ML20197H587

Independent Corrective Action Verification Program, Final Rept,Vol 1

ML20197H587
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Site:	Millstone
Issue date:	12/31/1998
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PPNR-2197, NUDOCS 9812140140
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RSONS Millstone Unit 2 Independent Corrective Action Verification Program Final Report Volume 1 l

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4 Millstone Unit 2 ICAVP Final Report i

Volume I Executive Summary....

.1-1 1.1. Introduction.

.1-1 l

l 1.2. Background...

... 1-1 j

l 1.3. Results....

..13 1.4. Conclusions by Review Area.....

. 1-4 i

1.4.1. Tier 1 - System Vertical Slice Review.,..

.1-4 1.4.2. Tier 2 - Accident Mitigation Systems Review..

.1-5 1

1.4.3. Tier 3 Process Review.

.1-5 l

1.4.4. Corrective Action Review...

.. 1 -6 1.5. Overall Conclusions..

. 1-7 l

2. Conduct oflCAVP.......

..2-1 2.1. Approach to ICAVP Audit..

. 2-1 2.1.1. System Vertical Slice Review (SVSR) of selected systems (Tier 1).............. 2-1 2.1.2. Review of Accident Mitigation Systems (Tier 2)..

......... 2 -6 l

2.1.3. Process Review (Tier 3)..................

....... 2-10 2.1.4. Regulatory Review..

..................2-13 2.1.5. Corrective Action Review.....

..... 2 14 2.1.6. Discrepancy Report Process..................................................... 2-16 2.2. Project Organization...

..2 19 Volume 2 -To be submitted i

3.

System Reviews....

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4.

Accident Mitigation Systems Review..

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5. Process Review....

P 5

PARSONS I

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s 6.

Corrective Action Review...

7.' Regulatory Review.

8.

Discrepancy Reports..

9.

Technical Advisory Group.

10. Quality Assurance,

11. Appendices.

1 l

' E.4 '

il PARMONS

1.

Executive Summary j

1.1.

Introduction ne executive summary of the final report provides the overall conclusions of the hiillstone Unit 2 Independent Corrective Action Verification Program (ICAVP) for the review perfonned by Parsons.

A supplement to the fmal report will be submitted when the Parsons resiew of a sample, selected by the NRC, of Corrective Actions being performed by Northeast Nuclear Energy Company (NNECo) in response to Parsons confirmed Significance Level 3 discrepancy reports has been completed.

1.2.

Background

l in August 1996, the Nuclear Regulatory Commission (NRC) issued a confirmatory order requiring completion of an Independent Corrective Action Verification Program before the restart of any hiillstone Unit. The purpose of the ICAVP was to provide the NRC, NNECo, and the public with an independent review to confinn the adequacy of NNECo's efforts to establish that hiillstone Nuclear Power Station's physical and functional characteristics are in conformance with their licensing and design basis.

l The confinnatory order required an independent review to verify the adequacy of NNECo's efforts to establish adequate design basis and design controls, including translation of the design basis into operating procedures and maintenance and testing practices, verification of system performance and implementation of modifications since the issuance of their original operating license.

Parsons was approved by the NRC to perfonn the hiillstone Unit 2 ICAVP. Parsons developed a comprehensive hiillstone Unit 2 ICAVP Audit Plan and implementing procedures that provided the approach for assessing NNECo's effectiveness at identifying and correcting licensing and design basis deficiencies. The Audit Plan and implementing procedures were approved by the NRC. The scope of the Unit 2 ICAVP review consisted of the following major review activities:

l Vertical Slice review of selected systems (Tier 1)

Review of Accident hiitigation Systems (Tier 2)

Review of design change process outputs (Tier 3) e Corrective Action Review e

The scope of the ICAVP encompassed all documented modifications made to the selected systems j

smce uutiallicensing and included:

1.

Review of engineering design and configuration control processes, t

2.

Verification of current, as modified conditions against design and licensing basis documentation, J

p 11 PARSONS f

i 3.

Verification that the design and licensing basis have been properly translated into operating procedures, and maintenance and test procedures, 4.

Verification of system performance through review of specific test records and/or l

observation of selected testing, 5.

Review of proposed and implemented corrective actions for NNECo identified design l

deficiencies.

l Vertical Slice System review of selected systems (Tier 1) l The purpose of the Tier I review was to confirm that the selected systems physical and functional characteristics are in conformance with the Unit's design and licensing basis. A total of 1I systems from the NRC Maintenance Rule Group 1 Systems were selected for ICAVP review by the NRC and Nuclear Energy Advisory Council (NEAC) of the State of Connecticut. These 1 I systems were grouped into four major systems for the purpose of the review. The Tier I review has now been completed. The systems selected for ICAVP review included:

1. High Pressure Safety Injection (HPSI)

2. Auxiliary Feedwater (AFW)

3. Radioactivity Release Control-Enclosure Building Filtration (RRC)

4. Emergency Diesel Generator (EDG)

Integrated into the Tier 1 review of the selected systems, Parsons performed a review of 19 regulatory based programs such as Control Room Design Review, NRC Generic Letter 89 10 (Motor Operated Valves), Environmental Qualification, Regulatory Guide 1.97, and electrical separation. Conclusions of this review are included within the Tier I conclusions in Section 1,4.1.

Review of Accident Mitigation Systems (Tier 2)

The purpose of the Tier-2 review was to validate the " Critical Design Characteristics"(CDCs) associated with the accident mitigation systems. The CDCs were extracted from the Accident Analysis (Updated Final Safety Analysis Report - Chapter 14). Analyses for all Chapter 14 accidents were reviewed, with CDCs applicable to approximately 50 systems. This review has been completed.

Review of design change process outputs (Tier 3)

The purpose of the Tier 3 review was to verify the adequacy of the NNECo Configuration Management Program (CMP) to identify and correct deficiencies that may have resulted from ineffective past change processes. Inspection areas chosen for review included engineering documents, parts procurement documents and operations and maintenance documents. The Tier 3 review has now been completed.

Corrective Action Review The purpose of the Corrective Action review was to verify the adequacy of NNECo corrective actions.

There were three specific areas of this review; in-scope (relating to selected Tier 1 systems) 1

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s corrective actions, NRC selected (Tier 3) corrective actions and corrective actions for confinned l

Significan~ce Level 3 Discrepancy Reports. Corrective actions resulting from Discrepancy Reports have not been completed by NNECo. Parsons review of this area will be completed in the future and the results will be included in a supplement to the fmal report.

1.3.

Results As a result of this audit, Parsons generated numerous discrepancy reports. The confirmed discrepancy reports form the basis of the conclusions by review area and overall conclusions presented in Section 1.4 and 1.5 of this report.

Each discrepancy report issued was assigned a significance level. No Significance Level 1 or 2 discrepancies were confirmed. Significance Level 3 discrepancy reports were generated when errors were found with the licensing and design basis that would not prevent the system from performing its intended safety function. Significance Level 4 discrepancy reports were generated to document minor errors or inconsistencies among documents Additional information relating to the Discrepancy Report process is provided in Section 2.1.6.

Confirmed Significance Level 3 discrepancies are to be addressed by NNECo prior to restart of Unit

2. Significance Level 4 discrepancy reports are to be tracked by NNECo and addressed prior to the first refueling outage following restart.

The numbers of Confirmed discrepancy reports by Tier review area are as follows:

Tier review area LConfirmed Significanes il Confirmed Sienificance Level 3 DR's I.evel 4 DR's Tier 1 67 410 Tier 2 7

21 j

Tier 3 1

69 Corrective Action 0

21 Total 75 521 As of December 4,1998, one discrepancy report remains to be resolved with NNECo. The resolution to this discrepancy will be included in the supplement to the final report.

Discussion of specific Significance Level 3 and 4 discrepancy reports is provided in each of the review summaries for Tier 1, Tier 2, Tier 3 and Corrective Action in Volume 2 of this report.

Significant trends resulting from the review of the Level 4 discrepancy reports are presented in the conclusions by review area in Volume 1 - Section 1.4 of this report.

i Additional discussion of the final status and disposition of discrepancy reports is presented in Volume l

2 - Section 8 of this report.

i m2 1-3 PARSONS

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1.4.

Conclusions by Review Area The conclusions are subdivided into the following four areas of primary review: System Vertical Slice Review (Tier 1); Accident Mitigation Systems Review (Tier 2); Process Review (Tier 3), and Corrective Action Review.

1.4.1.

Tier 1 - System Vertical Slice Review He ICAVP review of the selected systems has been completed, however the extent of CMP

" discovery complete" by NNECo in September 1997 adversely affected the implementation of the Unit 2 ICAVP review. After Sep; ember 1997, NNECo identified additional licensing and design basis issues affecting the AFW system causing this ICAVP system review to be placed "on hold" Similarly, NNECo placed the ICAVP review of several of the regulatory based programs "on-hold" during the audit due to newly identified issues and the extent of corrective actions required. The review of the AFW system has now been completed. The regulatory based program review has been completed with the exception of Station Blackout and Appendix R. Due to the extent of NNECo corrective actions and associated work in progress, Station Blackout and Appendix R programs will be reviewed by the NRC as part of their Restart Assessment Program.

j Sixty seven (67) confirmed Significance Level 3 discrepancy reports affecting the licensing and design basis of the selected systems were identified during the Tier 1 system review effort. Discrepancy Reports generated from the four system reviews and the review of regulatory based programs identified a programmatic configuration management weakness in relation to NNECo's utilization and translation of the licensing and design basis into the as-built plant design, specifications and procedures.

Approximately twenty percent of these sixty seven (67) discrepancy reports were identified during the regulatory based program review relating to the selected systems. Several weaknesses were identified in the electrical separation / isolation plant program. The as-installed plant conditions are not consistent with the plant electrical separation / isolation design requirements as evidenced by the lack of separation within plant raceway systems, in cabinet separation, and isolation between 1E and non-IE devices. The electrical isolation issue is of further concern when the plant fuse control program discrepancies are included.

l All confirmed discrepancies have been placed into the NNECo Corrective Action Program for i

resolution along with the issues identified by NNECo during CMP. Based upon the resolution of these corrective actions, the selected systems will meet their required licensing and design basis.

l A total of 410 confirmed Significance Level 4 discrepancy reports were generated during the Tier i systems review. Although these issues do not place the plant outside the licensing and design basis, several trends were noted during the system review ;

Scme calculations that support the Licensing and Design Basis include numerous errors, invalid e

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or undocumented assumptions. This condition is supported by the fact that the majority of discrepancies issued during the system level review were written against calculations.

Several inconsistencies exist between the Licensing and Design Basis and the Engineering Design Basis. This is evidenced by discrepancies associated with Licensing and Design Basis P

1-4 PARSONS

information in areas such as QA classification and pressure boundary classification no' being

. properly translated into the Engineering Design Basis.

Some calculations and other plant records that support licensing and design basis requirements cannot be readily identified nor retrieved Vendor technical infonnation interfaces and the translation ofirformation into the design basis e

and plant procedures is not dermed in a program manual. Control and use of vendor technical information associated with the following interfaces is weak:

Vendors / Original Equipment Manufacturer Industry Experience e

Regulatory information notices e

e Plant modifications The review of modification packages, corrective actions and regulatory based program e

documentation has identified a weakness regarding consistent procedural adherence and the lack of supporting documentation.

1.4.2.

Tier 2 - Accident Mitigation Systems Review After initiation of the Tier 2 review, NNECo identified, over a period of several months, that 16 of the 29 accidents to be reviewed would have to be reanalyzed. The ICAVP review of the reanalyzed accidents has now been completed.

A total of seven confirmed Significance Level 3 discrepancy reports were generated during the Tier 2 review. As a result of the review of the accident mitigation systems and validation of critical design characteristics, it is concluded that a weakness exists in NNECo's configuration management process in that it does not assure that the accident analysis design inputs are consistent with the as built plant and the operating and surveillance procedures.

Confirmed Significant Level 4 discrepancy reports identified a trend in that NNECo needs to ensure that processes which control calculations and analyses consider the cumulative effects ofincremental changes.

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1.4.3.

Tier 3 Process Review l

Millstone Unit 2 CMP adequately identified licensing and design basis discrepancies caused by j

historical configuration management processes which impacted physical plant functionality and plant operational requirements. The only Tier 3 Significance Level 3 discrepancy related to in Service i

Inspection and in Service Testing, (ISUIST).

Trending of the Significance Level 4 discrepancy reports identified the following areas where improvements would enhance the configuration management program:

1. Calculations:

P 15 PARSONS

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No dermed process exists for controlling the mcorporation of accident analysis 1

requiren.ents and assumptions into plant operation procedures.

The Design Control Manual (DCM) is silent on the need to document or track small

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incremental changes which individually can bejudged to be insignificant, but collectively over time could exceed allowable limits. This is especially important for modifications or operation changes which add various types ofloads, (e.g. electrical, structural, fire l

combustibles; and heat loads), or reduce a systems capacity, (e.g. cut rebar, plug tubes, l

reduce free volume).

2. Drawing Changes He review identified a configuration management work process deficiency that has historically resulted in drawing changes to match as-found plant conditions without a determination of whether the plant or the approved drawings were correct. The current DCM is still largely silent on resolving as-found plant conditions which differ from approved drawings.

3. Vendor Equipment Technical Information Program (VETIP):

Upgraded vendor technical manuals, (VTM) are incomplete in identifying vendor requirements, and inconsistency exists between similar manuals. Identification of plant procedures impacted by vendor technical infonnation is not consistent in its level of detail. Both of these fmdings point to a controlling procedure that needs improvement.

Currently, the VETIP requirements are not dermed in a program manual and procedure DC-16 does not provide a program definition.

4, Conuncreial Grade Dedication of Spare Parts:

Nearly 70% of the sample of Commercial Grade item dedication packages provided for ICAVP review lacked complete documentation: 1) for the test values from all Special Tests and Inspections performed to verify selected critical characteristics, and 2) of the technical basis for sampling of Commercial Grade Items undergoing Special Tests / Inspections.

5. Equipment Safety Classification (MEPL):

A number ofinstances were identified ofincomplete documentation or evaluation of non-Q equipment mstalled in the plant when the safety classification is changed from non-Q to Safety Category 1, 1,4,4.

Corrective Action Review No confirmed Significance Level 3 discrepancy reports were issued as a result of the review of NNECo identified corrective actions. The implementation of the Corrective Action process is generally effective in identifying and correcting licensing and design basis issues.

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Approximately twenty five percent (25%) of the corrective actions reviewed weie found to have errors associated with them which were assessed to be Significance Level 4 discrepancies. Based upon

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1-6 PARSONS

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trends noted during the review, the following improvements would enhance the Corrective Action process:

Increased emphasis placed on the extent of condition review.

i increased oversight to assure more consistent Condition Report analysis and processing.

e Additional attention is required to assure that close out of a corrective action package incorporates documentation that all required actions have been satisfactorily completed.

Increased emphasis on the consistent identification of the plant documents identified for update.

1. 5.

Overall Conclusions Based upon the overall results of the Parsons scope of the Unit 2 ICAVP resiew:

NNECo was generally effective in identifying problems and providing corrective actions relating j

to the licensing and design basis.

l A weakness exists in the configuration management process in that it does not assure that the e

accident analysis design inputs are consistent with the as-built plant and the oper: ting and surveillance procedures.

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1-7 b PARSONS

l 2.

Conduct of ICAVP 2.1.

Approach to ICAVP Audit A ICAVP Audit Plan was created for assessing hiillstone Unit 2 effectiveness at identifying and correcting licensing and design bases deficiencies. The ICAVP audit was based on the requirements identified in the August 1996 NRC Confirmatory Order and the NRC's ICAVP Oversight Plan issued as an attachment to SECY 97-003, The ICAVP Audit employed the approach noted in Exhibit 2-1 for assessing hiillstone Unit 2 efTectiveness at identifying and correcting licensing bases deficiencies. The scope of the ICAVP Audit provides additional confidence that hiillstone Unit 2 confonns to its design and licensing bases through the following approach:

System Vertical Slice Review (SVSR) of selected systems (Tier 1)

Review of Accident hiitigation Systems (Tier 2) e Process Review (Tier 3)

Regulatory Review e

Corrective Action Review e

2.1.1.

System Vertical Slice Review (SVSR) of selected systems (Tier 1) ne objective of the SVSR inspection (Tier 1) was to confirm, through an inspection sample of at least 4 systems selected by the NRC, that the hiillstone Unit 2's physical tad functional I

characteristics are in conformance with its licensing and design bases, and encompass all modifications made to the selected systems since initial licensing. In addition, the inspection examined the thoroughness of the hiillstone Unit 2's Corrective Action Plan for identifying and resolving nonconformances with the design and licensing bases. The system reviews were based in part on guidance provided by NRC Inspection hianual Chapter 2535, " Design Verification Programs" and Inspection Procedure 93801, " Safety System Functional Inspection" The selected systems were reviewed in depth, including design bases, impact on design bases by system modifications, safety margins, maintenance, operations, surveillance, training, and corrective actions for previously identified deficiencies.

The SVSR was performed in accordance with Project Procedure PP 01 " System Vertical Slice l

Review" and Project Instmetion PI 01 " Conduct of SVSR". The approach to the SVSR is shon on Exhibit 2 2 and is based on the activities noted below:

• Select Systems for SVSR Determine System Boundaries e

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F EXHIBIT 2-2 SYSTEM VERTICAL SLICE REVIEW t

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DEFINE FROM NRC

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BOUNDARY l

T= 2 5r== Fmerans NRCtJNECo Revaw y'

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Scope / Boundary p Resolve d&rences g

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]f IDENTIFY Requircmcats Y

i IlGNSINGDESIGN Curcat I ic-ing Basis REQUIREMENTS AND Review Y

l OIECKLIST Preigamatic 4

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_ _ _ _ _ _ _._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ y _________________

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EVALUAlE Is the Corrective Action Define Other COMURATION Input to System Mod g-Review unmodified partioni MANAGEMEhT AII Mods Managemcat Reviews of the syntesa j

CONSIDERATIONS ga CAP Review Pra~A-es. Testing, i

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Wa& downs, etc.

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Rcviews Y

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Systems Mod System CAP System

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Requirament Ovd t;.e Requiremcatruai e Configuration Checklist 4

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l INSPECTION ACIIVI1TES BASED ON CIIEtTI ttT REQUIREMENTS i

i Mer+.= < =1 Training Program Specialists l

and Technical Reps Conferences Wa& downs Electrical Procure IAC Chil as Required

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Identify Licensing and Design Basis Requirements e

Prepare System Specific Checklists e

Evaluate System Configuration Management

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Select System for SVSR j

On June 30,1997, NNECo notified the NRC that the problem identification stage of their Configuration Management Program was complete for one half of the Maintenance Rule Group 1 1

systems. Based upon that notification, the NRC informed Parsons that the High Pressure Safety i

Injection (HPSI) including the Refueling Water Storage Tank and the Auxiliary Feedwater System j

including the Condensate Storage Tank were to be the first systems to be reviewed.

i On September 15,1997 'NNECo advised the NRC that reviews of the sixty three systems within the 1

scope of their CMP were complete and the NRC and NEAC selected the remaining systems at a NEAC public meeting in Connecticut the following week. The NRC advised Parsons that the seven additional systems selected were the Emergency Diesel Generator, Emergency Diesel Generator Fuel Oil, Emergency Diesel Generator Room Ventilation,4160 Volt AC and fast bus transfer, and i

Engineered Safeguards features Actuation System (Emergency Diesel Generator Load Sequence only), Enclosure Building Filtration System and the Containment and Enclosure Building Purge 4

System.

1 System Boundan

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The System Boundaries defmed the scope of the SVSR in regards to each of the selected systems.

Interfaces with, and portions of other systems were included within the boundary of the selected system to the extent they are neassary to support the functional requirements. In addition, system 4

ooundaJ:s were defined at appropriate components that provide physical isolation, as long as the j

selected boundary did not split the component between systems. The NRC reviewed each of the system bcundary for agreement in interpretation of SVSR scope. System boundaries were presented to NNECo at public meetings on July 30,1997 and October 3,1997 for the selected systems.

Licensine and Design Basis Reauirements Following system selection and boundary determination, the SVSR Tier 1 Team reviewed appropnate licensing documentation, including the Unit 2 Updated Final Safety Analysis Report (UFSAR),

l Technical Specifications, and other regulatory and design documentation that identify the' Licensing l

and Design Basis requirements for the system. These requirements established the inspection criteria and were itemized in the inspection system specific checklists.

System SDecific Checklist and Samole Plans

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i The inspection team reviewed and assessed pertinent design and operational aspects of the selected i

systems, using checklists based on functional system and design engineering considerations. The detailed checklists were developed specifically for the Millstone Unit 2 system being inspected and se.yed to maintain inspection focus and ensured a complete and thorough review. Sampling plans were selected for use with repetitive component group evaluations. The sample plan and its rationale were submitted to the NRC for their review and approval.

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2-4 PARSONS

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The checidists, incorporating the input of each reviewer and the team leader, were developed in a team environment and included inspection targets, validation, and verification requirements, and details of the current and original license bases, system history and configuration. The SVSR Team used the checklists to guide the inspection process during major inspection activities such as document and l

calculation review and system walkdowns.

System Configuration Management q

The system verticd Qce review (SVSR) entailed a comprehensive engineering review of the selected 4

systems by a team of m;chanica I, electrical, instrumentation & control, maintenance and operations specialists. The team, supported by a staff of regulatory and nuclear licensing specialists, employed a broad based but focused examination process of sufficient depth to probe all aspects of the selected systems design, history and configuration.

Emphasis was on verifying that the subject processes, practices and procedures used to perform engineering design, design change control document control and records updating of the design bases have been successful in maintaining the system configuration in accordance with regulatory requirements. Operations, Maintenance, and Test Procedures were reviewed to verify that correct licensing and design basis information had been incorporated into the procedures.

Evaluation of configuration management considerations was focused on licensing and design bases requirements. Evaluations utilized appropriate level documentation (drawings, calculations, design documents, etc.) to the inspection detail necessary to verify and validate conformation to requirements.

The vertical slice reviews verified that.

The current configuration accurately reflects the licensing-bases, including the updated e

FSAR.

Calculations and analyses were performed using recognized and acceptable analytical methods and that assumptions made in calculations er analysis supporting changes are technically sound.

The results of calculations or analysis supporting the unmodified portions of the original configuration and design changes are reasonable (based on engineering judgment) for the scope of the change.

Millstone Unit 2 considered the effect of a change on design margins and that the design changes received the appropriate level of engineering and management review during the de:ign phase and prior to implementation.

Millstone Unit 2 considered the effect of a change on pre-operational, startup or system baseline acceptance test results.

Design changes are accurately reflected in operating, maintenance, and test procedures, as well as in training materials.

I roposed design changes, subsequently canceled, were not replaced by proced iral changes that imposed excessive burdens on plant operators.

P 2-5 PARSONS

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,9 Adequate control of operational procedures, maintenance procedures, test and e

surveillance procedures, operator training and control of the plant simulator configuration.

The current configuration is consistent with the licensing bases at the level of detail contained in piping and instrumentation diagrams (P&lDs) or system flow diagrams, piping isometric drawings, electrical single-line diagrams, and emergency, abnormal and nonnat operating procedures.

The analyzed configuration is consistent with the current plant configuration.

Identification numbers are as indicated on the P&lD or process flow diagram, and equip nent name plate data is consistent with design specifications and analyses.

The location of pipe supports, snubbers, and other pipe restraints is consistent with design specifications and piping stress analyses.

Divisional separation of safety-related systems, structures and components, seismic II/I, and other topics addressed by the licensee's hazards analyses are reflected in the current plant configuration 2.1.2.

Review of Accident Mitigation Systems (Tier 2)

The Accident Mitigation Systems Review (AMSR) or Tier 2 review identified and evaluated " Critical Design Characteristics" for the Millstone Unit 2 accident mitigation systems. Critical Design Characteristics are identified by reviewing the functional requirements of accident mitigation systems and components to ensure that they can perform their specified safety functions. Each characteristic was identified from calculations, analyses and other documentary evidence that supported the Chapter 14 Accident Analysis in the updated FSAR.

Assessment of the. critical design characteristics for the accident mitigation systems was performed in accordance with Project Procedure PP-02 " Accident Mitigation System Review." The AMSR review consisted of the following major activities, as shown on Exhibit 2-3:

Identification of Critical Design Characteristics Validation of Critical Design Characteristics e

identification of Critical Desien Characteristics In order to determine critical design characteristics, it was necessary to determine the critical functions that must be performed. A critical function is the set of actions, as a whole, that must take place in order to prevent or mitigate the effects of a Design Bases Events (DBEv), or reduce the consequences of an accident.

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I Exhibit 2 AMSR Review Process FSAR Chapter 14m 1

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Identfy Devdop Derme Each Develop System Crtical

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Function Boundary Diagrams Function Functons Dangram NNECo Data 52a.o Analysis Priodty DBEvCDC d

to NRC for Review

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Dev 4 T2 Crew Parameters &

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7 Chapter 14 of the updated Final Safety Analysis Report (FSAR) is the description of all credible 1

accidents that were addressed. The FSAR (updated) was selected as the licensing and design basis be'nchmark source, or that point where all changes that affect the ability of the plar.t to meet the critical function should have been captured. Based on this review, the DBEv v ere identified as:

Increase in Heat Removal by the Secondary System Decrease in Feedwater Temperature Increase in Feedwater Flow Increase in Steam Flow Steam Generator Relief Valve Opening Main Steam Line Break (MSLB)

Decrease in Heat Removal by the Secondary System i

Loss of Extemal Load Turbine Trip Closure of Main Steam Isolation Valves Loss of Normal Feedwater Decrease in Reactor Coolant System Flow

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l Loss of Forced Reactor Coolant Flow

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l Reactor Coolant Pump Motor Seizure Reactivity and Power Distribution Anomalies e

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l Rod Withdrawal at Low Power Startup Condition l

Rod Withdrawalat Power l,

Dropped Control Rod / Bank Single Control Rod Withdrawal CVCS Malfunction Resuhing in Reactor Coolant Deboration Rod Ejection Accidents Decrease in Reactor Coolant Inventory 4

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.c Large Break - Loss of Coolant Accident (LOCA)

Small Break - Loss of Coolant Accident (!.OCA)

Radiological Consequences of SG Tube Rupture Radioactive Release from a Subsystem or Component e

Waste Gas System Failure Fuel Handling Accident - Spent Fuel Pool Fuel Handling Accident - Containment Spent Fuel Cask Drop Accident Non Standard Review Plan Events Containment Analysis - MSLB Containment Analysis - LOCA Hydrogen Accumulation. in Containment Radiological Consequences of the Design Basis Accident Each DBEv required a specific set of activities to occur in order to ensure that the plant achieves and maintains a safe condition. These activities are called " Critical Functions" A Critical Design Characteristic (CDC) is defmed as that aspect of a component or system that must be included in the design to ensure that the component or system will perform its critical safety function.. The CDCs were determined based on the existing information contained in the licensing basis for Millstone Unit 2 including:

Updated FSAR for Millstone Unit 2 and Supporting Accident Analyses e

Technical Specifications for Milk:one Unit 2 Design Inputs for Accident Reanalysis e

1 System Design Calculations and Analyses i

The Team reviewed the DBEv and derived the critical safety functions and critical design characteristics. A listing of the critical design characteristics for each DBEv was prepared and is l

discussed in detail in Volume 2 - Sect on 4.1 of this report. The critical design characteristics were t

reviewed anhpproved by the NRC.

p Validation of Critical Design Characteristics The Tier 2 review process included a validation of the critical design characteristics derived from 1

FSAR Chapter 14 and supporting analyses. The team reviewed the accident mitigation systems to identify the critical design characteristics that have been incorporated. This validation was based on

-E 24 l

i review of plant test data, Technical Specifications, calculations, or other plant configuration documents such as drawings, calculations, etc. that reflect the current documented plant configuration as appropriate. The Emergency Operating Procedures (EOP) were reviewed to determine consistency with the CDCs.

Review of the characteristics associated with the selected systems being reviewed by the SVSR Team was coordinated with the Tier i review team.

Differences between the " derived" CDCs and the " incorporated" CDCs were evaluated and compared against the results from the NNECo corrective action programs. As discrepancies were identified during the review, tney were reported per the requirements of Project Procedure PP-07 " Discrepancy Reports" 2.1.3.

Process Review (Tier 3)

The Tier 3 (Process Review) portion of the audit verified the adequacy of the Millstone Unit 2 CMP to identify and correct design and configuration management deficiencies associated with past change processes. In accordance with NRC direction, a review to determine whether Millstone Unit 2 processes and procedures have been established for effective configuration management on a going-forward basis has been addressed by others and was not included as part of this review.

The Tier 3 process review was not an evaluation of change procedures used in the past but rather a review to deteimine the effectiveness of the Millstone Unit 2 CMP to identify and correct deficiencies that may have resulted from the ineffectiveness of past change processes. This was accomplished by a

" horizontal slice" inspection of examples of past changes to the facility design, practices, and documentation The horizontal slice program verification cut across plant systems and was a technical review to determine if:

Changes to the plant meet the current design and licensing basis documentation, Design and licensing basis requirements have been translated into operating, maintenance and testing procedures, The performance of systems / components has been verified through testing, e

Design and plant information contained in databases and documents are accurate and e

consistent with the plant, and CMP corrective actions, associated wi*h the examples of past changes selected for resiew, e

have adequately corrected the deficiency.

The Process Review of Millstone Unit 2 processes and procedures was performed in accordance with Project Procedure PP-03 " CMP Performance Horizontal Slice Review" Conduct of the review is based on the activities noted below:

Identify Change Processes CMP Horizontal Slice Review e

P 2-10 PAFISDNS l

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i Identify Channe Processes i

j In. preparation for performing the nrocess review and the System Vertical Slice Review, NNECo procedures were reviewed and a process model prepared to identify how various changes are performed and controlled, the organizations involved, titles of various documents, and where

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documents and information can be found. This was done to efficiently and consistently familiarize the t

ICAVP team members with what they would be reviewing and the organizations and kinds documents they would need to consider.

CMP IIorizontal Slice Review l

A review was performed on a sample of past change documentation and the resulting plant configuration, maintenance, operations, testing, or training changes. The review took into account:

Unrecognized modifications to the plant, design documents or information.

Departures from the plant licensing or design basis documents 1

1 Acceptable documentation of the results of the change and its basis.

This review was not an evaluation of change procedures used in the past, but rather a review to determine the effectiveness of the Millstone Unit 2 CMP to identify and corret 6esign or licensicg basis deficiencies that may have resulted from the ineffectiveness of past change processes. This was an "out-come" based comparison of the current conditions versus the current design and licensing basis.

To accomplish the objective of the Tier 3 inspection, specific change processes identified in Exhibit 2-4 were identified for review.

The sarapie in each of these areas was over and above what was reviewed by the System Vertical Slice Review. The sample of work products or outputs was chosen to provide, as appropriate, a cross section of attributes such as discipline, (mechanical, electrical, I&C, etc.), time frame in which the product was produced, and other characteristics which have been found by experience to be potential weakness,(e.g. numerous organizational interfaces, or past industry problems). Sample size and its l

rational was proposed and submitted to the NRC for review. Sampling.md reviews were conducted in two phases to ensure all CMP systems were considered.

The methodology, documentation requirements, and depth of review for this program verification l

review was similar to what is described in the System Vertical Slice Review procedures except this j

review is focused on change processes instead of systems.

Prepare Review Checklist l

Review checklists were developed specifically for the change processes identified in Exhibit 2-4. The i

checklists served to maintain inspection focus and to ensure a complete and thorough review.

i The checidists, incorporating the input of each reviewer and the team leader, were developed in a team environment to ensure maxunizing the expertise of the entire group. The checklists identified programmatic evaluation criteria for each of the inspection areas.

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Exhibit 2-4 Tier 3 Change Process Inspection Areas j

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2) Specification Revision (not associated with a modification)

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3) Drawing Revisions (not associated with a modification)

4) Calculations Revisions (not associated with a modification) i 1

5) Licensing Document Changes

6) Non-Conformance Report (use as is)

7) Engineering Work Request j

8) VendorTechnicalInformation Updates PARTS PROCUREMENT / SUPPLY 1

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2) Equivalency Substitution

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3) Master Equipment Parts List (MEPL) l OPERATIONS & MAINTENANCE l

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1) Revisions to Operations & Maintenance Procedures l

2) ISI/IST, ASME Section XI Repair and Replacement i

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3) Temporary Changes, including jumper. lifted lead, and bypass control i

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2-12 E PARSONS j

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Cdnduct the Review l

The review entailed a comprehensive engineering review of the above inspection areas by a team of mechanical, electrical, instrumentation & control, maintenance, operations, document control, configuration management, and information management specialists. The team, using the inspection area checklist reviewed the selected sample of change process outputs, confirmed database accuracy and consistency, and performed plant walkdowns.

If discrepancies were identified during the review, they were immediately communicated to management for evaluation. Discrepancy Reports were generated in accordance with the requirements of Project Procedure PP-07 " Discrepancy Reports" 2.1.4.

Regulatory Review As part of the Millstone Unit 2 ICAVP, a Regulatory Review was performed of selected licensing l

documents that were docketed for Millstone Unit 2. (Docket 50-336). The Regulatory Review included commitment identification for serificatica during the System Vertica! Slice Resiew (Tier 1).

The Regulatory Review was initiated to provide additional insight into NNECo's compliance with the current licensing and design bases at Millstone Unit 2.

l The Regulatory Review was performed in accordance with Project Procedure PP-04 " Regulatory Review" and consisted of the following main activities:

Identification of regulatory requirements, Millstone Unit 2 applicability and specific conwitments identified on the docket for items within the scope of Tier 1 (the scope of Tier 1 is limited to the systems selected by the NRC for Tier i review).

Verification of commitments and requirements validation (applicable items).

Identification of Applicable Renulatory Reauirements, and Related Commitments Specific regulatory documents were included in the Regulatory Review if they are applicable to Millstone Unit 2 and within the scope of the IC.AVP. These included:

NRC Bulletins NRC Generic Letters Safety Evaluation Reports associated with License Amendments Other Safety Evaluation Reports (not associated with License Amendments)

Millstone Unit 2 Licensee Event Reports All documents in each of these categories were screened for applicability. Documents relating to certain programmatic areas such as security, fire protection, environmental qualification, emergency response and planning and quality assurance were not reviewed as part ofihe Regulatory Review.

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2-13 E PARSONS

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Each applicable document was summarized keying on required licensee action. In addition, the licensee's docketed response or application as applicable was reviewed and summarized. This summary of the response focused on the licensee's commitments.

For each applicable document, a review of the current Updated Final Safety Analysis Report was performed to detennine if an FSAR change was required, and if required, whether the FSAR was updated as required by 10 CFR 50.71.

Commitment /Reauirement Verification Specific commitments identified during the Regulatory Review were verified during the Millstone Unit 2 ICAVP. The verification of the specific regulatory requirements were performed as part of the Tier i reviews.

2.1.5.

Corrective Action Review The corrective action review evaluated the NNECo implementation ofits corrective action resolution processes. The scope of review contained three parts, with similar objectives. The system scope focused on the ccrrective action documents relating to the four systems selected for ICAVP review.

The NRC Selected (Tier 3) scope included eighty two (82) corrective actions selected specifically by the NRC for review. The corrective actions resulting from ICAVP confirmed Significance Level 3 Discrepancy Reports is the third scope area. The sections below describe these in more detail and present the review methods which were used and the documentation which was produced.

Obiectives The System Vertical Slice Review (SVSR) process identified objectives for the Corrective Action Program, as follows:

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l 1.

Review proposed and implemented corrective actions for Licensee-identified design deficiencies 2.

Verify the adequacy of the licensee's corrective actions as part of the configuration Management l

Program (CMP) and in response to the ICAVP findings.

3. Assess the adequacy of the licensee's effectiveness ofimplementation of the corrective actions l

developed as part of the CMP and in response to the ICAVP findings, l

Scope Area 1-System Scope In order to achieve the objectives, and to assure the validity of the ICAVP system technical conclusions, a review population of corrective action documents was identified. This population contained the CMP items that require resolution or correction, as well as discrepancies discovered on a continuing basis by either NNECo, the ICAVP contractor or others. Two types of corrective action c

documents were included.

1. Adverse Condition Reports and Condition Reports (ACR/CR) were initiated and processed to evaluate and resolve conditions or concerns. The process is comprehensive, including reportability analysis, operability evaluation and possible root cause analysis.

2-14 V PARSONS l,

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2. ' Unrcsolved Item Reports (UIR) were generated during CMP to track questions which had a lower level of significance. If resolution of the UIR involved a safety issue, a CR would be initiated to assure proper evaluation.

3.

Because the review ppulation was large, a sample specification was used to focus the review effort.

. More than 1900 corrective actions were subjected to the sampling process. Application of the Sample Specification selected approximately half of the Corrective Actions for detailed review. More than 250 of these were reviewed in detail during the project time frame. Based on Millstone Unit 3 ICAVP lessons learned, a sample of 30 corrective actions which NNECo had completed in 1998 was selected by the NRC for ICAVP review.

Scone Area 2 - NRC identified (Tier 3) scope Specific corrective actions were identified by the NRC staff to be included within the scope of the ICAVP Tier 3 review at Millstone Unit 2. These corrective actions were selected from those identified during the licensee's implementation ofits Configuration Management Plan that were not associated with the ICAVP Tier i systems and not resulting from ICAVP reviews. The eighty two (82) selected items were identified in a December 22,1997 letter from the NRC. The NRC later requested that only completed corrective actions be reviewed, so the review scope was limited to the 57 items which 1

were complete on September 1,1998.

Scone Area 3 - Discrenancy Report Corrective Actions A sample of corrective actions resul:ing from Significance Level 3 Discrepancy Reports will be selected by the NRC for review by Parsons. The results of this review will be described in a supplement to this report to be prepared after the sample is identified and reviewed.

Review Method and Documentation Each corrective action was reviewed in detail, including supplementary information and referenced documents. The review was structured to focus on the following three areas:

1. Adequacy of the extent of condition review and any associated root cause analysis 2.

Specificity and technical adequacy of the resolution 3.

Completion state of the corrective actions, including configuration management documents, and appropriateness of any future scheduled elements.

For cc~ective actions which were scheduled to occur at dates which were after the unit had restacted, i

the action plan.s were reviewed. In these cases, the appropriateness of the schedule was the focus of the review.

Discrepancy Documentation Discrepancies identified in the review process were documented in Discrepancy Reports. Where the issue was initiated at Significance Level 3, a specific DR was issued for each corrective action issue.

Significance Level 4 issues were grouped or binned into several categories for trending prior to issue.

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Discrepancy Report Process During the course of the Unit 2 ICAVP, any Team member was able to identify an apparent discrepancy and originate a Discrepancy Report (DR) in accordance with Project I%cedure PP-07 A discrepancy was identified as a condition, such as an error, omission, or oversight which prevents consistence among the physical configuration, information sources (e.g. documentation and databases, design basis and/or regulatory requirements). The process for evaluation of Discrepancy Reports is presented in Exhibit 2-5.

All DR3 were evaluated by the responsible Group Lead, based on discussion with the Originator and other Team Members, to determine ifits basis was valid and to ensure that all known aspects of the Discrepancy are adequately described on the DR.

If the basis for the DR is determined not to be valid, the responsible Group Lead closed the DR.

During initiation, all valid DRs were assigned an initial significance level. Project procedures defined i

the four significance levels as follows:

SIGNIFICANCE LEVEL 1 1

A discrepancy that identifies that the system does not meet its licensing and design bases and cannot perform its intended function, i.e., has the potential to simultaneously affect redundant i

trains.

SIGNIFICANCE LEVEL 2 A discrepancy 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.

l SIGNIFICANCE LEVEL 3 J

A discrepancy that identifies that a system does not meet its licensing and design bases but the i

system is capable of performing its intended function.

SIGNIFICANCE LEVEL 4 A discrepancy that identifies that the systems meet its licensing and design bases, however, there exists minor errors such as minor arithmetic errors ().at do not significantly affect the results of a calculation or inconsistencies between documents of an editorial nature.

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

After a DR was reviewed and approved, the DR was reported concurrently to the NRC, NEAC and NNECo in accordance with the approved Communications Plan. DRs were posted on the Parsons World Wide Web page after reporting to NNECo, NEAC and the NRC. This included DRs that were closed following a determination that the basis was not valid and for issues that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management P!an.

Once NNECo responded to a DR and provided the proposed corrective action, Parsons prepared comrnents on the proposed corrective action. Once comments on the proposed resolution were 2-16 USARSONS

i i

reviewed and approved, they are fonvarded to the NRC, NNECo and NEAC. A summary of proposed NNECo resolution) and Parsons comn"ts was also reported on the Parsons World Wide Web.

The DR was closed in any of the following manners:

NNECo agreed that the DR is a new discrepant condition and provided Corrective a.

Action system tracking data (Closed-Confirmed DR).

b.

NNECo has shown and Parsons agreed that the specific issues identified in the DR were previously identified i:y NNECo during CMP (Closed-Previously Identified).

NNECo has shown through providing additional information and Parsons agreed that c.

the condition identified in the DR is no longer valid (Closed-Non-Discrepant).

5 If the proposed corrective action by NNECo was not complete or did not resolve the DR, the Deputy Project Director identified the DR as an open item. In some cases additional information was

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required from NNECo in order to close the response. These cases were tracked as Open-Follow-up required.

Ir fter a minimum of two NNECo responses, Parsons has not accepted the proposed NNECo a

resolution, the DR was classified as Unresolved. In only two cases, the NRC made the final l

determination on the condition of Unresolved DR's.

For confirmed Significance Level 3 discrepancy reports, Parsons will review an NRC selected sample of NNECo corrective actions as discussed in Section 2.1.5 i

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2-17 E PARSONS

^U Exhibit 2-5 EVALUATION OF DISCREPANCIES P P-07 AnyiCAvP Discrepancy Team M ember Report Process Discre pancy Check:

Identified MP identified IDENTIFICATION DR Log Descrapency Significance CF DISCREPANCY Number Report initiated etermination I

l..oup Lead l No and 2

EVALUATION Yes Yes MP-m anos No l Dep.Proj. Dir. l l Dep. Pro). Dir. l l Prolect DirecMr l [oject D6 rector l

REVIEW, APPROVAL AND FORWARDING l

NOTIFICATION l

l NEACl l NU Response l REVIEW OF llCAVP Team Rev4w and Comment H tao l PROPOSED CORRECTIVE ACTION eelptN lOpen item H ts e Ye

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>l Close l FINAL Unresolved l RESOLUTION y

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2-18 PARSONE

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2. 2.

Project Organization.

The Millstone Unit 2 ICAVP Project organization is shown in Exhibit 2-6.

The Millstone Unit 2 ICAVP organization is based on key project personnel who were assisted by a core team of technical specialists and additional support resources as required. All technical personnel assigned to the project were interviewed and approved by the NRC.

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Responsibilities of Project Director, Deputy Director, Group Leaders, Core Team personnel and technical support resourcea are:

j Project Director Overall management of the task was provided by the Parsons Fower Project Director. He was responsible for the task schedule, budget, senior client interface, and compliance to the NNECo contract requirements. He was the primary interface with NNECo, the NRC, and the public.

Deputy Project Director The Deputy Project Director assisted the Project Director in the overall management of the task, and was responsible for compliance to the ICAVP Audit Plan and the technical adequacy of the final report.

Group Leaders The Group Leaders were responsible to the Deputy Project Director for managing their assigned resources to complete the assigned items in their respective project areas. They are responsible for compliance to the ICAVP Audit Plan and the technical adequacy of their deliverables. They were betively involved in the pert'ormance of the work in their respective project U~ s. Group Leads were assigned for each of the following project areas:

System Reviews - Tier 1 (lead assigned for each system reviewed) a Accident Mitigation System Review - Tier 2 Process Model and Design Control Review - Tier 3 Regulatory Review e

Project Support e

Core Team Personnel The Core Team was selected based upon experience and particular areas of expertise. They are responsible for the performance of the systems audits, regulatory reviews, process revi w, document review, technical research and the generation of the necessary reports in their respective creas. These personnel work directly for the Group Leaders. The mechanical, structural, civil, electrical and instrumentation engineers were selected because of their expeitise in nuclear plant designs, modifications, assessments and programmatic knowledge. The operations specialists bring specific experience in operations, maintenance, procurement, configuration management and regulatory compliance Technical specialists in specific areas, e.g., Equipment Qualification, were utilized on an "as needed" basis across all inspection teams rather than being assigned to only one team.

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0-Technical Advisory Group l

An advisory group ofindustry experts assisted with ICAVP Audit Plan implementation and other l

activities as assigned by the ICAVP Project Deputy Director. The Technical Advisory Group (TAG) had the following responsibilities:

i The TAG provides advice, expert technical opinions and review services to the ICAVP l

Audit Team.

l The TAG reviewed the ICAVP Final Report.

l The TAG will review and comment on proposed corrective actions for all sampled l

l confirmed Significance Level 1,2 and 3 Discrepancy Reports (DRs).

l The TAG will review any Differing Professional Opinions e

Quality Assurance The Manager of Company Quality (MCQ) has been assigned the responsibility for monitoring the effective implementation of the Parsons Power Nuclear Quality Program. The MCQ reports to the President of Parsons Power and has the independence and authority to ass the effectiveness of quality l

activities and to provide mechanisms to initiate corrective actions as necessary.

The MCQ was responsible for internal audits and surveillances of the project in accordance with l

company procedures. A summary of the results ofinternal audits and surveillances and additional details of this corporate function are provided in Volume 2 - Section l0.0.

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Millstone Unit 2 ICAVP NNECo Interface Parsons Quality President Assurance Project Manager

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i Project Director Project Manager Deputy Technical Project Director Advisory Group i

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i Regulatory System Review -

Mitigatl< n system Support Tier 1 Review Tier 3 Support Review Tier 2 l

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Mechanical Electrical I& C Structural

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