanical systems area, the DRs selected for evaluation were related to HPSI minimum flow or NPSH concems. None of these DRs had been closed during the second phase of the inspection. The purpose of this evaluation was to determine if Parsons' review provided an insightful and thorough evaluation of potential discrepancies. The team concluded that these DRs were well developed and appear to have an in-depth perspective. They were considered to be evidence of work performed by a knowledgeable and mature organization. However, the team felt that DR-0079, entitled 'HPSI NPSHR not Met During Accident Condition," did not address all of the related issues. The team's comments are provided belo The team's review identified that this DR appropriately raised a concem about the adequacy of the Millstone's Unit 2 calculations addressing this issue. However, the team's review of the subject DR and referenced information identified the following additional concems;

-

The DR was determined to be a level 3 condition based on the Parsons'

position that operator action would prevent pump failure during an accident condition. The team reviewed the information provided in EOP 2532, Revision 15, which would be used to mitigate this action. The team's review suggested that the operator actions indicated in Step 2.37.c (credited in the determination of the significance level of this DR) could result in the flow rates lower than acceptable values provided in the Figure 3.4 referenced in Step 2.3 The team's review further suggested that the directions provided in the Step 2.37.c of EOP 2532 (to throttle the HPSI flow) appears to conflict with available licensing basis; operator actions discussed in the FSAR do not address this actio Parsons' estimates of the NPSHa for the subject DR were based on the Technical Specification volume value. The !&C discipline did not validate the value to be an 'as-buitt' valu The team discussed the above concems with Pa son's staff. Parson's staff concurred with these concerns and was pursuing their resolution by performir'g additional evaluation to determine if the subject DR needs to be revised, or a new DR needs to be issue )

e- Mechanical Components DRs

The team reviewed a sample of piping and structural DRs that Parsons had prepared to date. This sample included DRs-0041,0042,0043,0087,0088,0142,0175, and 0179. These DRs either document Parsons' review of Pipe Stress Package P 48, or are generic in nature. DRs 0041,0042,0043 and 017g document a total of 11 discrepancies and deficiencies that Parsons identified during the review of Pipe Stress Package P 48. DR 0041 notes that the calculation does not address the maximum thermal service condition, that no post accident environmental data is provided, that no seismic anchor movements were considered, and that the seismic input loads are inconsistent. DR-0042 notes that the calculation does not document the source of the HPSI and LPSI pump thermal movements used in the calculation and does not reference a formal pipe break evaluation. DR-0043 notes that the calculation does not evaluate welded attachments to piping, or evaluate valve accelerations or load DR 0179 notes that the computer output is not available for the calculation, that NNECO cannot retrieve the basis for the qualification of the equipment nozzle loads, and that penetration sleeve clearances are not evaluated with respect to piping thermal displacements. DR-0087 documents Parsons' generic concem that there is no procedural requirement to ensure adequate mass participation in piping seismic analyses. DR-0088 documents the generic concem that Millstone Unit 2 does not have Design Criteria documents that detail and specify the plant licensing bases and design guidelines necessary to adequately direct and control piping ano pipe support design activities. DR-0142 documents the generic concem that welded attachments to piping are not being evaluated in the pipe stress calculations. DR-0175 documents the generic concem that valve acceleration limits and minimum permissible frequencies are not being evaluated in the pipe stress calculation The team considers the quslity of the DRs that the team reviewed provides reasonable assurance of Parsons' detailed review of the piping and equipment in the HPSI system. The team's review indicated that those DRs in progress are well documented, as are those previously s'gned off. The staff agreed with the significance levels assigned by Parsons, o Operations, Maintenance, and Testing DRs The team reviewed DRs involving operations, maintenance, and testing with respect to technical adequacy, auditability, and assignment of significance level. Eased upon the review of the identification, evaluation, and issuance of DRs by Parsons, the team noted that thresholds involving the identification by Parsons of potential concems was appropriate, and they had conducted an appropriate evaluation before issuing the DRs. Also, the team noted that the DRs considered to be closed were either (1)

considered not to be valid and therefore did not require e licensee response, or (2)

were dispositioned by the licensee, and Parsons was in agreement with the dispositio During the review of DRs in this area The team identified one concem. The concem involved the inability of the team to fully assess Parsons thoroughness of review of

-. _ _ _ _ _ _ _ - _ _ _ _ _ _ _

_ - _ _ . __ _ __ _ __ __ _ __

l

'

proposed licensee corrective. Specifically, during the review of DR 0058 (not a valid DR since the licensee previously identified it), Parsons disposition did not explicitly address t5e licensee's schedule of the stipulated corrective measures. Also, the licensee's response was silent on the scheduler aspects of the corrective actio Therefore, the team was unable to verify by reviewing the Parsons disposition if this i

aspect of determining the adequacy of corrective actions was appropriately reviewe )

Subsequent discussion with the cognizant Parsons reviewer, and a review of i information provided by Parsons (i.e., licensee AR data base information), indicated that the information on scheduler completion for the planned corrective actions was l considered. The team observed that explicit information regarding scheduler aspects of the planned licensee corrective actions should be discussed in the resolution of the OR by Parson c Conclusions The team's overall conclusion was that the DRs were technically adequate, appeared to be properly categorized, and were identified. evaluated, and issued within the guidelines and instructions set forth in PP-07, " Discrepancy Reports." Parsons was using a proper threshold of concern for identifying potentialissues, was providing a detailed technical description with appropriate references to configuration documents, l and was assigning an appropriate significance level to the discrepancy, based on the '

information available at the time. The team's conclusion regarding Parsons' threshold NAS fulther f ein IOiCed by informal review of additional DRs being initiated and procewed by Passoas from the Tier 1,2, and 3 reviews. The team also noted that

closure of tha ors by INrsons was appropriate. However, the team noted that closure staMments provided by Parsons should document the thoroughness and

iina!,,ess of correctives actions as they relate to pre- or post startup scheduler commitment Owing tne fast phase of the inspection Parsons informed the team that in performing the Tier 2 activities, their review had identified potential DRs involving inconsistencies in the UFSAR. Parsons was accumulating these discrepancies and planned to issue an integrated DR on specific UFSAR chapters or topics. Discussions with Parsons indicated that pending further review, these appeared to be document discrepancies of Significance t.evel 4. Parsons indicated that if they identified a discrepancy of a higher significance level, a separate DR would be issued upon discovery. The team found tha approach acceptabl Quiing the second phase of inspection the review of accident scenarios still wa3 in progress, hence, no DRs related to UFSAR inconsistencies were issue Exit Meetina summarv On December 5,1997, the team conducted a public exit meeting at the Parsons office in Reading, Pennsylvania. During that meeting, the team presented its inspection findings to Parsons and members of the public. Parsons acknowledged the team's finding ,

_ . . - _ _ . . . .

,

.

INSPECTION PROCEDURES USED NRC inspection Procedure 93801, * Safety System Functional Inspection *

NRC Manual Chapter 2535, ' Design Vertfication Programs *

NRC Manual Chapter 0610,"Inspectior Reports *

, .

.

47

_ _ _ _ _ _ - - - _ - - - - - - _ - - - - - - - .- - -

_ . . . .- _ _ _ .. . _ _ - _ _ _ _ _ . _ . _ .._ _ _ _ _._

l

ACRONYMS AFW auxiliary foodwater CMP Configuration Management Plan DPO riiffering professional opinion DRs discrepancy reports I ECCS emergency core cooling system HPSI high pressure safety injection

! ICAV' Independent Corrective Action Verification Program IV instrumentation & control LPSI low pressure safety injection NNECO Northeast Nuclear Energy C NRC U.S. Nuclear Regulatory Commission

>

PM Project Manual P m ns Parsons Power Group, Inc.

! PDR public document room j PP projet, procedure QA quality assurance RAI request for additionalinformation RRG Regulatory Review Group RWST refueling water storage tank l S&L Sargent and Lundy

"

SQUG Seismic Qualification Users Group SVSR System Vertical Slice Review

TAG Technical Advisory Group

. UFSAR Updated Final Safety Analysis Report

.

.

]