ML20129E624
| ML20129E624 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/11/1996 |
| From: | Rooney V NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9610280116 | |
| Download: ML20129E624 (70) | |
Text
- p u to g Yh0 g k UNITED STATES c E NUCLEAR REGULATORY COMMISSION b f WASHINGTON, D.C. - =1 i
October 11, 1996
%.....o LICENSEE: Northeast Utilities Service Company i FACILITY: Millstone Nuclear Power Station, Unit No. 3
SUBJECT:
INDEPENDENT CORRECTIVE ACTION VERIFICATION MEETINGS, SEPTEMBER 24, 1996 PARTICIPANTS IN AFTERN0ON MEETING:
EC NORTHEAST UTILITIES R. Zimmerman, NRR/ADPR T. Feigenbaum, Exec. VP E. Imbro, ICAVP Team Manager J. Cowen, Recovery Officer L. Plisco, ICAVP Team Leader M. Brothers, Millstone Unit 3 P. McKee, NRR/PD/NU Directerate T. Harpster, Lic. Dir.
J. Durr, RI/DRP/BC J. Vargas, Eng. Dir.
T. Cerne, RI/ SRI P. Grossman, Eng. Dir.
V. Rooney, NRR/PM J. DeLoach, Exec. Asst.
On September 24,1996, at 1 p.ri. in the Leland F. Sillin Jr., Nuclear Training Center at Waterford, Connect' cut, a management meeting was held to discuss the l conduct and NRC oversight of the Independent Gorrective Action Verification l Program (ICAVP). The NRC order dated August 14, 1996, required that the ICAVP be conducted by an independent contractor to verify the results of corrective actions intended to resolve design control problems at Millstone. The meeting i was open for public attendance. The meeting consisted of a presentation of l
the status of ICAVP related activities by Northeast Utilities (NU), followed by a presentation by the NRC fleshing out the details of staff plans and expectations for the ICAVP. An opportunity for public comment and questions was provided at the end of the management meeting; although a meeting with members of the public to discuss the same information was also provided at the Waterford Town Hall at 7 p.m. on the same day.
NU PRESENTATION:
l -
ICAVP requests for proposal on a time and material contract have l been issued to:
Sargent and Lundy - Chicago, Illinois Burns and Roe - New Jersey Parsons Power - Reading, Pennsylvania ICAVP bids due week of October 7. f NRC approval of NU's selected contractor will be requested in k writing.
9610280116 961011 PDR ADOCK 05000423 k P PDR l _
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The Millstone Unit 3 FSAR will be 100% updated before restart.
The " annotated" FSAR is now 95% complete. FSAR review is now done l l in-house rather than with contractors. I l -
System Specific Assessments (SSA's), which confirm that all statements of fact in the FSAR are true, will be performed on all maintenance rule group 1 and selected group 2 systems.
NRC PRESENTATION: l ICAVP and NRC's oversight of ICAVP will verify on a " smart sampling" basis effectiveness of NU's corrective action program, i and implementation of the program. Oversight team will consist of l about eight handpicked people - some from outside the NRC.
NRC will consider financial and work involvement of review organization and review team members to achieve independence ;
! before approving an ICAVP contractor. I ICAVP review will begin after NU has completed the configuration management program for about half the risk-significant systems in order to not unduly delay Millstone Unit 3 restart. NU should realize, however, that if the ICAVP uncovers inadequacies, programmatic doubts will arise that may significantly delay completion of the ICAVP process.
NRC approval of Millstone Unit 3 restart will only occur after Commission approval, following successful completion of the ICAVP, 0350 process, and employee concerns process changes.
ICAVP will be conducted with high public visibility, including multiple public meetings. State and advisory council have been invited to observe process.
Handouts for the meeting from both NRC and NU are attached.
NRC PARTICIPANTS IN EVENING MEETING:
- R. Zimmerman, NRR/ADPR l E. Imbro, ICAVP Team Manager L. Plisco, ICAVP Team Leader P. McKee, NRR/PD/NU Directorate J. Durr, RI/DRP/BC On September 24,1996, at 7 p.m. at the Waterford Town Hall in Waterford, Connecticut, a meeting was held to discuss the conduct and NRC oversight of the ICAVP with the public and to provide an opportunity for public comments and questions. The meeting consisted of a presentation of the details of l
l l
l staff plans and expectations for the ICAVP, with public questions and comments both during the presentation and at the end of the presentation. A summary of l ICAVP status, including the points discussed above, were presented in the
! evening meeting, and the attached NRC handouts were also provided.
PUBLIC COMMENTS:
A petition with 551 signatures was presented urging that the NRC
- remove NU from any involvement in the selection of the restart independent verification team. The petition and signatures are attached.
Concerns were expressed regarding:
- the extent of activities required of NU prior to plant restart, the independence of review by any organization selected or paid for by NU, e the confidentiality provided for "whistleblowers" by the NRC, the need for removal of NU and NRC people with past Millstone involvement from the restart review and approval process, a the use of a " statistical sampling" basis to verify restart readiness, e need for rereview of cases of workers fired last winter, e the feeling that NRC is not really listening, e a desire that Haddam Neck be added to the watchlist, e a desire that there be a group responsible for overseeing the NRC.
(Original Signed By)
Vernon L. Rooney, Sr. Project Manager Northeast Utilities Project Directorate Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-423 Attachments: Northeast Utilities Handouts NRC Handouts Petition cc w/ attachments: Sea next page i
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DATE 10/9/96 10/10/96 10/A/96 0FFICIAL RECORD COPY l
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Northeast Utilities Service Company Millstone Nuclear Power i Station Unit 3 CC*
Lillian M. Cuoco, Esq. M. H. Brothers, Nuclear Unit Director Senior Nuclear Counsel Millstone Unit No. 3 Northeast Utilities Service Company Northeast Nuclear Energy Company P.O. Box 270 P.O. Box 128 ;
Hartford, CT 06141-0270 Waterford, CT 06385 Mr. Kevin T. A. McCarthy, Director Burlington Electric Department M9nitoring and Radiation Division c/o Robert E. Fletcher, Esq. ;
Department of Environmental Protection 271 South Union Street 79 Elm Street Burlington, VT 05402 l Hartford, CT 06106-5127 i Mr. M. R. Scully, Executive Director l Mr. Allan Johanson, Assistant Director Connecticut Municipal Electric Office of Policy and Management Energy Cooperative Policy Development and Planning Division 30 Stott Avenue 80 Washington Street Norwich, CT 06360 Hartford, CT 06106 Mr. William D. Meinert Mr. S. E. Scace, Vice President Nuclear Engineer Nuclear Reengineering Implementation Massachusetts Municipal Wholesale Northeast Utilities Service Company Electric Company P.O. Box 128 P.O. Box 426 Waterford, CT 06385 Ludlow, MA 01056 Regional Administrator Mr. E. A. DeBarba Region I Vice President - Nuclear Technical U.S. Nuclear Regulatory Commission Services 475 Allendale Road Northeast Utilities Service Company King of Prussia, PA 19406 P.O. Box 128 Waterford, CT 06385 First Selectmen Town of Waterford Joseph R. Egan, Esq.
Hall of Records Egan & Associates, P.C.
200 Boston Post Road 2300 N Street, NW Waterford, CT 06385 Washington, D.C. 20037 Mr. P. D. Swetland, Resident Inspector Millstone Nuclear Power Station I c/o U.S. Nuclear Regulatory Commission P.O. Box 513 Niantic, CT 06357 Mr. D. B. Miller, Jr.
Senior Vice President Nuclear Safety and Oversight Northeast Utilities Service Company P.O. Box 270 Hartford, CT 06141-0270 l
l
Northeast Utilities Service Company Millstone Nuclear Power Station Unit 3 cc:
Mr. F. C. Rothen Vice President - Nuclear Work Services
( Northeast Utilities Service Company l P.O. Box 128 l
Waterford, CT 06385 l Mr. Ernest C. Hadley, Esq.
l 1040 B Main Street -
P.O. Box 549 West Wareham, MA 02576 Mr. John Buckingham Department of Public Utility Control Electric Unit 10 Liberty Square l
New Britain, CT 06051 Mr. James S. Robinson l Manager, Nuclear Investments and
! Administration i New England Power Company l 25 Research Drive Westborough, MA 01582 Mr. B. D. Kenyon .
l President - Nuclear Group _I Northeast Utilities Service Company
! P. O. Box 128 l Waterford, CT 06385 j i Mr. Ted C. Feigenbaum Executive Vice President and Chief Nuclear Officer
, Northeast Utilities Service Company l c/o Mr. Terry L. Harpster Director - Nuclear Licensing Services l P.O. Box 128 l Waterford, CT 06385 t
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l-MEMORANDUM DATED October 11, 1996 o
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NORTHEAST UTILITIES HANDOUTS
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Agenda Independent Corrective
- overview r.c. Feigenseum i Action Verification Program
- conneuravon m.u.arothers ;
(ICAVP)
Program Status Ted C. Feigenbaum
- System Specific M. u. srothers Executive Vice Presidentand Assessments ChiefNuclear OMicer
, September 24,1996
- ICAVP Status R.J. DeLoach
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%) N.,thvs~ sr~. aw u e,a ) v.rt.h s st s, aw u e, Configuration Management Configuration Management Program (CMP)
Program Status
- objectives and . ,,,,,, ,,,,ii.no. .iin une System Specific resulations :
-identify and resolve design and Assessments i;,,,,io, ,,,,i, ,,,i,wn i.,
M.H. Brothers ,
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l Configuration Management CMP Actions: What's Done?
Program (CMP) . conducted detailed reviews to
- Three step process determine scope of discrepancies
-identify licensing and design basis -configuration control on 32 of 40 deficiencies Procedures
-Correct deficiencies - diagnostic review on 11 safety-shnmcantsyskrns
- Avoid deficiencies in the future through an effective Corrective Action Program -system readiness reviews on 41 Maintenance Rule category 1 and 2 systems l
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CMP Actions: What's Done? o- CMP Actions: Findings
- Extended reviews (examples):
? significant discrepancies identified
-contsinmentisolation in the accuracy and completeness of l
-FSAR Chapter 15 anayses Design and Licensing documents: I
~ **MC*I**P*'*U*" - FSAR, Technical Specifications, and
- Engineering programs (examples): Licensing Commitments
- Material Equipment and Parts List (MEPL) -Design Basis Document packages
-fire protection - Safety Evaluations (10CFRSO.59)
- equipment qualification (EEQ) -effectiveness and timelitiess of 1
- station blackout (SBO) corrective actions !
-individual plant exam t extemal events -VendorTechnicalInformation I
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CMP Actions:In Progress CMP Accomplishments l
- Actions identified in our MP3 '
Operational Readiness Plan (ORP): ;
- lasued new Design Control Manual - update the FSAR / ensure consistency l with the Technical Specifications and l
- Updated Design and configuration TechnicalRequirements Manual Control Procedures
- update drawings and calculations, DBDP's, and Safety Evaluation .
procedures
- perform System Specific Assessments l
Q)22% ocaw u e k)02% ocaw u oo System Specific Assessments (SSAs) ;
- Will conduct on all Maintenance Rule Group 1 and selected Group 2 systems ICAVP Status
- Includes Auxiliary Feedwater, service Water, Electrical Distribution' R.J.DeLoach Emergency Ac Power g ICAVPProjectManager(NU)
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4 Contractor Selection: Approach
- Competitive Bid Process Cone %We*lection:Criteria ficast %
-standard commercialpractice
- Initial tasamunog ad Prospective Bidders j
- pre <letermined, objective criteria - muttpsEscipliieGengineering firm
- Request for Proposals -reseentneresshd divsrsity 1
- NRC's Confirmatory Order -fina~rilliff TMlindependence I
-statement of work Millstone 3 only -qusM hy personnel
- commercial terms and conditions
- Bid EWluaW
-site procedures and policies - de criteria l
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Contractor Selection: Criteria Contrdbt#PB~ e lection: Criteria (continued) ,s i .stN4iRntinued) l l
- Essential Evaluation Criteria
- AdditRftfdl 3E4Wluation Criteria
-independence from NU and NU's design -lenll oft @te commitment l contractors
-technical capabilities in specific areas
-rih
' ct ynce nd leadership experience
-team members who satisfy , , ,g Confirmatory Order requirements -prpgtergatan satisfaction of Cgrmagorder
-information technology -
() U,*,,, sy . a w m ,,,, - plan for communications & reporting Contractor Selection: Status Contraictor Selection: Milestones
- Request for Proposals Sent to 3
- Kepner-Tregoe decision-making l methodology l Prospective Bidders on 9/11/96
-architect engineerfirms * $hrdhNview l -limited prior work for NU
- Phblic input
-large, skilled, experienced engineering
- NRC apptool sta h ,,,ae IC -3%gler
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Responsibilities - Contractor Responsibilities - Contractor
- select team members (conunuee
- Establish scope of work and sampling
- Participate in public meetings with plan the NRC, the State, and NU
- Conduct process reviews,
- Provide reports with imdings and documentation reviews and system recommendations (NRC / State / NU) walkdowns
- Receive Icomment on NU
- Provide quality oversight of process to disposition of ICAVP findings ensure integrity and independence Q)E*a"l%~ aw u ~,o ()ECsy.- aw u ,
Responsibilities - NRC Responsibilities - NU
- Award contract forICAVP
- Review and approve ICAVP Contractor and team members
- Develop interface protocol to ensure independence and integrity of process
- Review and approve ICAVP scope, plan, and schedule
- Participate in meetings and teleconferences
- MonitorICAVP activities, proceedings, and results (with representatives of the
- Review and disposition ICAVP findings and Connecticut Nuclear Energy Advisory reconmndations Council as observers)
- Respond to requests from the NRC,ICAVP Team, State and public -
- Provide for site access , logistics support,
) vom%,sr. ICA w u teg and administrative / Clerical assistance Communications and Reporting Summary
- All contractor communications in parallel to the NRC and NU
- Bids due next week
- Periodic meetings and teleconferences for
- NRC will be informed in writing of:
information exchange (with NRC -outcome of bid evaluation oversight) - NU's formal request for approval
- Monthly status review meetings with the l NRC and Connecticut NEAC (by NU and separ tely by the ICAVP Contractor)
- Electronic system (E4 nail) for routine
- information requests and responses 4 ,/u vs .sy.== _ oe us*tmo l
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MP3 GROUP 1 SYSTEMS SAFETY RELATED AND RISK SIGNIFICANT l System Group Auxiliary Feedwater: Auxiliary Feedwater(AFV4 1 CVCS: Charging Pumps (CHG) 1 l CVCS: Charging Pumps Cooling (CCE) 1 CVCS: Chemical & Volume Control (CVC) 1 Containment Containment isolation (CNT) 1 S 1 E_SAS: EGLS (ESA) l ESAS: Westinghouse 7300 Racks (ESA) 1 ESF: Injection: Accumulators (SIL) 1 ESF: Injection: HPSI (HPl) 1 ESF: Injection: LPS! (LPI) 1 ESF: Injection: RWST & Recirculation (OSS) 1 ESF: Injection: Recirculation Spray (CRS) 1 ESF: Injection: Residual Heat Removal (RHR) 1 ESF: Injection: St Pp Cooling (CCl) 1 ESF: Quench Spray: Quench Spray (OSS) 1 Electrical- AC: Vital 480 volt (ESO) 1 Electrical- AC: Vital MCC's (MCC) 1 Electrical- AC: Vital 120 vac (EVI) 1 Electrical- AC: Vital 120 vac inverters (EVI) 1 Electrical- AC: Vital 4160 volt (ES4) 1 Electrical - DC: DC 125 vde - Control (EDC) 1 Electrical - Gen: Normal Transformer (TRN) 1 Electrical - Gen: Reserve Transformer (RSE) 1 Electrical- Diesel: EDG Room Ventilation (DGV) 1 Electrical- Diesel: Engine (DES) 1 Electrical- Diesel: Fuel Oil (DFS) 1 Electrical- Diesel: EDG Generator (DGN) 1 Electrical- Diesel: EDG Lube Oil (DLS) 1 Electrical- Diesel: Starter (DSA) 1 Feedwater Feed Pump (FPS) 1 Feedwater. Feedwater(FWS) 1 Main Steam: Main Steam (MSS) 1 Main Steam: Steam Generator (STG) 1 Normal Power System (NPS) 1
- RPCCW
- RPCCW(CCR) 1 l Reactor Coolant Reactor Coolant (RCS) 1 I
Reactor Coolant SSPS (RPS) 1 Service Water Service Water (SWS) 1 Structures: Containment Structure (BGC) 1 l
Page 1 of 2
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f R: vision 0 s 09/12/96 Northeast Utilities :
Millstone Nuclear Power Station - Unit 3 !
Independent Corrective Action Verification Program (ICAVP) ;
Statement of Work i
i A. Backaround l
)
Currently, all three Millstone Units are shut down, placed on the NRC's " Watch ;
List," and cannot restart until authorized to do so by the Nuclear Regulatory j Comnfission (NRC). Because of long-standing concerns involving configuration l management, corrective actions, and oversight effectiveness, the NRC has l expanded their inspection and enforcement activities at Millstone Station by !
increasing resident and regional inspections, establishing NRC senior management oversight, planning for an Operational Readiness Team inspection j
, (focusing on human performance), and requiring a Manual Chapter 0350 restart '
l assessment.
l On August 12, 1996, the NRC met with Northeast Utilities (NU) in a public
- meeting at NRC Headquarters in Rockville, Maryland. The NRC stated that their inspections and NU's internal audits had identified several issues of concern at Millstone Station, namely: I Configuration (Design) Control, Implementation of Corrective Actions for known problems, l -
Implementation of Quality Assurance requirements (Oversight), and j
Compliance with the conditions of the Operating Licenses and NRC regulations.
Based on these findings, the NRC has determined that it is necessary to ensure that: (1) NU's programs to correct design control deficiencies at Millstone Units 1
1,2, and 3 are effective, and (2) identification of degraded and non-conforming
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conditions and implementation of corrective actioris are satisfactory, and can l effectively preclude repetition of these deficiencies in the future. Accordingly, l the NRC now requires an independent corrective action verification of the adequacy and results of the programs currently being implemented by NU that are directed at resolving existing design and configuration management issues.
This verification will consider the adequacy of NU's efforts to establish appropriate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices,
- verification of system performance, and implementation of modifications since
- issuance of the original facility licenses.
i 1
The NRC has directed NU to obtain the services of an organization, independent of NU and its design contractors, to conduct a multi-disciplinary review of Millstone Units 1, 2, and 3. This review is to provide independent verification that, for selected systems, NU's Configuration Management Program (CMP) has ,
identified and resolved existing problems (including making a "punchlist" of corrective actions, complete and prioritized based on safety significance),
documented and utilized the licensing and design basis, and established programs, processes and procedures for effective configuration management in the future. This review must be comprehensive, incorporating appropriate engineering disciplines, such that the NRC and the public can be confident that NU has been thorough in the identification and resolution of its design and licensing basis issues.
The ICAVP consultant will be required to establish a protocol to communicate with and report findings concurrently to both the Executive Vice President and :
Chief Nuclear Officer (T. C. Feigenbaum) at Northeast Utilities, through its Project Manager, and to the Director of Nuclear Reactor Regulation (W. T.
Russell) at the NRC through an NRC Project Manager. The NU Project Manager is R. J. DeLoach, Executive Assistant - Nuclear. The NRC Project Manager is E. :
V_ Imbro of the NRC's Division of Nuclear Reactor Regulation (NRR). l
~
B. Action This Request for Proposal (RFP) is seeking proposals for the development and [
performance of an Independent Corrective Action Verification Program (ICAVP) evaluation as enumerated in this Statement of Work and in. Attachments 1-6, '
which are incorporated herein by reference, for Millstone Unit 3 only.
NU expects that the ICAVP will be modeled after initial license verification reviews (e.g., independent Design Verification Programs) that were performed on certain plants after the Diablo Canyon design issues in 1981. As stated in tha attachments, the ICAVP covered by this Request for Proposal is intended to:
verify the adequacy of NU's implementation of design and licensing
~
requirements since initial plant licensing, and ensure that NU's Configuration Management Program is comprehensive and provides reasonable assurance that the Millstone design and licensing documentation is up-to-date, correct and consistent.
A copy of NRC materials covering an ICAVP is included as Attachment 1. NU's letter docketing our commitment to perform an ICAVP is included as Attachment
- 2. The NRC's confirmatory order containing specific details in this regard is included as Attachment 3. A transcript of our meeting with the NRC on 4
August 12,1996, to discuss the ICAVP is included as Attachment 4. The NRC's 2
Rev.0 09/12/96
Manual Chapter 2535 on Design Verification Programs is included as Attachment 5. NU's Gene.al Terms and Conditions for Nuclear Consulting l
Services, as well as requirements for unescorted access to Millstone Station and !
ALARA practices, are included in Attachment 6. The prospective ICAVP l consultant needs to cover the requirements of Attachments 1-6 in its proposal. '
Attachment 7 contains letters from parties that are not able to conduct the ICAVP in its entirety, but are willing to support others as needed. NU is forwarding this information to prospective ICAVP consultants solely as a matter of convenience, ,
en:! does not necessarily endorse, authorize, or approve the use of the l companies identified.
Enclosures 1-3 are summary documents that describe NU's Configuration Management Program, and certain other ongoing activities to identify and !
correct design and licensing basis deficiencies. This information is provided to help the prospective ICAVP consultant in determining the scope of review that will be required.
I C. Scope and Plan Reauirements in all respects, the Independent Corrective Action Verification Program must satisfy the confirmatory order (Attachment 3) issued by the NRC on August 14, 1996. Any discussion in this Request for Proposals should be read consistent with that objective.
The ICAVP shall provide a comprehensive examination of the design development and implementation for a selected sample, such as a system or portion of a system, on Millstone Unit 3. It will include onsite verification, on a .
sampling basis, of the design and configuration management process since l l
initial issuance of the unit's operating license.
The ICAVP will be conducted by an independent third party contractor for NU.
The review team must be comprised of a qualified engineering staff, based on experience and technical credentials. All members oPthe team, as well as the contractor, must demonstrate financial and technical independence from NU. In determining independence and qualifications, the primary focus will be on the individuals that will comprise the team. The independence and qualifications of i the contractor and members of the review team will be reviewed and approved I by the NRC prior to contract award.
As indicated in the NRC's confirrnatory order, Northeast Utilities has committed to undertaking an ICAVP that will include:
4 3
Rev.O ;
09/12/96
- Conducting an in depth review of selected systems which will address control of the design and design basic, since issuance of the operating license for Millstone 3; e Selecting systems for review based on risk / safety. based criteria similar to those used in implementing the Maintenance Rule (10 CFR 50.65);
e Developing and documenting an audit plan that will provide assurance that the quality of results of NU's problem identification and corrective action programs on the selected systems is representative of and consistent with that of other systems; 1
. Preparing procedures and schedules for parallel reporting of findings and recommendations by the ICAVP team to both the NRC and NU; and
. Preparing procedures for the ICAVP team to comment on NU's proposed resolution of the findings and recommendations.
The contractor will be responsible for developing a detailed ICAVP plan that will subsequently be reviewed and approved by the NRC prior to its implementation.
The contractor's proposal must include a detailed outline of its ICAVP plan. The scope of the plan will encompass modifications to selected systems since initial plant licensing and must include, in addition to the above attributes, the following elements for the selected systems:
. A review of engineering design and configuration control processes.
- Verification of current, as-modified plant conditions against design basis and licensing basis documentation.
. Verification that design and licensing basis requirements are translated into appropriate operating procedures, and maintenance and test procedures.
~
- Verification of system performance through review of specific test records and/or observation of selected testing on particular systems.
. Review of proposed and implemented corrective actions for NU-identified design deficiencies.
The third-party review will help NU demonstrate to the NRC and the public that when NU's Configuration Management Program is completed, NU will have thoroughly identified design and configuration control problems, corrected the design and documentation issues, and demonstrated that the Millstone Unit 3 plant can be restarted with confidence. Deficiencies in this regard will be 4
Rev.0 09/12/96
identified and reported by the independent verification consultant to both NU and the NRC.
D. Process i
The ICAVP will be a multi-discipline review that will address, as a minimum, areas such as mechanical, electrical, civil, structural, instrumentation and control for the systems selected. The ICAVP may include such details as checking or performing sample calculations; however, the emphasis should be on the systematic management of the total design process and the adequacy of NU's CMP.
The process must examine all facets of the design management process for a limited sample of systems as selected by the ICAVP consultant and approved by the NRC from initial full-power licensing to present. This may be modified by the NRC to be respcasive to unique conditions for a particular Millstone Unit, or known or suspected generic problems.
The evaluation will slart with development of a logic or flow network of the design process. Each functional entity within the design organization will be identified. For each of these entities, internal and external design interfaces !
which involve transmittal of design information will be specified. From this network, critical desic:i are as or areas with the least tolerance for error will also be identified. Within each of the design entities, the specific procedures for the verification and transmittal of design information will be reviewed for conformance with NU's overall Quality Assurance program, and to identify specific weaknesses in the design process. Based on the results of the review and the identification of critical design areas, a specific sample such as a system or portion of a system will be evaluated.
In examining design modifications to a system or structure and its specifications, the evaluation will focus on topics such as:
(a) Validity of design inputs and assumptions, -
(b) Validity of design specifications, (c) Validity of analyses, (d) Identification of system interface requirements, (e) Potential synergistic effects of changes, (f) Proper component classification, 5 i Rev.0 09/12/96 l
(g) Revision control, (h) Documentation control, (1) Verification o' as-built conditions, and (j) Other attributes as determined by NU and the ICAVP consultant, subject to NRC oversight and approval. j in addition, the ICAVP review also should address programmatic areas. For i example, classification of systems and components, design verification records, !
interface control and interdisciplinary review, consistency with the Final Safety l Analysis Report (FSAR), non-conformances and corrective actions, and audit l findings and resolutions should be sampled during the review process.
l l
E. NRC Oversicht The NRC is expected to provide close oversight of activities being performed by the ICAVP consultanE Specifically, the NRC Staff will likely- l l
- Approve the qualifications and independence of the ICAVP consultant, l organization, and team proposed.
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- Approve systems and/or subsystems selected for ICAVP review.
- Assess resolution of ICAVP findings and recommendations.
1 e Conduct parallel inspections; audit calculations; and review corrective action implementation for selected systems.
NRC restart oversight inspections (MC 0350) and the ICAVP l independent reviews are parallel and independent efforts.
l Conditions / actions required for restart will be determined by the l NRC Staff and approved by the Comniission.
The NRC Staff will be per:odically briefed on ICAVP program '
results and findings by NU and/or the ICAVP consultant.
Procedures for effecting this requirement shall be developed by the ICAVP consultant in conjunction with NU. !
I The NRC Staff shall be afforded access to ICAVP consultant records and information at all reasonable times. !
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1 Criteria to accept results or to reduce or expand the sample size used for the ICAVP shall be developed by the ICAVP consultant in conjunction with NU, and subiset to review by the NRC Staff.
The ICAVP consultant and NU shall maintain a strictly independent communications protocol. All requests for information shall be written. Phone calls and face-to-face meetings must consider the requirements of the- NRC, who will monitor the interactions to I
assure independence. Use of reasonable Information Technology, available to the NRC and public, shall be considered and included )
1 in the proposal. l F. Additional Information The ICAVP review for Millstone Unit 3 will not be initiated until NU believes that design and licensing basis deficiencies are complete for the population of systems (about 20) available for selection by the ICAVP consultant.
The ICAVP consultant and team will be afforded unescorted access to Millstone Unit 3 and associated facilities. Team personnel must be able to meet NU's and the NRC's requirements for unescorted access to vital areas. Also, all work
)
done by the ICAVP consultant shall be in accordance with their approved QA Program, i
The ICAVP consultant selection will largely be based on the probable effectiveness in demonstrating to the NRC and public that the consultant is highly qualified, technically competent, and capable of performing a truly independent, objective, and comprehensive review.
The project manager / lead for the ICAVP consultant will represent the ICAVP company in meetings and presentations to NU, the NRC, and the public. The ICAVP consultant should anticipate significant and frequent interactions with
, these entities.
The proposal must consider the likely existence of an executive level oversight board (committee) to which the ICAVP team would communicate with and keep informed of activities and results. The board may be comprised of one or more members - of the public and local business community around Millstone, academia, and highly respected nuclear industry leaders, in addition to senior i level representatives of the ICAVP consultant who are not directly involved in the !
ICAVP team. A Proposed independent Oversight Team (IOT) Charter is 1 included herein and provides a description of this requirement.
7 Rev.0A :
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-r---, .,---=.7- e.-- %:m *r -='T T m+- T '- +----- - - r- + W
I The following are general attributes that NU and the NRC are expected to consider in selecting / approving the ICAVP consultant, respectively:
1 Independence l -
Experience in Design Review Activities / Nuclear Plant Design Availability / Depth of Human and Other Resources Technical Experience of Human Resources Internal Quality Program Assessment Credentials of Key Project Personnel .
Ability to Make Regulatory Judgments on Findings and Recommendations NRC Experience
' Level of Corporate Interest
- NU expects to use a Kepner-Tregoe decision analysis methodology to select the ICAVP consultant, _ as described herein. NU's specific " Proposed Evaluation i Criteria for the ICAVP Procurement" are also included herein. Furthermore, the
- prospective consultants must address the attached "lCAVP issues to be t addressed by Contractors" in their proposals, and we will consider that
- information in our evaiuation of the ICAVP proposals.
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l KEPNER TREGOE MILLSTONE 3 ICAVP PROCUREMENT METHODOLOGY Backaround As directed in the NRC's August 14, 1996 confirmatory order, Northeast Utilities is committed to the Independent Corrective Action Verification Program (ICAVP) as an appropriate ' step in the Millstone 3 unit's restart plan. Because of the conditions !
surrounding this situation, it is recognized that the selection of the supplier for the ICAVP must be accomplished with the utmost objectivity, and that all aspects of the selection be documentable. Therefore, the company has decided to utilize the Kepner-Tregoe Decision Analysis process to make the supplier selection, and has retained the services of a Kepner-Tregoe professional to assist in the structuring of the selection.
Keoner-Treaoe Decision Analvsis (DA) Process in the 1950's, Drs. Charles Kepner and Benjamin Tregoe were employed by the Rand -
Corporation. Their assignment at the time was to help automate the decision making in use by Air Force missile launch officers in the defense of the country during the cold war. In practice, however, may officers used hunches and intuition, and the quality of their decisions was relatively poor. Subsequently, Kepner and Tregoe spent significant time in the business environment to understand how successful decisions were being made. They then articulated their findings into a " process" that could be transferred and replicated by others.
The most common pitfalls in decision making they discovered were that people became emotional about alternatives, and they failed to consider the risks around choices. The l DA process addresses these weaknesses by first focusing on the purposes of the decision, and lastly understanding the possible adverse consequences around what appears to be the best alternative (s).
Acolication of the DA Process to the Millstone 3 ICAVP Procurement The " purpose" of this procurement is to " Select an ICAVP Supplier." Using Kepner- !
Tregoe's facilitation, NU then developed criteria that defined the ideal candidate supplier to accomplish the ICAVP in a competent, comprehensive and independent manner.
The criteria were further refined into " Essential Criteria" and " Additional Criteria."
Essential criteria are aspects of the selection that must be present for the candidate supplier to be eligible to perform the project. If a criterion is not met, the supplier will 9
Rev.0 09/12/96
not be further considered to perform this effort. Additional criteria are measures of which eligible candidates can be directly compared to determine which one appears to be the best.
By making these selection criteria visible to candidate suppliers, as well as all other concerned parties, the intentions of the procurement should be clear and direct.
Further, once the supplier proposals are received, the application of the selection criteria to the various elements of each proposal will surface the important data and will rationally highlight the strongest candidate supplier.
When the best candidate (s) are identified, the project team will work to assess the possible adverse consequences of the candidate (s). This step will ensure that results can be managed and that the project can be accomplished effectively, with confidence of the public and NRC staff, and in full compliance with the NRC's confirmatory order.
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10 Rev.0.A 09/23/96
Proposed Evaluation Criteria for the ICAVP Procurement ESSENTIAL EVALUATION CRITERIA The following criteria must be met or the bidder will be considered ,
nonresponsive to the Request for Proposals:
. Suppliers must be independent of NU and NU's design contractors.
. . Project team must have technical capabilities in the following areas:
Electrical Engineering Instrumentation and Control Engineering Mechanical Engineering Civil Engineering Structural Engineering Nuclear Plant Operations Nuclear Plant Maintenance Probabilistic Risk Assessment Design and Licensing Basis Documentation at Commercial Nuclear Plants e Project team members must meet the following NRC criteria as enumerated in the NRC's Confirmatory Order dated August 14,1994:
No financial interest in NU or its affiliates .
No prior involvement in design reviews for NU Not the Engineer of Record or Architect-Engineer for the unit evaluated ADDITIONAL EVALUATION CRITERIA The following additional criteria will be considered. as part of the overall evaluation of the contractor's capability to conduct the ICAVP in accordance with NRC requirements. The evaluation will assess the proposal most likely to provide a credible, comprehensive, and independent review acceptable to the NRC and the public:
Contractor The following supplier attributes will be considered in evaluating capability to conduct the ICAVP:
. Level of corporate commitment to this project 11 Rev.0 09/12/96
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- e Related experience in design and licensing reviews (design and '
- configuration management, or safety evaluations) and design verification
! programs i
- Proiect Leader i
1 i e Project team leadership experience and capability that can accomplish a ' q i i quality verification. Example attributes that will be considered:
Managerial level within the contractor's organization Credentials, such as education, industry committees, publications
' Experience, including technical, managerial, and regulatory l
Communication experience and skills, including technical knowledge and j public speaking experience i
Project Team i
4 e The following project team capabilities and experience will be considered:
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j - Education of Team Members )
- - Experience with similar projects
- Other relevant experience, including utility, regulatory, and nuclear design 1 1 - Depth of human resources available in terms of quality and quantity l.
) Project Plan
! . The effectiveness of the ICAVP project plan in meeting the requirements of j-the NRC's Confirmatory Order !
i The tapability of the information Technology systems proposed (e.g.,
electronic bulletin board) for use in exchanging information under NRC and j public review i
! . The detail of the plan for organizing, directing, ahd controlling project i resources and activities t
j e The plan for conducting verification activities openly with joint reporting to the NRC and NU, and subject to public review l
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i I 12 i Rev.O i 09/12/96
ICAVP ISSUES TO BE ADDRESSED BY CONTRACTORS Experience:
- 1. Describe breadth of design experience of the proposed team in terms of type of design work (original plant design, preliminary, final, modifications) and scope (all disciplines, selected systems or selected disciplines).
1
- 2. Describe size of previous project involvements in terms of '
total plant, BOP, NSSS, and specific systems.
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- 3. Has the contractor performed any IDVPs or similar '
independent reviews? If so, please describe. ;
- 4. Has the contractor done design basis, plant configuration reviews such as for Bulletin 79-147 SSFis? Please describe.
- 5. Has the contractor performed in-depth evaluation of designed / operated / modified systems?
)
- 7. Which of above were inspected by the NRC7 Were there significant NRC findings?
Qualifications:
- 1. State credentials of key project personnel, with emphasis on spokesperson, project director, team manager, and subgroup leaders. _
- 2. State involvement of team personnel in industry and standards-type activities.
- 3. Provide the experience of key discipline personnel in terms of projects and years of applicable work.
Organization:
- 1. How would this project be organized?
13 Rev.0 09/12/96
- 2. What size review team and what disciplines do you anticipate?
- 3. Who would have responsibility for information to be reported to NU and NRC7
- 4. How would work / findings flow throtgh organization?
- 5. How would organization self-assess itself? What role will QA perform?
- 6. Oversight function be incorporated into the organization?
Independence:
- 1. What financial independence criteric would be imposed on team members? (See for example, NRC's inspection Manual Chapter 2535 on Design Verification Programs)
- 2. What independence criteria regarding expe#.nce with NU or NU contractors or suppliers would be imposed on team members?
Protocol:
- 1. What would be the internal protocol for review and identification of issues, and subsequent validation through the management review process?
- 2. What would be the extemal protocol for dissemination of results?
- 3. What internal protocol for communications, work space, interection with NU/NRC would' exist?
- 4. How will invalid findings, that is, findings which are found invalid within the contractors internal review process, be dispositioned?
- 5. What will be process for making this review transparent to NRC?
Plan:
- 1. Describe basic review plan.
14 Rev.0 09/12/96
1
- 2. How would you establish acceptance criteria to validate or invalidate previous work?
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- 3. What criteria would be used to expand the sample, or to l reduce it?
l 4. Would working-level procedures be generated or required?
- 5. What review would acceptance criteria undergo and would they be subject to review and modification es work proceeded?
- 6. How would selection of review items be made?
- 7. How would you determine that there is reasonable l assurance that the plant's physical and functional characteristics are in conformance with its licensing and design basis? i
- 8. How would you determine that the margins that existed l
- when plant was licensed had not been eroded by i I subsequent weaknesses in modification and other -
l processes? !
- 9. How would you determine whether the Millstone Unit 3 I Configuration Management Program is adequate?
- 10. How would you determine whether the Millstone Unit 3 Corrective Action Program is adequate?
l 15 Rev.0 09/12/96 I
PROPOSED CHARTER FOR THE ICAVP OVERSIGHT TEAM
- l. PURPOSE in order to provide additional confidence that the. Independent Corrective Action Verification Program (ICAVP) is performed competently, objectively, and independently, the ICAVP Oversight Team (IOT) will monitor and oversee all ICAVP activities. IOT is to ensure that the ICAVP meets all of the process require ments and objectives specified in the NRC's Confirmatory Order, including review and approval of the ICAVP contractor's work plan, protocol,
' independence and qualifications of project personnel, and decision making as work progresses.
II. MEMBERSHIP The IOT will be composed of persons having financial independence from Northeast Utilities and its subsidiaries, and independence from the designs, programs, and plant hardware being evaluated under the ICAVP. The IOT may be composed of persons having experience and )
credentials representative of the public sector, nuclear reactor regulation, technical excellence, and high quality nuclear programs.
Ill. RESPONSIBILITIES A. The IOT will review key documents and request timely briefings to provide the necessary background on the objectives of the ICAVP and the processes under which it will operate. The information will include NRC inspection and licensing correspondence and the confirmatory order as well as NU documents summarizing the results of internal assessments and planned corrective actions on relevant activities. With this as a basis, the IOT may generate any procedures, protocol, or workplans it believes necessary to accomplish item 1. above.
B. The IOT will review all appropriate documents and monitor all 1 appropriate meetings and conference calls ~ relevant to the ICAVP activities either as a team or as individuals. The IOT needs to adhere to the communication protocol established and needs to be sensitive to providing its views to all affected parties concurrently, in an open environment.
C. The IOT will review the independence and qualifications of the ICAVP project personnel to independently confirm that the criteria specified by the Order and the RFP have been fully satisfied. The IOT will review and comment on the procedures established to implement ICAVP work to ensure that program and process objectives are met. In this regard, major 16 Rev.0A 09/23/96
emphasis must be placed on the quality and integrity of the entire process.
4 D. The IOT will arrange periodic briefings to provide them with a basis for assessment of the verification process as it proceeds and the opportunity to provide timely guidance. Particular attention should be given to the criteria for acceptance of conditions verified to be " acceptable", the criteria for expansion of the verification sample, and the basis for close i
out of specific issues as being adequately verified. To the extent possible, the IOT should evaluate the technical decision-making being done by ICAVP personnel. Since the IOT process is one of oversight and recommendation, rather than direction, all recommendations from IOT should be documented.
i IV. REPORTS The IOT will complete their activities by preparing a brief report which-summarizes the IOT's conclusions concerning the ICAVP findings and identifies any points of disagreement left unresolved. This will be made
! part of the ICAVP final report. The IOT may be requested to participate in i
public meetings on the ICAVP and to brief the Nuclear Regulatory Commission on its findings.
1 ICAVP Oversight Team
- Reporting Relationships l W MC l ha hn i
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. Oversight = Project
- Team Director 4
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, Project Team 17 i
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ATTACHMENT AND ENCLOSURES Topic Attachment NRC Presentation, dated 8/12/96, to NU on ICAVP Program Plan 1 NU Letter to NRC, dated 8/13/96 Committing to ICAVP Program 2 NRC Confirmatory Order on NU's ICAVP at Millstone Station 3 NRC Official Transcript of Proceedings For Public Meeting with Northeast Utilities Regarding Millstone Units 1,2, and 3 Proceedings: Work Order No. NRC-812, Neal R. Gross and Company 4 NRC Manual Chapter 2535,
" Design Verification Programs" 5 General Terms and Conditions for ICAVP Consultant Proposal and Contract and Requirements for Unescorted Access and ALARA Principles 6 l l
Letters from Companies / Organizations Interested in l Supporting the ICAVP 7 Topic Enclosures l
FSAR/Gystems Vertical Slice Review Project Report 1 Millstone Unit 3 Integrated Assessment and Action Plan 2 Millstone Unit 3 Configuration Management Plan 3 l
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Millstono 3
. Key Performance indicators for Operational Readiness l (Through September 23,1996) l Summarv ;
Total Bypass Jumpers.. 46 System Specific Assessment Forms.. later Goal: 530 Goal:
Bypass Jumpers > 2 cycles.. 11 Correct Ops Critical Drawing Discrepancies.. . 46 Goal: 511 Goal: 63 NCR Closure-- 276 MEPL Validation.. 93 %
Goal: 151 by 10/30 Goal: 90%
NCRs Open > 60 days w/o Disposition.. 57 Validate Selected Vendor information.. 5 Goal: 0 by 10/30 Goal: 13 LOE & EWR Disposition.. .. later Outstanding Licensing issues.. 1 Goal: Goal: 26 l
DBDP Discrepancy not Dispositioned 8 Significance Lev. A.B.C ACR Review 190 l Goal: None allowed Goal: 165 Reviewed by 9/23 l All Reviewed by 10/30 initial SD Hardware Mods... .2 MTF Review.. 357 Goal: AllComplete Goal:No Open items Startup Tied Emergent Hardware Mods.. . 40 Number of Outage Personnel Error LERs.. 1 Goal: AllComplete Total Number of Outage LERs.. 23 Goal: No Outage Personnel Error LERs Operator Burdens . .6 Goal: 55 Possible Technical Procedure Deficiencies.. .141 Goal: No Open items Dept. Self Assessment... .8 Goal: 11 Operational Readiness Plan Deliverable Status. 47 Goal: 66 Upgrade Procedures Programs & Processes.. . 32 Goal: 40 AWO Backlog - Corrective Maintenonce.. .1679 Goal: 5500 Cat 8 DCN Review.. .later Goal: Unplanned LCO Entry.. .5 Goal: 0 DBDP Verification.. later Goal: Work Planning Effectiveness.. .80%
Goal: >90%
FSAR Review.. 5507 Maintenance Rework Goal: 5500 Number of Work Orders Completed.. 6183 Number of Outage Rework AWOs.. 30 Tech Specs & TRM Review.. .later Percent Rework... 0.49% l Goal: Goal:1% of AWOs Completed
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i Update Critical Calculations.. .later Operational Readiness Punchlist Summary.. 1411 Goal: Goal: All Reviewed l
Glossary of Nuclear Terms ACR - Adverse Condition Report -- The means by which an employee reports a condition adverse to plant performance and other station matters. These can range from equipment malfunctions to employee 4 performance issues to the physical condition of equipment.
ACR 7007 - An event response team report, dated 2/22/96, issued by Northeast Utilities exploring the reasons for a loss of design control at Millstone Unit 1. Design control refers to the entire process by which plant design changes are made and then documented. For instance, a " loss of design control" may mean there are 4
pieces of documentation missing.
AR - Action Request - The AR provides a means to track ARCS and other work. It is a part of the ACR process that spells out the actions which will be taken to resolve the ACRs.
10CFR50 - NRC regulations pertaining to domestic licensing of nuclear production and utilization facilities.
j CMP - Configuration Management Program - A document that describes all actions NU is taking to ensure that the designs of its Connecticut nuclear plants are in conformance with NRC requirements and is accurately documented.
DBDP - Design Basis Documentation Package - This a package of documents that describe the design information for individual plant systems.
ECP - Employee Concerns Program - An avenue by which employees can raise a concern, as well as the department which would investigate / remedy that concern. It was previously named the NSCP. Employees may 4 raise a concern with their supervisor, with a ECP Peer Representative, with the ECP, directly to any member of
] the nuclear management team or directly to the NRC at any time.
EOP - Emergency Operations Procedure -- These procedures are required by the NRC for all nuclear power plants and, in great detail, provide specific instructions for handling emergency situations which could arise.
1, 50.54(f)- Nuclear Regulatory Commission regulation that requires a nuclear facility to provide background information regarding plant procedures and to provide reasonable assurances that the future operation of each unit will be conducted in accordance with the terms of the license, NRC regulations and the FSAR. NU's
- response to this letter provides the NRC with the basis for taking further regulatory ar inn.
s 50.59s - This is an NRC regulation that governs the conduct of safety evaluations.
FCAT - Fundamental Cause Assessment Team - The FCAT was established to dete.mine the fundamental cause of the decline in performance of NU's nuclear program. The report has been docketed with the NRC and is available in the public document rooms.
FSAR - Final Safety Analysis Report -- A description and safety analysis of the plant. This document is required prior to issuing a plant an initial operating license and must be modified as a result of subsequent physical changes to the plant.
FPI- Failure Prevention and Investigation Inc. -- A highly specialized company based in San Clemente, l CA, that studies nuclear power plants, their cultures and operations as a way to help utilities improve their performance.
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s G14 - Generic Letter -- A NRC letter usually requesting information from licensees to demonstrate that they are in compliance with specific NRC requirements.
IE Bulletins - A NRC bulletin requesting licensees to take actions which are necessary to achieve or continue compliance with current regulations. No new requirements are imposed by a bulletin. I ins - Information Notice - A NRC letter that alerts licensees to a condition which may be important to safety. It does not require a response to the NRC.
Independent Corrective Action Verification Program - A program used to evaluate the effectiveness of corrective actions conducted by a third party " independent" team.
INPO -Institute for Nuclear Power Operations - An industry organization whose mission is ensuring safe operations of nuclear plants.
]
ISP - Improving Station Performance plan -- The ISP is the plan submitted to the NRC in early 1995 describing planned actions to improve perfonnance at Millstone. The remaining elements of the ISP are incorporated in the Nuclear Excellence Plan.
JUMA - Joint Utility Management Audit -- This is an audit of the quality assessment department conducted by representatives from other utilities.
KPI- Key Performance Indicators -- KPIs are a tool to measure performance of the plants. KPis include such things as a downward trend in the quickness to respond to employee concerns.
Leadership Man.gement Training -- Training given to employees to develop managerial and leadership i skills.
LER - Licensee Event Repcn - a report submitted to the NRC informing them of certain events as defined by regulation.
MCB - Main Control Board - The panels in a control room that indicate plant status and allow the operators j to control equipment in the plant.
MP3 LPSI - 14w Pressure Safety Inspection System - This is one of the safety systems that would, in case of emergency, pump water into the reactor to keep it cool.
MEPL - Material & Equipment Parts List - This lists all structures, systems and components that are safety related. NU's Quality Assurance Program applies to all of them.
NCAT - Nuclear Committee Advisory Team - A team formed in May 1996 to assist Northeast Utilities' Nuclear Committee of the Board of Trustees in evaluating the performance of NU's nuclear program. The NCAT commissioned the FCAT study and report.
NSCP - Nuclear Safety Concerns Program - NSCP is an avenue by which employees could raise nuclear safety concern and by which those concerns were investigated. This is now the new Employee Concerns Program (ECP).
NSAB - Nuclear Safety Assessment Board - A senior level safety review board that includes NU officials as well as representatives from other utilities and outside consultants.
NSARC - Nuclear Safety Audit Review Committee -- A senior level safety review board based at Seabrook Station that includes NU officials as well as representatives from other utilities and outside consultants.
Nuclear Oversight -- Department responsible for safety and oversight of nuclear at all five of NU's nuclear facilities. The ECP is a department within nuclear oversight. Nuclear oversight supplements every employee's commitment to and responsibility for safe operations.
OIR - Open Item Report - a report that reviews a potential discrepancy between FSAR testing guidance and actual implementation procedures.
ORPI- Operational Readiness Performance Indicators - Measurements that must demonstrate satisfactory performance, or at a minimum, demonstrate satisfactory performance trends prior to restart. These indicators will be presented to the NRC and must be reviewed and approved prior to restart.
ORP - Operational Readiness Plan -- The document that specifies responsibility and action items that must be completed before Millstone 3 restart. The ORP will spell out the ORPIs to be reviewed and approved prior to restart.
PEO - Plant Equipment Operator - Individuals who operate plant equipment such as valves and switches.
PORC - Station / Plant Operations Review Committee -- A committee chaired by a nuclear unit director. At NU's Millstone 3, the chairman is Mike Brothers. It reviews design changes and looks for safety issues.
Punch List -- A list of actions that need to be completed before a given event, for instance, prior to startup.
PUP - Procedure Upgrade Project -- A program designed to improve plant procedures by making them more user-friendly.
QAS - Quality Assessment Services - This is the department within Northeast Utilities responsible for quality assurance activities. These activities include audits and inspections.
RCA - Radiological Control Areas -- These are areas inside the plant where specialized procedures and processes are in place to minimize radiological exposure.
SALP - Systematic Assessment of Licensee Performance -- This is a NRC " report card" on a nuclear plant.
SBO Diesel - Station Blackout diesel generator -- A generator that would supply power to certain safety components at a unit in case of a widespread blackout in which the two other backup Emergency Diesel Generators also fail, a highly unlikely event.
SORC - Station Operations Review Committee - This committee reviews station-wide safety related activities.
SSA - Safety System Assessments - Northeast Utilities in-house diagnostic tool which reviews operations of a specific safety system.
SSFI - Safety Systems Functional Inspection -- A comprehensive diagnostic tool which reviews operations of a specific safety system.
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ST&I - Surveillance Test and Inspection - Activities performed to ensure the condition and operation of .
equipment meets established standards.
Temp Mods - These are temporary modifications to plant systems that are made in place of permanent modifications until such times as the permanent modifications can be made. Lifted leads and by-pass jumpers are examples of temporary modifications.
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4 0
0' NRC HANDOUTS
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INDEPENDENT CORRECTIVE ACTION .
VERIFICATION PROGRAM y tA" "E%< .
Gene Imbro U.S. ' Nuclear Regulatory Commission September 24,1996
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i PURPOSE OF ICAVP ;
i i
i e ASSIST NRC IN ASSESSING THE EFFECTIVENESS OF NNECO PROGRAMS IN IDENTIFYING AND CORRECTING PROBLEMS
- THE NRC'S ICAVP OVERSIGHT WILL VERIFY ON A SAMPLE BAS /S THE THOROUGHNESS OF THE ICAVP REVIEW AND THE VALIDITY OF THE ICAVP CONCLUSIONS i
- 2. ,
4
N ICAVP INDEPENDENCE REVIEWING ORGANIZATION -
e NO FINANCIAL INVOLVEMENT WITH NU e NO CURRENT INVOLVEMENT AT THE UNIT BEING REVIEWED TEAM MEMBERS _
e NO FINANCIAL INVOLVEMENT WITH NU e NO PRIOR INVOLVEMENT WITH THE UNIT BEING REVIEWED l
3.
ICAVP INDEPENDENCE cont'd ;
PROGRAM CONDUCT -
e NRC TO SELECT SYSTEMS e INDEPENDENT REVIEW CONDUCTED IN THE OFFICES OF THE REVIEW ORGANIZATION e COMMUNICATIONS PROTOCOLS i
e DUAL REPORTING OF FINDINGS TO NRC AND NNECO e STATE AND NUCLEAR ENERGY ADVISORY COUNCIL OBSERVATION OF NRC OVERSIGHT i
t I
4.
ICAVP ATTRIBUTES i e NRC WILL APPROVE THE ICAVP TEAM AND REVIEW PLAN PRIOR TO IMPLEMENTATION e COMPREHENSIVE REVIEW OF SELECTED SYSTEMS THAT WILL BE i' CONDUCTED BY AN INDEPENDENT REVIEW ORGANIZATION e BEGIN AFTER NNECO HAS COMPLETED THE PROBLEM IDENTIFICATION PHASE OF THE CONFIGURATION MANAGEMENT PROGRAM FOR APPROXIMATELY ONE-HALF THE RISK SIGNIFICANT SYSTEMS 5.
1 ICAVP SCOPE e ALL MODIFICATIONS MADE TO THE SELECTED SYSTEMS SINCE INITIAL LICENSING
- WILL INCLUDE:
REVIEW OF ENGINEERING DESIGN AND CONFIGURATION CONTROL PROCESSES VERIFICATION OF CURRENT PLANT CONFIGURATION AGAINST DESIGN AND LICENSING BASES DOCUMENTATION ,
VERIFICATION THAT DESIGN AND LICENSING BASES HAVE BEEN TRANSLATED INTO REVISED PLANT PROCEDURES VERIFICATION OF VALIDITY OF TEST DATA TO REPRESENT SYSTEM PERFORMANCE AFTER PLANT MODIFICATIONS REVIEW OF CORRECTIVE ACTlONS 6.
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NRC ICAVP OVERSIGHT i
e REVIEW ON A SAMPLE BASIS THE MATERIAL REVIEWED BY THE ICAVP CONTRACTOR TO VERIFY THEIR RESULTS/ CONCLUSIONS .
t WALKDOWNS OF THE SELECTED SYSTEMS DESIGN CALCULATIONS AND 50.59 EVALUATIONS TEST DOCUMENTATION TO VERIFY SYSTEM PERFORMANCE REVIEW PLANT PROCEDURES ,
t REVIEW LICENSED OPERATOR TRAINING ON PLANT MODIFICATIONS REVIEW POST-MODIFICATION TESTING 1
- 7. i
4 NRC ICAVP OVERSIGHT CONT'D e PUBLIC VISIBILITY OF NRC OVERSIGHT PROCESS STATE AND ADVISORY COUNCIL INVITED TO OBSERVE NRC TEAM INSPECTION PROCESS MULTIPLE NRC/NNECO MEETINGS OPEN TO PUBLIC ICAVP PROCESS (SEPTEMBER 24) 1 AUDIT PLAN ICAVP EXIT MEETING PERIODIC STATUS MEETINGS e REVIEW AND APPROVE INDEPENDENT ORGANIZATION, QUALIFICATIONS OF INDIVIDUAL REVIEWERS AND REVIEW PLAN e REVIEW OF CORRECTIVE ACTIONS ON SELECTED SYSTEMS e PUBLIC EXIT MEETING e INPUT TO NRC'S RESTART DECISION MAKING PROCESS 8.
1
CONDUCT OF NRC OVERSIGHT
- 1. INSPECT SCOPE, AUDIT PLAN, INCLUDING i QUALIFICATIONS / INDEPENDENCE OF REVIEWERS AND CONTRACTOR PRIOR TO INITIATION OF ICAVP APPROVE AUDIT PLAN
- 2. CONDUCT SYSTEM WALKDOWNS
- 3. IN-PROCESS INSPECTION OF INDEPENDENT CONTRACTOR
- 4. REVIEW OF SPECIFIC AND GENERIC / PROGRAMMATIC CORRECTIVE ACTIONS FOR FINDINGS IDENTIFIED BY ICAVP TEAM AND NNECO REVIEWS i
9.
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start I up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective _ assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team.
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We the pndersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team.
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- . We the undersigned, believe that Northeast Utilities should not be the
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Regulatory Commission has mandated as a necessary step prior to the start
, up of the Millstone Units. As residents of the localities which adjoin the l Millstone Power Station, we seriously question the independence of any j group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove i
Northeast Utilities from any involvement in the selection of the start up verification team.
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l We the undersigned, believe that Northeast Utilities should not be the
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear l Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team. ,
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any l group which is selected and paid for by the same utility on whom they are l supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove l
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be perfonning an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove ,
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are su'pposed to be performing an objective assessment and evaluation. We urge tho Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up Terification team.
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- We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear i'
Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station. we seriously question the independence of any group which is selected and paid for by the same utility on whom they are j supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up l verification team.
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. We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear ;
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the l Millstone Power Station, we seriously question the independence of any l group which is selected and paid for by the same utility on whom they are l supposed to be performing an objective assessment and evaluation. We urge l the Nuclear Regulatory Commission to rescind this decision and remove l Northeast Utilities from any involvement in the selection of the start up verification team.
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear 3
Regulatory Commission has mandated as a necessary step prior to t1 e start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any i group which is selected and paid for by the same utility on whom they are I supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team.
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team.
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We the undersigned, believe that Northeast' Utilities'should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team.
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstose Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team. Name Address
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We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove l Northeast Utilities from any involvement in the selection of the start up verification team. Name Address
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l . <- l We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear l Regulatory Commission has mandated as a necessary step prior to the start I up of the Millstone Units. As residents of the localities which adjoin the ! Millstone Power Station, we seriously question the independence of any ! group which is selected and paid for by the same utility on whom they are ! supposed to be performing an objective assessment and evaluation. We urge : the Nuclear Regulatory Commission to rescind this decision and remove l Northeast Utilities from any involvement in the selection of the start up verification team. Name Address l b' AW ffd' s ..DV va u u - ny A 4 2 73 % & : 9tm2b heb ?+a-u[ Asu. & ' W k) //i ra - &J A hann
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. We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any l group which is selected and paid for by the same utility on whom they are I supposed to be performing an objective assessment and evaluation. We urge l the Nuclear Regulatory Commission to rescind this decision and remove l
Northeast Utilities from any involvement in the selection of the start up i verification team. Name Address l Auk (b to Anuuv ts. Q.tt Cu uss'ti Wa r' He8m ao 9B Laku,eaf H4L Akaak LT Cb367
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r 1 t [ i j . We the undersigned, believe that Northeast Utilities should not be the j selector of the independent verification team on whose approval the Nuclear i Regulatory Commission has mandated as a necessary step prior to the start 4 up of the Millstone Units. As residents of the localities which adjoin the ; j MillstoWb Power Statio'n, we seriously question the independence of any i group which is selected and paid for by the same utility on whom they are , i supposed to be performing an objective assessment and evaluation. We urge : i the Nuclear Regulatory Commission to rescind this decision and remove ! j Northeast Utilities from any involvement in the selection of the start up '
- verification team.
i Name Address ! Od.be '/'nnn ?,nx 32_th As % CLotA
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. We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are
, supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team. Name Address l CJ._ GMf 7.c 0.~$<rf m m v a m'~39, o a%G%hS d, k (*2?> cay 2fmx& }4L. l h,, x .,% _ tl
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, We the undersigned, believe that Northeast Utilities should not be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up ; verification team. ' Name 3 gg_ Address JL42 k// b /// [ Jt Q! GW MM m k m & Adu k JZ a m , lPA ALI 4AW ' " we., mw cn : 8 $ )1 /) L Wl$l$fa Qu 4 (Tep Nf 0 Cf . j W, 'I/ RETE _, ,e4}R
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- We the undersigned, believe that Northeast Utilities should r$ot be the selector of the independent verification team on whose approval the Nuclear Regulatory Commission has mandated as a necessary step prior to the start up of the Millstone Units. As residents of the localities which adjoin the Millstone Power Station, we seriously question the independence of any group which is selected and paid for by the same utility on whom they are supposed to be performing an objective assessment and evaluation. We urge the Nuclear Regulatory Commission to rescind this decision and remove Northeast Utilities from any involvement in the selection of the start up verification team.
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