ML20113E297

Rev 0 to Final Rept Fsar/Sys Vertical Slice Review,Project Rept for Northeast Nuclear Energy Co

ML20113E297
Person / Time
Site:	Millstone
Issue date:	07/01/1996
From:	MPR ASSOCIATES, INC.
To:
Shared Package
ML20113E249	List: B15790, Submits Initial Results of Unit 3 Recovery Activities. Substantial Portion of Activities Completed ML20113E260 ML20113E262 ML20113E267 ML20113E281 ML20113E297 ML20113E301 ML20113E316
References
NUDOCS 9607050232
Download: ML20113E297 (93)

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FSAR/ SYSTEMS VERTICAL SLICE REVIEW PROJECT REPORT r

For Northeast Nuclear Energy Co.

Millstone Unit No. 3 FINAL REPORT Date: 7/01/96 Rev.O leR'A88?R8t888% PDR

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FSAR/ Systems Vertical Slice Review Project Report July 1,1996 Submitted By:

MPR Associates,Inc.

Yankee Atomic Electric Company Prepared for:

Northeast Nuclear Energy Company Millstone Unit No. 3 Waterford, CT

, v EXECUTIVE

SUMMARY

During May and Ame 1996, the vertical slice review team (VSRT) consisting primarily of about thirty engineers from MPR Associates, Yankee Atomic, Seabrook Station, Boston Edison, Raytheon, Westinghouse and other firms perfonned in-depth, structured assessments of eleven PRA-significant systems at Millstone Unit 3 (MP3). The reviews were part of an overall Configuration Management Plan initiated by Northeast Utilities to address design and licensing basis issues raised in several recent NRC letters.

The objectives of these reviews were to evaluate and assess (1) the accuracy and completeness of design and licensing basis documents for the selected sample of MP3 systems, (2) the conformance of the plant design, testing, maintenance, operation and configuration with licensing and design bases requirements, and (3) the effectiveness of plant programs and procedures in maintaining plant conformance with design and licensing bases. In addition, as part of the review, the applicability to MP3 of the findings and issues described in the Millstone Unit 1 (MPI) ACR-7007 Event Response Team Report was assessed.

Eleven systems were selected for review based on: 1) PRA significance,2) coverage of known outstanding issues,3) inclusion of fluid / mechanical components / systems, electrical and I&C systems, and systems important to FSAR safety analyses, and 4) engineering judgment. This selection process resulted in a representative number of fluid, electrical and I&C systems including six systems representing approximately 85% of the calculated core damage frequency (CDF) in the MP3 PRA. Five systems were added because of their impact on safety and to increase the extent of the reviews based on known issues.

In this vertical slice review of the eleven systems, over 3200 attribute checks in 26 categories of )

plant design, licensing, and operations documents and programs were examined and evaluated by six teams supported by a seventh walkdown team. The team activities and findings were documented on assessment forms and the findings were characterized either as acceptable or as discrepancies. Discrepancies were submitted for disposition by Northeast Utilities (NU). The discrepancies were categorized according to significance and prioritized for correction by NU as part of this process. Separate evaluations were also made by the VSRT of these discrepancies to: 1) identify their frequency of occurrence by document or program reviewed,2) establish their degree of correlation with the categories of deficiencies identified in the root cause analysis of MP1 ACR-7007, and 3) establish alignment with complementary reviews and programs by NU which address extent of condition and correction of programmatic deficiencies that contributed to occurrence of the discrepancy.

The VSRT supplemented the efforts described above by 1) additional reviews in selected areas to address extent of condition issues for identified discrepancies, and 2) walkdowns to assess the linkage between as-built condition and as-designed condition, design and licensing basis, and engineering programs.

The principal conclusions of the review are summarized below:

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. Correlation with MP1 ACR-7007 and NRC Inspection Findmgs l

The root cause analysis of MP1 ACR-7007, Event Response Team Report, identified six root cause categories of which two categories were investigated by the VSRT. The results of the VSRT review indicate clear linkage between MP3 and MP1 ACR-7007 in two of these categories. These cover deficiencies in documentation of the current design and configuration of the plant (the Current Configuration category) and in the administrative programs, processes and procedures for control of the plant design and i

configuration (the Administrative Programs category). Figure 2-3 of the report illustrates this correlation. Further, the characteristics of the discrepancies identified by the VSRT review in these categories align with the categories used by the NRC to summarize their findings in the March and May 1996 inspections of MP3, i.e., Licensing Basis Documentation, franslation of Licensing Basis / Design Basis (LB/DB) to Procedures / Practices, Corrective Action Process, and Engineering and Modifications.

There is, therefore, correlation between the VSRT findings and those from the NRC inspections.

It is noted, however, that it is not possible to establish a quantitative comparison of the extent of the discrepant conditions at MP3 compared with MP1, because the MP1 evaluation did not develop data similar to that developed in the MP3 vertical slice review.

Accordingly, conclusions that are drawn on the extent of discrepant conditions at MP3 are made on an absolute basis and no attempt is made to compare extent with MPl.

• Conformance of Plant Design with Design and Licensing Basis Of the more than 3200 attribute checks performed as part of the VSRT review,257 discrepancies were identified (about 8% of the total). The discrepancies range from editorial items to more significant issues which require resolution prior to restart of the plant. Tables 2-1and 2-2 and Figures 2-1 and 2-2 in the report describe the areas where discrepancies were identified by the system specific reviews and the nature of the discrepancies.

As noted previously, the priorities for resolution of the discrepancies were established by NU using an Unresolved Item Report process established as part of the Configuration Management Plan. A few of the VSRT identified discrepancies were resolved by NU without further action based on additional information and clarifications. About half of the remaining discrepancies have been prioritized by NU for correction prior to restart.

For the discrepancies which were prioritized by NU as nometart items, the VSRT has confirmed that these items do not represent issues outside the categories identified for the restart items. For the more significant discrepancies, the VSRT either has established extent of condition through internal review or has identified a complementary program i

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, c with that objective. The VSRT has also either identified the NU activity which addresses any programmatic or precedural deficiencies associated with the discrepancy or has recommended initiation of such an activity.

. Correlation of Discrepancies with NU-Upgraded Programs, Processes and Procedures NU has initiated or has committed to programs which address the extent of condition for those discrepancies which require it. Additionally, NU has initiated or committed to upgrade programs, processes and procedures to address those areas with a high percentage of discrepancies. The priorities for resolving discrepancies are consistent with their significance, and resolution of the more significant discrepancies is scheduled prior to restart. Longer term programs and follow-on actions have been initiated or are planned by NU to resolve the total population oflower significance discrepancies and trend the effectiveness of the upgraded programs and process controls. The VSRT has specific recommendations concerning the scope and schedule for these programs and has identified a few areas requiring additional effort. They are described in the .

Recommendations section (Section 3.0).

. Further Extent of Condition Reviews Several extent of condition reviews have been initiated by NU as a result of discrepancies identified by the VSRT and others. These reviews included: 1) a complete review of

. FSAR Chapter 15, Accident Analysis, to complement the VSRT review in this area,2) a complete review of Containment Isolation as a result of the Auxiliary Feedwater turbine-driven feed pump isolation valve deficiency,3) review of Electrical Separation to establish extent of condition of discrepancies found by the VSRT and by other walkdown activities, and 4) review of Electrical Calculations and Drawings to establish extent of condition of a VSRT finding. These reviews are being conducted under the direction of the NU Independent Assessment Team and documentation of the reviews in progress is outside the scope of the VSRT review.

Finally, the results and conclusions of these vertical slice reviews have identified the locations of

' discrepancies and areas where focused short term and long term corrective actions are warranted.

The results of the review also identify where NU has taken action or has action planned to address the majority of these areas. With regard to generic implications of the identified discrepancies, the results of the reviews also provide a relative measure of the extent of discrepancies by category of document and plant program. These results, however, need to be integrated with the results of the other " horizontally based" review programs, and the system readiness reviews to address fully' questions raised in the NRC 50.54(f) letter conceming the degree to which the findings in the MP1 ACR-7007 apply to MP3, and to assess readiness to restart.

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Millstone Unit 3 Vertical Slice Review Project Report Table of Contents Executive Summary 1.0 Introduction 1.1 Objectives 1.2 Goals 1.3 Methods 1.4 Organization 1.5 Governing Procedures / Oversight 1.6 Project Quality Assurance and Self-Assessment 1.7 Report Contents 2.0 Results and Conclusions 2.1 VSRT Discovery Results 2.2 Evaluation of Results of VSRT Discovery P';ase 2.3 Walkdown Results 2.4 Conclusions 3.0 Recommendations 3.1 Design Basis Documentation Deficiencies (A.1) 3.2 Key Documents (A.2) 3.3 Design Details / Implementation (A.3) 3.4 Regulatory Issues / Compliance (A.4) 3.5 Physical Configuration (A.5) 3.6 Operations / Maintenance (A.6) i

4.0 Methods 4.1 General 4.2 Selection of Systems for Review 4.3 Selection of System Scope, Review Attributes, and Documentation 4.4 Review Documentation Process 4.5 Walkdowns 4.6 Identification of Discrepancies 4.7 Review Scope Expansion 4.8 Categorization of Observations and Discrepancies 4.9 Correlation of VSRT Discrepancies with Sub-Categories 4.10 Engineering Judgment Applied to Correlation Mapping 4.11 Correlation of Discrepancies with NRC Findings Categories 5.0 References Attachments 1 Project Organization Chart 2 Participating Organization 3 NUC PI 15 " Selected Millstone Unit 3 System Reviews" 4 Project Quality Assurance Task Plan 5 Initial Scope Definition and Results Summary System Vertical Slice Review Matrices l

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Millstone Unit 3 Vertical Slice Review Project Report List of Tables Tables Title P_aage 2-1 Summary of Nature of Discrepancies 2-11 Identified in Vertical Slice Review of MP3 Documentation 2-2 Status Summary System Vertical Slice 2-15 Review Matrix 4-1 Mapping of Reviewed Documents with 4-10 ACR-7007 Categories l

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Millstone Unit 3 Vertical Slice Review Project Report ,

I List of Figures Figures Title P;!g i

2-1 Status Summary- System Vedical 2-16 Slice Review 2-2 Discrepancies by Percentage of Attribute 2-17 l Checks  !

2-3 Vertical Slice Summary - Discrepancies by 2-18 Percentage of Attributes for Subcategories Identified in MP1 ACR-7007 2-4 Discrepancy Significance Levels by 2-19 Percentage of Attributes i

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i Millstone Unit 3 i Vertical Slice Review ,

1.0 Introduction 1.1 Objectives  ;

l The vertical slice review is a two step process: discovery and evaluation. In the discovery step, structured in-depth reviews were performed of selected portions of eleven PRA-significant systems to assist Northeast Utilities (NU) in developing responses to issues raised in NRC 50.54(f) letters (References 1 and 2) concerning operation of Millstone Unit 3 in accordance with the licensing basis for the plant. In addition, these reviews addressed specific technical issues concerning plant readiness for restart. The results of these reviews were evaluated, in Step 2, to assess the completeness and accuracy of licensing and design basis documents, compliance of programs and procedures with the licensing and design basis documents, and adequacy of process controls to maintain correspondence between the licensing basis and design basis documentation and plant configuration and operations.

1.2 Goals .

Specific goals of the review were to: l l -

Assess the applicability and extent of the findings and issues in the Millstone Unit 1 (MP1) ACR-7007 Event Response Team Report (Reference 3) to Millstone Unit 3 (MP3).

Evaluate and assess conformance of the plant design and configuration with the licensing and design bases as documented in the Final Safety Analysis Report (FSAR), technical specifications and design basis documentation. The evaluation included specific areas such as component capabilities and qualifications, alarm and protective function setpoints, operating procedures, surveillance inspection and test requirements, and critical plant drawings.

Evaluate and assess the effectiveness of plant programs, procedures and processes in maintaining the accuracy and currency oflicensing basis and system l configuration documentation.

It should be noted that identification of every discrepancy in a system is not a goal of the  ;

vertical slice review. Instead the vertical slice has obtained a sufficient sample of the  ;

status of the key attributes to: 1) provide a sense of the accuracy, completeness and l consistency for key system attributes,2) identify and categorize the nature and t

contributing factors of discrepancies to help identify programmatic upgrades to prevent

future occurrence, and 3) establish the generic applicability of the discrepancies to assist in i

assessing system readiness for restart.

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1.3 Methods 1.3.1 Discovery Eleven systems were selected for review based on: 1) Probabilistic Risk Assessment (PRA) significance, 2) coverage of known outstanding issues, 3) inclusion of fluid / mechanical components / systems, electrical and I&C systems, and systems important to FSAR safety analyses, and 4) engineeringjudgment. This selection process (Reference

3) resulted in a representative number of fluid, electrical and I&C systems including six systems which appear in core damage sequences which contribute to approximately 85%

of the calculated core damage frequency (CDF). That is, if all these systems could be made perfectly reliable, the calculated MP3 core damage frequency would be reduced by approximately 85%. Five systems were added because of their impact on safety and to increase the extent of the reviews based on known issues. The eleven systems selected are:

Service Water System Quench Spray & Recirculation Spray System Reactor Trip System Auxdiary Feedwater System Including ESFAS and AMSAC Initiation Emergency AC Power System j Station Blackout Diesel Generator System 120 V Vital AC System Class lE 125 V DC Power System Control Building Filtration and Ventilation System Residual Heat Removal System: Safety Injection Mode Pressurizer Safety and Relief Valves The accuracy and conformance of system documentation with the as-built configuration and the design licensing and design bases were established by taking a vertical slice through the design and licensing documentation for several selected key attributes of each system to assess design control, configuration control and complementary programs. This effort included examining: 1) selected parts of key design, licensing, and operating and maintenance documentation and drawings, and 2) the results of application of the design and configuration control processes. This effort also included selected walkdowns of the systems to confirm configuration, particularly when changes have been made since startup, and to identify and confirm system and component attributes.

All observations of the review were documented on project assessment forms. When discrepancies were identified they were captured on screening forms to expedite turnover of potentially significant discrepancies to NU for tracking and disposition. Where significant discrepancies were concluded to have potential generic application, the range of review was expanded to establish the extent of the condition and potential generic applicability.

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1.3.2 Evaluation Statistics on total observations and discrepancies were maintained by system attribute and document / program to assist in identifying areas requiring corrective action. Discrepancies were then further evaluated to: 1) identify factors contributing to the existence of the discrepancy, and 2) categorize the discrepancy. The discrepancies were assigned to categories which evolved from the root cause evaluation ofMPl ACR-7007 to permit direct comparison offmdings for MP3 with the MPl condition report. Categories within the scope of the vertical slice review cover the current design and configuration of the plant, and the administrative programs, processes and procedures for control of design and configuration. The vertical slice review did not address the categories of management, culture, oversight and training.

1.4 Organization Attachment 1 is an organization chart for the Vertical Slice Review project. The project was managed by MPR Associates, Inc. with support from Yankee Atomic Electric Company. An ANSI Lead Auditor was provided by Yankee Atomic to provide quality assurance oversight and coordination of project activities. interfaces with NU were coordinated by the NU activities coordinator. The system reviews were performed by six teams comprised of personnel from MPR, Yankee Atomic and other engineering organizations. A seventh team comprised of designer oersonnel from Seabrook Station performed system walkdowns. A complete roster for the team is included in Attachment 2.

1.5 Governing Procedures / Oversight This effort was conducted as part of the NU Configuration Management Plan. The data and information retrieval and reporting processes were governed by NUC Project Instruction-15 (Reference 4 - also see Attachment 3). The activities of the VSRT were reviewed periodically and approved by the NU Management Quality Committee. This included approval of the initial review scope, certain intermediate steps, and the system-specific reports. All discrepancies identified by this review were also transferred to the Unresolved Item Report (UIR) system for resolution by the Plant Verification and Readiness Team (PVRT) under NUC Project Instmetion-5 (Reference 5). Walkdowns by the VSRT walkdown team were conducted in accordance with NUC Project Instmetion-4 (Reference 6).

1.6 Project Quality Assurance and Self-Assessment The specific quality processes to be implemented for the Vertical Slice Review were defined at the start of the project in the " Project Quality Assurance Task Plan" (Attachment 4). The Task Plan identified the roles and responsibilities of all project personnel and included the plan for performance of self-assessments on the various project components.

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The project took the initiative to ensure the consistency and quality of the generated product by establishing a formal training program for the project membss. The program was developed in conjunction with the Millstone Training Department and consisted of required reading and discussions with project supervision. Because of the need for the Lead Auditor to perform extensive quality and consistency reviews of data collection and database requirements, the other originally scheduled self-assessments were not performed and therefore, more in-line quality reviews were performed by the Lead Auditor as allowed by the Project Quality Assurance Task Plan.

When discrepant conditions were identified by VSRT members, formal reviews of the discrepancies by the System Team Leaders and the Lead Auditor were built into the process. For each discrepant condition identified, the reviewers assessed the quality, level of detail and accuracy of the information provided to NU to facilitate discrepancy resolution. I 1.7 Report Contents ,

Section 2 of this report presents results and conclusions from this review. This includes discussion of the linkage of findings to the MP1 ACR-7007 categories and discussion of the significance of the discrepancies identified in these reviews. Section 3 presents the recommendations. Section 4 describes the vertical slice review process in detail, including the selection of the systems reviewed, selection of the key attributes reviewed for each system, the criteria applied for expanding the range of review, and the categories for dNrepancy correlation.

There are five attachments to the repon as follows: 1) Project Organization Chan,2)

Participating Organizations,3) NUC PI-15, the station procedure used by the VSRT,4)

Project Quality Assurance Task Plan, and 5) Initial Definition and Results Summary -

System Vertical Slice Reviews. Attachment 5 consists of 11 matrices, one for each system evaluated, that summarize the initial scope of each system-specific vertical slice review and the statistics regarding attributes checked and discrepancies found.

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Millstone Unit 3 Vertical Slice Review 2.0 Results and Conclusions This section summarizes the results of the vertical slice reviews and presents the conclusions. The results of the evaluation are summarized in Tables 2-1 and 2-2, and in Figures 2-1 through 2-4 which present the results graphically.

The vertical slice review consisted of two steps, discovery and results evaluation, which were supplemented by walkdowns. These aspects of the review are summarized in Section 2.1,2.2, and 2.3, respectively. The conclusions are presented in Section 2.4.

2.1 VSRT Discovery Results The methodology for the vertical slice reviews is presented in Section 4. The discovery phase included the selection of system scope, review of attributes and documentation, the vertical slice review documentation process, system specific walkdowns, identification of discrepancies and review of scope expansion. Attachment 5 presents the matrices for each system specific review that: 1) show the scope of the review and the numbers of attribute checks made and discrepancies found for the 26 categories of documents and programs pertaining to plant design, licensing and operations / maintenance.

The majority of discrepancies identified by these reviews involved inconsistencies, misstatements and errors among the various documents such as the Final Safety Analysis Report (FSAR), Technical Specifications (Tech Specs), Design Basis Documentation Packages (DBDPs), surveillance tests, drawings and calculations. In some instances, documents were not updated to reflect changes. A little more than half of these are minor in nature, e.g., a walkdown identified that some valve identification tags did not include an

"*" in the valve identifier even though this is the standard convention for safety related valves. However, the number of discrepancies noted and some of the other higher significance items point to the need for improvements in attention to detail and engineering standards.

2.1.1 Documentation, Design and Calculation Discrepancies Examples of discrepancies in the area of documentation, design and calculations include:

Service Water System -- RSS Heat Exchanger Fouling Factor Inconsistency There is an inconsistency in the fouling factor used for calculation of the heat transfer capabilities of the RSS heat exchanger with that stated in the FSAR. The calculation is not conservative compared with the FSAR. NU Engineering is evaluating the impact of this inconsistency on the capabilities of this heat exchanger. To check the extent of this 2-1

condition, the use of fouling factors in other heat exchangers was checked and found to be consistent with industry practice and with the statements in the FSAR.

Ouench Sprav/ Recirculation Spray Systems -- Radiological Safety Evaluation for the TSP Basket Change is not Valid There have been several changes made to off-site and control room dose rate calculations as a result of modifying the containment from sub-atmospheric to pressurized and modifying the means for containment atmosphere fission product control. The latest calculation was associated with a Tech Spec change request which combined installing TSP baskets, in place of the NaOH system for pH control, with a higher containment leak rate and modified dose rate calculation. The NRC did not approve the higher containment leak rate and calculation, but approved the installation of TSP baskets. This invalidated the safety evaluation supporting the Tech Spec change and changes in the assumed leak rates. The result is that there are several inconsistencies in the FSAR and the Tech Specs on this issue. A separate review of this discrepancy was made under the direction of the Independent Assessment Team (Reference 8) and this assessment confirmed the VSRT conclusion that the safety evaluation should be revised.

Reactor Trio System -- Electrical Separation and Vendor Technical Manual Program Several areas of potential violation of requirements on electrical separation of redundant train wiring were noted. It has not been established whether these occurred as a result of a modification or existed since the start of commercial operation. NU has responded to this discrepancy by planning additional walkdowns to determine the extent of this condition. The review of this system also raised concerns with the vendor technical manual control program.

Auxiliary Feedwater System -- Setpoint Control The technical bases for safety-related setpoints generated by Westinghouse are not addressed in the configuration control program. These setpoints are documented in various Westinghouse documents which are not controlled documents. The setpoints are documented in the Tech Specs which are controlled documents.

Emergency AC Power System -- Emergency Diesel Generator (EDG) Cable Sizing Potential discrepancies in the EDG rating and the ambient temperatures used to size the EDG cabling were identified.

Station Blackout Diesel Generator -- Installation Discrepancies Several discrepancies were found in the review of the SBO diesel installation. These discrepancies included specified battery sizes / ratings different than actually installed and  !

potential electric loads not included in load lists. This modification was implemented in f

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1993 using current process controls but, despite the relatively recent completion of this modification under the reported improved MP3 modification process, there are still numerous examples ofinattention to details.

120 V Vital AC System -- Calculation Errors and Fuse Control Potential deficiencies were identified in fuse coordination calculations and between installed fuse sizes and those evaluated in the calculations.

Class lE 125 VDC System -- Operating Voltage Discrepancy Recent calculations indicate that end-of-cycle voltage may drop below that level calculated previously as the minimum voltage at the terminals of the Reactor Trip Switchgear Shunt Trip Relay sufficient to operate the shunt trip under all conditions.

Control Buildine Filtration and Ventilation System -- Surveillance Testing There have been several instances of failure of Tech Spec surveillance tests of control room pressurization. Corrective actions taken to-date do not appear to have been effective in resolving this problem. Also the decisions regarding reportability of the failed surveillance may not have been conservative and should be reviewed by management for ,

the potential need for clarification of training or expectations.

Residual Heat Removal System in the SI Mode -- Suction Relief Capacity Until recently identified by the VSRT, a concern expressed by Westinghouse in a 1990 letter to NU was not tracked by the most recent NU corrective action program (AITTS).

This concern related to the potential ofinadequate RHS suction relief valve capacity.

Pressurizer Safety and Relief Valves -- Tech Spec Issues In relation to reactor coolant pump (RCP) operating restrictions, a potential nonconservative assumption identified in 1993 was resolved by restricting the number of RCPs which can be operated at low temperature. The operating restriction was promulgated by memo instead of Tech Spec change.

2.1.2 Weaknesses in Plant Programs and Configuration Control l The findings of this review alst identified weaknesses in programs, processes and j procedures for design and confih uration control. The more important areas are the following:

Vendor Technical Manual Proaram -- Evidence of failures to control and maintain manuals current and accurate was identified in addition to deficiencies in translating maintenance manual procedures and criteria to plant procedures. A potentially significant l

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discrepancy in this area ofincorporating vendor-recommended maintenance was found in the maintenance procedures for the reactor trip breakers. Concern has been raised that the procedures do not accurately reflect the detailed procedures and criteria in the latest technical manuals for these breakers.

Corrective Action Program - Deficiencies were noted in identifying the proper corrective action to prevent recurrence of problems; implementing corrective action; reaction to identification of deficiencies from audits, inspection and assessments on a timely basis; and a tendency to re-assign and/or defer problems rather than address them directly.

Design Control /Confinuration Control -- Strong correlation was found between identified deficiencies and the programs, processes and procedures that are in place to protect the design and licensing basis.

2.2 Evaluation of Results of VSRT Discovery Phase In the evaluation phase, the results of the discovery phase were evaluated to assess the effectiveness of plant programs, processes, and procedures. in maintaining the accuracy and currency of design and licensing bases and system configuration documentation. This effort also assessed the applicability and extent of the findings and issues in the MP1 ACR-7007 (Reference 3) to MP3.

Table 2-1, Summary of Nature of Discrepancies Identified in Vertical Slice Review of l MP3 Documentation, correlates the nature of the review and a discussion of the findings by document / program. Table 2-2, Status Summary System Vertical Slice Review Matrix 1 is a compilation of the attribute checks and discrepancies from the system specific reviews.

l The vertical axis of this table lists the 11 systems reviewed. The 26 columns of the table )

represent the documentation and program areas reviewed for each system attribute. In  ;

total 3273 attribute checks were made across all systems in the scope of the venical slice l review and a total of 257 discrepancies were identified in the scope of the vertical slice review. The several rows at the bottom of this table summarize the significance level of discrepancies. Figure 2-1 is a histogram showing the distribution of attribute checks and discrepancies by reviewed document type. Figure 2-2 shows the distribution of discrepancies by document type as a percentage of the number of documents of that type reviewed. The significance levels of the discrepancies and their disposition are discussed in Section 2.2.2.

The number of attributes reviewed in each category of documentation / programs (Column

1. in Table 2-2) reflects the population of attributes in that area. For example, the larger number of attributes checked in the calculation (Column 3), drawing (Column 6), and operations / maintenance open items backlog (Column 26) categories reflects the relative high population of attributes associated with the documents / programs. In the accident '

analysis (Column 4) and the licensing open item backlog (Column 18) categories, the population of attributes is relatively low.

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Table 2-2 shows the number of discrepancies in each level of significance. Figure 2-2 illustrates the level of significance of discrepancies in comparison with the total number of attribute checks made for each category of documents / programs, and FiF ure 2-3 correlates the discrepancies with sub-categories derived from MP1 ACR-7007 (Reference 3). The level of significance was established by whether the discrepency is to be resolved prior to or after restart. As noted in these figures and the table, overall the division between restart and non-restart issues is about 50-50. Figure 2-4 illustrates this by showing the percentage of restart and non-restart discrepancies as a function of the total number of attribute checks made (a little over 3% each).

2.2.1 Correlation with ACR-7007 Categories Figure 2-3 shows the discrepancies categorized into the sub-categories of Current Configuration and Administrative Programs as derived from the Root Cause Analysis of MP1 ACR-7007 (Reference 3). The total number of discrepancies are correlated in two ways on the same figure: by Current Configuration and again by Administrative Programs.

This figure shows strong conelation with the root cause categories both relative to the overall percentage of discrepancies and the level of significance. They also illustrate that the nature of discrepancies are fairly evenly distributed across all categories. The areas of highest levels of significance (percentage in the prior to restart category) are in the Design / Design Implementation and Corrective Action Program. In the Current Configuration Category, Design Basis, Regulatory Compliance and Physical Configuration sub-categories, the discrepancies have about the same levels of significance. In Administrative Programs Design Control / Configuration Management, Licensing Commitment Tracking and Procedures discrepancies have similar levels of significance.

2.2.2. Level of Significance The significance of discrepancies identified by the VSRT was established by NU in the UIR process under NUC PI-5 (Reference 4). In a few cases the discrepancies were resolved and closed out within this process through identification of additional information or documentation. Some issues were designated as restart items and were typically dispositioned with Adverse Condition Reports (ACRs). Others were assigned lower priority and dispositioned with Action Requests (ARs), Trouble Reports (TRs) or Non-conformance Reports (NCRs). To assess the significance of these items and relate the significance level of deficiencies in each category to NU corrective action, each discrepancy was graded according to its disposition. Three grades (levels) of significance were established: ,

Ley 11 Definition Level 1 - High A significant safety issue prioritized by NU in the Significance UIR procedure as priority 1.

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Level 2 - Restart A restart item (UIR procedure priority 2) or an Item item which was dispositioned by an ACR.

l Level 3 - Non- Not a restart item (UIR procedure priority 3 or 4)

Restart Item and was dispositioned by an AR, TR or NCR.

Any item that was resolved within the UIR process without any further action, is considered to have no safety significance.

Figure 2-4 is a histogram summarizing the overall levels of significance of the i discrepancies identified by the VSRT using the levels defined above. Of the total of 257 i discrepancies, about 6% were dispositioned by the Plant Verification and Readiness Team i (PVRT) without funher action. About half of the remaining were assigned priority 3/4 and dispositioned with an AR, TR or NCR and the other half were restan items and dispositioned with ACRs. As of the date of the repon there were no issues of high safety significance (Level 1) identified as part of the vertical slice review. This distribution is considered to be consistent with the early screening of significance made by the VSRT during the system reviews which considered about 50% of the discrepancies to be potentially significant.

2.2.3 Extended Reviews - Extent of Condition Additional extent of condition reviews have been initiated as expansions of the VSRT under the direction of the NU Independent Assessment Team (IAT) as follows:

Containment Isolation A complete review of all containment isolation valving was conducted as a follow-up to a problem identified with containment isolations valves in the Auxiliary Feedwater System.

Electrical Separation Walkdown As noted above, the VSRT identified during walkdowns several areas of poteatial violation of electrical separation criteria. Accordingly, NU is planning a completc walkdown of Class IE panels.

Electrical Calculations and Drawings As a result of the VSRT identification of several discrepancies in electrical ,

calculations and electrical one-line drawings, NU is planning a complete review of l electrical calculations and drawings under the direction of the NU IAT. These  !

reviews are in progress and the level of significance of discrepancies identified from these reviews is unknown. In addition, NU engineering is reviewing and resolving discrepancies identified to-date.

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FSAR Chaoter 15 Design Basis Review 1

NU initiated a comprehensive review of the MP3 safety analysis provided in l

Chapter 15 of the FSAR. The review has been completed and a preliminary repon has been prepared which documents the results of the review.

These additional extent-of-condition reviews have identified two potential concerns related to requirements on separation of redundant train electrical wiring and the potential for concrete at the containment penetration for the RHS discharge lines to the cold legs to i experience higher than design temperatures. NU is conspleting the operability  !

determinations and other reviews of these issue 1

2.3 Walkdown Results The VSRT walked down attributes from twemy-five Plant Design Change Records (PDCRs) to assess the linkage between the as-designed and the as-built condition of the plant. Thineen PDCRs were considered satisfactory by the VSRT. The remainder were generally satisfactory, but had a few minor discrepancies. Because the number and significance of the discrepancies was small in relation to the number of correct attributes, {

the overall coaclusion is that the completeness of the PDCRs is satisfactory and there is good linkage between the as-designed and the as-built condition of the plant.

The VSRT walked down physical plant characteristics, data, and attributes to assess the linkage between the design and licensing bases and the as-built conditions. The VSRT attribute walkdown identified a concern regarding electrical separation in cabin?s installed prior to commercial operation. To determine the extent of this issue, NU has initiated additional electrical walkdowns that will be completed prior to restart. Apart from the electrical separation issue described in Section 2.2.1, the overall conclusion is that there is good linkage between the design and licensing bases and the as-built conditions.

In the process of walking down the PDCRs and the system-by-system attributes, the VSRT also observed physical plant characteristics related to the Engineering Programs to confirm the linkage between the Engineering Programs and the as-built conditions.

Attributes from nine of the nineteen Engineering Programs were assessed. The discrepancy in electrical separation discussed above is the only significant discrepancy from the Engineering Progre.ms review.

During the walkdowns discussed above, the material condition of the plant areas and systems was observed. The overall conclusion is that the material condition of the plant is acceptable. However, while there were numerous areas that were considered to have a good to very good material condition, there we-a also some areas with material conditions that were unsatisfactory (missing insulation. od k iks, boric acid indications). This conclusion is only briefly noted because the review of the unit's material condition was not the primary focus of the VSRT walkdown team, but is within the scope of the System Readiness Teams.

2-7

l .

l 2.4 Conclusions .

t l

2.4.1 Correlation with ACR-7007 and NRC Inspection Findings j The root cause analysis ofMP1 ACR-7007, Event Response Team Report, identified six ,

root cause categories as follows:

- Current Configuration I

- Administrative Programs Trainins

- Culture l l -

Management j l -

Oversight  !

I The VSRT invstigated for first two categories in detail. The results of the VSRT review I indicate clear linkage between MP3 and MPI ACR-7007 in these two root cause ,

categories. These cover deficiencies in documentation of the current design and  !

configuration of the plant (Current Configuration category) and in the administrative l programs, processes and procedures for control of the plant design and configuration (the i Administrative Programs category). Figure 2-3 of the report illustrates this correlation.  ;

Further, the characteristics of the discrepancies identified in these categories align with the categories used by the NRC to summarize their findings in the March and May 1996 l inspections of MP3, i.e., Licensing Basis Documentation, Translation of Licensing i Basis / Design Basis (LB/DB) to Procedures / Practices, Corrective Action Process and Engineering and Modifications. There is, therefore, correlation between the VSRT  !

findings and those from the NRC inspections. j i

It is noted, however, that it is not pos:ible to establish a quantitative comparison of the  !

exteut of the discrepant conditions at MP3 compared with MP1, because the MP1 evaluation did not develop data similar to that developed in the MP3 venical slice review. ,

Accordingly, conclusions that are drawn on the extent of discrepant conditions at MP3 are  ;

made on an absolute basis and no attempt is made to compare extent with MPl.

2.4.2 Conformance of Plant Design with Licensing and Design Bases  !

Of the 3273 attribute checks performed as part of the VSRT,257 discrepancies were  !

identified (about 8% of the total). The discrepancies range from editorialitems to more i significant issues which require resolution prior to restart of the plant. Table 2-1 and l Figures 2-1 and 2-2 in the report describe the areas where discrepancies were ioentified by j the system specific reviews and the nature of the discrepancies.

l As noted previously, the priorities of the discrepancies were established by NU using an l l Unresolved Item Report (UIR) process established on part of the Configura. tion i Management Plan (CMP) (Reference 9). A few (about 6%) of the VSRT-identified l 2-8 i

4 t

discrepancies were resolved by NU without further action based on additional information 4

and clarifications. About half of the remaining discrepancies have been prioritized by NU ,

~

for correction prior to restart because they relate to the conformance of the plant design with the licensing and design basis.

4 For the discrepancies which were prioritized by NU as non-restart items, the VSRT has confirmed that these items do not represent issues outside the categories identified for the restart items. For the more significant discrepancies, the VSRT either has established extent of condition through internal review or has identified a complementary program with that objective. The VSRT has al 3, ;ither identified the NU activity which addresses any programmatic or procedural defi.' acies associated with the discrepancy or has recommended initiation of such an activity.

2.4.3 Correlation of Discrepancies with NU Upgraded Programs, Processes and Procedures NU has initiated or has committed to programs which address the extent of condition for those discrepancies which require it. Additionally, NU has initiated or committed to upgrade programs, processes and procedures to address those areas with a high percentage of discrepancies. The priorities for resolving these discrepancies are consistent '

with their significance, and resolution of the more significant discrepancies is scheduled prior to restart. Longer term programs are follow-on actions initiated or planned by NU to resolve the total population oflower significance discrepancies and trend the effectiveness ofthe upgraded programs and process controls. Section 3.0, Recommendations, discusses these short term and long term programs in more detail and makes recommendations for completion and trending of the effectiveness of these plans.

2.4.4 Further Extent of Condition Reviews Several extent of condition reviews have been initiated by NU as a result of discrepancies identified by the VSRT and others. These reviews included: 1) a complete review of FSAR Chapter 15, Accident Analysis to complement the VSRT review in this area,2) a complete review of Containment Isolation as a result of the Auxiliary Feedwater turbine-driven feed pump isolation valve deficiency,3) review of Electrical Separation to establish .

extent of condition of discrepancies found by the VSRT and by other walkdown activities, and 4) review of Electrical Calculations and Drawings to establish extent of condition of a VSRT finding. These reviews are being conducted under the direction of the NU Independent Assessment Team and documentation of the reviews in progress is outside the scope of the VSRT review.

2-9

l I

4 2.4.5 Generic Implications I

Since this vertical slice review was limited to eleven systems and to only a sampling of attributes of each of these systems, it is not sufficient to establish a complete assessment of the status of the plant design and licensing bases and plant physical configuration.

Although the VSRT results highlight the categories of deficiencies and provide a relative j measure of the extent of discrepancies, the vertical slice reviews do not in themselves l completely address the generic implications of the identified deficiencies on the general state of design, design basis and licensing basis for restart. Accordingly, the VSRT resiew alone does not address the NRC question regarding the degree to which the identified deficiencies extend to MP3. For a complete assessment, the information and data developed in these vertical slice reviews are being be integrated with the results from the other " horizontally based" review programs, system readiness reviews and the " work off" t of the higher significance issues, to address this aspect of the 50.54(f) letters. This will also require initiation of follow-on corrective actions which will resolve the total population oflower significance discrepancies and trend the effectiveness of the upgraded programs.

4 l

2-10

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

1 Table 2-1 Summary of Nature of Discrepancies Identified in Vertical Slice Review of MP3 Documentation No. Document Nature of Review Discussion of Findings 1 Corrective ACR's, PIR's, NCR's, AR's, TR's, etc. These discrepancies were deficiencies in scope Action Program which applied to the specific systems and of the ACR and its recommended corrective components under review were examined action, excessive time periods before for appropriate and timely action. implementing action and ineffective corrective action. >

2 Codes and Conformance with the applicable industry Only one discrepancy was identified in Standards codes and standards which apply to the Auxiliary Feedwater - a reference to a HELB systems as indicated in the FSAR and manual was incorrect.

other NU commitments was evaluated.

3 Calculations Calculations were reviewed for The identified discrepancies include errors or completeness, accuracy and consistency incorrect assumptions in the calculations, ofinputs and assumptions with design inconsistencies between the calculation inputs and licensing basis documentation. and assumptions and the FSAR, control and tracking problems and missing or incomplete calculations. The system reviewers attributed these problems to inattention to detail and incomplete engineering.

4 Accident Consistency was checked between the The relatively high percentage of Analyses functional characteristics of components discrepancies to attribute checks obtained in and systems described in other design these reviews reflects the low number of basis documentation and the assumptions attribute checks made, t' sed for these characteristics in the FSAR Chapter 15 analyses.

5 Vendor Appropriate use of vendor information in The majority of discrepancies in this area were Information developing procedures and maintenance related to problems with control and requirements, control, currency and application of vendor technical manuals and accuracy of vendor technical manuals, technical information bulletins, missing control and distribution of vendor vendor technical manuals and translation of technical bulletins and supply of vendor vendor requirements into procedures.

calculations were evaluated.

6 Drawings Consistency among supporting Discrepancies included editorial problems and documentation, the actual plant omissions on P&ID's, e.g., valve positions, configuration and drawings was missing notes, inconsistent data and evaluated. inconsistencies with other drawings showing the s:une components, and several inconsistencies in electrical one-line diagrams.

7 Specifications Consistency of the specified functional Discrepancies included failure to update requirements and design criteria with the specifications when changes are made to the design basis, completeness of the system, missing specifications covering specifications and conformance of specific design issues, e.g., electrical supplied equipment with the specification separation, setpoint calculation, and were evaluated. inconsistencies between specification and installed equipment.

2-11

Table 2-1 Summary of Nature of Discrepancies Identified in Vertical Slice Review of MP3 Documentation No. Document Nature of Review Discussion of Findings 8 System Consistency of the system descriptions The teams found system descriptions have not Descriptions w th the as-built design and requirements been updated since construction and were as s+ated in design basis documentation. never approved documents. As a result, they A few checks were also made of training were not reviewed in detail since the manual accuraev. information in them is obsolete.

9 DBDP's Consistency and accuracy of the DBDP's The discrepancies identified failures to update with the as-built configuration, FSAR, the DBDP when changes were made to the tech specs, procedures, etc., were system, errors, inconsistencies with other reviewed. documents or drawings and editorial problems.

10 Equipment List Accuracy and completeness of the The identified discrepancies included missing equipment lists with the as-built and incorrect information. ,

configuration, FSAR, tech specs, and I vendor information were reviewed.

I1 Change Reports PDCR's, DCN's, PA's, TSCR's, Over 40 change reports were reviewed by all including 50.59 FSARCR's, CCN's, etc. were reviewed teams. The discrepancies with the change Analyses for accuracy and completion, including reports typically involved failure to ensure that review of 50.59's where completed in all related documentation was updated and association with the change. impact on other systems or programs established, inconsistencies with specifications and possible inappropriate use of a lower level procedure, e.g., an RIE in place of a PDCR.

About thirty 50.59 analyses were reviewed as part of this effort. Four discrepancies were identified. These relate to incomplete consideration of a!! factors and failure to justify not performing an analysis.

12 Design Open The VSRT reviewed those items Very few discrepancies were identified in Items Backlog identified in the close out of critical review of these backlog items. The identified design backlog items. The VSRT also discrepancies concern failure to close out reviewed lists of backlog items for system change reports on modifications that are changes since startup. complete and open documentation on equipment that is no longer installed.

13 FSAR Accuracy and consistency of the FSAR A significant number of discrepancies were ,

with other design and licensing basis identified. The majority of these were minor documentation, drawings and procedures in nature usually reficcting failure to were reviewed. completely update the FSAR as a result of a change, inconsistencies between sections of the FSAR, or inconsistencies between the FSAR and other documentation or drawings.

The more significant discrepancies include inconsistencies between sections on functional requirements of systems, inconsistencies in setpoints between the FSAR and tech specs and inconsistencies on design requirements with other documents and specifications.

I I

l 1

2-12 )

l

Table 2-1 Summary of Nature of Discrepancies Identified in Vertical Slice Review of MP3 Documentation No. Document Nature of Review Discussion of Findings 14 Technical Accuracy and consistency of the technical Minor discrepancies include minor Specifications specifications with other design basis and documentation errors or omissions, questions licensing basis documentation and other or clarifications. More significant plant documentation, drawings and discrepancies include inconsistencies with procedures were reviewed. other design basis documentation and questions on interpretation.

15 Licensing Adherence, tracking and completion of Discrepancies identified failure to fully Commitments licensing commitments were reviewed. implement corrective action as a result of NRC findings and actions, inadequate tracking of commitments and potential failure to meet general design criteria, e g., separation.

16 Audits, The actions taken to address findmgs and Only one discrepancy was found in the Assessments and meet commitments were reviewed. Auxiliary Feedwater resiew - NRC Inspections concurrence with NU's position on RG 1.97 deviations was not documented.

17 GL's, IN's, IE Tracking, determinations of applicability Performance in this area was considered Bulletins, etc. and completion of required actions were acceptable. The discrepancy involved a failure reviewed. to meet a commitment to inspect the TDAFP internals every five years. See also No. 20 in this table.

18 Licensing Open A review was performed by others of all No discrepancies were identified in review of Items licensing open items. Those items which these items.

covered the systems under vertical slice review were also reviewed by the VSRT.

19 Procedures Accuracy and consistency of translating Discrepancies identified omissions, improper design basis and licensing basis references, inadequacies, errors and I l

requirements into procedures were inconsistencies with other documentation in reviewed. the procedures.

20 Surveillance Accuracy and consistency of the Discrepancies include an incomplete GL 89-13 Tests and surveillance tests and inspection program, inconsistencies with design basis Inspections procedures and the frequency of the tests documentation, incomplete or unclear and inspections with design and licensing procedure requirements and acceptance basis requirements were reviewed. criteria.

p 21 Operator The operstor burden list and the main Timeliness of resohing operator burdens was Burdens and control board were reviewed. questioned, labeling and instrument indication Main Control problems on the MCB were identified.

Board Deficiencies

)

i 2-13

i Table 2-1 Summary of Nature of Discrepancies Identified in Vertical Slice Review of MP3 Documentation No. Document Nature of Review Discussion of Findings l 22 Temporary Mods Temporary modifications and lifted leads, One discrepancy was noted in this review.  ;

including jumpers and bypasses were reviewed.

LL, J & B Note that the problem with the bypassjumper i' on the SW booster pump was ident;fied by others. This deficiency was reviewed along  !

with the complete NU bypass jumper program.

No problems were identified with this program.

A concern was raised with the corrective i action for the booster pump bypass jumper problem. This was captured under Corrective l Action Program (column 1), Senice Water l system.  ;

23 Walkdowns Walkdowns were conducted of each The majority of the discrepancies identified in  ;

system under review, to verify completion the walkdowns involved material condition ,

of PDCR's assigned by the SRT and to problems, missing labeling and inconsistencies i examine configuration issues related to in nameplate or identification data with design  ;

the 19 Engineering Programs at NU. documentation and drawings.

24 Inteniews Several inteniews were conducted with No discrepancies were identified as a result of i Engineering, Operations and the inteniews. The results of the inteniews  ;

Maintenance personnel as part of the were used to focus and expand the system l y iews. reviews.

25 Preventative Accuracy and completeness of translation Discrepancies included failure to effectively i Maintenance of vendor reaf irements into maintenance include detailed procedural requirements and  ;

requirements and procedures was criteria, part replacement and maintenance reviewed. completion, schedule deficiencies and an ,

identified need in the 120 V Vital AC system to add ground detection circuitn'. j 26 Operations and Review of open AWO's and operations Timeliness of the closure of open work orders  !

Maintenance open items that pertain to the systems was questioned.

Open Items under review.

l I

1 l

i I

2-14 i

1

Frtes TABLE 2-2 .

STATUS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX

~hstem Name Design L6 censing Operations & Maintenance 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

a. ass ne es c sm m m ma e== t==

e e e* e em t, E e

ca > gum a h.e W.nde Sy.na. hhg it Tk C Wh E est ma R.n. h> f.W. .n. RICs tuh.bg M hm Pe t

.m com. a == o s o esop. a t. ea se. e.a=. enan s c. e===, e == eu. u. n o an e Sum Sennce Water Attribute Ctmecks 2 10 49 5 7 47 13 1 12 32 to 20 5 20 20 11 5 16 14 2 3 11 10 2 12 339 Total Dtscrepancies 1 1 2 1 2 2 2 1 1 1 14 QSS/RSS Attnbute Checks 14 5 26 5 10 31 11 19 22 2 21 23 38 25 3 50 97 8 9 37 8 4 14 8 7 299 794 Total Demer.as 4 3 1 1 1 3 3 2 3 2 5 28 Reactor Trip Attnbute Checks 22 2 52 22 22 13 21 5 30 2 44 21 26 9 3 1 28 9 9 2 343 Total Dimer.as 1 7 1 2 1 4 1 2 19 Aux. Fowater. vnth Attribute Checks 21 24 47 9 28 124 24 9 14 4 36 16 27 12 15 7 18 4 22 20 3 24 17 5 3 533 ESFAS & AMSAC Total Diwesues 1 1 8 1 3 4 3 1 1 2 8 2 1 1 1 2 3 2 4 2 51 Emergency AC Attnbute Checks 12 9 1 1 51 11 1 3 2 9 2 11 5 15 3 3 139 Power Total Discrepancies 5 2 4 1 2 1 15 Class 1E 125 VDC Attribute Checks 2 10 5 12 6 1 3 2 9 5 4 1 11 4 2 2 79 Power Total Discrepancies 7 2 1 2 1 1 14 SBO Diesel Attribute Checks 2 7 8 4 10 1 4 5 6 1 9 7 1 1 12 8 1 5 t 2 79 Generator TotalDewc des 3 2 2 2 1 1 1 1 13 120V Vital AC Attnbute Checks 6 3 14 3 1 1 1 1 2 1 1 2 1 1 1 39 Total Discrepancies 6 1 2 1 1 1 1 1 1 1 1 17 Cbt. Bldg. Filtration Attribute Checks 28 22 50 2 4 25 22 20 17 4 18 2 66 28 22 14 21 13 9 12 5 3 20 3 6 40 476

& Ventitation Total Descrepancies 4 to 1 3 1 5 2 13 1 3 1 2 1 1 4 1 53

• 22 2 4 2 15 11 15 2 28 6 11 17 30 4 36 63 279 Residual Heat Attnbute Checks 1 1 1 1 1 1 Removal Total Discrepancies 1 2 1 1 1 3 1 s is PORV & Code Attribute Checks 2 2 24 2 25 3 6 1 3 1 16 10 5 4 19 15 2 2 2 4 1 3 152 Safety Valves Total Discrepancies 1 4 0 3 4 1 2 15 Sum Attribute Checks 67 102 231 27 142 357 129 68 118 27 141 56 254 96 133 97 173 30 152 132 25 14 142 61 75 424 3273 Sum Discrepancies 11 1 47 4 18 13 8 2 15 2 11 2 40 11 10 2 1 0 11 8 4 1 26 0 8 1 257 Percentage Discrepancies 16 % 1% 20 % 15% 13% 4% 6% 3% 13% 7% 8% 4% 16% 11 % 8% 2% 1% 0% 7% 6% 16 % 7% 18% 0*4 11 % 0% 8%

StGNIFICANCE CLASSIFICATION Restari ttems 7 0 27 3 5 7 3 0 6 0 6 0 12 7 8 2 1 0 3 1 1 1 12 0 3 0 115 NonGestart items 3 1 19 0 13 4 5 2 8 2 3 2 27 4 2 0 0 0 4 7 1 0 12 0 5 0 126 Disposition Without Action items 1 0 1 1 0 2 0 0 1 0 2 0 1 0 0 0 0 0 2 0 2 0 2 0 0 1 16 2-15

7/1/96 l

- l l

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7/1/96 FIGURE 2-2

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E Percentage Discrepancies E % Restart items 0% Non-Restart items 2-17

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7/1/96 FIGURE 2-3 Vertical Slice Summary - Discrepancies by Percentage of Attributes for Subcategories identified in MP1 ACR-7007 Current Configuraten Adnurnstratrve Process and Prw=es Category 1 2 3 4 5 6 7 8 9 10 11 Desagn Correctrve Lecensmg Findings Design Basis Key Document Design Opera' ions Controt/Config Maintenanos Action Comma Procedures Manan Program Tracking Total Attribute Checks 570 384 597 500 400 822 1748 773 164 336 252 "g g']~* 67 15 79 24 39 33 174 43 13 11 16

• 8* 11.8% 39% 13.2% 48%

Di-. y.. ~-. 9.8% 4.0% 10.0 % 5.6% 7.9% 3.3% 6.3%

SGNIFICANCE CLASSIFICATION HS" 8N 6'8 0  ; O O O O O O O Rems O O

"*

• 0.0% 0.0% 00% 0.0% 0.0% 0.0% 00% 00%

3 g 0.0% 00% 0.0%

Restart Items 25 7 38 18 18 9 76 16 9 9 5

% Restart hems 4.4% 1.8% 6.4% 3.6% 4.5% 1.1% 43% 2.1% 5.5% 2.7% 2.0%

NorWestart hems 40 6 39 5 17 19 90 24 3 2 7

% Nordestart herns 7.0% 1.6% 65% 1.0% 4.3% 2.3% 5.1% 3.1% 1.8% 06% 2.8%

2 2 2 1 4 5 8 3 1 0 4 Action hems 0.4% 05% 0.3% 0.2% 1.0% 0.6% 0.5% 0.4% 0.6% 0.0% 1.6%

Current Configuration Admernstrative Process & Procedures 14 0 %

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. Millstone Unit 3

. Vertical Slice Review I i

3.0 Recommendations This section includes the recommendations of the VSRT for resolution of the discrepancies. Also included are the NU activities and commitments for the upgrade of I programs, processes and procedures that address extent of condition and corrective ]

actions for discrepancies identified by the VSRT. i

! This section is organized by the sub-categories of ACR-7007 Current Configuration (sub-categories A.1 through A.6 as defined in Section 4.8) and correlates the discrepancies to these sub-categories. The resulting correlation of discrepancies to Administrative Processes and Procedures is shown in Figure 2-3. For convenience, this section also shows the document column numbers from the VSRT attribute matrices that apply to the sub-categories of Current Configuration.

3.1 Desien Basis Documentation Deficiencies (A.1)

FSAR, Technical Specifications & DBDP Discrepancies (columns 13,14,9) >

The FSAR and Technical Specifications discrepancies identified by the System Readiness Reviews, the FSAR/ Testing Procedure Validation Review and the Vertical Slice Reviews have been prioritized.

Many of the FSAR editorial discrepancies identified by the VSRT appear to be the result ,

ofinadequacies in the procedures and implementation of the procedures for FS AR update.

For example, under past procedures, once a change request (FSARCR) was submitted there was no requirement for review of the final revision by the initiator of the request.

Examples were found where the FSAR was not updated fully in accordance with the change request. This procedure has been updated at MP3 to ensure that the initiator is involved fully in the FSAR update.  ;

i In the CMP, MP3 committed in the near term to complete a FSAR review and update, and in the longer term to develop Design Basis Documents (DBD) for key systems. In conjunction with the FSAR and DBD activities, NU is also planning a review of Tech Specs for accuracy and completeness.  ;

)

VSRTRecommendation No.1: Complete the FSAR update, the development of DBD's and the review of Tech Specs.

VSRTRecommendation No. 2: Establish performance indicators and trend the effectiveness of the FSAR update procedures.

3-1

Codes and Standards (column 2)

The VSRT did not identify significant discrepancies or large numbers of discrepancies in this category.

3.2 Key Documents (A.2)

Drawings (column 6)

The number and significance level of drawing discrepancies identified in the VSRT was relatively low. However, a number of these discrepancies were identified in ops critical electrical drawings. The Deficiency Review Team has also highlighted the issue of accuracy of the ops critical drawings and recommends correction ofidentified discrepancies prior to restart. The VSRT concurs with this recommendation.

In a related area, an extended review of electrical drawings and calculations is planned by NU to establish extent of condition of discrepancies noted in these calculations and drawings in the VSRT review.

VSRTRecommendation No. 3: Correct the ops criticaldrawings.

VSRTRecommendation No. 4: Complete the extendedreview ofelectrical drawings andcalculations.

Equipment List (column 10)

A review of the Materials, Equipment and Parts List is being conducted prior to restart.

The discrepancies identified in the equipment list category by the VSRT were not significant.

VSRTRecommendation No. 5: Correct the identifieddiscrepancies andcomplete the review of the Materials, Equipment and Parts List.

3.3 Desien Details / Implementation (A.3)

Calculations (column 3)

About half of the discrepancies identified in the calculation category were associated with the electrical calculations. As noted in Section 3.2, a broader scope review of the electrical calculations is planned by NU. The results of this review will be used to determine extent ofcondition.

The assessment of the VSRT on the contributing factors for the discrepancies with the calculations focused on inattention to detail and incomplete engineering. To address these characteristics, NU has initiated an Engineering Excellence Program for all five nuclear 3-2

units with the objective of raising the standards of engineering performance. Specific performance objectives and criteria have been defined along with key performance l indicators to track adherence to standards and appropriate training modules have been

( developed. The effectiveness of this program will be tracked over the long term using the l individual and department performance indicators.

l VSRTRecommendation No. 6: Issue the Engineering Excellence Program and keyperformance indicators. Track the effectiveness of the Program.

Accident Analyses (column 4)

A review of the FSAR Chapter 15 was performed under the direction of the Independent Assessment Team. All discrepancies identified by this effort and by the VSRT will be dispositioned and tracked for completion in the AITTS. In addition, training is planned to

! improve Engineering personnel's understanding and facility with the Chapter 15 e.nalyses.

VSRTRecommendation No. 7: Resolve the discrepancies in Chapter 15.

VSRTRecommendation No. 8: Complete the training on Chapter 15.

i i Vendor Information (column 5) l Deficiencies in the vendor information control and tracking program at MP3 have been identified in other reviews in addition to the VSRT. Accordingly, NU has initiated a vendor technical information control and tracking program upgrade. Prior to restart, the vendor information associated with Generic Letter 90-03 systems will be reviewed and upgraded as necessary to meet industry standards. These vendor manuals will be checked l for currency and accuracy and the appropriate plant equipment maintenance and test i procedures will be checked against thest aanuals. In addition the vendor manual and technical information control and distribution procedures are being updated and a formal program will be established and maintained over the longer term. The vendor technical information discrepancies identified in the VSRT will be corrected as part of this process.

VSRTRecommendation No. 9: Review and upgrade the vendor information associated with GL 90-03, and check the testprocedures against the manuals.

VSRTRecommendation No.10: Establish aformalprogramfor control and distribution of vendor manual and technical information.

VSRTRecommendation No.11: Correct the discrepancies in vendor technical information identified by the VSRT 3-3 l

Specifications (column 7)

The discrepancies in specifications identified by the VSRT concerned inadequate installation specifications, e.g., electrical separation, instrument tubing support criteria, setpoint calculation requests, and failures to update specifications when components were installed, upgraded or replaced, or when system changes were made that affected the environmental or operating conditions for the equipment. Review of the potential contributing factors for these discrepancies revealed that there is currently no procedural requirement to update equipment specifications. These are typically pre-commercial

operation architect engineer specifications that in most cases have not been converted to NU specifications. The VSRT considers that maintaining these specifications current is an important facet in configuration management. Accordingly, it is recommended that procedures be developed to bring these specifications up-to-date and maintain them current as changes are made in the plant.

VSRTRecommendation No.12: Developprocedures to bring the equipment specifications up-to-date and to maintain them current and upgrade inadequate specificationsidentifiedby VSRT.

System Descriptions (column 8)

System descriptions are not maintained current and are not controlled documents.

Accordingly, they were not reviewed for discrepancies in the VSRT review, but were used for general system information.

3.4 Renulatory Issues /Com oliance (A.4)

Corrective Action Program (column 1)

The VSRT's concerns with the effectiveness of the corrective action program at MP3 have been raised in other reviews, including recent NRC inspections and letters.

Accordingly, NU has initiated a complete review and upgrade of the corrective action program. A five unit common corrective action manual is in development. Review of open ACRs is part of the Critical Backlog review and closcout program. NU QAS has performed an audit on the Connecticut plants' ACR processes and will be performing an evaluation of closed ACRs at MP3 to assess generic implications ofidentified deficiencies.

The program upgrades address the issues of root cause evaluation, extent of condition, timeliness and effectiveness ofimplementing corrective action. Tracking of corrective action program activities is part of the upgrade program and measures of effectiveness of the program will be taken and evaluated by NU and the NRC prior to restart. These were

issues also identified by the VSRT. Finally, training modules are being developed for the Management Review Team (MRT) process and for general personnel use of the corrective action program.

3-4

l VSRTRecommendation No.13: Complete thepve unit common corrective action manual.

VSRTRecommendation No.14: Perform a review ofopen ACRs andan evaluation ofclosed ACRs at MP3 to assess generic implications ofidentiped depciencies.

1 VSRTRecommendation No.15: Develop training modulesfor the MRTprocess l andfor the corrective actionprogram. I Licensing Commitments (column 15)

The discrepancies in this category comprise questions on tracking and completing {

commitments to the NRC and compliance with GDCs, specifically, in the areas of l

electrical separation and single failure criteria. ' An extent of condition review of electrical i separation deficiencies in all Class IE systems will be completed by NU. These reviews l will address the issues raised in the VSRT. The single failure issues raised by the VSRT are not of the same significance level or extent as the separation issues and will be resolved on a case basis.. i With respect to licensing commitment tracking, MP3 licensing will initiate a review of the  ;

MP3 docket to ensure that all commitments have been identified and are either completed, in process or are appropriately tracked. In addition, the program for identifying and i tracking oflicensing commitments has been reviewed and upgraded.  ;

i VSRTRecommendation No.16: Complete the extent ofcondition review of electrical separation depciencies in Class IE systems.

l VSRTRecommendation No.17: Resolve the singlefailure issues raised by the VSRT. i VSRTRecommendation No.18: Complete the review of the MP3 docket to ensure that all commitments have been identiped andare either completed, in process or  ;

are appropriately tracked l VSRTRecommendation No.19: Establish performance indicatorsfor the i upgraded licensing commitmentprogram and trend the effectiveness of the program.

Audits, Assessments and Inspections (column 16) 1 No significant concerns were raised in the reviews of this category. Note that some of the concerns raised in the review of the corrective action program (column 1) are associated with either failure to address or timeliness ofresponse to issues raised in prior audits, 3-5

assessments and inspections. - These will be addressed in the reviews of the corrective action program discussed above.

GL's, IN's, IE Bulletins, etc. & Licensing Open Items / Backlog (columns 17,18)

(

No significant concerns were raised in these categories by the VSRT review.

l 3.5 Physical Confieuration (A.51 Change Reports including 50.59 Analyses (column 11)

This category covers PDCR's, DCN's and other change programs, e.g., FSAR changes ,

and technical specification changes. The discrepancies identified by the VSRT in these  ;

l areas involved failures to ensure all documentation was updated and impact on other .

systems or programs established, inconsistencies with specifications and possible  !

inappropriate use of a lower level procedure, e.g., a Replacement Item Evaluation (RIE), ,

in place of a PDCR. These issues are being addressed by use of the Design Control ,

Manual (DCM) at all NU units. The use of the DCM is accompanied by the development and implementation of training modules on the use of the manual to avoid recurrence of these issues.

The percentage of discrepancies identified by the VSRT in change reports was not high and impact is not significant. Additional reviews of PDCR implementation by the System i Readiness Review Teams obtained similar results. The extent of condition is considered j

to be consistent with the VSRT results.

With respect to 50.59 analyses, about 30 analyses were reviewed by the VSRT with four discrepancies identified. Three of these questioned the completeness of the review and one questioned the decision not to make an analysis for a plant change. A prior review of the 50.59 process in March 1996 by the NU Safety Engineering Group concluded that about 8% (overall),13% (MPl) of the analyses reviewed "Needed Improvement". They also concluded that the screening process for determining whether a 50.59 analysis was required was not effective. This group recommended improved training on 50.59 analyses  ;

and upgrade of the 50.59 procedures, particularly in the areas of screening. The VSRT results are consistent with these findings and the VSRT concurs with the  ;

recommendations. ,

Nuclear Group Procedure (NGP) 3.12 " Safety Evaluations" is being revised as part of the NU procedures upgrade program. NU has also initiated development of training modules i' to raise the level ofunderstanding of proper implementation of a 50.59 analysis and the j factors which dictate when such an analysis is required.

i VSRTRecommendation No. 20: Establishperformance indicatorsfor the effectiveness of the DCM and trend the effectiveness of the DCM 3 . . ._

VSRTRecommendation No. 21: Trainpersonnelon the use ofthe DCM.

VSRTRecommendation No. 22: Issue the revision ofNGP 3.12.

VSRTRecommendation No. 23: Trainpersonnel on the revisedNGP 3.12.

VSRTRecommendation No. 24: Establishperformance indicatorsfor the effectiveness ofNGP 3.12 and trend the effectiveness of the revision.

l Walkdowns (column 23)

The discrepancies found during the walkdowns performed by the VSRT involved issues

that can generally be attributed to inattention to detail by either the installation crews or by I

the engineers who prepared the original plant design documents or the PDCRs. These issues are being addressed by the use of the Design Control Manual at all NU units. The use of the DCM is being accompanied by the development and implementation of training l modules on the use of the manual to avoid minor design and installation discrepancies in the future.

Although not part of the VSRT's scope of work, the VSRT also identified inadequate i material conditions during the walkdowns. These conditions were reported in the UIR process for NU follow-up.

l The major issue identified by the VSRT walkdowns is electrical separation in cabinets installed prior to commercial operation. To determine the extent of this issue, NU has initiated additional walkdowns that will be completed prior to restart (see VSRT Recommendation No.16 above).

Design Open Items / Interviews (columns 12,24)

No significant concerns were raised in the VSRT review of these categories.

3.6 Operations / Maintenance (A.6)

Procedures (column 19) l The discrepancies in procedures principally involved failure to accurately or completely i translate requirements stated in the FSAR into testing and operating procedures. NU has

! initiated a review of consistency between the FSAR and surveillance testing procedures 2- and testing aspects of operating procedures.

Because the abnormal operating procedures and emergency operating procedures have not been upgraded since the 1990 to 1992 timeframe, the VSRT recommends that a review for FSAR consistency also be completed for the abnormal operating procedures and 3-7

emergency operating procedures to cover the complete range of discrepancies identified by the VSRT.

VSRTRecommendation No. 25: Complete the review ofconsistency between the FSAR and the surveillance testingprocedures and the testing aspects of the operatingprocedures.

VSRTRecommendation No. 26: Review the abnormal operatingprocedures and the emergency operatingprocedure:for consistency with the FSAR.

Surveillance Tests and Inspections (column 20)

None of the discrepancies identified by the VSRT in surveillance tests and inspections were designated by the UIR process as requiring correction prior to restart. Many of these involved inconsistencies between the surveillance tests and inspections and design basis documentation. As noted above, the consistency of surveillance tests and inspections with the FSAR is being checked in a complementary NU program.

One of the VSRT discrepancies in the service water system noted that implementation of that part of the GL 89-13 program which confirms the heat transfer capabilities of heat exchangers in the program was in a very early stage of development and lagging industry progress in this area. There is one heat exchanger that has been tested but the results have not been evaluated. It is recommended that the evaluation of this heat exchanger be completed and the program development be completed in Phase 2 of the CMP.

VSRTRecommendation No. 27: Complete the evaluation of the test resultsfor one heat exchanger and complete the testing of the heat transfer capabilities of the other heat exchangers in the program.

Operator Burdens and MCB Deficiencies (column 21)

All of the operator burdens and main control board deficiencies are being addressed in review and close out of critical backlog items.

Temporary Modifications and Bypass Jumpers (column 22)

All of the bypassjumpers in MP3 are being addressed in review and close out of critical backlog items.

1 Preventive Maintenance (column 25) 1 Several discrepancies in preventive maintenance identified by the VSRT were the result of incomplete engineering. These discrepancies indicate the need for more thorough interaction between the design engineering and maintenance staffs when preparing or reviewing maintenance procedures. Other discrepancies identified by the VSRT were i 3-8

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

apparently caused by inattention to detail, procedural noncompliance and human error.

Three discrepancies of a total of eight in this area will be addressed prior to restart.

VSRTRecommendation No. 28: Review the effectiveness of the prccedures applicable to the design engineering review ofmaintenance procedures. \

Operations / Maintenance Open Items (column 26)

There was only one potential discrepancy in this area, but this was subsequently clarified as not a discrepant condition.

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4 8 Millstone Unit 3 Vertical Slice Review l 4.0 Methods 4.1 General l The MP3 vertical slice review began with a scope that was initially oflimited system breadth but covered the full depth of design, licensing, documentation, testing, maintenance, operations and configuration aspects of the system related to that scope, with emphasis on changes since commercial operation. As the review progressed the scope naturally expands into additional areas to follow issues to closure. When significant discrepancies were identified the scope expansion at times required looking outside the specific system under review to others within the Project to establish extent of condition.

l The objective of the vertical slice, however, is not to identify every discrepancy or deficiency in the system. Instead the vertical slice has obtained a sufficient sample of the status of the key attributes to 1) provide a sense of the accuracy, completeness and consistency for key system attributes,2) identify and categorize the nature and l contributing factors of discrepancies to help identify programmatic upgrades to prevent l

future occurrence, and 3) establish the generic applicability of the discrepancies to assist in assessing system readiness for restart. ,

1 4.2 Selection of Systems for Review Bases for Selection - The first step in the vertical slice review was to select the systems to be reviewed. The principal criterion applied for selection was the significance of the system in core damage frequency calculations performed by the Northeast Utilities l Probabilistic Risk Analysis (PRA) Group. Reference 7 summarizes the key systems involved in those plant transients which account for 85% of the calculated core damage frequency (CDF) for internal events. In summary:

The following systems participate in transients accounting for approximately 60%

of the calculated CDF:

l - RSS/QSS, because of the critical functions of these systems in Chapter 15.6.5 LOCA

! - Service Water, because ofits supply of cooling to the RSS heat exchanger, RCP seal cooling during LOCA and SI cooling 1

4 4-1

Adding the following systems accounts for about 85% of the calculated CDF:

- Reactor Trip Breakers /SSPS, because of ATWS reactivity control

- SBO diesel as the independent air-cooled alternative to the EDG's

- Control Building Filtration and Ventilation, because ofits functions to limit Control Room dose rates and Switchgear Room cooling

- Auxiliary Feedwater because ofits role in transient operations This set was then augmented based on engineering judgment by the following systems to provide wider scope of system coverage:

- Residual Heat Removal, for its interfaceing LOCA (V Sequence)

- Pressurizer Valves, because of their role in support of mitigating overpressure transients

- 125 VDC Safety Related Batteries and Buses, because of their potential impact  !

on CDF, even though these are considered to be highly reliable  !

1

- Emergency AC Sygems at their interface with the EDG

- 120 V Vital AC System because ofits potentialimpact on CDF l 1

This set of systems and the range of attributes reviewed combine to cover the following specific objectives in the review:

I

- Chapters 3,6,7, 8,9,10 and 15 of the UFSAR are covered

- A significant fraction of the internal cut sets used for calculation of core damage frequency is accounted for based on current MP3 PRA

- Specific technical issues raised by the NRC in the 50.54(f) letters are covered Specific Systems Reviewed - Considering all of the above factors the following are the specific systems and UFSAR sections covered by the vertical slice review:

Service Water at its interface with the RSS heat exchanger, Section 9.2.1 Quench Spray and Reactor Recirculation Spray Systems, Sections 6.2.2 & 6.3, including Residual Heat Removal in the Safety Injection mode, Section 5.4.7 4 4-2 l

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- Reactor Trip Breakers and their interface with SSPS, Section 7.2  ;

- Auxiliary Feedwater including actuation by ESFAS and AMSAC, Section 10.4.9

- Control Building Filtration and Ventilation, Sections 6.4 and 9.4.1

\

l Pressurizer Safety and Relief Valves, Section 5.4.13

- SBO Diesel Generator, Sections 8.3.1.1.5, 8.3.1.1.6 & 8.3.1.1.7 125 VDC Safety Related Batteries and Buses, Section 8.3.2.1.2 120 V Vital AC Power including inverters and buses, Section 8.3.1.1.2 Emergency AC Power including interface with EDG, Section 8.3.1.1.2 1

4.3 Selection of System Scope, Review Attributes and Documentation For each system reviewed the teams first identified the specific components to be included in the review, selected key attributes to be covered in the review and then identified specific documents and programs to be reviewed for each of these attributes. These l selections were documented: (1) on simplified P&ID type sketches of the specific parts of the systems to be reviewed, (2) in matrices which cross-referenced each selected attribute with the specific documents to be reviewed for that attribute and (3) in backmp descriptions of the bases for selection of the attributes.

The scope of the system to be reviewed was selected to cover those areas identified as critical to system function in the PRA evaluations and to cover areas of known concern.

For example, those portions of the senice water system which are required to provide cooling for the RSS heat exchanger and the Booster Pump supply to the RCA/MCC cooler were included in the review. The former was selected because ofits impact on the PRA and the latter was selected because of previously identified problems with modifica-tions to the control circuitry on this pump. Similarjudgments were made for each system reviewed.

l The key attributes selected for review fall into three categories. The first includes system unique functional requirements and design bases. Examples are the flow supply requirements of the Auxiliary Feedwater system and the loading requirements of the Station Blackout Diesel Generator. The second category covers generic component or system related design issues. Examples of these are specific piping design and analysis requirements, and design, installation and testing requirements for valves and heat exchangers. The third category includes generic regulatory requirements and specifications, such as the GDC requirements, e.g., single failure, separation, redundancy, 4-3 l

programs, e.g., seismic, environmental qualification, Appendix R, and regulatory guide and generic letters, e.g., GL 89-13. The system specific matrices arrange the attributes in this order to facilitate review and cross-correlation with concern areas identified in previous inspections and ACR-7007.

Finally, each team provided a first cut estimate on the specific documents that would be included in the review, cross-referenced against the key attributes.

l In accordance with the requirements of PI-15, Reference 4, the scope of the system and l the key attributes selected for review and the attributes to be walked down were submitted l to the Management Quality Committee (MQC) for review and approval. The estimate of

[

the documents to be reviewed was also submitted to the MQC for information. The total list of document types which could be reviewed is shown on Table 2-2.

As noted, the initial selection of the specific documents to be reviewed was a preliminary assessment. The actual documents reviewed evolved as the review progressed. The specific reports generated by each team itemized all documents ultimately reviewed, cross-referenced against the key attributes. The final review matrices are contained in the specific team reports and are discussed in more detail later in this report.

( 4.4 ' Review Documentation Process l

The collection ofinformation, data and documentation as well as the results of all reviews of these items were recorded on project assessment forms (Attachment 5.2 to PI-15).

Each project assessment form was uniquely numbered and captured in a database. Each system specific report (contained in Supporting Project Documentation, Section 2, Tabs A through K) contains copies of all of the assessment forms generated in the course of the review of that system.

4.5 Walkdowns For completeness of the vertical review of the configuration management process, this l assessment also included walkiowns. All walkdowns were performed by a walkdown team comprised of four qualified and experienced designers from Seabrook Station. This team was trained to PI-4, Reference 6. Engineers from the system review teams accompanied the walkdown team on many of the walkdowns. All observations and data were recorded on VSRT assessment forms.

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The walkdowns had several objectives:

System familiarization. Familiarization tours were conducted with the members of each system review team. In these tours the engineers became familiar with the configuration of the system, examined the material condition of the system and, using the walkdown team members, collected nameplate data and confirmed various design attributes of the system.

Review the linkage between as-designed and as-built conditions. The team walked down PDCR's selected by the System Readiness Review team to confirm the linkage between as-designed to as-built conditions and to confirm the completion of the required work. In addition, the VSRT also selected additional PDCR's to augment those selected by the System Readiness Review team. The selection of the PDCR's was reviewed and approved by the MQC. A total of twenty-five PDCR's were walked down. These walkdowns were conducted to the component level where the components were accessible.

- Review the linkage between design and licensing basis and as-built conditions. During these walkdowns design and licensing basis attributes of the systems were also confirmed. Most of these attributes were part of the base plant design, i.e., the design at the time of commercial operation.

Review the linkage between the engineering programs and the as-built conditions. The ,

team walked down the as-built attributes of NU's engineering programs, such as Environmental Qualification, Appendix R, Station Blackout. These programs were walked down in two ways. First, during the VSRT system walkdowns ofPDCR's and attributes, numerous engineering program attributes were reviewed during the process of the system walkdowns. Second, program-specific walkdowns were conducted to ,

augment the thoroughness of the program walkdowns because the system reviews by  ;

themselves did not intersect with some of the programs.

4.5.1 Extent of the VSRT Walkdowns The VSRT walked down over two hundred individual components, such as pumps, valves, heat exchangers, diesel generators (EDG and SBO), MCCs, power panels, switchgear, the MCB, cabinets, instruments, cable, conduit, wire, and HVAC equipment. The physical attributes of the components that were field-verified included: nameplate data, measurements, removals of equipment, color coding of cable, identification tags, cable and wire separation, elevations, material condition, accessibility, and installation details.

An additional way to quantify the extent of the walkdowns is to estimate the number ofin-plant walkdown staff-hours by the engineering team and by the designer team. An estimated two hundred staff-hours of actual in-plant time was expended by the VSRT. In addition to actual in-plant time, the teams spent, on the average, six times the number of in-plant hours on walkdown preparations (such as selecting the attributes for field-4-5

i verification, locating and reviewing the relevant drawings, etc.) and on the analysis of the -

data gathered from the walkdown.

4.6 Identification of Discrepancies During the course of the review any unclear item or item which was suspected to be incorrect was considered a potential discrepancy and investigated until it was either resolved, e.g., by finding additional documentation or by discussions with NU personnel, or confirmed as an actual discrepancy. Examples of actual discrepancies include ,

inconsistencies in data or discussions between sections or documents oflicensing basis and design basis documentation, e.g., the FSAR, Tech Specs, DBDP's, or between these '

documents and calculations and drawings, or between drawings and the in-plant configuration. Others include surveillance test problems, incorrect calculations, material ,

condition deficiencies and process problems, e.g., vendor technical manual update, tracking ofinternal and external commitments.

When a discrepancy was identified it was noted on the project assessment form and a screening form (Attachment 5.5 to PI-15) for the discrepancy was prepared. The screening form was used to make a preliminary assessment of the significance of the discrepancy and to transmit the discrepancy for disposition through the UIR process under PI-5, Reference 5. A preliminary assessment of significance was made by the VSRT, characterizing the discrepancy as either potentially significant or not significant. This  ;

determination was initially made by the Team Leader using the three questions in the Adverse Condition Report Initiation Form, RP 4.1 which determines whether an ACR needs to be reviewed by a Shift Supervisor. The screening form was then transmitted to 3 the ANSI Lead Auditor or the Project Manager in the absence of the Lead Auditor for review of the issue. If the Lead Auditor concurred with the judgment of the Team Leader that an affirmative answer to any of the three questions was correct, the issue was considered to be potentially significant. All screening forms were then approved by the ANSI Lead Auditor and submitted for disposition by the UIR process. This process provided consistency in applying the characterization of potentially significant within each  ;

team and across the teams in the project.  ;

The distinction between potentially significant and not significant was made by the VSRT to permit expediting those discrepancies which the reviewer considered may need to be resolved in the near term. As is discussed in detail later, the actual determination of the level of significance of the discrepancy was determined by the Plant Verification and Readiness Team as part of the UIR resolution procedure (PI-5).

1 4-6 4

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y 4.7 Review Scope Expansion As noted above, the methods of ve tical slice review include a natural increase in initial I scope as discrepancies are identified and "run to ground" These are typically within the i system and either result in resolution of the discrepancy or bounding ofits scope and I

impact. In some cases, however, it may be necessary to extend the review more  ;

horizontally to establish the extent of a discrepant condition and its potential for generic  :

a applicability. This is a typical progression in a vertical slice review. These " expansions of the scope of review" were performed by all teams throughout the implementation of this project. The extent of condition and generic applicability are discussed for the major ,

potentially significant discrepancies in Section 2 of the system specific reports.

The identification of potential programmatic issues also evolved naturally from this review }

since a wide range of systems were reviewed across all engineering disciplines. For j example, certain discrepancies were found in all systems reviewed. This leads, therefore, j to a conclusion that this type of discrepancy has generic applicability. This occurs with no  ;

expansion ofreview scope.

For this review additional criteria were applied for expansion of the scope of review in the

• event significant safety or operability discrepancies are identified or ifit is considered ,

required to address a suspected process or program weakness. In this event the scope would be expanded to include additional vertical and/or horizontal reviews, as i appropriate, to further test the process weakness identified by the discrepancy. The i specific criteria for the expansion are dependent on the nature of the finding and were to  !

be determined by the review team leaders ar.d approved by the Project Manager and the i MQC, As of the date of this report, this level of scope expansion has not been entered. .

4.8 Categorization of Observations and Discrepancies The NRC 50.54(f) letter for MP3, Reference 2, referred to findings from the Event Analysis Report for ACR-7007 (an MP1 ACR). An ACR-7007 Transition Matrix was I prepared by NU which took the issues, concerns, and recommendations of the report and {

which, were put them into the following categories:

Current Configuration

- Administrative Programs / Procedures Training Management Effectiveness Oversight

- Culture The NRC 50.54(f) letter as well as NRC statements during exit interviews following inspections at MP3 questioned the linkage of the ACR-7007 findings to MP3 an 1 the degree to which these findings exist at MP3. Accordingly, to assist in addressing this 4-7

i I

question, the discrepancies identified in the venical slice review were categorized using two of these categories, Current Configuration, Administrative Programs / Procedures.

Sub-categories were then developed for each of these high level categories to provide better definition of the nature of findings under each category and to focus evaluation of i corrective actions being taken by Northeast Utilities to address deficiencies in these areas.

The following summarizes these sub-categories.

Category A. Current Configuration A.1 Design basis f A.2 Key documents (FSAR, DBDPs, Technical Specifications, Ops critical  :

drawings) i A.3 Design details / Design implementation i A.4 Regulatory program compliance  ;

A.5 Physicalconfiguration  !

A.6 Operations (ops, LCOs, Surveillance tests and inspections)

Category B. Administrative Programs / Procedures  ;

i B.1 Design Control and Configuration Management B.2 Maintenance (Opea Work authcrizations/backlcg, calibration program)  ;

B.3 Corrective Action (ACRs, LERs)  ;

B.4 Licensing commitment tracking system {

B.5 Procedures  !

Station Licensing  ;

Industry Experience l Engineering Technical Work Load Management and Control Operating These sub-categories are consistent with other root causes and programmatic assessments, e.g., program and procedure upgrade, undenaken by NU to address all of the 50.54(f) letters. The sub-categories also line up with the several corrective action programs which have been initiated to address deficiencies.

4.9 Correlation of VSRT Discrepancies with Sub-Categories l Correlation of VSRT findings with these categories was accomplished by mapping the l reviewed document types into the sub-categories. A complete mapping was performed l for the Current Configuration and the Administrative Program / Procedure sub-categories.  !

Table 41 summarizes this napping.

4-8

4.10 Engineering Judgment Applied to Correlation Mapping This mapping was developed by the VSRT using engineeringjudgment. To test the effect of variations in this mapping on the results, other mappings were generated by NU engineering, and licensing personnel. The results using the alternative mappings were examined to estai,Fsh if changes in conclusions would result from use of one mapping versus the other. The conclusion was that although in some cases the mappings varied significantly, the conclusions were not changed. Accordingly, all correlation's included in this report were developed using the above mapping generated originally by the VSRT.

4.11 Correlation of Discrepancies with NRC Findings Categories The NRC findings from the inspections in the early part of 1996 were categorized by the l NRC into five categories. These are:

Licensing / Design Basis Documentation Translation of LB/DB to Processes and Procedures Corrective Action Process Engineering and Modifications These categories align well with the sub-categories used under the ACR-7007 Current Configuration and Administrative Programs categories. Accordingly, conclusions drawn concerning correlation of the VSRT findings with the ACR-7007 categories apply to the NRC categories as well.

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4-9

Table 4-1 Mapping of Reviewed Documents with ACR-7007 Categories Current Configuration Sub-Category VSRT Document / Program Review A.1 Design Basis FSAR (13). DBDP (9), Technical Specifications (14),

Codes & Sta sdards(2)

A.2 Key Documents Equipment List (10), Drawings (6)

A.3 Design Details / Implementation Calculations t;3), Accident Analyses and 50.59 Analyses (4), Vendor hformation (5), Specifications (7), System Descriptions (8)

A.4 RegulatoryIssues/ Compliance License Commitments (15), Corrective Action Program (1), Audits, Assessments and Inspections (16), GL's, IN's, IE Bulletins, etc. (17), Licensing Open Items / Backlog (18)

A.5 Physical Configuration PDCR's/DCN's (11), Design Open items / Backlog (12),

Walkdowns (23), Inteniews (24)

A.6 Operations / Maintenance Operating Procedures (19), LCO's, Surveillance Tests ,

and Inspections (20), Operator Burden and MCB l Deficiencies (21), Temporary Modifications including LLBJ's (22), Preventative Maintenance (25),

Ops / Maintenance Open Items (26)

Administrative Programs / Procedures Sub-Category VSRT Document / Program Review B.1 Design Control and Configuration FSAR(13), Calculations (3), Accident Analyses and Management 50.59 Analyses (4), Drawings (6), DBDP's (9), Technical Specifications (14), PDCR's/DCN's (11), Design Open Items (12), Specifications (7), System Descriptions (8),

Equipment Lists (10), Codes & Standards (2), Vendor Information (5)

B.2 Mainter,ance/ Testing Surveillance Tests and Inspections (20), Walkdowns (23), Preventative Maintenance (25), Ops / Maintenance Open Items (26) ~

B.3 Corrective Action Corrective Action Program (1), Audits, Assessments and Inspections (16)

B.4 Licensing Commitment Tracking License Commitments (15), GL's, iN's, IE Bulletins, etc. l (17), Licensing Open Items /Backleg (18) )

B.5 Operations / Procedures Procedures (19), Operator Burden and MCB Defir ' ncies (21), Temporary Modifications including LLBJ (22),

Inteniews (24) 4-10

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

Millstone Unit 3 Vertical Slice Review ,

5.0 References ,

1. W.T. Russell, Nuclear Regulatory Commission letter to R.E. Busch dated March 7,1996

2. W.T. Russell, Nuclear Regulatory Commission letter to R.E. Busch dated April 4,1996

3. NU Letter dated March 8,1996,

Subject:

Millstone Nuclear Power Station, Unit No.1 -

Submittal of ACR 7007 - Event Response Team Report  ;

4. NUC PI 15, Rev 1, dated June 20,1996, " Selected Millstone Unit 3 System Reviews" i 1

5. NUC PI 5, Rev 0, dated May 5,1996, " Millstone Unit 3 System Readiness Review" f

6. NUC PI 4, Rev 0, dated May 5,1996, " Millstone Unit 3 Walkdowns" .

7. Memo NE-96-SAB-115 from S.D. Weerakkody to J.M. Vargas dated May 1,1996

8. Memo, Yankee Atomic Electric Company, " Yankee Review ofMP3 Vertical Slice Team Observations Regarding PDCR-135," REG 97/96, June 7,1996 ,

9. CMP, Rev.1, dated May 23,1996, " Configuration Management Plan" 5-1 1

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l Attachment 1 Organization Chart I

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Project Organization Chart .

Vertical Slice Review Team Millstone Unit No. 3 Project Manager '

i MPR NU MPR Coordinator Coordinator Yankee Atomic Coordinator ANSI Lead Auditor (QA)

GSS/RSS/RHS Team Service WaterTeam

-Containment Recirculation Scram Breakers 1 Reactor

-Service Water System System Protection Walkdown Team

- Also, Contributed to

- Quench Spray System - Reactor Trip Breakers Pressurizer Safety and Relief

- Residual Heat Removal Valves System (Safety injection Mode)

Electrical Systems Team Auxiliary Feedwater System

- Emergency AC Power System Control Building Filtration / Team

- Station Blackout Diesel Ventilation Team . Auxiliary Feedwater including Generator -Control Building Filtration and ESFAS and AMSAC Initiation

- 120V Vital AC Ventilation System - Also, Contributed to Pressurizer

- Class 1E 125V DC Power Safety and Relief Valves

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t VERTICAL SLICE REVIEW TEAM MILLSTONE UNIT No. 3 PARTICIPATING ORGANIZATIONS MPR Associates,Inc.

Yankee Atomic Electric Company Westinghouse Electric Company Seabrook Station Bosto, Edison Raytheon Engineers and Constructors Contract Solutions

. Administrative support for the project was provided by Northeast Utilities l

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, hDLLSTONE NUCLEAR POWER STATION

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' ' ' ' UITitDirectA PORC Mtg. No: 3-9(.c-l33 nate: _.

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Level of Use Subject Matter Expert:

General MPR

Revision i PROJECTINSTRUCTION NUC PI15 SELECTED MILLSTONE UNIT 3 SYSTEM REVIEWS 1.0 Introduction -

gg 1.1 Purpose Provide a consistent review and evaluation approach for selected Millstone Unit 3 (MP3) systems in order to develop a basis for assessing the effectiveness of design controls and configuration controls. This activity is a vertical slice review.

1.2 Objectives 1.2.1 Provide guidance to the review team panicipants when evaluating systems for effective implementation of design and configuration controls.

1.2.2 Provide guidance for documenting the system evaluations and the results of these evaluations.

1.3 Scope 1.3.1 This P1 will be used to evaluate the following systems:

- Service Water

- Quench Spray and Containment Recirculation

- Reactor Trip Breakers

- Auxiliary FeedwaterIncluding ESFAS and AMSAC Initiation

- Emergency AC Power System

- Class IE 125V DC Power

- Station Blackout Diesel Generator  ! r21

- 120V Vital AC

- Control Building Filtration and Ventilation

- Residual Heat Removal (SI mode)

- Pressurizer Safety and Relief Valves Reference 6.1 provides the rationale for selecting the systems listed above.

1.3.2 This PI provides guidance for evaluating system configuration controls as they apply to plant documents. This PI also describes associated walkdown activities. l g; I

2.2.3 Discrepancy A finding generated as the result of an activity performed in accordance with this PI which indicates a potential need for process improvement or remedial action and for which an Unresolved Item Report (UIR) has been prepared but which has not yet been reviewed by the Plant Verification and Readiness Team (PVRT) in (,

accordance with PI 5 to determine the significance of the UIR and its priority for resolution. i l

2.2.4 Design Bases (DB)(')

- Information which identifies the specific functions to be performed by a structure, system or component

- The specific values or range of values chosen for controlling parameters as reference bounds for design -

2.2.5 Design Control A process defined in 10CFR50, Appendix B, which satisfies the following requirements:

- The design shall be defined, controlled and verified.

- Applicable design inputs shall be appropriately specified on a timely basis and correctly translated into design documents. l

- Design interfaces shall be identified and controlled. ,

1

- Design adequacy shall be verified by persons other than those who designed the item.

2.2.6 Engineering Design Bases (') [g l

- Information which describes a system, stmeture, or component

- Operating values or parameters which are not reference bounds for design

- Information which identifies functions important for economic, maintenance, installation, or other nonsafety function of design basis systems, structures, or components  !

l (1) Definition from CMP l g.

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slice system review. Ifa The review team will select key system attributes appropriate to the specific system being reviewed on the basis ofimportance to the safety-related system design bases. Attributes will be selected from the following parts of the Design Cortrol Manual NUC DCM:

- Design Inputs, Attachment 4-1 1

- Interdiscipline Review Engineering Evaluations, FORMS 4-1C through 4-1F

- Interdiscipline Review Evaluations for Engineering Programs, FORMS 4LIG through 4-1M

- The Management Quality Committee (MQC) must approve the attributes selected by the VSRT prior to commencing the system reviews. dl The following activities are associated with completing these matrices.

3.1.2 Document retrieval: For each system attribute to be evaluated, request the retrieval of tl.e necessary documents by completing the "1996 MPR Assessment-MP3" form, Attachment 5.2. Attachment 5.3 is an example of a completed document request form.  !

These forms are input to an NU computerized database for future retrieval, if necessary. g; A completed, computer generated form will be retumed to the requester when the i

documentation is retrieved.

3.1.3- System attribute evaluation: For each system attribute the systems review team member assigned will document positive and negative comments and/or observations of the evaluation on an Attachment 5.2 form. An example of a completed system attribute evaluation is shown in Attachment 5.4. Potential discrepancies which require safety significance screening shall be indicated on this form as shown and processed in accordance with Section 3.3 of this Project . Instruction.

3.1.4 The NU team coordinator shall prepare and update a database of all MPR Assessment Request Forms prepared in accordance with subsections 3.1.2 and 3.1.3 above.

3.1.5 Each system review team shall update the appropriate system review matrix as the evaluation process continues.

3.2 Information Sources Information sources and data bases should be queried to obtain information on past and present status of the system attributes being reviewed. This information will be part of ((

what is used to make ajudgment on design basis validity, configuration management and 5

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

process to ensure this item gets further review by the Team Leader for that system.

. 3.3.2 For each assessment item that indicates " DISCREPANCY IDENTIFIED", the cognizant i Team Leader shall complete a Discrepancy Screening Form (see Attachment 5.5).

The purpose of the screening is to identify those items that have potential safety g; significance for expedited tumover as described in 3.3.3 below. .

NOTE: The term " potential safety significance" is intended only to expedite review by NU, and is not intended to imply a level of safety significance.

3.3.3 Upon completion, the Discrepancy Screening Form shall be forwarded to the ANSI Lead Auditor for a review of document consistency and completeness and, agreement with the Team Leader's determination. The Lead Auditor shall initial on the form to indicate ,

concurrence and the form shall be provided to the NU Unit Project Manager for preparation of an Unresolved Item Report in accordance with PI 5.

gI 3.4 Scope Expansion If NU determines that the vertical slice review has identified safety / operability significant discrepancies, or if other problems symptomatic of new process weaknesses not hb previously identified are found, the reviews will be expanded to include additional vertical and/or horizontal reviews, as appropriate, to further test the process weakness identified by the discrepancy. For example, these areas could include FSAR updating, drawing control,50.59 process, etc. The specific criteria for the expansion are dependent on the nature of the finding and will be determined by the review team leaders and approved by the Project Manager and the MQC. If no additional significant discrepancies are found in the expanded reviews, the initial discrepancy will be considered an isolated error.

3.5 Characteristics of Review Results.

In order to facilitate evaluation of review results, general guidance for sorting these p rest!ts is provided in Attachment 5.6.

3.6 Walkdowns 3.6.1 General For the systems listed in subsection 1.3.1, the System Reviewer shall perform a system  ;

general area walkdown and/or one or more directed system walkdowns i

A system general area walkdown is performed by VSRT members assisted as necessary IU by a team of qualified designers. These walkdowns do not require advance preparationof  !

attribute check lists but are based on the VSRT reviewers' general system knowledge (see I

7

- - - - .- -. - -__ _ - = .. -- , , ~

I 3.7 Communications 3.7.1 Intemal communications are defined as team to team communications and

• communications between the teams and the assigned NU coordinator. Intemal l communications will be facilitated by brief meetings at the end of each work day to  !

highlight in-process review results and overall review progress.

3.7.2 Extemal communications are defined as communications between team members and NU provide daily briefings to NU management and oversight representatives on review team progress.

1 3.8 Deliverables 3.8.1 The deliverable for this system review will be a technical reports. Attachment 5.7 provides a typical outline for this report. Thi.e report will be transmitted to the Project Manager for incorporation into the final Project report.

4.0 Reviews 4.4 Internal Reviews Intemal reviews will be conducted by a qualified ANSI Lead Auditor. These reviews will provide additional assurance that team activities are conducted in accordance with thisPl.

4.5 External Reviews l

l Extemal reviews will be conducted by NU oversight organization representatives as assigned by NU management.

5.0 Attachments  ;

5.1 Example System Review Matrix 5.2 Example 1996 MPR Assessment - MP3 (Vertical Slice) Form 5.3 Example of Completed 1996 MPR Assessment - MP3 (Vertical Slice) Form (Document Request) 5.4 Example of Completed 1996 MPR Assessment - MP3 (Vertical Slice) Form (Review Results) 9

Attachment 5.1 Example System Review Matrix 1

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1996 MPR ASSESSMENT - MP3 (Vertical Slice)

UNIT: 1 2 3 Site MM NUMBER REVIEWER:

REVIEWER ,

NUMBER I I (Please Print)

TOPICS: ,

O Document O service water O ResidualHeat Removal O Information O osS/RsS OPZR Safety Relief Valve O Meetins O ReactorTrip Breakers O Other:

ODMput O Auxiliary Feedwater including ESFAS & AMSAC for AFW D On Site AC Power Owalkdown O E Power .-

O W App.B D Control Blds FiltrationNentilation ATTRIBUTE NO. I I 1 ISSUE: I l

NARRATION:

1 DISCREPANCY lDENTIFIED: C DOCUMENTATION ATTACNED: W.S l l NOl l RECETVED BY: DATE: 11ME:

ASSIGNED TO: l l

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Assessment - MP3 (Vertical Slice) l Form (Document Request) l l l l

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g U Auxiliary Feedwater including ESFAS & AMSAC for AFW CWalkdown D On Site AC Power ODCPower D W App.B D Centrpl Bldg FiltrationNentilation ATTRIBUTE NO. 1 I ISSUE:

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Forms (Review Results) 6

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g , O Auxiliary Feedwater including ESFAs & AMSAC for AFW l OWalkdown OOn Site ACPower O DC Power D W App.B

D contr,1 Bids riitretion/ ventilation ATTRIBUTE NO. ISk)P OSI ISSUE

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i 1996 MPR ASSESSMENT - MP3 (VERTICAL SLICE)

, Screening Form

. i REVIEWER NO.: TEAM LEADER:

kame!Date Safety Significance Review .

l Could the issue involve an actual or potential:  !

O Y;s O No Personne!, environmental, or equipment safety hazard? I Oyes O No Operability or reportablilty concem? -

O Yes O No Adverse impact on the unit?

NOTES: l l

3ased on the above information, this information O should O should not be forwarded to the plant for further review and consideration.

This issue is determined to be:

O Potentially Significant O Not Significant QA REVIEW: DOCUMENTATION ATTACHED: O YES O NO ina,al/Date l

RECEIVED BY: DATE TIME 8$

ASSIENED TO: RESOLVED:

RESPONSE

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This item is considered closed.

Attachment 5.6 Categorization of Review Results l

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CATEGORIZATION OF RE'4EW RESULTS The results of all system reviews will be sorted in the manner described in this attachment.

1. 'Ile process described in this attachment applies to all system review results. .Specifically, a review result is defined as either a determination that a specific resiew action did not identify any potential deficiencies (i.e. a " positive" result) or a determination that the review action identified one or more potential deficiencies.

2. ' The results of all system reviews performed in accordance with the matrices in Attachment 5.1 as well as reviews of previous inspection / audit results and ofpreviously recorded open item reports such as ACRs, LERs, DCNs will be sened into 3 major categories:

-A. Current Configuration

-B. Administrative Programs C. Training .

These categories were selected to conform to similar categories in the ACR 7007 Event Response Team Report.

3. After sorting all review results into the 3 major categories described in paragraph 2, above, the results are further subdivided into subcategories. These subcategories have been selected based on the results of earlier reviews and are intended to assist in analyzing the review results. The following listing relates the appropriate subcategories for each major category.

Category A. Current Configuration A. I . Design basis A.2. Key document (FSAR, DBDPs, Technical Specifications, Ops critical drawings)

A.3. Design details / Design implementation A.4. Regulatory program compliance A.S. Physical configuration A.6 Operations (ops, LCOs, Surveillance tests and inspections)

Category B. Administrative Programs B.1 Design Control and Configuration Management Processes (PDCRs, DCNs)

B.2. Maintenance / resting (Open Work authorizations /b Aig, Calibration program, Surveillance Testing)

B.3. Corrective Action (ACRs,LERs)

B.4. Licensing commitment tracking system B.5 Operations / Procedures

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Category C. Training 1

3 C.I. Industry and Internal Issues 1 C.2. General Training I

4. After sorting the review results into the categories and subcategories described in paragraphs 2. and 3. above, review results will be divided into those which did not identify any problems (positive results) and those which indicate a potential deficiency. Potentia.

deficiencies within each cate;,ory and subcategory will then be sorted to indicate the probable contributing factors. Dese contributing fhetors will be selected from the following list:

a. inadequate training

b. attention to detail

c. non retrievable information -

d. inadequate supervision

e. ma:erial defect

f. insufficient resources (management)

g. human error

h. procedure inadequacy ,

i. procedure noncompliance

j. incomplete engineering l

L acceptance of nonconforming condition

5. The sorted review results will be maintained in a database for use in preparing the final report.

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Attachment 5.7 Typical System Specific Report Outline

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l TYPICAL SYSTEM SPECIFIC REPORT OUTLINE

1.0 INTRODUCTION

1.1 Purpose 1.2 Scope 2.0 RESULTS AND CONCLUSIONS 2.1 Overall System Ob servations 2.2 Potentially Significant Discrepancies  !

2.3 Significant Walkdown Results 3.0 SYSTEM ATTRIBUTES 3.1 Detailed Attribute Matrix 3.2 Summary of Attributes, Bases, and Results l 3.3 Summary of Walkdown Results I

4.0 DISCREPANCIES

5.0 REFERENCES

APPENDICES A. Individaal Assessment Form.c l >

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9 S Attachment 4 QA Plan i

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MPR SYSTEM /FSAR VERTICAL SLICE REVIEW PROJECT OUATm' ARKURANCE TASK PLJLN I

PURPOSE ,

I This Project Quality Assurance (QA) Task Plan provides the project team members and Northeast  :

Utilities Project Oversight personnel with definitions of.the roles and responsibilities of the  ;

participants in this effort regarding the QA requirements of this task for compliance with l Appendix B of 10CFR50. In addition, the proposed scope of project self assessments is included i' for approval by project supervision.

SCOPE This document applies to all personnel associated with the MPR System /FSAR Vertical Slice Review Project, including Northean Utilities personnel designated within.

DEFINITIONS OF RFCPONSTBTT TTTES All individuals associated with the project are expected to use ' STAR" as it applies to engineering reviews and documentation completion. As individuals perform their assigned tasks they are required to Stop, Think, Act and Review all their work to ensure that it is accurate, based on sound engineering principles, technically defensible, and in accordance with the appropriate Project Instruction.

Director of Nuclear Design Engineering and Procram Services a

As the Northeast Utilities Director responsible for overall project performance, the Director of Nuclear Design and Program Services or his designee has the following specific responsibilities;  ;

o Implementation of Project Instruction NUC PI-15, " Selected Millstone Unit 3 System Reviews".

e Ensuring that personnel responsible for performing tasks under PI-15 are adequately trained.

o Approval of all scheduled self assessments prepared by the ANSI Lead Auditor.

e Acceptance of the results of the overall project for use by Northeast Utilities.

e Integration of the results of the project with other 50.54(f) response projects.

l NU Coordinator An individual assigned by Nonbeast Utilities to coordinate the utility fumished suppon of the project team. This includes development and implementation of a data-gathering process which tracks infonnation, including identified discrepancies, through resolution.

'Ibe NU Coordinator is also the initial contact point to ensure all identified discrepancies get to the MP3 Unit Project Manager (per PI-15), the designated cognizant person for review and determination of the appropriate action under the Millstone Station corrective action program.

Qualified ANSI N451'2312nd Auditor ,{

The ANSI Lead Auditor is responsible for performing self-assessments of project activities and feeding back recommendations for improving project task methods to the Project Manager and the Director of Nuclear Design Engineering and Program Senices. These self-assessments should be periodic in nature. The initial set of self-assessments are detailed below. In addition, the I. cad Auditor has the following specific responsibilities;

• Review each of the identified discrepancies as pan of the seteening process to ensure consistency and adequacy of documentation.

e Facilitate the interface with the NU Oversight QA activities (audits etc.).

e Assist in the preparation of the ' final project repon.

Svetem Team Irnders The System Team I.caders are responsible for the daily performance of work and the quality of work performed by the System Review Engineers assigned for a specific system.

As pan of the discrepancy reponing process, the System Team 1.cader will complete the initial screening process to determine the potential safety significance of the issue for input to the plant's corrective action process. Items that are considered potentially significant will be transmined as soon as possible for the appropriate plant review. Items designated as having less potential significance will be transmined to the plant prior to project completion. In addition, each Team Leader is responsible for preparation of the system specific section of the fmal project repon.

,5vstem Review Fnyineers Personnel assigned as System Review Engirnrs for the project are responsible for the quality and thoroughness of their own work. Team members shall comply with the requirements of PI-15, ' Selected Millstone Unit 3 System Reviews".

Attachment 5 System Specific Matrices

~,

Initial Scope Dermition and Results Summary l System Vertical Slice Review Matrices i

Table System A Service Water System B Containment Recirculation System /

Quench Spray System C Reactor Trip System D Auxiliary Feedwater Including ESFAS and AMSAC Initiation E Emergency AC Power System F Station Blackout Diesel Generator  !

G 120 V Wal AC H Class IE 125 V DC Power System I Control Building Filtration and Ventilation J ResidualHeat Removal System Safety Injection Mode K PORV and Code Safety Valves l l

l l

l i

I

TABLE A _

INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX Syr. tem: Service Water System As Attritpute Des 6gn Licensing Operat6ons & Mainterience 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 15 19 20 21 22 23 24 25 26 No. 1 Ceienge Amen GLs Bes. Sunes. Operator Tony crut Cowed.

Reposes Design Leonee m E useneag knas Sweet genes teena ese SW Aeolese Veneur Droe. Byewe Eems encheng op een* Yeek Com somet 4 Duneene op Isone h Teens ens esca senser's m N awsonessop eene Armen eres Cane Anestein esp Des Spest Deegt DSDPS Ltlt 90 5em Bechhg F5AR Specs meses e see Geradog esse queperms DEFs LL J 8 8 enuns stoess tamed Bestig swees Frosion/ Corrosion X X X X X X X X X X X Flooding X X X X X X X X X weies wvret He Encti insp a Chng Req's X X X X X X

. - . . _ Heat Exch. Layup Req's X X X X X wuru Statx>n Blackout X X X X X X X X X X X X X X X X X X X X X X X X X X X m Pg>ing Design X X 'X X X X X X X X X X X swww Pump DesiQn wven Pump Instr. & Control Req's X X X X X X X X X X X X X X X Pump Test Requirements X X X X X X X X wet wvets Pump Maw:.ance Req 4 X X X X X X weres Heat Excbenger Desgo X X X X X X X X X X X X X 4 wree Heat Exchgr. Test Req's X X X X X X X wares Matertal Requirements X X X X X X X X X X X X X X were. Seismic Qual. X X X X X X X X X X X X wers Electrical Separation X X X X X X X X X X X wms Operator Training X X X X X X X X Attnbute Checks 2 10 49 5 7 47 13 1 12 0 32 10 20 5 20 20 11 5 16 14 2 3 11 10 2 12 Discrepancies 1 0 0 1 0 2 0 1 0 0 0 2 0 0 0 0 0 2 2 1 0 0 0 1 1 k.ideptdata\hickman\svwater.xts

_ . _ _____.h_-__ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . . . _ _ _ _ _ . _ _ _ _ _ _. _ .-- ,_-4.. - - - - - _ _ . - - - -

TABLE B -

INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX Sytem: Containment Recirculation System I Quench Soray System (RSSlQSS)

Att. Attribute Design Licensing Operations & Maintenance No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 l 25 26 cm. . m ma m. e v anne c===* ao= o=,a ta=== a= .- e um ,  % in e e==+ n.es . w.m. m e,. . e, ==ne, ce s=-- v.* c.- . am a em co in i. m v ace , m w .,

Assun een tems Anssene ten men esse Demus CEGro Ls. M 9Be e=ames FRAR esame muuan .m e. eme esos asemasse OEFe LL at e emune wome tenue esmano essi Containment Pressure Cntrl X X X X X X X X cso -h Faseen Prod kur Crint X X X X X X X caen t&C Cahbration and Setecints X X X X X X X X X X X X X csee Denny Trne to Operation X X X X X caer Containment Sump pH X X X X X X X X X X X X X X X X X X X caos OSS Spray pH X X X X X X X X X X X X X X X X X X X cave RS*3 CooW Heat Removal X X X X X X X X X X X X X X X X X X X X X X es.e OSS/RSS Spray Coverage X X X X X X X X X X X X X X X X X X X co : essame c.,s o airones e X X X X X X X X X X X X X X X X esse Contamment Sump Pluggmg X X X X X X X X X X X X X X X esis Sprsy Nozzle Pluggeg X X X X X X X X' X X X X X X X cete coatm to VWehmarus Persadenes X X X X X X X X X X X X X ess, une er cervessan nemsenre usseriass X X X X X X X X X X X X X X esse Ppng Design X X X X X X X X X X X X X X X X X X X X X X cas, Desica Service Conditions X X X X X X X X X X X X X X X X caos Pump Design X X X X X X X X X X X X X X X X X X X X X X X X case Seesmic Category X X X X X X X X X X X X X X X X X cs,e Safet/ Cass X X X X X X X X X X X X X X X X X m mspectatz1 sty X X X X X X X X X X X X X X X X X X

. sz, TestatAtw X X X X X X X X X X X X X X X X X X m Seg8e Fadure X X X X X X X X X X X X X

-s:s Redundancy X X X X X X X X X X X X X cses Post Accident Operateg U8e X X X X X X X X X X X X X Artnbute Checks 14 5 26 5 to 31 11 19 22 2 21 23 38 25 3 50 97 8 9 37 8 4 14 8 7 299 Otscrepanoes 4 0 3 1 0 1 1 0 3 0 3 2 3 0 0 0 0 0 0 2 0 0 5 0 0 0 t wecantavocomarnessrsa es

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

TABLE C -

INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX Cy; tem: Reactor Trio system Attritnste Design Licensing Operations & AAaintenance Att.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 No.

cmease a sea, GLE 9e em Orweier Tog Cymr em me,== ces,. us w a (n.m e==. em enn um te aw meassse V.near De eyesens Egup hot h, Op mems Tech comme- oneses 4 genne Op meen h feels one uCe Insameng m h poeventou Op som 8 men. .e. ce=. a e. me. .,. a.-. eessen omrw ue ne ss. 3*=. rsan ee-. se. e= e ame e.e. orr. u. n o -. -e us e m.e Automatic Trip togic X X X X X X X X X X X X X X X X X X X X X X X X em Manual Trips X X X X X X X X X X X X X X X X X X X X X X X aver avos inp Devices X X X X X X X X X X X X X X X X X X X X X X j Testsng X X X X X X X X X X X X X X X X X eves gros Annunciation of Bypasses X X X X X X X X X X X X X atos Operat6on of Bypasses X X X X X X X X X X X X X X em IsotationfSepe ation X X X X X X X X X X X X X X X

-l '

mies Sennce Conditions X X X X X X X X X X X X X X am Seismic X X X X X X X X X X X X etse Single Faikre X X X X X X X X X X X X X em Redundancy ,

Attribute Checks 0 22 2 0 52 22 22 13 21 0 5 0 30 2 44 0 21 0 26 9 3 1 28 9 9 2 Drscrepancies 0 0 1 0 7 0 1 0 2 0 'O O 1 0 4 0 0 0 0 0 0 0 1 0 2 0  ;

t kWatutsanarteactry als

. . ., m _ _~

TABLE D -

INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX Sy; tem: Auxiliary Feedwater(FWA) including ESFAS and AMSAC Initiation Attnbute Design Licensing Operations & Maintenance l Att.

h 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Ca.ng. a.eg IRA ses SM Op.m T.g Op.t C.6 R.P re. D gm L a.e a- E Lt.n mg wue W te.d. te e sw a v- c- s, ew men.e s e, e v.m C =a me as vm esce m.mme m.m. a em.o, e a c w ne. e,. e o cem. tw se se. e m. raan a - .= o car. tuae - es.m e waes Flow DeNvery X X X X X X X X X X X X X X X X X X X X X X X X X X waar Water Supply X X X X X X X X X X X X X X X X X X X X X X X X X X

<waas initiation & Controt X X X X X X X X X X X X X X X X X X X X X X X X X awaos Station Black Out X X X X X X X X X X X X X X X X X

<waas TDAFP Operation - X X X X X X X X X X X X X X X X X X X X X X awaae Conta'nment a isolation X X X X X X X X X X X X X X X X X X X X X rwaer Operator Training X X X X X X X X X X X X X X X X awaas Seistnic Qual. X X X X X X X X X X X X X X X X X rweae Erruo. . .aal Oual X X X X X X X X X X X X X X X X X X X X X X rwaio ME1HE Une Breaks X X X X X X X X X X X X X X rwaii Electrical Sep. X X X X X X X X X X X X X X X X X X X rum,2 Piping Design X X X X X X X X X X X X X X X X X X IJtribute Checks 21 24 47 9 28 124 24 9 14 4 36 16 27 12 15 7 18 4 22 20 3 0 24 17 5 3 Di:2epancies 1 1 8 1 3 4 3 0 1 1 2 0 8 2 1 1 1 0 2 3 2 0 4 0 2 0 twsea-- -:- mis

~.

TABLE E -

INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX SyCtem: EmeIgency AC Power System Att. Attribute Des 6gn Licensing Operations & Maintenance No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 A.us e Ansanit OLa 98. sw op.me.r vp op.t c a.ar o s. t= m u  % e e u.a. es w si.* a no se v o, s,m== sw roca , e, e v.* c %a e.a.m. o, a. m v esce n.m.m., w - % e,. n c.=. a.m == .,. e o onor. un oc= e mi., rsan s w s.es otr. t.t s a s es e EAces EDG Loading X X X X X X X X X X X X X encar EDG Fuel Consumption X X X X X X X X X X eaces EDG Start & Load X X X X X X X X X X X X X e.nces System Protection X X X X X X X X X X axes Short CPeuit X X X X X X X X X X encos Load Flow X X X X X X X X X X raccr Service Conditions X X X eaces Seismic X X X X X X X X X caces Single Failure X X X X X X X X X r_acio Redundancy X X X X X X X X X Attritxts Checks 0 12 9 1 1 51 11 1 3 0 2 0 9 2 11 5 0 0 15 0 0 0 3 3 0 0 Discrepancies 0 0 5 0 0 0 0 0 2 0 0 0 4 1 0 0 0 0 2 0 0 0 1 0 0 0 l

l i

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

4 TABLE F INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX ,

Syztem: Station Blackout Diesel Generator Att Attribute Design Licensing Operations & Maintenan:e No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 cmeas. a.em. au em am 0, v., o,.t c n o ,. t, a m u=== s m em u.a. is e to es.re as.mme W.ne.t D.e- Bra.as Esp.p testsang 0, m.m. T.sh. Cornne pena. 4 sua m. Op sman Pe.sg. Y es.no iACs butsame m ine.n. 8e.ue.em. Op a.m.

m n c a, De se o se coo um as se. a.ame rsait se.<. a. .a- ei. e.=mi e e car. Ltase . is e e s.,

secw Rating X X X X X X X X snoor Start & Loading X X X X X X X X X X X sacos Electrical Loads X X X X X X X X X X X unoes Fuel Consumption X X X X X X X X X X X X j sacos instaRation X X X X X X X X X X X X X X X j X X X X X X X X X X X X X

_ seres Supply Breakers seoer Battery Size X X X X X X X X X X X X seces Electncalinterface X X X X X X X X X X X X soons Ventilation X X X X X X X X l seow Protection X X X X X X X X X X X mm Service Condstions X X X X X X X X X X X X X X X X Attnbute Checks O 2 7 0 8 4 10 1 4 5 6 1 9 0 7 0 1 1 12 8 1 0 5 0 6 2 Disaepancies 0 0 3 0 2 0 2 0 0 0 2 0 0 0 1 0 0 0 1 0 1 0 0 0 1 0 4

mto sesstavnesmaestabie:km+s

. -- n _ - . . _ = _ _ _ _ _ _ - _ . . - _ _ . _--_- _ _____ - -_____ - __.__ _ _---______--_______ _ _ _ _ . _ _ - - _ _ - . _ _ - - _ _ _ - _ _ _ . - _ _ . _ - - _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

f TABLE G INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX Sy; tem: 120VVital AC Att. Attribute Design Licensing Operations & Maintenance No. 1 2 3 4 5 6 7 8 9 10 -11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Demps musea. MA ins. W Operater Tony Oper N Aepen. Design Leonee Asemes. E thenome lease W GAese tem he h assenese %nse Dw System fenp Isakseng Op itens fed Comme 6 anom., 4 aussebus Op meses Puese faste ene IsCS  % WAuth- h 8te=emese Op hems a e rm a =, e me. .u.e e es m once. La se se. esase, ma ses .m e ses ee or,. u.4 a e es os Rosse es vacci inverter Sizing and Ratings X X X X X X X X X X X X X X X X X X X X X wen Transformers X X X X X X X' X X X X X X X vacos Distribution Panets X X X X X X X X X X X X X X X X vacoe System Coordination X X X X X X X X X X vacas System Short Circuit X X X X X X X X X X veces Voltage Drop X X X X X X X X X X

<acer Service Conditions X X X X X vaca Seestruc X X X X X X vacee Single Failure X X X X X X vacw Redundancy X X X X X X Attribute Checks 0 0 6 0 3 14 3 1 1 0 1 1 2 1 1 0 0 0 2 0 0 0 1 , 1 1 0 06saepancies 0 0 6 3 1 2 1 0 1 0 1 0 1 1 0 0 0 0 1 0 0 0 1 l0 1 0 k wawwtmarM20vac wts

_____m ____m_ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ . _ _ - . _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ __ _ m

TABLE H INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX Syctem: Class 1E 125V DC Power System Att. Attribute Design Licensing Operations & Maintenance No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 15 20 21 22 23 24 25 26 ca.as. w ata em sa e, v., o,w  !

c m ,== o ua t=. a a tm m em u m

h. sw a.emma womeur thes> System Eeny huhdhg Op G.esi To k CenpG. menet & DAsk. Op h.m.i h Teme. .me MCs tuhahng h Int.> Pue nheOp neuw m.a com. m.w ne. a o onor. um se ss. e.ame ese s .ne e ne es. tu s e e =. - es a e satts Loadsng & Sizing X X X X X X X X X X X X o earse Rating X X X X X X X X X X X X X X X X eavea instaMation X X X X X X X X X X X X I eaves Battery Charger X X X X X X X X X X X X X X <

eaves Cable String X X X X X X X X X X X X X X X j uros Design Requirements X X X X X X X X X X X X X X X X Xy aaver Protection X X X X X X X X X X X X X X X X X X  !

i saine Service Conddions X X X X X X X X X X X X X X X earne Seistnic X X X X X X X X X X X X X X earm Single Faaure X X X X X X X X X X X X X X  !

t miss Redundancy X X X X X X X X X X X X X X t

Attribute Checks 0 2 10 0 5 12 6 1 3 0 2 0 9 5 4 1 0 0 11 0 0 0 4 2 2 0 Desceoaroes 0 0 7 0 2 1 0 'O O O O O 2 1 1 0 0 0 0 0 0 0 0 0 0 0  ;

i st - . __ c.,_..,

TABLEI INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

SYSTEM VERTICAL SLICE REVIEW MATRIX Cy; tem: Control Building Fil Att. Attribute Des 6gn Licensing Operations & Maintenance No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Chuge Audh (EA Wes W Operseer Tag Opef c e. no en. e.e,e toe.ee w e use.g mee. em eien. eses.

he Same Accusess veneer Ow Syeene Egne tachesig op tems Teust Ceems mama. 4 Suseme Op toom Paese. Teeen ess AICS tessedeig m h pieweseheop team Aseen eres teks Asesween ties >gn Space Deerst DEDPt Lee 50 Sea Eocenes FSMt Space enses es ,. Remass essa Nepeates CEFs Lt.J 4 3 essuns gueusa toast gesideg

. wet, Wateng Capacity X X X X X X X X X X X X X X X X X X X X X e Cooling Capacity X X X X X X X X X X X X X X X X X X X X X X X X

.wces tsolation Requirements X X X X X X X X X X X X X X X X X X X X wens Emerg Pressurtration Req's X X X X X X X X X X X X X X X X ,

X

.wcas Air Flow Capacity X X X X X X X X X X X X X X X X X IX X X

.wccr Humidity Control X X X X X X X X X X X X X X

.wces Finer Capat@ty X X X X X X X X X X X X X X X X X X X X X

=ces Toxic Gas Protection X X X X X X X' X X X X X

.weie Radiation Protection X X X X X X X X X X X X X X X X X weir Pressure Loads X X X X X X X X X X X w is CB Chiller Des 6gn X X X X X X X X X X X X X X X X X X X X X X X

.wcw Logic Intedocks X X X X X X X X X X X X X X awets Station Bischout X X X X X X X X X X

.weie Fire Protechon X X X X X X X X X X X X X e Single Failure X X X X X X X X X X X X X

.wess Seesmic Category X X X X X X X X X X X X X X X X Attritsute Checks 28 22 50 2 4 25 22 20 17 4 18 2 66 28 22 14 21 13 9 12 5 3 20 3 6 40 l Discrepancies 4 0 10 0 1 3 0 1 5 0 2 0 13 1 3 1 0 0 2 1 0 1 4 0 1 0 l

k%sseksmesh._t M sts

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . . _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ i

TABLEJ INITIAL SCOPE DEFINITION AND RESULTS

SUMMARY

t SYSTEM VERTICAL SLICE REVIEW MATRIX l

Syttem: Residual Heat Removal System (RHS) Safety In_lection Mode AtL Attr6bute De36gn Licensing Operations & Maintenance No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 cm s.  % au m e o, n. vm e,,

em me = o u, m e (m , i em is in e i

b. De.6 A.eu.as ba.ser th Sysem Egmy hutseng op seam Tosh Com.se. esses. a sua.eme op som., h fosa. e adCe tid.s.g h h .se.ashe0, t.sm l e. c a, == e o onor. t., se se. e- ream e e osv. u.a s s - en e cecH System Alignments X X X X X X X X X X X X X X X X X X meet Sutten t sw Over Pressuntmen X X X X X X X X X X X X X X X X X X X caos I & C Setpoints & Intertocks X X X X X X X X X X X X X X X X X ases Piping Design X X X X X X X -X X X X X X X X enor Design Sennee Con &tions X X X X X X X X X mens Pump Design X X X X X X X X X X X X X X X X X mece Vane Design X X X X X X X X X X X X X X mens Matettalt X X X X X X X X X cesse Seismic Category X X X X X X X X X X X X mees Sa8ety Class X X X X X X X X X X X X mesi inspectatwirty X X X X X X X X X X X X X met Testability X X X X X X X X X X X X X esis Single Failurs X X X X X X X X Attnbute Checks 0 1 1 5 22 2 4 2 15 11 15 2 28 6 1 0 0 1 11 17 1 1 30 4 36 63 Discepancies 0 0 1 2 0 0 0 1 1 1 0 3 1 0 0 0 0 0 0 0 0 8 0 0 0

d TABLE K INITIAL SCOPE DEFINITION AND RESULTS SUM!AARY SYSTEM VERTICAL SLICE REVIEW MATRIX Sy; tem: PORV and Code Safety Valves A.'a Attribute Design Ucensing Operations & Maintenance Na 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 .t5 26 cs s. m.es m een sw o,.ee. T., come c- as, m owen u m a tm.=. w. em is en.et sw no v o, e, s. , % o, no ve ca a4 a.a o, w ,,e v uca nm w a. ,,s c.. m actee ans, came mener.s nian tige spese Due.se DROPS une 50 St. Oscaeng Fgan spees snente ses gesados e.es innescens CEFs LL J 4 5 deus. samme teena toenmg wset Overpressure Protection X X X X X X X X X X X X X X X X X X X esca Low Temp. Overpress. Prot X X X X X X X X X X X X X esos Safety Grade Cold Shtdwrt X X X X X X X X X X X X X

=csos TM1 issues X X X X X X X X X X X X gesos Piping Design X X X X X X X X X X X X X X X ecsos Vahre Deskyn X X X X X X X X X X X X X X X X vsar Valve Instr. & Control Req's X X X X X X X X X X X X X X X X acsos Valve Test Requirements X X X X X X X X X X acsee Matedal Requirements X X X X X X X X X X

=ccio SW Jc Quahfication X X X X X X X X X X X X

= cut Single Failure X X X X X X X X X Redundancy X X X X X X X gin I

Attribute Checks 2 2 24 0 2 25 3 0 6 1 3 1 16 10 5 0 4 0 19 15 2 2 2 4 1 3 Discrepancies 1 0 4 0 0 0 0 0 0 0 0 0 3 4 0 0 0 0 1 0 0 0 2 0 0 0 a wedstammargressare um

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