ML20149G495

Requests Modification to Procedures for Documenting Discrepancies Discovered During Implementation of Facility Independent Corrective Action Verification Program Audit Plan

ML20149G495
Person / Time
Site:	Millstone
Issue date:	07/15/1997
From:	Imbro E NRC (Affiliation Not Assigned)
To:	Curry D External (Affiliation Not Assigned)
References
NUDOCS 9707230278
Download: ML20149G495 (6)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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wasseworoN, D.C. 30086 0001 July 15, 1997 i

i Daniel Curry, Project Director l

Parsons Power Group Inc.

j 2675 Morgantown Road Reading, PA 19607 i

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Dear Mr. Curry:

i During a June 19,1997, meeting with the Connecticut Nuclear Energy Advisory Council (NEAC), the NRC stated in response to questions from NEAC that tha Independent Corrective l

' Action Verification Program (ICAVP) contractors would provide a preliminary assessment of the potential significance of the discrepancies identified during the performance of the ICAVP at the j-Millstone Nuclear Generating Station. In addition, during a teleconference on June 26,1997,

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with representatives from Sargent & Lundy (S&L), Parsons Power Group inc. (Parsons), the i

NRC, and NEAC participating, the NRC stated that it would provide additional guidance to the ICAVP contractors regarding assessing the potential significance of identified discrepancies.

I The enclosure provides four levels of potential significance that the NRC staff has determined shall be used by the ICAVP contractors when assessing the significance of all discrepancies j

they identify during the performance of the ICAVP at the Millstone site.

l You are requested to modify your procedures for documenting discrepancies discov3 red during j

the implementation of your ICAVP audit plan to reflect the added requirement for conducting a preliminary assessment of the potential significance. You should base you.T assessment on the i

information that is readily available at the time the discrepancy is identified and the technical c

judgement of your organization. The discrepancy reports should include a brief discusion of the i

rationale for the selection of the significance level. The NRC recognizes that as new information becomes available or after the licensee completes its review of the discrepancies, j'

the actual significance of the discrepancies may change. However, when implementing this requirement, a reasonable effort should be made to classify each of the identified discrepancies to one of the four significance levels provided in the enclosure at the time the discrepancy report is prepared.

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In addition, the NRC requests that any discrepancies that may already have been documented f

before incorporation of this requirement into your procedures be updated to reflect your preliminary assessment of their significance. When updating the existing discrepancies, you Il should base your assessment on the information that you have readily available at the time you are updating the discrepancy and the technical judgement of your organization.

Whde the NRC requires the ICAVP contractors to provide's preliminary assessment of the potential significance of the discrepancies, it is important to reaffirm that Northeast Utilities (NU) remains the organization with the primary responsibility for assessing each of the discrepancies you identify during the ICAVP for impacts on the operations and mas.enance of its licensed facilities.

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NRC EE CENT li!sluisigs,! Willi

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Don Schopfer -

2 if you have comments or there are further questions on assessing the significance of discrepancies identified during the implementation of the ICAVP at the Millstone site, please contact me at (301) 415-1490, i

Sincerely, i

Eugene Imbro, Deputy Director ICAVP Oversight Special Projects Office Office of Nuclear Reactor Regulation j

Enclosure:

l Criteria for Categorizing the Relative Significance of Discrepancies identified by the ICAVP cc w/ encl: See next page i

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s, Don Schopfer 2

July 15, 1997 If you have comments or there are further questions on assessing the significance of discrepancies identified during the implementation of the ICAVP at the Millstone site, please contact me at (301) 415-1490.

Sincerely, Original signed by:

Eugene Imbro, Deputy Director ICAVP Oversight Special Projects Office Office of Nuclear Reactor Regulation

Enclosure:

Criteria for Categorizing the Relative Significance of Discrepancies identified by the ICAVP cc w/ encl: See next page DISTRIBUTION:

'6ocket Files (Docket 50-423)M PUBLIC WTravers JDurr SPO R/F PMcKee JAnderson i

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LA oe ICAVP/SPO ICAVP/SPO SPO NAME JANakoskl*

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/h/97 7 /11 /97 7//I/97 DATE 7 /11 /97 OFFICIAL RECORD COPY l

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7 Northeast Nuclear Energy Company Millstone Nuclear Power Station Units 2 and 3 Lillian M. Cucco, Esquire Citizens Regulatory Commission tienior Nuclear Counsel ATTN:' Ms. Susan Perry Luxton Northeast Utilities Service Company 180 Great Neck Road P. O. Box 270 Waterford, Connecticut 06385 Hartford, CT 06141-0270 Mr. F. C. Rothen Mr. Kevin T. A. McCarthy, Director Vice Preskient - Nuclear Work Services Monitoring and Radiation Division Northeast Nuclear Energy Company Department of Environmental P.O. Box 128 Protection Waterford, CT 06385 79 Elm Street Hartford, CT 06106 5127 Charles Brinkman, Manager Washington Nuclear Operations Mr. Allan Johanson, Assistant Director ABB Combustion Engineering Office of Policy and Management 12300 Twinbrook Pkwy, Suite 330 Policy Development and Planning Rockville, MD 20852 Division 450 Capitol Avenue - MS 52ERN Mr. D. M. Goebel P. O. Box 341441 Vice President - Nuclear Oversight Hartford, CT 06134-1441 Northeast Nuclear Energy Company P. O. Box 128 Regional Administrator, Region l Waterford, CT 06385 I

U.S. Nuclear Regulatory Commission

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475 Allendale Road Mr. M. L. Bowling, Jr.

King of Prussia, PA 19406 Millstone Unit No. 2 Nuclear Recovery Officer First Selectmen Northeast Nuclear Energy Company Town of Waterford P. O. Box 128 Hall of Records Waterford, CT 06385 200 Boston Post Road Waterford, CT 06385 Senior Resident inspector Millstone Nuclear Pruer Station Deborah Katz, President clo U.S. Nuclear Pegulatory Commission Citizens Awareness Network P. O. Box 513 P. O. Box 83 Niantic, CT 06337 Shelburne Falls, MA 03170 Mr. J. K. Thayer Mr. Wayne D. Lanning Recovery Officer - Nuclear Deputy Director of inspections Engineering and Support Special Projects Office Northeast Nuclear Energy Company 475 Allendale Road P. O. Box 128 King of Prussia, PA 19406-1415 Waterford, CT 06385 Mr. M. R. Scully, Executive Director Burlington Electric Department Connecticut Municipal Electric clo Robert E. Fletcher, Esq.

Energy Cooperative 271 South Union Street 30 Stott Avenue Burlington, VT 05402 l

Norwich, CT 06360 1

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Northeast Nuclear Energy Company Millstone Nuclear Power Station Units 2 and 3 cc:

Mr. William D. Meinert Mr. John Buckingham Nuclear Engineer Department of Public Utility Control Massachusetts Municipal Wholesale Electric Unit Electric Company 10 Liberty Square P. O. Box 426 New Britain, CT 06051 Ludlow, MA 01056 Mr. James S. Robinson Emest C. Hadley, Esq.

Manager, Nuclear Investments and 1040 B Main Street Administration P. O. Box 549 New England Power Company West Wareham, MA 02576 25 Research Drive

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Westborough, MA 01582 1

Joseph R. Egan, Esq.

Egan & Associates, P.C.

Mr. B. D. Kenyon 2300 N Street, NW President and Chief Executive Officer l

Washington, D.C. 20037 Northeast Nuclear Energy Company P. O. Box 128 The Honorable Terry Concannon Waterford, CT 06385

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Co-Chair i

Nuclear Energy Advisory Council Mr. M. H. Brothers Room 4035 Vice President - Millstone Unit 3 Legislative Office Building Northeast Nuclear Energy Company Capitol Avenue P. O. Box 128 i

Hartford, Connecticut 06106 Waterford, CT 06385 Mr, Evan Woolacott Mr. John C. Markowicz Co-Chair Nuclear Energy Advisory Council Nuclear Energy Advisory Council 9 Susan Terrace 128 Terrys Plain Road Waterford, CT 06385-3515 Simsbury, CT 06070 Ms. P. Loftus

. Director-Regulatory Affairs for Millstone Station Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385 Mr. N. S. Carns Senior Vice President and Chief Nuclear Officer Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385

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CRITERIA FOR CATEGORIZING THE RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED BY THE ICAVP e

SIGNIFICANCE LEVEL 1 A discrepancyW that identifies that the system does not meeting its licensing and design bases and cannot perform its intended function, i.e., has the potential to simultaneously affect redundant trains SIGNIFICANCE LEVEL 2 A discrepancyW that that identifies that a single train of a redundant system does not meet its licensing and design bases and that the train cannot perform its intended function.

i SIGNIFICANCE LEVEL 3 A discrepancym that identifies that a system does not meet its licensing and design bases but tne system is capable of performing its intended function.

e SIGNIFICANCE LEVEL 4 A discrepancyW that identifies that the systems meets its licensing and design l

bases, however, there exists minor errors such as minor arithmetic errors that do l

not significantly affect the results of a calculation or inconsistencies between documents of an editorial nature.

NOTE (1)

A discrepancy may identify programmatic, procedural, or design issues or editorial inconsistencies.

Enclosure

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