ML20149G502
| ML20149G502 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/15/1997 |
| From: | Imbro E NRC (Affiliation Not Assigned) |
| To: | Curry D AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9707230287 | |
| Download: ML20149G502 (16) | |
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July 15, 1997 5-Daniel L. Curry, ICAVP Proje::t Director 5#~ 3 Parsons Power Group 2675 Morgantown Road Reading, PA 19607
SUBJECT:
MILLSTONE UNIT 2 ICAVP AUDIT PLAN
Dear Mr. Curry:
This letter communicates to you our approval of your proposed audit plan for the conduct of the Millstone Unit 2 Independent Corrective Action Verification Program (ICAVP). The enclosure to this letter provides the results of our assessment that forrra P 1 basis of our approval. The staff reviewed ti.e audit plan, conducted interviews with each pr. ct ed team member, and verified that the audit team has sufficient expertise to implement tt CAVP as outlined. The financial
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e,nd professional independence of each ICAVP participant wn also examined and found to meet the NRC's specified acc,7tance criteria. The staff found that the scope and depth of the audit plan should provide the insight necessary to judge the effectiveness of Northeast Nuclear Energy Company's Configuration Management Program in identifying and resolving existing problems, documenting and utiliting %nsing, and des y bases.
Please contact me at (301) 415-1490 if you have any questions.
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Sincerely, IS Eugene V. Imbro, Deputy Director ICAVP Oversight Special Projects Office Office of Nuclear Reactor Regulation
Enclosure:
As stated
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Distribution:
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j NUCLEAR REGULATORY COMMISSION 1
2 WASHINGTON, D.C. 30666 4 001
- +l (li4 July 15,1997 i
I Daniel L Curry, ICAVP Project Director Parsons Power Group Inc.
2675 Morgantown Road j
Reading, PA 19607
SUBJECT:
MILLSTONE UNIT 2 ICAVP AUDIT PLAN
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Dear Mr. Curry:
This letter communicates to you our approval of your proposed audit plan for the conduct of the
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Millstone Unit 2 Independent Corrective Action Verification Program (ICAVP). The enclosure to j
this letter provides the results of our assessment that forms the basis of our approval. The staff reviewed the audit plan, conducted interviews with each proposed team member, and verified i
that the audit team has sufficient expertise to implement the ICAVP as outlined. The financial and professionalindependence of each ICAVP participant was also examined and found to meet the NRC's specified acceptance criteria. The staff found that the scope and depth of the audit plan should provide the insight necessary to judge the effectiveness of Northeast Nuclear Energy Company's Configuration Management Program in identifying and resclving existing problems, j
documenting and utilizing licensing and design bases.
l Please contact me at (301) 415-1490 if you have any questions, l
- SWwaly, M
l Eugene V. Imbro, Deputy Director ICAVP Oversight l
Special Projects Office Office of Nuclear Reactor Regulation i
Enclosure:
As stated cc w/enci: See next page l
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j Northe2st Nucirr En:rgy Comp:ny Millst:n3 Nuclerr Power Station Unit 2 l,
cc:
1 Ullian M Cuoco, Esquire Mr. F. C. Rothen Senior Nuclear Counsel Vice President - Work Services j
Northeast Utilities Service Company Northeast Nuclear Energy Company i
P. O. Box 270 P. O. Box 128 i
Hartford, CT 06141-0270 Waterford, CT 06385 1
Mr. John Buckingham Emest C. Hadley, Esquire l
Department of Public Utility Control 1040 B Main Street Electric Unit P.O. Box 549 10 Liberty Square West Wareham, MA 02576 l
New Britain, CT 06051 Mr. D. M. Goebel i
Mr. Kevin T. A. McCarthy, Director Vice President - Nuclear oversight Monitoring and Radiation Division Northeast Nuclear Energy Company j
Department of Environmental Protecilon P. O. Box 128 79 Elm Street Waterford, CT 06385 Hartford, CT 06106-5127 1
Mr. M. L. Bowling, Jr.
Regional Administrator, Region l Recovery Officer-Millstone Unit 2 U.S. Nuclear Regulatory Commission Northeast Nuclear Energy Company J
475 Allendale Road P. O. Box 128 King of Prussia, PA 19406 Waterford, CT 06385 First Selectmen Mr. J. K. Thayer Town of Waterford Recovery Officer - Nuclear Engineering Hall of Records and Support 200 Boston Post Road Northeast Nuclear Energy Company Waterford, CT 06385 P. O. Box 128 Waterford, CT 06385 Mr. Wayne D. Lanning i
Deputy Director of Inspections Mr. B. D. Kenyon i
Special Projects Office President and Chief 475 Allenc44 Road Executive Officer King of Prusaa, PA 19406-1415 Northeast Nuclear Energy Company P. O. Box 128 Charies Brinkman, Manager Waterford, Connecticut 06385 Washington Nuclear Operations ABB Combustion Engineering Mr. Allan Johanson, Assistant Director 12300 Twinbrook Pkwy, Suite 330 Office of Policy and Management Rockville, MD 20852 Policy Development and Planning Division Senior Resident inspector 450 Capitol Avenue - MS# 52ERN Millstone Nuclear Power Station P. O. Box 341441 c/o U.S. Nuclear Power Station Hartford, CT 06134-1441 P.O. Box 513 Niantic, CT 06357 u ---
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Northe:st Nuue:r En:rgy Comp:ny Millst:na Nucle:r Power St: tion Unit 2 cc:
Citizens Regulatory Commission ATTN: Ms. Susan Perry Luxton 180 Great Neck Road Waterford, Connecticut 06385 Deborr.h Katz, President Citizens Awareness Network P. O. Box 83 Shelbume Falls, MA 03170 The Honorable Terry Concannon Co-Chair Nuclear Energy Advisory Council Room 4035 Legislative Office Building Capitol Avenue Hartford, Connecticut 06106 Mr. Evan W. Woollacott j
Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, Connecticut 06070 Uttle Harbor Consultants, Inc.
Millstone -ITPOP Project Office P. O. Box 0630
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Niantic, Connecticut 06357-0630 Mr. Don Schopfer Verification Team Manager I
Sargent & Lundy 55 E. Monroe Street Chicago, Illinois 60603 Mr. Neil S. Cams l
Senior Vice President
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and Chief Nuclear Officer
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Northeast Nuclear Energy Company i
clo Ms. Patricia A. Loftus 1
Director-Regulatory Affairs P. O. Box 128 Waterford, Connecticut 06385 l
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RESULTS OF THE STAFF'S REVIEW OF THE PARSONS PROPOSED ICAVP AUDIT PLAN FOR MILLSTONE UNIT 2 3
INTRODUCTION l
On August 14,1996, the U.S. Nuclear Regulate"y Commission (NRC) issued a Confirmatory Order to Northeast Nuclear Energy Company (NNECO or Licansee) requiring completion of an Independent Corrective Action Verification Program (ICAVP) before the restart of any Millstone unit. The Confirmatory Order directed the Licensee to obtain the services of an organization independent of the Licensee and each facility's design contractor to conduct a multi disciplinary review of Millstone Units 1,2, and 3. The staff conditionally approved Parsons Power Group Inc.
(Parsons) as the ICAVP contractor for Millstone Unit 2 on May 28,1997, pending verifiention of financialindependence.
The purpose of the ICAVP, as stated in the Confirmatory Order, is to confirm that the plants' physical and functional characteristics are in conformance with their licensing and design bases.
The ICAVP audit required by the NRC is expected to provide independent verification, beyond the Licensee's quality assurance and management oversight, that the Licensee has identified and satisfactorily resolved existing nanconformances with the design and licensing bases, and documented and utilized the licensing and design bases to resolve nonconformances. The requirement of the Confirmatory Order that the ICAVP verify that the Licensee has established programs, processes, and procedures for effective configuration management in the future is separately addressed by a review of common unit procedures during the ICAVP audit of Millstone Unit 3, which will be conducted by Sargent & Lundy (S&L). (See letter dated June 3,1997, from j
E. Imbro, NRC to D. Schopfer, S&L.)
l BACKGROUND On August 13,1996, the Licensee committed to contract an independent team to implement the ICAVP, which would include: (1) in-depth review of selected systems to address control of the design and design basis since issuance of the operating license for each unit; (2) selection of j
systems for review based on risk and safety-based criteria similar to those used in implementing
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the Maintenance Rule (10 CFR 50.65); (3) development and documentation of an audit plan that j
will provide assurance that the quality of results of the Licensee's problem identification and i
corrective action programs on the selected systems are representative of and consistent with that of other systems; (4) procedures and schedules for parallel reporting of findings and recommendations by the ICAVP team to both the NRC and the Licensee; and (5) procedures for the ICAVP team to comment on ths Licensee's proposed resolution of the findings and recommendations. The Licensee also committed to the scope of the ICAVP review, which will encompass modifications to the selected systems since initial licensing, and will include: (1) assessment of the engineering design and configuration control processes; (2) verification of current, as-modified plant conditions against design basis and licensing basis documentation; (3) verification that design and licensing bases requirements are translated into operating procedures and maintenance and test procedures; (4) verification of system performance i
through review of specific test records and/or observation of selected testing of particular systems; and (5) review of proposed and implemented corrective actions for Licensee-identified design deficiencies.
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i Through the issuance of the Confirmatory Order, the NRC required NNECO to complete the ICAVP for Units 1,2, and 3 before restart. The Confirmatory Order stated, in part, that the ICAVP team shall provide for NRC review and approval prior to implementation, a plan for the conduct of the team's review.
The Confirmatory Order further stated that the audit plan must describe: (1) the conduct of an in-depth review of selected system's design and design basis since issuance of each facility's 1
operating license; (2) risk and safety-based criteria for selection of systems for review; (3) the audit plan to assure that the quality of results of the Licensee's problem identification and corrective action programs on the selected systems is representative of and consistent with that of other systems; (4) procedures and schedules for parallel reporting of findinrs of the ICAVP l
team to both the NRC and the Licersee; and (5) procedures for the ICAVP team to comment on j
the Licensee's proposed resolution of the ICAVP team's findings and recommendations. Finally, the Confirmatory Order stated that the scope of the ICAVP shall include: (1) a review of engineering design and configuration control processes; (2) verification of current, as-modified l
conditions against design and licensing bases documentation; (3) verification that the design and licensing bases requirements have been properly translated into operating procedures and maintenance and test procedures; (4) verification of system performance through review of l
specific test records and/or observation of selected testing; and (5) review of proposed and i
implemented corrective actions for Licer see-identified design deficiencies.
l In a Commission Paper (SECY-g7-003) dated January 3,1997, the staff described the Millstone restart review process; in the portion of the Commission Paper that addressed the ICAVP, the staff acknowledged that the scope and depth of the independeat contractor's effort will be i
j determined during the staff's review of the ICAVP. To provide the level of assurance necessary l
to support a unit restart decision, the staff's expectation, described in SECY-g7-003, is that the j
ICAVP will encompass the aspects of configuration control stated in the staff's three tier
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j approach.
i In Tier 1, a minimum of four systems will be selected to test the thoroughness of the Licensee's j
reviews in identifying potential nonconformances with the design and licensing bases. The ICAVP contractor is expected to conduct a thorough review of design changes made since the j
j issuance of the operating license, the remaining portion of original system configuration, and i
operational aspects of these systems, including maintenance, surveillance testing, and training.
The contractor is also expected to review the Licensee's corrective actions for previously identified design-related deficiencies for the selected systems, including the deficiencies j
discovered during the implementation of the Licensee's corrective action programs.
i Tier 2 will review, on a limited basis, systems that mitigate accidents and transients analyzed in the (Updated) Final Safety Analysis Report (UFSAR). Tier 2 of the ICAVP audit will review aspects of accident mitigation systems that are not being examined as part of the Tier 1 reviews.
These reviews were described in SECY-97-003 as more limited in scope than those performed on the Tier 1 systems. The objective of Tier 2 is to verify that critical design characteristics of l
systems relied upon to mitigate the consequences of accidents analyzed in the UFSAR are consistent with those used in the analyses.
Tier 3 of the ICAVP audit will review a sample of changes made to the facility configuration since I
issuance of the operating license. These include processes such as calculation changes, proposed technical specification chang 4 temporary modifications, drawing changes, procedure i
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changes, set point change requests, and replacement item evaluations. The staff concluded that this approach will provide insights into the effectiveness of the varicus change processes in I
controlling the plant's configuration.
STAFF REVIEW i
On April 3,1997, Parsons submitted a proposal for the conduct of the ICAVP in the form of a i
Project Manual, which included an audit plan and project procedures (PPs) goveming specific technical activities. Following the staffs review of the Project Manual, the staff held working meetings during the week of May 27,1997, with Parsons to discuss the staffs observations and findings regarding the Project Manual. At the working meetings, Parsons also provided a draft i
copy of Project instruction PI-01, " System Vertical Slice Review"(SVSR). A representative of the i
Nuclear Energy Advisory Council (NEAC) ot, served these meetings on a part time basis. As part j
of its assessment, the staff also reviewed the resumes and interviewed personnel that Parsons proposed for participation in the audit. On June 9,1997, Parsons submitted Revision 1 of the l
lCAVP and Revision 0 of PI-01 to the staff for review and approval. These documents incorporate, with minor exceptions, the staffs comments on the Parsons ICAVP audit approach discussed during the week of May 27,1997. The PI-01 provided generic checklists to be used l
with each of the implementing procedurer included in the audit plan. In a telephone call with Parsons held on June 25,1997, and also monitored by NEAC, the staff requested further clarifications on aspects of the Manual and Instructions and requested that Parsons make several final revisions to their revised audit p!an. Parsons agreed with the proposed changes j
i and indicated it would submit revised page changes to the NRC.
On June 27,1997, Parsons submitted revisions to the audit plan and implementation j
procedures in response to NRC comments during the June 25,1997, telephone conference.
1.0 PARSONS ICAVP TEAM COMPOSITION 1.1 Technical Qualification of Individual Team Members On June 27,1997, the staff completed interviews with personnel proposed by Parsons to be involved in the ICAVP. The staff determined that the individuals have sufficient breadth of technical expertise in their specialty areas to perform the assigned tasks.
1.2 Technical and Financial independence of Team Members During the interview process, the staff evaluated the technical and financialindependence of the proposed ICAVP team members. One of the individuals proposed was fcund to own stock in companies involved in the design and/or construction of Millstone Unit 2. This individual elected to be removed from consideration from the Millstone Unit 2 ICAVP. No individuals were identified as having been previously involved in activities at Millstone Unit 2.
1.3 ICAVP Team Composition The staff evaluated the composition of the various groups that comprise the ICAVP, including the individuals assigned to the Advisory Panel, the System Review Group, the Accident Mitigation System Review Group, the Process Model & Operational Analysis Group, the Regulatory Review Group, the Project Support Group, and engineering specialists. Each group and the Parsons team appear to have the necessary mix of expertise and experience in the engineering 3
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h-disciplines and accident analyses. Additionally, each group is to be headed by an experienced supervisor or manager with broad technical experience. During the week of May 27,1997, the i
staff noted that the Parsons team appeared to be weak in the Operations and Maintenance areas. Parsons agreed to strengthen these areas, and in a June 25 telephone conference with the staff, noted that additional personnel were being proposed to cover these areas, in addition, in their June 27 submittal of revisions, Parsons revised its audit plan to specifically require operations expertise during the conduct of Tier 2 to cover, for example, assessment of the emergency operating procedures.
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Parsons' management indicated that each team would be suppleniented as needed with engineering specialists, depending on the size and complexity of the systems selected by the staff, in accordance with Project Procedure PP-06, " Substitution or Addition of Personnel."
Parsons also acknowledged that interaction among the ICAVP audit groups was necessary to i
effect a comprehensive review. To encourage a team approach, Parsons indicated that they j-would plan frequent team meetings to discuss resource allocation.
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1.4 Conclusions l
Based on Parsons' commitment to strengthen the ICAVP team in the Operations and l
Maintenance areas as discussed above, the staff finds that the proposed ICAVP team expertise i
is sufficient to perform the ICAVP as described in Parsons' ICAVP audit plan and implementing procedures, including revisions dated June 27,1997.
2.0 ICAVP TIER 1 The Tier 1 process will review design and operational aspects of the selected systems, including maintenance, surveillance testing, and training. Parsons described its approach to Tier 1 of the ICAVP in its audit plan and in PP-01, " System Vertical Slice Review"(SVSR). In addition, Parsons submitted PI-01, "SVSR implementation Checklists and Workbook," which provided detailed instructions for the Tier 1 review.
2.1 System Boundaries and Interfacing Systems Review Parsons submitted a document identified as "SVSR Checklists" dated April 21,1997, which stated that interface with, and portions of, other systems will be included within the boundary of the selected system to the extent they are necessary to support the functional requirements of the selected system. At the working meetings held during the week of May 27,1997, the staff requested that Parsons clarify how the SVSR system lead would define the system boundaries and the components to be evaluated. in response to this request, PP-01, Revision 1, incorporated the functional criteria contained in the "SVSR Checklists" document for establishing system boundaries and also clarified the definition of support system boundaries for mechanical, electrical, instrumentation and control, and piping interfaces with the system under review. The staff found these definitions acceptable and consistent with the foregoing functional basis for system boundaries. The staff will review and approve the specdic system' boundaries following the selection of each system.
The Parsons audit plan, project procedures, and project instructionc (Pis) provide for review of topical areas such as environmental qualification, erosion / corrosion, extemal events / hazards, high and moderate energy line breaks, and 10 CFR Part 50, Appendix R," Fire Protection." in addition, Parsons proposed a regulatory review process intended to identify and verify applicable t'
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regulatory requirements and commitments for use in the Tier 1 review. This regulatory review would capture specific requirements and commitments for these topical areas for use in the
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SVSR. For the Appendix R topical review, Parsons will develop specific conformance attributes 4
after the systems are selected and after the Millstone Unit 2 fire protection evaluation report is i
r6trieved and Appendix R conformance bases are established. The staff found this approach to topical area interfaces generally acceptable. However, the staff will require clarification of detail regarding the proposed scope of review for 10 CFR Part 50, Appendix R, conformance attributes i
relative to the system under review. Typical areas where the staff will require clarification of Parsons' Appendix R review scope include:
e verification of equipment, cables, and circuits required for safe shutdown l
. review of fire areas involving the system under review
. review of associated circui's of concem e review of ampacity derating calculations that support the use of fire barriers e review and walkdown activities regarding safe shutdown operating procedures, accessibility, i
pre-staging of equipment, habitability, lighting, and communications The staff will review and approve the specific ICAVP scope for Appendix R following the selection of the systems.
2.2 Retrieval of Documents Project Procedure PP-01 described the types of controlled documents that Parsons will request for review in accordance with its communication plan (PLN-02). PP-01 also stated that the SVSRs will be focused on licensing and design bases requirements and will use the appropriate level of documentation (e.g., drawings, calculations, design documents) to the detail necessary to verify and validate conformance to the requirements. The use of these documents in various aspects of the Tier 1 review was identified in PI-01. Parsons proposed to develop system-specific document requests following the selection of each system. Based on the broad scope of multi discipline documents identified in the various lists and the commitment to an appropriate level of inspection detail, the staff found that the overall scope of the review based on the types of documents to be examined by Parsons was generally adequate for the Tier 1 review.
However, the staff concluded that operational data records should also be retrieved where available for comparison with the results of appropriate design output documents (e.g.,
calculations, analyses, or qualification reports). PP-01 identified typical information for consideration in the Tier 1 review, including system test data. During the June 25,1997, telephone conference, the staff requested that Parsons add operational test data to the list of typical information. The June 27,1997, submittal of the audit plan and implementing procedures revisions included this commitment in PP-01, Revision 2.
l 2.3 Engineering Review of the Selected Systems The Tier 1 system reviews (SVSRs) proposed by Parsons will focus on confirming that the selected systems' physhal and functional charactenstics are in conformance with its licensing and design bases. The SVSR will examine system-related activities from original design, 5
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i construction, and testing to the present system configuration. The system review will be l
functionally based and will use a top-down process based on specific system requirements in addition to the generic, multidiscipline engineering attributes identified in PP-01 and Pl-01. A
. separate regulatory review will identify regulatory requirements and commitments applicable to the ICAVP scope and will also be used to verify that commitments have been property 4
incorporated in the UFSAR. The audit plan provides a structure for additional and more focused inspection planning after the systems are selected. The staff found this approach generally j
acceptable and sufficiently detailed. However, during the meetings of the week of May27,1997, i
l the staff requested clarification regarding the following areas of the SVSRs proposed by Parsons:
Revision 0 of PP-01 provided only a vertical slice review of the selected system; that is, a.
the review would have been limited to a representative sample of the selected system.
1 At the working meetings with Parsons, the staff directed that the SVSR as proposed be expanded to include a comp'ete review of the selected system against the licensing and i
design bases. Parsons incorporated this direction in Revision 1 of PP-01, and proposed that for repetitive, standard, or identical functional components the verification would include a screening process to confirm that the components are repetitive and identical, followed by validation of the licensing or design basis requirement using a component group process. The staff found this approach acceptable, but required Parsons to submit its screening method and results for staff review and approval. The justification for the i.
method should provide a technical basis for the screening and should be based on safety significance and consideration of the overallICAVP process.
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The staff indicated that it was important for the individual verifiers to approach the review with a critical and questioning attitude, and not rely solely on the items in detailed checklists. Parsons agreed to include this type of guidance in the indoctrination and train!ng of Tier 1 personnel. From the interviews of the team members, the staff concluded that the proposed personnel had the requisite technical skills as well as substantial design, analytical, and engineering experience for performing critical reviews in their cognizant areas. Therefore, based on the results of the interviews and the proposed emphasis in training of ICAVP personnel, the staff concluded that the Tier 1 effort as proposed was acceptable.
2.4 System Physical Configuration Review PP-01 identified a process for developing system-specific walkdow.a packages. PI-01 included T1-CL-l-10, " System Review Checklist instructions, Walkdown - Form 10," and Attachment A,
" Source Book of Additional Questions." These documents would be applied to the modified and unmodified portions of the system under review. These documents identified questions or review attributes that were generic in content, but which characterized a depth and breadth of review that was generally acceptable to the staff.
2.5 Review of Operations, Maintenance, Testing, and Training Aspects of the Systems PI-01 included checklists for review of maintenance procedures, operating procedures, testing, and traintr,g. These documents would be applied to the modified and unmodified portions of the system under review. These documents identified questions or review attributes that were generic in content, but which characterized a depth and breadth of review that was generally acceptable to the staff.
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g.6 Conclusions -lCAVP Tier 1 l
Based on the stars review of the proposed Tier 1 effort as discussed herein, the stan has concluded that the proposed Tier 1 review contained within the audit plan satisfies the applicable -
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requirements of the August 14,1996, Confirmatory Order and the stafs expectations as described in SECY-97-003. The Tier 1 processes described in the revised audit plan were clear, i
thorough, and well structured. The accompanying PI was comprehensive and generally reflected the stars expectations for breadth and depth of scope.
3.0 ICAVP TIER 2 i
Tier 2 will review, on a limited basis, systems that mitigate accidents and transients analyzed in j
the UFSAR. Tier 2 of the ICAVP audit will review aspects of accident mitigation systems that are not being examined as part of the Tier 1 reviews. The objective of Tier 2 is to verify that critical 1
design characteristics of systems relied upon to mitigate the consequences of accidents analyzed in the UFSAR are consistent with those used in the analyses, d
The stats review of Revision 0 of the Project Manualidentified that:
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The audit plan did not include NRC approval of the critical design characteristics of the accident mitigating systems that the Accident Mitigation System Review Group would j
compile.
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The audit plan did not commit to perform a complete comparison between the critical design characteristics / parameters and the "as-documented" condition, or a cornplete validation of the critical design characteristics identified in UFSAR Chapters 14,6,7,8, j
and 9.
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At the meetings held during the week of May 27,1997, Parsons agreed to revise the audit plan to address these concems. Parsons willidentify system-level design characteristics by Design i
Bases Events (DBEv)'n two phases and submit the results to the NRC for staN review and approval. Phase 1 will provide the characteristics on a generic basis; Phase 2 will identify the i
characteristics specific to each DBEv. Parsons also committed to perform a complete comparison between critical design characteristics / parameters and the "as-documented" i
condition, and a complete validation of the critical design characteristics identified in UFSAR f
Chapters 14 and in Chapters 6,7,8, and 9 as they relate to the postulated accident under i
review.
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During a June 25,1997, telephone conference with the sta#, Parsons agreed to revise its audit j
plan to document these commitments. The June 27,1997, submittal of the audit plan and j
implementing procedures revisions included these commitments.
3.1 Conclusions - lCAVP Tier 2 The staff concluded that the revised plan to implement Tier 2 of the ICAVP audit satisfies the applicable requirements in the August 14,1996, Confirmatory Order, and the stars expectations described in SECY-97-003. The Tier 2 process presented in Revision 1 of the ICAVP audit plan was clear, thorough, and well structured.
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i 4.0 ICAVP TIER 3 The Tier 3 review is intended to provide insights into the effectiveness of the Licensee's change 4
control processes, other than the design control processes that are being examined in detail in l
Tier 1, that maintain the plant's configuration in accordance with the design and licensing bases.
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Parsons proposed to conduct a review, including an evaluation of corrective actions, in PP-03, j
" Process Review, CMP Horizontal Slice" of various changes performed under both the current
. and past change process procedures. The review of changes made under the current procedures includes output documents such as drawings, specifications, calculations, procedures, temporary alterations, licensing documents, vendor manuals, like-for-like replacements, and setpoints. The additional requirement of the Confirmatory Oroer that the ICAVP verify that the Licensee has established programs, processes, and prncedures for effective configuration management in the future is being addressed by review of common unit procedures during the ICAVP audit of Millstone Unit 3, which will be conducted by Sargent &
Lundy (S&L). (See letter dated June 3,1997, from E. Imbro, NRC to D. Schopfer, S&L) 4.1 Review of Project instructions The staff questioned the sample size and scope of past changes to be reviewed by Parsons.
During the week of May 27,1997, the staff described the expected scope of the review of past changes. The staff indicated that the examples to be reviewed will be selected from changes to the following output documents: abnormal operating procedures, emergency operating procedures, standard system operating procedures, maintenance procedures, surveillance procedures, inservice testing procedures, drawings, temporary alterations, lifted leads, jumpers, licensing documents, vendor manuals, like-for-like replacements, setpo!nts, specification changes, master parts list changes, commerciai grade dedication items, nonconformance reports dispositioned as "use-as-is," engineering work requests dispositioned as "use-as-is," and changes made througn the American Society of Mechanical Engineers (ASME)Section XI, Repair, Replacement, Modifipation Program. With respect to the sample size, the staff noted that Parsons should propr.6 the sample size to the NRC for review and approval after the ICAVP begins.
4.2 Conclusions - lCAVP Tier 3 On the basis of the staff's review of the proposed plan to implement Tier 3 of the ICAVP audit, and the commitments made during the week of May 27,1997, the staff concludes that the plan satisfies the applicable requirements documented in the August 14,1996, Confirmatory Order and the staffs expectations contained in SECY-97-003.
5.0 COMMUNICATION PROTOCOL The August 14,1996, Confirmatory Order required the Licensee to implement an ICAVP for each Millstone unit. Further, the Confirmatory Order requires that the ICAVP team's review plan provide procedures fcr parallel reporting of its findings to both the NRC and the Licensee, and for providing the NRC with comments on the Licensee's proposed resolutions to the ICAVP team's findings. In order to ensure that Parsons remains independent of the Licensee and to ensure that the ICAVP is implemented openly, a communication protocol was developed by Parsons as part ofits audit plan.
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l 5.1 Review of Communication Protocol The staff reviewed Parsons' communication protocol as described in PLN-02, " Communication j
Plan." Comments from the staff's review were provided during the meetings between Parsons and the staff the week of May 27,1997. During the June 25,1997, telephone conferenc~e with I
i the staff, Parsons agreed to revise PLN-02 to incorporate the staff's comments concoming areas such as contact lists, meeting summaries, and the posting of various reports on Parsons' j
website. Changes to be made to PLN-02 will make Parsons' communicatior, plan consistent with the communications plan for the ICAVP to be separately conducted for Mil' stone Units 1 and 3.
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5.2 Conclusions i
The staff determined that, if effectively implemented, the communication protocol provides adequate controls to maintain the independence between Parsons and the Licensee during the i
performance of the ICAVP.
6.0 DISCREPANCY RESOLUTION PROCESS
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The Confirmatory Order requires that the ICAVP review plan provide procedu as for parallel
' reporting of its findings to both the NRC and the Licensee, and for the contractor to comment on i
the Licensee's proposed racolution of the ICAVP discrepancies. The staff reviewed Parsons' j
procedure for processing and documenting ICAVP findings as described in Project Procedure i
PP-07, " Discrepancy Reports." The staff verified that PP-07. Revision 2, included: (1) submitting i
hardcopy of all valid Discrepancy Reports (DRs)in accordance with Parsons Communications Plan PLN-02; (2) adding NEAC to the distribution requirements; and (3) a clarification of the j
timing for posting DRs on the electronic bulletin board.
6.1 Definition and Threshold of " Discrepancy" l
l Parsons provided the following definition of" discrepancy"in Revision 1 of the audit plan:
i A disc:epancy is n.~, adverse condition, such as an error, omission, or oversight which prevents consistence among the physical con &guration, information sources (e.g., documentation and databases), design basis and/orregulatory requirements.
The staff concluded that the foregoing use of the word " adverse" suggests an undefined evaluation has been made prior to validation of the discrepancy, and could suggest too high a threshold for fact-finding. In a June 25,1997, telephone call with Parsons, the staff advised that elimination of the word " adverse" would make the definition acceptable. In addition, PI-01
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identified a different definition of discrepancy, and the staff directed that PI-01 use the same i
' definition acceptable to the staff. Parsons agreed with the revised definitions and committed to change the audit plan accordingly.
The staff also advised Parsons that the description of ICAVP Acceptance Criteria in Section 4.5 of the audit plan should reflect ICAVP results and conclusions and that the staff will evaluate the number and severity of discrepancy reports identified by Parsons and determine if additional l
corrective actions are warranted.
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l-F 6.2 Conclusions i
The staff found the discrepancy resolution process proposed by Parsons satisfied the 4
Confirmatory Order and the staffs expectations in SECY-97 003.
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7.0 DIFFERING PROFESSIONAL OPINIONS j
The staff reviewed Parsons' procedure that established the requirements for handling and resolving dinering professional opinions (DPOs) as described in PP-05, " Differing Professional j
Opinion." Following the meetings between Parsons and the staff during the week of May 27, 1997, Parsons revised PP-05 to add the requirement to submit a copy of each completed DPO and resolution to the NRC primary contact in accordance with PLN-02 with the name of the i
initiator redacted. During a telephone conference on June 25,1997, the NRC confirmed that the redacted version of the DPO would also be sent to the Licensee, in addition to being available to j
the public.
8.0 PUBLIC COMMENTS 8.1 Number of Systems Reviewed by the ICAVP At meetings sponsored by the NRC to discuss NRC regulatory activities and to solicit comments l
from the public on the ICAVP audit plan, a concem was raised regarding the number of systems l
to be reviewed in Tier 1 of the ICAVP. The concem was that a review of a minimum of five i
systems (four by the ICAVP contractor and one by NRC) was not sufficient to assess the adequacy of all the risk-significant and/or safety-related systems for Unit 2. The NRC staff responded that the combined ICAVP effort, which includes an in-depth review of five systems l
(Tier 1), the Tier 2 review of critical accident mitigation system design characteristics relied c.n in i
the analyses of postulated accidents, and the Tier 3 review of plant configuration changes will i
provide substantial and sufficient insights into the effectiveness of NNECO's Configuration i
Management Plan (CMP). The three-tier process will encompass, either entirely or in part, a l
substantial number of the risk significant and/or safety-related systems. NRC will evaluate all deficiencies identified through the ICAVP and will retain the option to expand the scope of the i
ICAVP should the ICAVP identify deficiencies not discovered through the Licensee's CMP.
8.2 Threshold for NRC Action A member of the public expressed a concem that specific lCAVP evaluation criteria and thresholds either for expansion of scope or suspending the ICAVP have not been established by the NRC. Considering the complexity of the reviews conducted under the ICAVP and the wide breadth in scope and severity of discrepancies that may be identified by the ICAVP, the staff could not define explicit criteria prior to the implementation of the ICAVP that would fairly and adequately address all possible outcomes. The staff feels that this must be done on a case-by-case basis by the NRC, in a manner open to public observation. However, as prevbusly stated, the NRC will evaluate all discrepancies identified through the ICAVP. If the ICAVP identifies a significant discrepancy, such as one which could prevent a safety system from performing its specified function, or a number of minor errors, such as inconsequential drawing inaccuracies or mathematical errors in calculations, the NRC will evaluate these both individually and collectively and take appropriate action up to and including suspendir.g the ICAVP. In response to a suggestion by tha Connecticut Nuclear Energy Advisory Council (NEAC), the NRC has developed criteria for groupi,o discrepancies based on potential safety significance (See attached). The 10
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significance level of each discrepancy and the basis for the category selected will be indicated on a
each discrepancy report.
8.3 Public Availability of Discrepancies Discovered by the ICAVP A member of the public expressed a desire to have additional information made available in order to gain insights into the discrepancy development process described in Parsons' ICAVP audit 4
plan. As originally envisioned, the process would have made publicly available only those discrepancies that had been reviewed by the Project Director and determined to be valid. Those i
discrepancies determined to be invalid based on additional review would have been available for review by the NRC during its ICAVP oversight and the Nuclear Energy Advisory Council (NEAC) during its observation of the NRC oversight of Parsons' conduct of the ICAVP. However,in response to the request, the process was changed such that all discrepancies, both those validated by Parsons and those determined to be invalid by the Parsons management review, will be made publicly available. As modified, the process now requires that both va'id and invalid discrepancies be submitted to the NRC (and therefore publicly available) and also be posted on Parsons' electronic bulletin board. In addition, the NRC has requested that NNECO's response to discrepancies and Parsons' evaluation of the NNECO response also be made available to the public.
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8.4 Public Availability of Other ICAVP Related Information A member of the public expressed a desire to havo the following information related to the i
ICAVP made available: (1) Parsons'intemal quality assurance audits on the conduct of the ICAVP; (2) DPOs; (3) design review checklists; (4) discrepancy reports that indicate a violation of the plant's technical specifications; and (5) discrepancy reports reviewed by the NRC. During a June 25,1997, telephone conversation with the staff, Parsons agreed to make publicly available l
the results of its intemal quality assurance audits, and to revise its audit plan to document this commitment. The DPOs were to be submitted to the NRC as described in the ICAVP audit plan.
Parsons has submitted the design review checklists to the NRC as part of its audit plan.
Therefore, both of these document types will be available to the public for review. As stated i
above, all of the discrepancy reports will be available to the public. The discrepancy reports will I
articulate the nature of each discrepancy, including any violation of the plant's technical specifications. The NRC will review all discrepancies generated as part of the ICAVP. The NRC j
inspection process will assure that corrective acticas required to be implemented before restart have been completed.
CONCLUSION The staff concluded that the ICAVP proposed in Revision 1 of the Project Manual satisfies the applicable portions of the August 14,1996, Confirmatory Order and the staff's expectations contained in SECY-97-003. Parsons was respontive to the observations and comments provided by the staff during its review. The ICAVP process reflected in the Project Manual included a critical review of the selected Millstone Unit 2 systems, and established the appropriate protocols for resolving discrepancies and DPOs, and communications among the Licensee, Parsons, and the NRC.
The staff also concluded that the personnel selected by Parsons for implementation of the ICAVP were well qualified for their assignments.
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l E !.
Attachment CRITERIA FOR CATEGORIZlNG THE RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED BY THE ICAVP e
SIGNIFICANCE LEVEL 1 A discrepancym 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 simultanrusty affect redundant trains.
1 e
SIGNIFICANCE LEVEL 2 1.
A discrepancym 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 l
intended function.
o SIGNIFICANCE LEVEL 3 A discrepancyW that identifies that a system does not meet its licensing and design bases but the system is capable of performing its intended function.
i
}
e SIGNIFICANCE LEVEL 4 A discrepancym that identifies that the systems meets its licensing and design bases, however, there exists minor errors such as minor arithmetic errors that do 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.
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