B16358, Forwards Addl Info on Selected Items of Work Previously Performed by Util,Correction to Slide Presentation & Resumes for Contractor Selection for ICAVP

Forwards Addl Info on Selected Items of Work Previously Performed by Util,Correction to Slide Presentation & Resumes for Contractor Selection for ICAVP

ML20137F149
Person / Time
Site:	Millstone
Issue date:	03/27/1997
From:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137F155	List: B16358, Forwards Addl Info on Selected Items of Work Previously Performed by Util,Correction to Slide Presentation & Resumes for Contractor Selection for ICAVP ML20137F157 ML20137F167 ML20137F189 ML20137F200
References
B16358, NUDOCS 9704010001
Download: ML20137F149 (14)

Text

__

1 Ned Rope Ferry Rd (Route 156), Waterford, Ur 06385 g NuclearEnergy us.ooe Noaear Po er station Northeast Nudear Energy Company P.O. Box 128 i

Waterford, Cr 06385-0128 (203) 447-1791 Fax (203) 444-4277 l

The Northeast Utihties System March 27,1997 Docket No. 50-336 B16358 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Additional Information on Contractor Selection for the Independent Corrective Action Verifirgtion Proaram (ICAVP) in the letter of February 14, 1997,5 Northeast Nuclear Energy Company (NNECO) proposed the selection of Parsons Power Group, Inc. (Parsons) as the ICAVP contractor for Millstone Unit No. 2 and provided background information supporting this selection. The basis for the selection of Parsons was discussed at a public meeting with the Nuclear Regulatory Commission (NRC) in Waterford, CT on March 18,1997.

The purpose of this letter is to provide additional information to the NRC in response to questions posed during the meeting. to this letter contains additional information on selected items of work previously performed by Parsons for NNECO. provides a correction to the presentation r,iido entitled " Qualifications of Project Team." The nature of the correction is to show et'citional Parsons people who would be conducting the Tier 2* review outlined in the NRC's Millstone ICAVP Oversight inspection Plan dated December 19,1996. provides resumes of additional pursonnel that may be assigned by Parsons with sufficient information to demonstrate their technical qualifications.

Martin L. Bowling letter to U.S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station, Unit 2, independent Corrective Action Program (ICAVP)," dated February 14,1997.

O Review of tne criticei neremeters for the systems used to miti ete eccieents t

9 described in the FSAR.

9704010001 970327 ApocK0500p3o QOf l g

y on sppspppppg T'

^

U.S. Nucirr R:gul: tory Commission B16358\\Page 2

' modifies Parson's commitment regarding performance of future work for Northeast Utilities (NU) and its subsidiaries, further describes the anticipated j

location (s) for the performance of the ICAVP work, and provides additional information concerning the financial independence of Parsons.

If you have any additional questions concerning this submittal, please contact Mr.

Martin. L. Bowling, Jr. at (860) 440-0436.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY l

Martin. L. Bowling, Jr.

/

Millstone Unit No. 2 Recovery Officer cc:

H. J. Miller, Region i Administrator j

D. G. Mcdonald, Jr., NRC Project Manager, Millstone Unit No. 2 D. P. Beaulieu, Senior Resident inspector, Mil. stone Unit No. 2 W. D. Travers, PhD, Director, Special Projects Office P. F. McKee, Deputy Director of Licensing, Special Projects Office W. D. Lanning, Deputy Director of Inspections, Special Projects Office E. V. Imbro, Deputy Director for ICAVP, Special Projects Office l

,~,

'y,l

a l

4 l

ICAVP l

)

I i

i l

1 l

1 4

d,

..f ( i\\

i 1

l I

l i

i i

i i

i i

Millstone Unit 2

./

]

i

,'l~

j

.or;'

(;

J M

y

. -. ~

i

[

i O

i Docket No. 50-336 B16358 i

I k

l t

Millstone Nuclear Power Station, Unit No. 2 I

Additional Information on Selected I e! is of O

Work Previously Performed by Parsons i

March 1997

o O

O 4

Previous Work Performed by Parsons All Nuclear Units 1984 Quality Assurance services 1992 Process mapping services for MOV, HELB, i

and CMP Millstone 1 and 2 and CT Yankee i

1990 Review of check valve program Millstone 2 and 3 l

1992 Erosion / corrosion inspection criteria and independent review of piping corrosion (subcontracted by Altran Corp)

A~"~

1. //jjp) Northeast NRC Presentation Utilities System

U.S. Nuclur R:guintory Commission i

B16358\\ Attachment 1\\Page 1

'O Miiistone Nucieer eower Sietion. unii No. 2 Additional Information on Selected items of I

Work Previously Performed by Parsons i

' Attachment 2, Enclosure 1 to NNECO's letter 816256, dated February 14,1997, provided a summary of past work performed by Parsons Power (formerly Gilbert Commonwealth Associates, et al) for Northeast Utilities (NU). The following clarifies specific work performed by Parsons for NU Nuclear and responds to questions raised by the NRC Staff at our meeting on March 18,1997.

1 l

Quality Assurance services under blanket purchase order (1984).

This work only involved manpower to conduct vendor audits and surveillances associated with purchasing (procurement) activities.

a l

Process Mapping services for Configuration Management Program, Motor Operated Valve Program, and the High Energy Line Break Program

]

(1992).

Gilbert / Commonwealth, Inc. performed an assessment of l

NU's Configuration Management Program.

The results of this assessment were detailed in a Configuration Management j

Program Assessment Report issued in May 1993 (Management Summary provided in Enclosure 1).

The report provided recommendations designed to strengthen NU's efforts to manage the configuration and information support of its nuclear plants. Six subprograms of configuratior, manage ant were reviewed: Design Control, Engineering Programs, Licensing Basis, Material Control, Design Basis Reconstruction, and Controlled Documents.

1 Gilbert / Commonwealth did not change, alter, or modify any existing process or procedure. Gilbert / Commonwealth was not contacted to perform any follow-on work related to the Configurauon Management Program review.

Gilbert / Commonwealth performed an assessment of NU's High Energy Line Break (HELB). The results of this assessment were detailed in an NU HELB PROCESS Evaluation Report dated December 21,1992 (Enclosure 2).

The assessment report identified several issues and problems with the existing program, plus opportunities for NU to significantly strengthen the NU HELB program. NU took responsibility for the follow-up work.

1 i

U.S. Nucl:rr Ragulntory Commission 816358\\ Attachment 1\\Page 2

O Gilbert / Commonwealth completed an assessment of NU's Motor Operated Valve related programs in October 1992 (Enclosure 3). The results of the i

assessment were provided in a report entitled "NUSCO MOV PROGRAM

- Results of the Process Mapping of the Northeast Utilities' MOV Program." The assessment concluded that the MOV Program was not

}

fully developed, did not fully integrate existing NUSCO programs, and did not fully align with the NRC Inspection Plan. NU took responsibility for the follow-up work.

i l

Review of check valve program (1990)

The Check Valve Reliability Analysis Inspection Criteria and Check Valve Design Application Review documents prepared by i

Gilbert / Commonwealth for Millstone Unit No. 2 are provided in Similar documents were prepared for Connecticut Yankee and the other two Millstone Units. The work only involved

(

a programmatic review of the NU check valve maintenance program and practices. Gilbert / Commonwealth did not change or modify any existing program or procedure. NU took responsibility for the follow-up work Erosion / corrosion inspection criteria and independent review (1992) l The two Gilbert / Commonwealth employees were seconded to ALTRAN. These individuals had received training in the EPRI Check-Checkmate Programs and performed their work under the 3

direction of ALTRAN supervisors. Neither of these individuals are i

currently employed by Parsons and will not be rehired for the lCAVP assignment at Millstone Unit No. 2.

j 4

5

,4 i O 1

._m.

Docket No. 50-336

-B16358 I

Millstone Nuclear Power Station, Unit No. 2 Configuration Management Program Assessment Report 4

i March 1997

~

(

1. Management Summary Gilben/ Commonwealth has concluded the project to provide Process Mapping Senices and an

'(]

Overview Assessment of the NU Nuclear Group Configuration Management Program. This report discusses the results of the G/C project and provides Process models, Obsen ations, Recommendations, and Documentation designed to strengthen NU's efforts to manage the configuration ofits Nuclear Plants.

He G/C project included reviews, interviews, research and documentation of the Configuration Management (CM) program efforts at Berlin as well as the CY and MP plant sites. The G/C project has identiSed several opportunities to signi6cantly enhance the positive business impact of a tr ture configuration management process. In the course of project efforts several issues have been identiSed which should be considered as priority opportunities for process enhancement through reengineering. He G/C project focused the research on not only the overall CM program, but specifically on six sub programs (PEP 2.3.1 Priority Items):

Design Control Engineering Programs Licensing Basis Material Control Design Basis Reconstruction Controlled Documents ne project team also researched the support of these programs by the Information Resources needed to perform the processes. He project has identified the issues and problems by the type of issue and has indexed the isstes to the elements of the CM Program Manual Rev. 2. Section 3 of p

this report documents the issues identified by the project research.

G/C has included in Section 2 of this report a series ofobservations and recommendations which we believe will enhance the NU return on its CM investment. He recommendations are organized to address three levels ofissues:

CM Program Sub-program Data Integration & Support G/C believes that the most signific mt recommendations regardL,g the CM Program are focused on the need for a comprehensive Plant Equipment Knowledge Base suppora:d by a Production focused set of Processes which are proactive in nature and are not characterized by stimulus response patterns of activity.

De G/C project team believes that NU is well positioned to capitalize on presious process engineering efforts and can effectively integrate many of the mature sub-systems already in place.

A key to the success of the CM program will be linked to the efforts to focus existing programs toward " management" of the configuration as a step forward from the current " support" of configuration processes.

G/C believes the models and recommendations in this report can be a catalyst and an empowerment towards that goal.

=

F j

j a

4

\\

2. Recommendations r

The following are the r=_-e- = 4=:ons of the G/C team. General broad based sw...w.dations i

are presented at the Configuration Management Program Level, and specific derail

}

rw....er.d.iaans are presented at the PEP 2.3.1 priority items level.

}-

i Pice.wn Level Rm-..su i=;a==

i

(

i

1. The existmg CM program u described in the Configuration Manage.1cnt Program M.aual l-appears to be focused on a t-:-:4== daa i~.# ve rather than on a Business perspecove. This l

6 4

?= -- = don focus is similar to a typical NRC audit focus. It is recommended that NU alter ats i

Configuraten Management focus to be one that is focused on the Business of managmg the configuration of the plant, rather than can~ dag ?=- - =tatmo i

i

2. The existmg Configuration Management Program appears to be in a mode of providing support

{

{

to several elements of the desip program, rather than providing direction on how to cor. trol plant i

configuration. The Configuration M==g-Program should act as a management control tool j

which provides direction on how to control the desip effort, rather than a program that supports individual desip program elements.

i

)

2

3. "Ihe existing Configuration M*a=e-t Program is limited by the condition ofits current i

supporting Data Structures. The existing data structures are not properly integrated enough to i

allow for the development of a " mature" Configuratson Management Program. The current data 10 c e -

sci ra 4.

4 P <

• a au s i-e 'i r ei t t

eP

}t Specification Data must be developed in order to allow the proper growth of the Configuration i

Management Program i

i 1

i f

4. Ahhough the existing Matertal LP-H-g processes are mature, there is an aspect which has not been fully transitioned from a construction focus to an operations focus.. Materials appear to be managed on a request by request basis (response mode) mther than a materials requirements i

i planmng basis. A Material Requirements Plannmg Program, and supportmg systems are needed. It is im-.. = 1=5 that a reph==~* parts engmeermg function be developed to address this issue.

i PEP 2 31 Priority item Rs..a.dations Diagram Block 1.1 Control of Design:

The Desip Program appears to be more focused on the control of design projects rather than on i

the acmal control of the physical plant design. The process is designed to respond to change requests or problem scenarios, rather than to provide direction on how to control plant configuration.

4 1

1. NU should consider enhancing the design control program to add process elements engineered I

to proactively manage the design of each unit towards a business prodection capacity efficiency / effectiveness paradigm.

i O

4

)

4 t

i

~

g G

2. NU should strengthen the close-out process of modifications to assure:

2.1 Changes are fed to other processes in an expeditious manner.

2.2 Material obsolescence is managed.

2.3 Excess material is charged t:, the ordering project.

2.4 DBDP update process is engmeered to keep the design basis current.

3. NU should strengthen the detail design process to provide standard designs for items such as hangers.

4. NU should develop an enhanced serpoint control process.

1

5. NU should strengthen its Design Projects by requiring a greater degree of consistency of records required from Pmject Engineers.

4 Diagram Block 1.2 Engineering Programs Some of the current En5 neering Programs are spread across multiple departments, which also i

spreads responsibility for the programs. This makes these programs appear to be project focused l

rather than providing on-going management direction for the everall Engineering Process.

1. Several programs should require more effective front end input data to become more effective.

Examples are'RCM, EEQ, Serpoints, PDCR short form inputs, and Material specs.

2. Change the focus of engineering prograrns from a project / problem solving support mode, to one of a cybemetic management focus. (i.e., one which sets the agenda and measures results by means of built in feedback control mechanisms. )

Diagram Block 1.3 Licensing Basis The current program appears to lack defmition and is not properly integrated with other CM programs.

1. NL should reengineer the licensing basis process to develop a process which is:

1.1 Integrated with other CM processes.

1.2 Has a clear flow ofinputs and outputs, and provides a " product" 1.3 Provides a consistent service to engineers.

1.4 Is linked to the mamstream flow of plant technical data.

1.5 Integrates PDCR results with FSAR analysis.

1.6 Has a comprehensive Action Item Tracking System.

1.7 Has a clear responsibility for Licensing Basis.

i

2. NU should design data flow processes, and Action Item systems to support this process.

C/

2

(.

/

Diagram Block 1.4 Material Control The Material Control Program is currently limited to controlling the acquisition and inventory of material due to the lack of a fully developed Material Requiremenu Planmng Cycle.

1. NU should revise the process of material control to elimmate feedback of material engineering deficiencies to non-engineering material handlers. Material deficiencies of this type should be referred directly to an engineering function.

2. NU should review the proposed MIMS design to assure that electronic requisitions and automated budget appmval have been considered in the design of new material systems.

3. NU should reengmeer the current process to capture material specifications developed during the Purchasing process and to include them in a Material Specification Data Base.

4. NU should begin design of a Comprehensive Material Specification Data Base which will be controlled and updated by the control of the Engineering function.

5. NU should enhance the Material Control of the plants by development of r. Lplacement Parts Engineering function which would be a key component in the adoption of.tn Operations focus for (3

the control ofPlant material. Replacement pans engineering is a critical success factor in the V

development of a complete Plant Equipment Data Base.

Block 1.5 Design Basis Reconstruction it is perceived that the DBDP's are not being updated in an aggressive manner. This leads to a lack of confidence in the DBDP accuracy. Target dates for updating DBDP's have been slipped. Here are organizational questions about responsibilities for performing this function.

l

1. Reengineer the PCDR close ort process to insure that changes made to the plant are reflected in i

the DBDP in an expeditious manner.

2. Reengineer the PDCR and PA initiation process to insure that the DBDP records the existence of an in-process PDCR or PA.

3. Reengineer the DBDP development process to allow for the definition of a DBDP summary section which provides a clear abstract of the package for occasional users.

U 3

O

%.)

Block 1.6 Controlled Documents The current program is fragmented and inconsistent between sites. This leads to varying degrees of quality of support that is available through the Records Programs The current program was not designed with the intent to support a configuration management program It is not focused on document retrieval by types or attnbutes which support configuration management.

1. Reengineer the Vendor Technical Manual control process to have the data managed by document control. 'Ihis process is aimed at the elimmation of uncontrolled personal files.

2. Reengineer the process ofindexing and abstracung records, to incorporate standard conventions which are focused on the needs of document retrieval for CM purposes.

Conficuration Management Data Systems Sunoort and Intecration Current Information Resources plans appear to be focused on various line functions within the Nuclear Group. the Data Systems effect of this is that there is no Group-wide Plant Equipment Data Base available to support Group-wide processes such as Configuration Management.

Another sub-optimizing effect of this environment is a lack ofdata systems integration which has produced a series ofissues focused on lack ofinformation and potential Quality exposures.

(V3

1. NU should enlist IRG support for the development of a comprehensive Plant Equipment Data Base for each Unit. 'Ihis data base should contain the broad logical Data Structure to support a i

mature CM Program concept of a Configuration Data Brokerage functionality.

2. NU should enlist IRG support to revisit the MIMS system to assum ? will accept the interface of a comprehensive Materials Requirements Planning function and the necessary support systems and processes.

3. NU should reengineer the use of technology such as Image Systems to be an element of a process rather than the application project to apply a new piece of technology. New IRG solutions should be driven by the needs of the business process and not by the availability of the technology.

4. Review the current Action Tracking project to develop a " commitment follow system" to assure that changes needed in the Licensing Basis Program are properly supported by a new integrated Commitment T racking system. It is very important that any new system be able to integrate with the need to track on-going licensing commitments and Tech Spec surveillances.

5. NU should rniew the current project which is focused on the development of an RCM Database. In order to have useful data in the RCM database, changes will need to be implemented in both PMMS and in the Root Cause Analysis of failures by Plant Systems Engineers. The additional process integrations are necessary control stack transitions for successful RCM results.

4

)

(

Docket No. 50-336 B16358 Millstone Nuclear Power Station, Unit No. 2 NU HELB Process Evaluation Report O

March 1997

-