ML20199M022

Provides Info to Further Explain & Specify Process by Which Staff Will Assess Results of Independent Corrective Action Verification Program

ML20199M022
Person / Time
Site:	Millstone
Issue date:	01/30/1998
From:	Travers W NRC (Affiliation Not Assigned)
To:	Schopfer D SARGENT & LUNDY, INC.
References
NUDOCS 9802100100
Download: ML20199M022 (7)

Text

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NUCLEAR REGULATORY COMMISSION WAsMINGToN, D.C. 30006 e001 l J, .wey 30,.1998

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Mr. Don Schopfer.

L Vice President and ICAVP Manager Sargent & Lundy 55 E. Monroe Street -

I- . Chicago,IL 60603 i . .

Dear Mr. Schopfer:

i-1 L in order to reemphasize the objective of the independent Corrective Action Verification Program

. (ICAVP), and the regulatory standard /accep'ence criteria upon which the licensee's performance is being measured be the U.S. Nuclear Regulatory Commission (NRC), the NRC l

staff is providing the following info,mation to further explain and specify the process by which

[ the staff will assess the results of the ICAVP. Contained in this information is a discussion of the process being used by the staff to determine if ICAVP findings, which are being categorized -

in one of four levels of significance, warrant an expansion of ICAVP scope.

L As stated in the NRC Confirmatory Order of August 14,1996, the purpose of the ICAVP is to

confirm the effectiveness of the licensee's ;togram in assuring that the plant's physical and functional characteristics are in conformance with its licensing and design bases. Accordingly, i

the regulatory standard being used to evaluste the licensee's performr :ce a..d restart -

, readiness is conformance with the plant's licensing and design bases. Consistent with the ICAVP purpose, the staff established in SECY-97-003, dated Jancary 3,1997, the term " defect'

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i to represent any condition, ideatified during the ICAVP review, that results in the plant being outside its licensing and design bases. The acceptance criteria being applied for the ICAVP are

'. conformance with the plant's !! censing and design bases. Nonconformances with the licensing and design bases are being assessSd through the identification of any " defects," identified

during the ICAVP reviews.  ;

in addition to the identification of "Jefects," the ICAVP reviews include the identification and

[ assessment of other errors that do not meet the definition of a " defect' (e.g., minor calculational L , errors).- Although such findings do not involse nonconformance with the licensing and design L - bases, they are being reviewed to determine if any pre;rammatic trends raise a cuestion about U conformance with the plant's_ licensing and design bases.-

I_ As a result of questions /concems from members of the public, expressed in periodic briefings I held by the NRC, the NRC staff developed four levels of significance which are being used to -

telegorize findings from the ICAVP. The levels _ illustrate findings (Leveb 1,2, and 3) which would indicate nonconformance with the licensing and design bases (i.e., defects) and findings  !

t f(Level 4) which would not question the licensing and design bases.' As such, the condition -

- represented by each level serves to illustrate the. type of findings which would result in the plant I g_

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being outside its licensing and design bases (Levels 1-3). These levels further indicate the graded signific nce the staff would associate with such findings. This is important since, given the technical complexity of the ICAVP reviews, the significance of an ideritified

• defect' could very markedly. The significance levels developed by the NRC staff are viewed as appropriate

. for establishing a clear hierarchical groupi9g of the ICAVP findings.

! In addition to the establishment of the graded significance levels, the NRC staff developed a listing of likely or potential NRC actions corresponding to each significance level. A listing of predetermined NRC actions resulting from ICAVP findings has been requested by some.

However, the complexity inMrent in detailed licensing and design review does not lend itself to the establishment of automatic thresholds to trigger an expansion of ICAVP scope. The NRC's existing process for performing these reviews, relying on established regulatory requirements and risk insights, provides for a broad consideration of possible ICAVP findings and is consistent in its use of the licensing and design bases as the regulatory standard for measuring the licensee's performance.

i The ICAVP oversight plan, as currently established, allows the NRC sta'f to make informed j judgments based not only on an assessment of the individualissues, but also on the licensee's

corrective actions for that iswe including the identification of root cause(s) ar,d causal factors

associated with the issue, tne proposed resolution to the issue, the applicability of the issue to

, other systems, and broader programmatic and opera'ional implications. As such, an important element in the ICAVP process is the NRC staff's or ICAVP contractor's independent veri'ication of corrective actions being taken by the licensee in response to ICAVP findings. This independent verification of the adequacy of corrective actions results in additional ICAVP l evaluations of the plant's licensing and design bases.

L . In carrying out its evalastions of ICAVP findings and the licensee's correctivo actions, the staff

!- . is using, in part, the requirements of 10 CFR 50, Appendix B, Criteria XVI, and the guidance L contained in NRC Generic Letter No. 91-18 (GL 91-18) Revision 1, daied October 8,1997.

Both Apper; dix B and GL-91-18 address actions necessary for the resolution of degraded and nonconforming conditions. These actions include evaluation for both operability and reportability to NRC, and prompt disposition of the finding us* effective corrective action program. An important element of effective corrective actior , . eccordance with Apoendix B, is to ensure that the root cause is identified and the issue is fully addressed in a timely manner,

, A further discussion of corresponding NRC actions related to the ICAVP findings, as follows, is intended to better explain and document the process being used by the NRC staff.

Level 1: System does not meet licensing and desiga bases and cannot perform its intended function.

O NRC Action: Would likely result in selection of additional system (s) for ICAVP review l Additional Discussion:

1 -If either the ICAVP contractor review or the NRC staff review confirms a Level 1 finding, the 1-

' NRC staff anticipates that, as a minimum, an additional system or systems will be added to the i-A

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current scope of the ICAVP review. Following confirmation of a Level 1 finding, the Special Projects Office (SPO) staff will immediately present the finding and recommendations for ICAVP scope expansion to the Director, Office of Nuclear Reactor Regulation (NRR), and the Executive Director for Operations (EDO). Expansion of ICAVP scope will involve an additional system or systems review by the ICAVP contractor, the NRC sta*f, or both. Absent a negative j determination by the EDO, the SPO staff will require the expansion of the ICAVP scope. The NRC staff determination and bases for requiring scope expar slon will be communicated to the licentee by written correspondence.

Level 2: Single train of redundant system does not meet licensing and design bases CM cannot perform its intended function.

NRC Action: Would likely result in expansion of ICAVP scope to evaluate for si.nilar

, nonconformance issues in other systems Additional Discussion:

If eit5er the ICAVP contractor review or the NRC staff review confirms a Level 2 finding, the NRC staff anticipates thsit the scope of the ICAVP would be expanded to, as a minimum, require the evaluation of similar operational, procedural, or design attributes in other safety-related or risk-significant systems for potential rionconformances. Following confirmation of a Level 2 finding, the SPO Cdiwill immediately present the finding and recommendations for ICAVP scope expansion to me Director, NRR. The extent of reviews required under a.iy expansion of the ICAVP will be based on (1) an NRC staff assessment of the licensee's root cause of the Level 2 finding, and (2) an NRC staff assessment of the corred.ive actions taken by the licensee to address both the staff's specific finding and any broader programmatic implications. Absent a negative determination by the Director, NRR, ths 3PO staff will require the appropriate expansion of the ICAVP scope. The NRC staff determination and bases fer requiring scope expansion will be communicated to the licensee by written correspondence.

, Level 3 : Systera does not meet licensing and design bases bet able to perform its intended function.

MRC Action: Could result in expansion of ICAVP scope to evaluate for similar nonconformance issues in other systems Additional Discussion:

If either the ICAVP contractor review or the NRC staff review confirms a Level 3 finding, the NRC staff will consider expanding the sc ope of the ICAVP to require the evaluation of similar operational, procedural, or design attributes in other safety-related or risk-significant systenis for potential nonconformanss. The SPO staff will present confirmed Level 3 findings and recommendations regarding ICAVP expansion to the M;iistone Restart Assessmer:t Panel (RAP). The staff recommendation on possible ICAVP expansion for individual findings will consider the spec 3c finding, and the effectiveness of the licensee's corrective actions. The effectiveness of coi ective actions will be independently verified by the NRC staff, or the ICAVP -

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i contractor, and will consider the requirements of Appendi : B, Criterion XVI, and the guidance of GL-gi 18. The staff expects that, for an individual Level 2 finding, offectivt, licensee corrective L action to address both the specific ' defect," as well as any broader implication for other

systems, would lead to an NRC staff determination that the ICAVP need not be expanded.

Conversely, a negative tietermination on effective licensee co,Tective action would be expected to result in a de, cision to expand the ICAVP. The RAP dec5 ion on ICAVP expansion will be documented in the RAP meeting minutes, and the Director, NRR, will approve any expansion of

.L ICAVP scope. The NRC staff determination and bases for requirir g scopa expansion will be communicateo to the licensee by written correspondence.

in addition to evaluating individual Level 3 findings, the NRC staff (Chief, ICAVP Branch, SPO, NRR), will periodically, at least beweekly, consider the collective group of confirmed Level 3 findings identified during the conduct of the ICAVP reviews. Negative trends established by .

l these Level 3 findings, which raise a questicn about licensing and design bases conformance in

- other systems, would, in the absence of ;Jfective corrective actions by the licensee, be i

expected to result in expansion of the ICAVP to address possible similar nonconformances in other systems. In its eva,uation of possible trends, the NRC r.aff will consider whether or not j (1) the findings represent a large fraction of items reviewed.: (2) the findings are implementation

! errors (e.g., program or procadural requirements were not properly performed; (3) the findings are concentrated in a particu ar discipline (e.g., mechanical, electrical, instrument and controls, or structural); and (4) the findings are concentrated in a particular .ype of document (e.g.,

operating procedure, calculation, drawing, FSAR, maintenance procedure). Any decision to expand the scope, based on negative trends associated with Level 3 find;ngs, will be approved

, by the Director, NRR. The NRC staff determination ar< bases for requiring scope expansion will be communicated to the licensee by written correspondence.

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Level 4: System meets licensing and design bases but contains minor calculational errors or inconsistencies of an editorial nature.

MC Action: Multiple examples could result in expansion of ICAVP scope to evaluate for

. similar errors / inconsistencies in other systems Additional Discussion:

. Although they do not result in the plant being outside its licensing and design bases (i.e., the ICAVP regulatory standard / acceptance criteria), Level 4 findings will be assessed by the NRC staff. - Level 4 findings will be assessed to determine whether trends exist which could raise a question regarding the plant's licensing and design bases. Confirmed Level 4 findings are being assessed initia 'y by the contractors to determine if licensee corrective actions are

appropriate. ' The NRC staff, on an ongoing basis, is also reviewing these findings for ident:fication of multiple examples of specific findings and corresponding trends. In its

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evaluation of possible trends, the NRC staft will consider whether or not (1) the findings -

napresent a large fraction of items reviewed; (2) the findings are implementation errors (e.g.,

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l 5-program or procedural requirements were properly performed); (3) tne findings are concentrated in a particular discipline (e.g., mechanical, electrical, instrument and controls, c,r structural); and (4) the findings are concentrated in a particular type of document (e.g.,

operating procedure, calculation, drawing, FSAR, rnaintenance procedure). The staff anticipates that if licensee corrective actions are determined to be effective, and trends which raise questions about the licensing and design bases are not identified, the scope of the ICAVP would not be expanded. The status of Level 4 findings are periodically presented to the RAP.

Any expansion of ICAVP scope resulting from Level 4 findings will be approved by the EDO.

The NRC staff determination and bases for requiring scope expansion will be communicated to the licensee by written correspondence.

Sin ppeAMd Will'ia'm D. Travers, Director Spscial Projects Office Office of Nuclear Reactor Regulation Docket No.: 50 ' 423 cc: See next page Distnbution:

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