ML20113E301
| ML20113E301 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/02/1996 |
| From: | Vargas J NORTHEAST UTILITIES |
| To: | |
| Shared Package | |
| ML20113E249 | List: |
| References | |
| PROC-960702-02, PROC-960702-2, NUDOCS 9607050233 | |
| Download: ML20113E301 (35) | |
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\ Northeast '
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1 Millstone Unit 3
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- INTEGRATED ASSESSMENT and 1 ACTION PLAN Northeast Nuclear Energy Co.
Millstone Unit 3 1
Date: 7/2/96 Rev: 0 i
- M7 188s M 838!22 P PDR
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MILLSTONE UNIT 3 INTEGRATED ASSESSMENT PROGRAM DESCRIPTIONS AND STATUS i
July 2,1996 l
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1 Approved: kb 7/2/f4
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J. Mf. @ argas, Direc$r l Dedgn Engineering and Program Services
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. . i Millstone Unit 3 Integrated Assessment Programs Description and Status Table of Contents si .
I 1.0 Introduction :.
i 1.1 Background and Purpose 1.2 Objectives i
1.3 Scope i 1.4 Measures of Success 2.0 Summary 1 2.1 Individual Programs 2.2 Integrated Assessment Results and Conclusions to Date 1
Program Descriptions 3.0 i
3.1 Vertical Slice Reviews ;
3.2 . Horizontal Reviews of System Readiness -
l 3.3 Configuration Management Procedure / Process Review Extent of Condition Review
! 3.4 3.5 Engineering Program Assessments l
3.6 Applicable Phase 2 Programs l 4.0 Integrated Assessment Methodology 5.0 References 1
6.0 Tables i
7.0 Attachments ,
l' r 1. Configuration Management Action Plan l
! l i 2. Integrated Assessment MP3 Restart Programs Summary and Status Review J i
! Checklist i
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L SECTION
1.0 INTRODUCTION
1.1 BACKGROUND
AND PURPOS,E-p .
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1.1.1 Background b Northeast Utilities (NU) has prepared a Configuration Management Plan to address conditions .
identified in 10CFR50.54(f) letters issued for Millstone Units 1,2 and 3. (CMP, reference 1).
The CMP includes two phases. The first phase includes completing several programs to survey, diagnose and evaluate the accuracy and completeness of the design and licensing basis documentation, the conformance of the plant design, operation and maintenance with the DB/LB and the effectiveness of programs, processes and procedures which maintain plant conformance with DB/LB. These programs include:
- Vertical Slice Reviews
- ' Horizontal Slice Reviews
- Configuration Controls and Management Procedure / Process Reviews Phase 2 of the CMP covers longer term programs to upgrade documentation, programs, processes and procedures to address deficiencies identified in Phase 1 and to trend the effectiveness of these upgrades.
1.1.2 Purpose This report ties together the results of the Phase 1 programs and provides the bases for an action -
plan to implement the CMP. The Action Plan (Attachment 1) reflects the results of completion of Phase 1 of the CMP. These results indicate the need to initiate some of the corrective actions earlier than originally scheduled for Phase 2 of the CMP. Specifically, the Action Plan subdivides Phase 2 into near term corrective actions to address problems identified in Phase 1, and longer term actions to complete, monitor and trend the effectiveness of upgraded documentation, programs, processes and procedures.
Other programs were initiated in Phase 1 to address emerging issues. These include: (1)
Extended Reviews, which were added to Phase 1 efforts to provide further in-depth review of areasjudged to have potentially significant generic implications, and (2) Engineering Program Assessments, which cover the 19 engineering programs established in response to regulatory initiatives such as EQ, Fire Protection, etc. Since these other programs are not yet complete, the Integrated Assessment program has been prepared to describe and summarize the currem status of the various programs, and to report major conclusions which have been reached from the efforts to date. This interim report covers the status of programs as of June 28,1996.
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l 1.2 OBJECEVES The integrated assessment program combines the results of the Phase 1 MP3 CMP to:
- Establish generic implications offbR - 7007 root causes for MP3, ,
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- Establish adequacy of processes, controls and upgrades to prevent unacceptable recurrences of ACR - 7007 problems, and
- Identify areas requiring corrective action i 1.3 SCOPE l
As noted above, Phase 1 of the CMP includes three major programs in addition to the MP3-specific assessment. Two additional programs were initiated to address emerging issues. Each of these five programs is described in detail in Section 4 of this report and program status and results as of June 28,1996 are summarized. The following provides a brief summary of these five programs.
Vertical Slice Reviews have been performed of 11 systems or portions of systems. Six of these systems appear in core damage sequences which contribute to approximately 85% of calculated core damage frequency (CDF). Additional systems were included to ensure adequate coverage of all engineering disciplines and because of their impact on safety. For each system, key safety related attributes have been identified, and in-depth reviews have been performed in the overall areas of Design, Licensing, and Operations and Maintenance to assess adequacy of plant configuration to satisfy the required attributes, and adequacy of process controls to ensure continued capability to satisfy the attributes.
Horizontal reviews of system readiness covers the review of the 39 plant systems included in Maintenance Rule Group 1, i.e., the plant systems that have been identified as being both safety related and risk significant. Two more systems were added based on the results of the vertical slice reviews. These include the Station Blackout (SBO) diesel generators and the control room HVAC systems. The reviews include system related documents of each system, such as work i
orders, ACRs, etc. to determine that required system work has been completed. It also includes walkdowns of each system to assess material condition and obtain visual confirmation that selected design changes have been properly implemented.
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l Configuration Management Procedure / Process Review covers plant programs, processes and l I
procedures that provide configuration management, so as to maintain control oflicensing and design basis requirements on a " going forward" basis. It has identified deficiencies in programs, processes and procedures which need to be resolved in both the short term and the long term. In l
accordance with the Validation step of the MP3 CMP (see Attachment 3 of Reference 1), this program also includes a review of configuration management deficiencies identified in the other restart programs including the Vertical Sllcp and Horizontal Slice Reviews to ensure that 'the Configuration Management program imprqvements provide effective barriers to recurrence.
In addition, as a result of findings dudng Phase 1 reviews, a program was initiated to upgrade the vendor technical information control and tracking program.
Extended reviews have been undertaken for additional technical areas which were considered to warrant further in-depth evaluation during Phase 1 because of their potential for having significant generic implications. These include (1) containment isolation review , (2) electrical separation, (3) electrical calculations and drawings, and (4) FSAR Chapter 15 Design Basis Review.
Encineering Procram Assessments include review of the 19 engineering programs which have been established in response to regulatory initiatives, such as EQ, Fire Protection, etc. For och program, the review identified outstanding licensing commitments, technical adequacy of program implementation, and adequacy of program configuration management.
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SECTION 2.0
SUMMARY
l 2.1 INDIVIDUAL PROGRAMS STA,TUS ll .
Il' 2.1.1 Vertical Slice Reviews ..
The vertical slice reviews are complete. They are documented in "FSAR/ Systems Vertical Slice l Review", Project Report, July 1, ly96.
2.1.2 Horizontal Reviews of System Readiness A review report has been prepared for each of the systems covered by the horizontal reviews, and l each report has been presented to and accepted by the MQC (Management Quality Committee).
i 2.1.3 Configuration Management Procedure / Process Review The Configuration Management Team (CMT) has developed the rationale for including various l MP3 programs, processes and procedures in their review, and have prepared a list of the 100 l programs, processes, and procedures to be evaluated. They have been categorized as follows:
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= Station Procedures
= Licensing Procedures
- Engineering Technical Procedures
= Work Load Management and Control l
= Document Control and Management l
l The evaluations have been completed for the programs, processes, and procedures identified for Phase 1, and specific revisions to the pertinent procedures have been prepared for the Phase 1 l programs. 'Ihe Procedures Review Board process is ongoing. Interim evaluation forms which i document the review and identify all of the required improvements have been prepared. Formal documentation of results and recommendations for improvement are to be via the UIR process, and plant approval to employ this process is pending. The UIRs will be prepared once approval is finalized, and following this, a means for tracking improvement recommendations will be
. identified. The Validation review of configuration management deficiencies identified in the
. Vertical Slice and Horizontal Slice reviews has not yet started.
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! 2.1.4 Extended Reviews Extended reviews were initiated to address emerging issues in Containment Isolation, FSAR Chapter 15 Accident Analyses, Electrical Separation and Electrical Calculations and Drawings.
An upgrade program for control and tracking of vendor information was also initiated. The extended reviews and the vendor information program are discussed in Section 3.0.
2.1.5 Engineering Program Assessments l
l Assessment reports have been initiated for each of the engineering programs included in this
! area. These reviews are underway and discussed in Section 3.
i 2.2 INTEGRATED ASSESSMENT RESULTS AND CONCLUSIONS TO DATE t i
The results to date of the other Phase I horizontal reviews of system readiness, configuration management process reviews and engineering program assessments are consistent with the results of the vertical slice reviews. Specifically, they point to the same general areas of weakness and also correlate with the MP1 ACR 7007 problem categories. In the case of the
- horizontal system readiness reviews, where the data gathering and recording process is similar to l the vertical slice reviews, the location of discrepancies and the significance level of discrepancies are also comparable to and consistent with the results of the vertical slice reviews.
The principal results and conclusions that can be drawn from integration of the results of these programs to date are as follows: ,
Correlation with MP1 ACR-7007 and NRC Inspection Findings The root cause analysis of the event analysis report for MP1 ACR-7007 identified six root cause categories. The results of the VSRT review and the Configuration Control and Management (CCM) review indicate clear linkage between MP3 and the MP1 ACR-7007 for two of the root cause categories. These cover discrepancies 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 configuration (the Administrative Program category). 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 inspections of MP3, i.e., Licensing Basis Documentation, Translation of Licensing Basis / Design Basis (LB/DB) to Procedures / Practices, Corrective Action Process and Engineering and Modifications. There is, therefore, correlation between the VSRT and CCM findings, and those from the NRC inspections.
. Note that the VSRT review concluded that it was not possible to make a quantitative comparison i between the extent of discrepant conditions at MP3 compared to MP1 because the MP1 l
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conditions were not quantified sufficiently. Accordingly, the conclusions on extent of the discrepant condition in MP3 were made on an absolute basis.
Accuraev and Comnleteness of Desien and Licensing Bases In the vertical slice review of the 11 systems, relative discrepancy rates in excess of 5% were found in 17 of the 26 categories of documppts and programs reviewed. Among the largerpeaks were discrepancies in the FSAR (includinSChapter 15 Accident Analyses), Tech Specifications, DBDPs and calculations. A threshold of $% was established by engineering judgement as a level which is beyond that which would be expected for a typical plant. In the horizontal review, significant numbers of discrepancies were also identified in the FSAR. The nature of the discrepancies range from editorial to more significant items which have been prioritized for resolution prior to restart. Additionally, other lower peaks, but still in excess of 5%, were also identified in the areas of the accuracy of 50.59 analyses and licensing commitments.
The relatively high discrepancy rates in these areas indicate the need for expanded review to establish the extent of condition of these discrepancies. This action should include review and update of:
appropriate sections of the FSAR, including review of past licensing commitments and improvement in the understanding of Chapter 15 Accident Analyses critical calculations, a
technical specifications, design basis documentation packages (DBDPs) and a
performance of 50.59 analyses.
Accuraev of Kev Documents Gngineering Documentation)
A significant peak in discrepancy rate was identified in the vertical slice review for vendor technical information control and tracking, e.g., failure to control vendor technical manuals and inadequate translation of vendor maintenance requirements into procedures. A peak in excess of 5% was also identified in the equipment list category related to missing or incorrect information.
Although the discrepancy rate for drawings in the vertical slice was less than 5%, overall a number of the discrepancies were found in ops critical drawings, e.g., inconsistent data or errors on electrical one-lines. The area of ops critical drawings has also been identified as a focus issue by the Deficiency Review Team. Accordingly, effort is required in the near term to establish extent of condition and correct discrepancies in the following areas: i ops critical drawings material, equipment and parts list (MEPL)
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vendor technical information control and tracking program 2-3
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Corrective Action Program One of the largest discrepancy rates identified by the VSRT was in the corrective action program.
Deficiencies in this program included inadequate scope of ACR's and their recommended corrective actions, excessive time periods before implementing action and ineffective action.
'Ilese findings are consistent with NRC findings as noted in recent letters and in internal NU QAS audits. Accordingly, NU has initiate program. Key performance indicators hAv,d a complete upgrade of the corrective ^ a e been established to trend the effectiveness of this program. This program upgraded should be completed and its effectiveness tracked as pan of the near term CMP Phase 2 effon. ' '
i Ooerations rnd Maintenance Issues The venical slice review identified significant discrepancy rates in operator burdens including MCB deficiencies, e.g., timeliness in resolving these deficiencies, implementation of l preventative maintenance program (e.g., failure to perform maintenance on prescribed intervals or missing program), and the material condition of the plant as determined by t walkdowns. The results of the horizontal reviews also identified significant numbers of discrepancies in the maintenance and material condition areas. The venical slice reviews identified lesser peaks, but ones in excess of 5 %, in the areas of bypass jumpers and temporary modifications, surveillance tests, incomplete programs and procedures, (e.g., i omissions, improper references and inconsistencies with other documentation).
The significance of these peaks indicates that effort is required to review and correct the extent of condition of deficiencies in the following areas:
a review and upgrade of operating and surveillance procedures and inspections address operator burdens and MCB deficiencies
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address bypassjumpers and temporary modific ations a
review and correct plant maintenance management system (PMMS) correct significant material condition deficiencies i
Additionally, System Readiness Reviews need to be completed for the remaining safety-related systems (Maintenance Rule Group 2) to ensure that the extent of the condition of discrepancies ,j identified in the initial system reviews is established, and significant discrepancies corrected prior to plant restart.
I Design and Conficuration Control Program The occurrence of the significant peaks in discrepancies identified above indicate programmatic b deficiencies in the structure and past implementation of the design and configuration control 2-4
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l program. During Phase 1 of the CMP several program and procedure reviews were performed by the Configuration Management and Control group and upgrades of deficiencies in these programs and procedures were initiated. In addition, the Design Control Manual (DCM) was upgraded to address design control weaknesses. The upgraded configuration management and ,
control program, including the DCM, should be completed. Also tracking should be initiated to l confirm their effectiveness in ensuring that ~a'dequate communication links are maintained between programs, processes and }
procedg}es. l Extended Reviews Several extended reviews have been initiated by NU as a result of discrepancies identified by the VSRT and others. These reviews include: 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 AFW turbine-driven feed pump isolation valve deficiency,3) a review of Electrical Separation to establish extent of condition of discrepancies found by the VSRT and by other walkdown activities, and 4) a review of electrical calculations and drawings to establish extent of condition of VSRT findings. These reviews are in progress, and when they are complete, their results will be included in the final integrated assessment report. 2-5
l l l t SECTION 3.0 PROGRAM DESCRIPTIONS 3.1 VERTICAL SLICE REVIEWS ,., n . .. H In-depth, structured assessments ofeleveEPRA-significant systems were performed. These assessments are aferred to as "verti' cal slice reviews".The objectives of these reviews were to L 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, l maintenance, operation and configuration with licensing and design basis requirements, and (3) l the effectiveness of plant programs, procedures and processes in maintaining plant conformance l with licensing and design bases. In addition, as part of the review, the applicability to MP3 of L the findings and issues described in the Millstone Unit 1 (MP1) ACR-7007 Event Response ! . Team Report was assessed. 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 L 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 which appear in core damage sequences which contribute to approximately 85% -f the calculated core damage frequency (CDF). Five systems were added because of their impact on safety and to increase the extent of the reviews based on knownissues. l In this vertical slice review of the eleven systems, over 3200 attribute checks in 26 categories of l 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 l 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 j which address erant of condition and correction of programmatic deficiencies that contributed to occurrence of the discrepancy.
- - The VSRT supplemented the efforts described above by 1) performing 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. . i { 3-1 l
3.2 REVIEWS OF SYSTEM READINESS ( HORIZONTAL SLICE) Comprehensive, structured assessments, including walkdowns with experienced walkdown teams were conducted for 41 key systems at MP3. Thirty-nine of these systems were the Maintenance Rule Group 1 systems,i. ! plant systems that have been identified as b'eing both safety related and risk significant.jMvo systems were added as a result o Slice Review; these additions were:the Station Blackout Diesel Generator and the Control Room HVAC systems. The horiz'ontal reviews of each system included review and evaluation of the following elements:
- AWOs
- Design changes
- NCRs
- Trouble Reports Maintenance Rule implementation
- EWR review jumper bypass review operability determinations or JCOs control room panel deficiencies operator burdens a
pre-outage work list work not performed (rejected OSCRs) A/R reviews
- ACR review punch list evaluation preliminary system walkdown surveillances system testing
- LER review _ _ _
abnormalplant conditions long-standing system issues other system issues final system walkdown
- UIR summary startup items System-related documents, such as Work Orders, ACRs, NCRs Bypass Jumpers, etc.,were reviewed to determine that design changes have been adequately documented and current system configuration will support unit startup for these 41 systems. This actisity also included walkdowns of each system to assess material condition and obtain visual confirmation that selected design changes have been properly implemented.
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For those documents utilized to check system status, for example Work Orders, each documented work order that has been issued since the plant startup in 1986 has been checked to ascertain linkage to design change documents and adequacy of retest plans. In . most instances, a full Work Order search back to 1983 was conducted. For those Work Orders that were found to have been improperly implemented, an Unresolved Item Report i (UIR) was created and entered into thgresent system for disposition. Similar checks and comparisons were made for most of the same 26 categories of documents checked in the Vertical Slice Review and which make up the horizontal axis of the results matrix presented in the Vertical Slice Final Report.'(Figure 2.1 of the Vertical Slice Review Summary Report). In this horizontal slice review, more than 70,000 individual attribute checks were made to [ l verify their status. From this review,275 discrepancies were identified (a 0.4% rate), of l l which 111 were items requiring action prior to plant startup. . ! l The discrepancies of the System Readiness Reviews (Horizontal Slice) were compiled and ' compared to the results of the Vertical Slice Review. The reviews were conducted independently by the Horizontal Slice Review personnel. Evident in the comparison were similarities in the high frequency of discrepancies in the FSAR documentation and in the features checked in the Walkdown and Maintenance categories. The high frequency in the latter two categories reflect the focus of Horizontal Reviews on the physical configuration of the system. The Vertical Slice showed a significant number of discrepancies in other categories, e.g. the " Calculation" category, which can be attributed to the strong focus of the Vertical Slice Review on design basis verification where a large number of calculations were checked. Also evident in review of the discrepancy tabulations of both Vertical and Horizontal Slice Reviews is the absence of new and previously undiscovered high areas of discrepancies. Table 4.2 is a compilation of the results of the Horizontal Slice Review process. 3.3 CONFIGURATION MANAGEMENT PROCEDURE / PROCESS REVIEW
'Ihe Configuration Control and Management activity was developed to:
(1) identify programs, processes and procedures within Unit 3 required to ) communicate changes among the as-designed, as-licensed, as-operated and physical plant ' configuration. (2) review each activity to determine if weaknesses exist in the communication of i configuration information. I (3) develop appropriate corrective actions which resolve the identified weaknesses. j Since this report covers only survey and evaluation activities, further discussion of
- the approach and results of this activity is outside the scope of this report. We note, however, that this activity is divided into Phase 1, short-term fixes and Phase 2, long-l 3-3 i
l I term recommendations. Ongoing actions are proceeding to develop and implement necesse:/ corrective improvements under Phase 1. Iong-term recommendations are provided to improve efficiency and not intended to address identified configuration controlweaknesses. (4) develop criteria (key performance indicators) for monitoring the performance of the identified change activities. - A review was performed to identifythe controlling process, program or procedural (PPP) documents which control Unit 3 a'ciivities involving changes to the plant configuration, operation, design basis, or licensing basis. These PPPs were then evaluated to identify configuration controlweaknesses. The reviews emphasize the linkages between the various PPPs to ensure that adequate procedural steps exist for configuration control between controlled activities. Interviews were performed with cognizant plant personnel to also evaluate the specific implementation with the corresponding PPP documents. A total of 100 procedures, processes or programs have been identified for review under this program. They have been categorized as follows:
- Station Procedures !
- Licensing Procedures
- Engineering Technical Procedures
- WorkImad Management and Control
- Document Control and Management The Phase 1 group consists of 40 PPP documents which were selected based on their importance to the CMP near-term objectives of submitting the 50.54f response letters.
Phase 2 group includes the balance of the PPP documents. The detailed systematic review has been completed on the Phase 1 group and 73% (29 documents) have been identified as requiring some level of corrective action. The majority of the configuration control changes involve improvements to the definition of the communication interfaces between individual PPPs to ensure that the configuration controlled documents are maintained in synchronization with the plant and with each other. He key conclusion from the Configuration Control and Management program activity j relevant to this report, is that a majority of the selected PPP activities involving l configuration control have weaknesses in either the controlled documents or the process as it is implerrsented in the plant. These weaknesses are of an extent and type that reasonably } could have lead to the types discrepancies identified in the. system and program review e 3-4
l l activities. It also demonstrates that the discrepancies are consistent with the types of L configuration control discrepancies identified in ACR 7007. l 3.4 EXTENDED CONDITION REVIEWS i .. I1 3.4.1 ContainmentIsolation Revi'e w
'Ibe recent identification by NU oflongstanding design deficiencies in auxiliary feedwater j system containment isolation valves was cited in the NRC letter of April 4,1996 to NU. The l letter requested a written response to support a determination under 10CFR 50.54(f) as to l whether the license for Millstone Unit 3 should be suspended, modified, or revoked. In addition to correcting the discrepant auxiliary feedwater system valves, NU initiated an independent assessment of all containment mechanical penetrations. This assessment was performed in l
l accordance with NUC PI-11 of the Configuration Management Plan. At the time of preparing this report, the independent assessment report was in draft form. The repon provides an item by item evaluation of each mechanical containment penetration and lists a number of discrepancies resulting from these evaluations. These discrepancies generally involve either the FSAR, the LLRT procedures or the ILRT procedure. Two potentially significant discrepancies involve the design temperature for two piping penetrations and tiv failure to correct ILRT results for
. penetrations not exposed to containment test pressus e.
The completion of the containment isolation independent assessment report in fmal form and the resolution of the discrepancies identified in this report is expected to be an effective extent of condition response to the adverse condition resulting from the deficient auxiliary feedwater l system containment isolation valves. 3.4.2 Electrical Separation Walkdowns l The vertical slice review of the reactor trip system resulted in the identification of a number of violations of separation criteria between safety related electrical cables in different trains. The vertical slice review was expanded to sample additional electrical systems and similar discrepancies were identified. Based on these vertical slice results, NU has initiated planning for additional walkdowns of electrical systems to inspect for cable separation discrepancies. Although plans have not been finalized at this time, an effective walkdown effort is expected to include the following steps:
- Prepare walkdown guidance document and data sheets
- Train walkdown team members
- Perform walkdowns and record discrepancies 3-5
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- In parallel with walkdowns, determine need to develop and justify altemate separation criteria
- Categorize walkdown discrepancies and identify resolution actions 1
- Revise design and licensing docuhnts as needed to reflect resolution ,- actions )
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3.4.3 Electrical Calculatidds and Drawings l De vertical slice review of selected electrical systems identified a number of discrepancies in electrical calculations and drawings. Based on the vertical slice results, NU is plan-%g an expanded review of electrical calculations and drawings that extends beyond the system sample selected for the vertical slice review. Plans had not been finalized for this expanded review at the l time this report was prepared. l l 3.4.4 FSAR Chapter 15 Design Basis Review
- The ACR 7007 - Event Response Team Report identified that the Millstone Unit 1 FSAR contained iaaccuracies. The Millstone Unit 3 vertical slice system review also identified similar discrepancies with the Unit 3 FSAR. The review has been completed and a preliminary report has been prepared which documents the results of the review. De preliminary report contains a number of observations and recommendations for resolution which define actions required to conform the Unit 3 safety analyses described in the FSAR accurately to the accident analyses performed by the NSSS vendor (Westinghouse).
3.4.5 VendorInformation I l The vertical slice system reviews identified a number of discrepancies in the control and implementation of vendor supplied information relating to the operation and maintenance of their equipment. NU has initiated a near term review of vendor information covered by Generic Letter 90-03. This review will serve as an expansion of the sample of vendor information examined in the vertical slice reviews and will also provide a basis for defining appropriate longer term actions. 3.5 ENGINEERING PROGRAM ASSESSMENTS i
- 3.5.1 Assessment Overview
! Dese assessments cover 19 engineering topical areas which have been established in response to ! regulatory initiation. Each program, listed below, has been reviewed for: 3-6
Coverage oflicensing commitments of the program. Technical adequacy of the program Configuration management of the program n Each program review is conducted in accordance with a general guidance document, " Review of Engineering Programs"(Reference 1) and,the applicable project instruction contained in the Configuration Management Plan. As. indica' ted in this document, each of the 19 programs should have a Unit 3 specific position paperprepared by the System Review Team in accordance with NUC PI 6 and PI 1. Each program review covers the areas bulleted above. The results of the Configuration Management internal review performed in accordance with PI 10, are submitted to the Configuration Management Review team for extemal review. Any program discrepancies identified are documented on an Unresolved Item Report (UIR) in accordance with PI 5 and PI 14 or on an Adverse Condition Report (ACR). All identified discrepancies are also included in the individual assessment reports for each topical area. The 19 programs that are reviewed are: l
- 1. ATWS Program
- 2. Control Room Design Review Program
- 3. Electrical Equipment Qualification (EEQ) Program
'4. Erosion / Corrosion Program l S. External Events / Hazards Program
- 6. Generic Letter 89-10(MOV) Program i
- 7. HELB/MELB Program i
- 8. Inservice Inspection
- 9. IPEEE Program
- 10. Master Equipment and Parts List (MEPL) Program i
l 11. Regulatory Guide 1.97 Compliance Program
- 12. =
Safe Shutdown /10CFR 59 Appendix R Program
- 13. Separation / Independence and Diversity Program
- 14. Setpoint Control Program
- 15. Single Failure Program
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- 16. Station Blackout Program
- 17. 10CFR50 Appendix J Compliance Program
- 18. USI A 46 Program
- 19. Heavy Loads Program , ., -
i i . Reviews of these engineering programs h'aye been initiated and they in various stages of completion. , 1 ) I i 3-8
SECTION 4.0 INTEGRATED ASSESSMENT METHODOLOGY i The methodology employed to perform the integrated assessment is as follows: 4.1 REVIEW BACKGROUND DOCUMENTS The integrated assessment team (Team) reviewed relevant background documents and plans l which contain commitments regarding individual programs which must be completed during l Phase 1. The purpose of this background document review was identify the individual programs 1 l to be included in the integrated assessment. The documents reviewed included the Configuraticn , i l Management Plan (CMP) contained in Reference 1, the Project Instructions (PIs) employed to I l implement the CMP (see References 3 through 18), the Operational Readiness Plan (Reference l 19), the MP3 Restart Criteria (Reference 20), and the letter to the NRC dated June 20,1996 I (Reference 21). Discussions were also held with various individuals to identify programs not ; included in the documents but which have, nonetheless, been established to satisfy some portion of required restart activities. 4.2 INTERVIEW KEY INDIVIDUALS l The Team interviewed key individuals responsible for the individual restart programs in order to understand the purpose, scope, review approach and major results of each program. In addition, l the number ofindividual program participants, their organizations, and the total effort in person-months was identified. The checklist employed for these interviews is contained in Attachment
- 1. Completed checklists for the individual programs are contained in subsequent attachments, l and are referenced in the program descriptions in Section 4 of this report.
l l 4.3 PREPARE
SUMMARY
DESCRIPTIONS A summary description was prepared for each individual program and is provided in Section 4 of
- this report. It summarizes the interview information, as well as the information contained in I individual program reports and other documented information which is available. The l descriptions also identify the results of each program, summarized in a consistent format to the i extent practical. The desired format is that contained in the Vertical Slice Review, where the l results were presented in the form of(1) number and type of areas, key attributes, and specific items reviewed (attribute checks); (2) number, type, and % of discrepancies, and (3) the major cause(s) contributing to the discrepancies. In addition, a flow chart which provides an overview of all of the programs and their interrelationships has been prepared and is enclosed as Figure 1.
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l 4.4 INTEGRATE AND ASSESS RESULTS 4.4.1 Discrepancy Assessment The discrepancies from each of the programs are correlated and evaluated to identify key weaknesses and their cause, and to correlate these with the ACR-7007 findings. They are also evaluated with regard to the success criteria, and to reach an overall conclusion with regard to the need for any required Phase 1 program expansions. 4.4.2 ProgramImprovements Assessment In addition to specific discrepancies, the individual programs identify improvements needed to address programmatic issues. These improvements are correlated to ensure the programmatic
- weaknesses identified are covered. In addition, the programmatic weakness are correlated with
! ACR-7007 findings. 1 l 4.5 DEVELOP CONCLUSIONS AND RECOMMENDATIONS l l l Conclusions and recommendations were developed based on the results of the integrated assessment. ! l l t I l l f 1 i l l 4-2
SECTION
5.0 REFERENCES
l l
- 1. Configuration Management Plan, CMP, Rev. 2, June 10,1996 l 2. Millstone Unit 3 Project Instructids 2 (PI 2), MP 3-Specific Assessment: Report to MP3 l UPM and MQC on PI 2 Team Fiddings, Revision 1, June 21,1996 l
- 3. Document Identification anh Retrieval, NUC PI 1, Rev. O, May 15,1996
- 4. Unit - Specific Assessments, NUC PI 2, Rev. o, May 17,1996
(
- 5. Employee Concerns, NUC PI 3, Rev.0, May 15,1996
- 6. Millstone Unit 3 Walkdowns, NUC PI 4, Rev.1, May 24,1996 l 7. Millstone Unit 3 System Readiness Review, NUC PI 5, Rev.1, May 24,1996 l
l 8. Licensing Renews, NUC PI 6, Rev. 0 (une.ated)
- 9. Graded System Review, NUC PI 7, Re ,. O, May 23,1996 i
- 10. Plant Verification and Readiness Team, NUC PI 8, Rev. O, May 23,1996 i l
l l
- 11. Design Basis Documents, NUC PI 9 (later) l
- 12. Configuration Management, NUC PI 10, Rev. ), May 10,1996 .
- 13. Independent Assessment, NUC PI 11, Rev. 0, May 15,1996
- 14. Short and Long Term Communication, NUC PI 12 (later)
- 15. FSAR Changes,NUC PI 13 (later)
- 16. Configuration Management Plan Project Process Administration Instruction, NUC PI 14, i Rev 0, May 10,1996 (Rev. 2 is pending)
- 17. Selected Millstone Unit 3 System Reviews, NUC PI 15, Rev.1, June 20,1996
- 18. Licensing and Design Bases V/alkdowns, NUC PI 16, Rev. O, May 23,1996
- 19. Millstone Unit 3, Operational Readiness Plan, draft, June 21,1996
- 20. MP3 Restart Criteria (undated) 5-1 i
- 21. Letter to the U.S. Nuclear Regulatory Commission from NU (T. C. Feigenbaum),
Millstone Nuclear Power Station, Unit No. 3, Response to May 21,199610 CFR 50.54(f) Letter
- 22. Horizontal Slice Review Team (HSRT) Final Reports, M3-UPM-96-002, dated July 1, 1996. .
i 1 e O d d i i l l l l l B m i 5-2
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SYSTEM VERTICAL SUCE REVIEW lillATRIX 5 i p pensees C- - . Liceneeng Cy " & ^^ 1 2 3 4 S S 7 5 e to 11 12 13 14 15 16 17 18 to 28 21 22 23 24 25 28 en.e e_.ap m.am m s
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Pesser ToteI DIserops ties 5 2 4 1 2 - 1 15 CIsos 1E 125 VDC Asetute Chotse 2 to S 12 6 1 3 2
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Posser Tabul Deutsepenties 7 2 1 2 1 1 14 Astenuto Chette 2 7 e 4 te 1 4 5 e 1 e 7 1 1 12 e 1 e e 2 7e seo causes . Generatur TetsI DIserspenties 3 2 2 2 1 1 1 1 13 120V VIIsl AC Alttuto Chette 8 3 14 3 1 1 1 1 2 1 1 2 1 1 1 3e .! Total Disempantdes 8 1 2 1 1 1 1 1 1 1 1 ty Cet. 8kg FheBert Actresse Chetfe 2e 22 50 2 4 25 22 20 17 4 to 2 88 29 22 14 21 13 e 12 5 3 2e 3 e 40 478 4 Venessest Totaf Dietsspenties 4 to 1 3 1 5 2 13 1 3 1 2 1 1 4 1 53 _j steesgess plast Albeste Chotse 1 1 5 22 2 4 2 15 11 15 2 2e 8 .J 1 11 17 1 1 30 4 38 83 27e ,f , stesused Tetel Deutsepent$es 1 2 1 1 1 3 1 e 18 , P0ftV S CJe Aettuto Checke 2 2 24 2 25 3 8 1 3 1 18 16 5 4 to 15 2 2 2 4 1 3 152 If SasseyVtfues Tegel DIntsepancies 1 4 9 3 4 1 2 15 [ Sune A81sthute CIsottte 47 102 231 27 142 357 12e SS 110 27 141 SS 254 es 133 e7 173 3e 152 132 25 14 142 41 75 424 3273 [ Sisne Deetsopenties 11 1 47 4 to 13 8 2 15 2 11 2 de 11 to 2 1 e 11 3 4 1 28 e g 1 257 :j 7_ _ ,_ DIetsopentles 15 % 1% 2e% 15% 13% 4% 8% 3% 13% 7% 8% 4% 18 % 11% e% 2% 1% e% 7% 8% te% 7% 10 % e% 11% e% e% seosariCasoce CtAssir:CATsDes steatert glosne 7 e 27 3 5 7 3
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SUMMARY
OF DISCREPANCIES NOTED IN HORIZONTAL SLICE REVIEWS *
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y 2 2 1 1 3 7 1 1 1 20 3301 Reactor Coolant 1 4 3 1 6 3 3 20 > 3304 CVCS: Chem & Volume 4 1 3 9 l 3306 injection: Recirc Spray 1 4 1 1 1 7 3307A injection: LPSI 1 4 5 , 3307B RHR 1 1 1 2 1 1 12 4 1 26 l-3307C QSS/RWST Recirc-RST 1 1 ' 2 1 2 2 3 1 1 2 5 1 20 3308 HPSI ' 2 2 4 3 1
** 16 9 3 40 3309 QSS/RWST Recirc-OSS 2 3 12 3 7 28 ,
3312A Contamment Structure 1 1 3 -m - 2 1 7 l 3314F HVC/HVK 3314H EDG Room Vent 1 2 1 1 1 7 1 7 7 ain am/St Generator _ _ _ _1_ _ _ _ _ 1 _ _ _ _ _ _ _2_ _ _ _ _ ._ r 4 3 6 1 1 21 . 3322 Auxiliary Feedwater 2 2 1 1 3 2 1 11 14 1 9 42 3326 Service Water 1 2 4 2 2 1 7 3 22 3330A RPCCW 1 6 2 1 1 1 l 33300 CVCS: Charging Pump 1 ' 1 2 3330E St Pump Cooling 1 1 2 4 4 3343 Elec. AC: Vital 4160 Volt 1 1 1 1 1 1 6 1 3344A Eke. AC: Vital 4BO Voh 1 1 3 2 2 8 33448 Elec. AC: Vital MCCs 1 1 3 5 33458 Vital 120 DC Control 1 2 2 5 3345C 125 Volt DC Control 9 1- 2 5 4 3 1 2 3 6 4 44 3346A E.py,4 Diesel 2 1 1 4 2 8 3346B Emergency Diesel: Fuel Oil 1 1 3 7 1 3346C 125 Volt DC Control ? 3 1 3347 Normal Power System 1 1 1 1 1 5 3347C MTX/GML 1 17 1 5 1 2 1 5 2 3405 ESAS: EGLS 1 1 6 1 11 3406 Reactor Protection: SSPS 1 1 1 4 2 5 1 13 3407A ESAS: West. 7300 Rackt Discrepancy Totals 13 0 11 1 1 41 il 0 1 19 46 14 54 0 1 0 2 0 3 8 0' 1 109 0 51 35 438
- DOES NOT INCLUDE VSRT ITEMS Page1
SECTION 7.0 ATTACHMENTS
- 1. Configuration Management Action Plan
. \. \. -
- 2. Integrated Assessment MP3 Restart Programs Summary and Status Review Checklist i
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l Attachment 1
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II CONFIGURATION MANAGEMENT ACTION PLAN I t 1 7-2
i 1 l l ACTION PLAN i. TITLE: Configuration Management oEo #2: Rebuild Resulatory Cmru~ (see Figure 1) iniomive n: confisurmion Manasanen: DESCRIPTION: [f ., ! \\ The objective of the Configuration Management Plan (CMP) is to ensure effective communication links are establihhed for the following attributes:
- 1. Design and Licensing Basis (DB/LB)
- 2. Physical Plant Configuration
- 3. Facility Operations and Maintenance 1
These objectives will be met in a two phase effort: Phase 1: Assess the accuracy and completeness of the design and licensing basis i documentation (DB/LB), the conformance of plant design, operation and maintenance with the DB/LB and the effectiveness of programs, processes and procedures which maintain plant conformance with the DB/LB. l l Phase 2 (near term): Correct significant identified deficiencies in DB/LB and plant ! design and configuration identified in Phase 1, and initiate update of programs, processes j l and procedures which ensure the plant configuration is designed, maintained and operated consistent with the DB/LB. Phase 2 (long term): Complete update of all documentation and CMP and trend KPI's to l' verify effectiveness of CMP and identify required enhancements. EXPECTED RESULTS: 1 Effective, fully implemented Configuration Management will ensure that each of the three CMP attributes are complete and consistent with the others. This includes consistency with the established LB/DB of the plant, an operating configuration that is ! consistent with procedures, and maintaining critical documentation to support plant operations. The expected results within each phase ofimplementation of the plan include: Phase 1: Assessment of the degree oflinkage,if any, between MP3 and MP1 ACR-7007 root cause categories and identification of areas requiring corrective action. l Phase 2 (near term): Definition and implementation of near term corrective action. I
AW 6 Phase 2 (long term): Completion of longer term corrective action and monitor, trend, l and implement long term enhancements ACTIONITEMS: l Phase 1: This phase is complete. Lhge to the root cause categories of MP1 ACR-7007 which led to deficiencies in cunpnt configuration and in effectiveness of ' l administrative programs, procesAes add procedures has been confirmed by a combination
- of horizontal and vertical systenneviews, evaluation of Engineering Programs and assessment of configuration control procedures. Corrective actions have been identified l
as reqmred in five areas covering current configuration and administrative programs. j Phase 2 (near term): Develop and initiate corrective action in the five areas identified in Phase 1. These include: (1) Review and update appropriate sections of the FSAR (including review of past licensing commitments), critical calculations, technical specs, DBDP's and upgrade performance of 50.59 analyses i l (2) Review and correction of ops critical drawings, address MEPL program and upgrade of vendor technical information control program (3) Initiation ofimproved corrective action program 1 (4) Review and upgrade of operating and surveillance procedures and inspections, l address operator burdens and MCB deficiencies, address bypassjumpers and temporary modifications, review and address PMMS program, and correct significant material condition deficiencies. In addition, complete system readiness reviews on remaining safety related systems. (5) Initiation of a configuration control program, including the DCM, to ensure effective communication links between programs, processes and procedures that is consistent with industry exparience for multi-site plants and includes effective records management. i Phase 2 (long term): Complete configuration control program, correct lower significance deficiencies, complete implementation of upgraded documentation, l programs, processes and procedures, prepare DBD's for key systems, establish technical ! data bases and initiate trending of KPI's to verify effectiveness of upgraded programs, processes and procedures. l l i i
]
l PERFORMANCE ME ASUREMENTS: Phase 1: This Phase is complete Phase 2 (near term) KPI's for Design Eiigineering Director: . i .. - (1) Establish a plan to update the MP-3 FSAR, critical calculations, tech specs, DBDP's, ops critical drawings, and MEPL; Report weekly progress against the plan. (2) Revise the 50.59 procedure. Train staff. Measure the effectiveness of the new procedure by the number of discrepancies identified through monthly self-assenments, QAS audits, and independent assessments. (3) Revise the vendor technicalinformation control program. Train staff. Measure the effectiveness of the new program by the number of discrepancies identified through monthly self-assessments, QAS audits, and independent assessments. (4) Initiate the configuration control program, including revised programs, processes and procedures. Train staff. Measure the effectiveness of the new programs by the number of discrepancies identified through monthly self-assessments, QAS audits, and independent assessments. 1 Phase 2 (long term) KPI's for Design Engineering Director: (1) ACR's Related to Licensing Basis and Desien Basis Documentation Measure the trend in ACR's with a root cause related to discrepant licensing basis l or design basis documen'ation. (2) ACR's Related to Programs. Processes. and Procedures i Measure the trend in ACR's with a root cause related to discrepant Programs, Processes, and Procedures. (3) ACR's Related to Physical Plant _Conficuration Control Measure the trend in ACR's with a root cause related to physical plant departures from the design and licensing basis. (4) ACR's Related to Configuration Control of Facility Operations and Maintenance Measure the trend in ACR's with a root cause related to operations and maintenance departures from the design and licensing basis.
OWNERSHIP / DEPARTMENT: Sponsors - E. DeBarba/P. Richardson (Director MP2) l Action Plan Manager - J. Vargas (Director of Engineering) Task Manager - , Task Team - ; e' . i .
- I' SCHEDULE ,;
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l Attachment 2 l Date: Reviewer: INTEGRATION ASSESSMENT MP3 RESTART PROGRAMS i I
SUMMARY
AND STATUS REVIEW CHECKLIST
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- 1. PROGRAM NAME:: l
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. l 1
- 2. LEADER / COG MGR:
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- 3. PARTICIPANTS: Totalof_ personnelfrom: i
- 4. PURPOSE (ACR-7007, CMP, ORP):
1. 2. 3. 4. 5.
- 5. SCOPE (systems, programs, processes):
l Coverage as follows: Attribute Checks: Total attribute checks made. Attribute Categories:
- 1. l i
l 2. 3. 4. 5. l l 6. APPROACH: 1 1. 1 . 3. 4. 5. I 6.
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- 7. PROCESS CONTROLS: 1. ProjectInstruction PI i (ProcedureNo. AndTitle ) 2.
I 3. 4. 5. i
- 8. EF70RT: person-months l
l 9. RESULTS: , p-4 - Summary:: Example findings as follows: t I t
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- 1. Favorable I
i ! 2. Not Favorable i' F 1 l
- Attribute results
i Category Items Found RestartItems Non-restart items ; l amanw: :s i Total Cheeks $ Rf %
. f@muag#_ B@. GNWn&pMg>In Discrepancies ( %) ( %) ,
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- 10. DOCUMENTATION: )
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- 4. i
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