ML20199M040

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

ML20199M040
Person / Time
Site:	Millstone
Issue date:	01/30/1998
From:	Travers W NRC (Affiliation Not Assigned)
To:	Curry D AFFILIATION NOT ASSIGNED
References
NUDOCS 9802100105
Download: ML20199M040 (7)

Text

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4. [ h UNITED STATES g ,

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. SegeMGM Jar ==ry 30,1998

< Mr. Daniel Curry a

Project Director = ._

j 1 Parsons Power Group inc.

2675 Morgantown Road

' Reading, PA 19607

Dear Mr. Curry:

In order to reemphasize the objective of the independent Corrective Action Verification. Program

= (ICAVP), and the regulatory standard / acceptance criteria upon which the licensee's performance is being measured by the U.S. Nuclear Regulatory Commission (NRC), the NRC.

staff is providing the following information 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.-

As stated in the NRC Confirmatory Order of August 14,1996, the purpose of the _I_CAVP is to confirm the effectiveness of the licensee's program in assuring that the plant's physical and -

functional characteristics are in conformance with its licensing and design bases. - Accordingly, i

t the regulatory standard being used to evaluate the licensee's performance and 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 January 3,1997, the term " defect" to represent any condition, identified during the ICAVP review, that results in the plant being ;

f outside its licensing and design bases.' The acceptance criteria being applied for the ICAVP are -

conformance with the plant's licensing and design b6ses. Nonconformances with the licensing -

and design bases are being assessed through the identificatbn of any

• defects," identified durir.g the ICAVP reviews.

- in addition to the ident:fication of " defects," the ICAVP reviews include the identification and assessment of other errors that do not meet the definition of a " defect'. (e.g., minor calcuistional- <

errors)J Although such findings do.not involve noncenfoniiance with the licensing and design bases, they are being reviewed to determine if any programmatic trends raise a question about .

conformance with the plant's licensing and design bases. ,

As a result of questions / concerns from members of the public, expressed in periodic briefings held by the NRC, the NRC staff developed four levels of significance which are.being used to i categorize findings from the ICAVP. The levels illustrate findings (Levels 1,2, and 3) which would indicate nonconformance with the licensing and design bases (i.e., defects) and findings (Level 4) which would not question the licensing and design bases. As such, the condition i represented by each level serves to illustrate the type of findings which would result in the plant C(D\

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being outside its licensing and design bases (Levels 1 3). These levels further indicate the the technical complexity of the lCAVP rwiews, the signmem vary markedly The signincance levels developed by the NRC staff are viewed as appr for establishing a clear hierarchical grouping of the ICAVP Andings.

In addnion to the establishment of the gwled signmcanos levels, the NRC staff dev listing oflikely or potential NRC actions corresponding to each signmonnoe level. A predetermined NRC actions resulting from ICAVP findings has been requested by some

. However, the complexity inherent in detailed licensing and design reviews does not y - the establ;shment of automatic thresholds to trigger an expansion of ICAVP scope. Th existing process for performing these reviews, relying on established regulatory requirem

- and risk insights, providas for a broad consideration of possible ICAVP findings and is the licensee's performance. consistent in its use of the licensing and design bases

. The ICAVP oversigh plan, as currently established, allows the NRC staff to make informed judgments based not only on an assessment of the individuti issues, but also on the li corrective actions for that issue including the identmcation of root cause(s) and causal factor associated with the issue, the proposed resolution to the issue, the applicability of the issu other systems, and broader programmatic and operational implications. As such, an im 1 element in the ICAVP prooses is the NRC staff's or ICAVP contractor's independent ve of conective actions being taken by the licon,:.se in response to ICAVP findings. This itxiependent verification of the adequacy of cen.ctive actions resuRs in additional IC%VP evaluations of the piant's licensing and design bases, in carrying out its evaluations of ICAVP findings and the licensee's corrective actions, th

' is using, in part, the requirements of 10 CFR 50, Appendix B, Criteria XVI, and the guid contained in NRC Generic Letter No. 91 18 (GL-gi 18) Revision 1, dated October 8,19g7.

Both Appendix B and GL-gi 18 address actions necessary for the resolution of degraded rcncenhining conditions. These actions include evaluation for both operability and -

reportability to NRC, and prompt disposition of the finding using an effective corrective action to ensure that the root cause is identified and the wue is fully '

' A further discussion of corresponding NRC actions related to the ICAVP findings as follow ,

intended to better explain and document the process being used by the NRC staff, Lavalt i System does not meet licensing and design bases and cannot perform its

.. Irwended function.

NRC Action: Would likely result in selection of additional system (s) for ICAVP reviewi

' '~ ' ' '

3 -

3 Additionni Diseasks if either the ICAVP contractor review or the NRC staff review con 6rms a Level 1 finding, the NRC staff anticipates that, os a minimum, en additional system or systems will be added to the current scope of the ICAVP review.- Following con 6rmailon of a Level 1 Anding, the Special  !

Projects Ofnos (SPO) staff win immediately presord the Anding and recommendations for i

ICAVP scope expansion to the Director, Ofhoe r4 Nuclear Reactor Regulation (NRR), and the -

Executive Director for Operations (EDC,. Expansion of ICAVP scope wili irwolve en additional system or systems review by the ICAVP contractor, the NRC staff, or both. Absent a negative determiristion by the EDO, the SPO staff will require the expansion of the ICAVP scopo. The NRC staff determination and bases for requiring scope expansion win be commanicated to the -

l liconese by writteo correspondonos.

LasL2: Single train of redundant system does not meet licensing snu design bases and cannot perform its intended function.

l NRC Action: Would likely result in expansion of ICAVP scope to evaluate for similar nonconformance issues in other systems .

l Additional Dimeunnion:

if either the ICAVP contractor review or the NRC staff review con 6rms a Levr ! 2 Anding, the NRC staff anticipates that 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 nonconformances. Following conArmation of a Level 2 finding; the SPO staff will immediately present the finding and recommendations for l ICAVP scope expansion to the Director, NRR. The exterd of reviews required under any expansion of the ICAVP will be based or. 31) an NRC staff assessment of the licensee's root cause of the Level 2 finding,' and (2) en NRC staff assessment of the f. srective actions taken by the lloonsee to address l'oth the staff's specific finding and any broeder programmatic _ ,

implications _ Absent a negative determination by the Director, NRR, the SPO staff will require the appropriate expansion of the ICAVP scope. The NRC staff determination and bases for requiring scope expansion will be communicated to the licensee by written cerrespondence.

LeeUU System does not meet licensing and design bases but able to perform its

- intended function.

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

If either the ICAVP contractor tsview or the NRC staff revbw confirms a Level 3 finding, the NRC staff will consider expanding the scope of the ICAVP to require the evaluation of similar operational, procedural, or design attributes in othei safety-related or risk-significant systems for potential nonconformances. The SPO staff will present confirmed Level 3 findirgs and

e'

. 4 reemendations regarding ICAVP expansion to the Millstone Restart Assessment Panel (RAl'). The staN tocommendation on possible ICf.VP expansion for individual Andings will consider the spoolRc finding, and the eNoctiveness of the licensee's corrective actions. The

' eNectiveness of corredive actions will be independently vertfled by the NRC staN, or the ICAVP -

contractor, and will consider the requirements of Appendix B, Criterion XVI, and the guidance of GL g1 18. The staff expects that, for an individual Level 3 finding, effective licensee corrective

' adlon to address both the spoolfic "defod,' as well as any broader implication for other systems, would lead to en NRC staff determination thr' +4 '~ AVP need not be expanded.

Conversely, a negative determination on effective lioer, orrective action would be expected -

' to result in a decision to expand the ICAVP, The RAP oJsson on ICAVP expansion will be documented in the RAP meeting minutes, and the Director, NRR, will approve any expansion of ICAVP scope. The NRC staff determination and bases for requiring scope expansion will be communicated to the licensee by written correspondence, in addition to evasusting individual Level 3 findings, the NRC staff (Chief, ICAVP Branch, SPO, NRR), will periodically, at least biweekly, consider the collective grcup of confirmed Level 3 findings identified during the conduct of the ICAVP reviews. Nega'ive trends established by '

thess Level 3 findings, which raise a question about licensing and design bases conformance in other systems, would, in the absence of effective corrective actions by the licensee, be-expected to result in expansion of the ICAVP to address possible similar r,cr,cer,Mir,ances,in

- other systems. In its evaluation of possible trends, the NRC staff will consider whether or not (1) the findings reproson'. a large fraction of items reviewec', (2) the findings are implementation errors (e.g., program or procedural requirements were not properly performed; (3) the findings are concentrated in a particular discipline (e.g., mechanical, eNetrical, instrument and controls, or structural); and (4) the findings are concentrated in a particular type of document (e.g.,

l operating procedure, calculation, drawing, FSAR, maintenance procedure). Any decision to expand the scope, based on negative trends associated with Level 3 findings, will be approved f by the Director, NRR. The NRC staff determination and bases for requiring scope expansion

- will be communicated to the licensee by written correspondence.

Laval4: System meets licensing and design bases but contains minor calculational errors or inconsistencies of an editorial nature, NRC 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 balog 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 L.ad design bases. Confirmed Level 4 findings are being assesse* '..!tially by the contractors to determine if licensee corrective actions are apprnpriate. 'i ne NRC staff, on an ongoing basis, is also reviewing these findings for

_ __ J

5 Identification of multiple examples of specific findings and corresponding trends. In its evaluation of possible trends, the NRC staff will consider whether or not (1) the findings represent a large fraction of items reviewed; (2) the findings are implementation errors (e.g.,

program or procedural requirements were properly performed); (3) the findings tre i

concentrated in a particular discipline (e.g., mechanical, electrical, instrument and controls, or structural); and (4) the findings are concentrated in a particular type of document (e.g.,  !

operating procedure, calculation, drawing, FSAR, maintenance 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 expended. 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.

SincerkMSignybn n%.

William D. Travers, Director Special Projects Office Office of Huclear Reactor Regulation-4 Docket No.: N cc: See next page Distribution:

PUBLIC Docket File SPO R/F Elmbro PMcKee SReynolds

. PEselgroth DOCUMENT NAME:P: Letter.lCP (*see prsvious concurrence)

T@ receive a copy of this document, Indicate in the box "C" copy w/o attachtenci"E" copy wInttachlenci"N" no copy ,

w OFFICE TA SPO D:SPO M NAME RPerch/sr WTraheb DATE

~

1/23/98* // N8 OFFICIAL RECORD COPY

i Northeast Nuclear Energy Company Millstone Nuclear Power Station ,

Unit 2 cc:

Ullian M. Cuoco, Esquire Senior Nuclear Counsel Mr. F. C. Rothen Northeast Utilities Service Company Vice President Work Services P. O. Box 270 Hartford, CT 06141-0270 Northeast Utilities Service Company P. O. Box 128 Waterford, CT 06385 Mr. John Buckingham Department of Public Utility Control Emest C. Hadley, Esqu!re Electric Unit 1040 B Main Street 101.iberty Square P.O. Box 54g New Britain, CT 06051 West Wareham, MA 02576 Mr. Kevin T. A. McCarthy, Director Mr. D. M. Goebel Monitoring and Radiation Division Vice President Nuclear Oversight Department of Environmental Protection Northeast Utilities Service Company 79 Elm Street P. O. Box 128 l

Hartford, CT 06106 127 Waterford, CT 06385 ,

Regional Administrator, Region i Mr. David Amerine U.S. Nuclear Regulatory Commission Vice President - Nuclear Engineering 475 Allendale Road and Support King of Prussia, PA 19406 Northeast Utilities Service Company P. O. Box 128 First Selectmen Waterford, CT 06385 Town of Waterford H:ll of Records Mr. Allan Johanson, Assistant Director 200 Boston Post Road Of5ce of Policy and Management Waterford, CT 06385

! Policy Development and Planning Division Mr. Wayne D. Lanning 450 Capitol Avenue - MS# 52ERN Deputy Director of Inspections P. O. Box 341441 Special Pro}ect: Office Hart'ord, CT 061341441 475 Allendale Road King of Prussia, PA 19406-1415 Mr. M. H. Brothers Vice Frosident - Operations Charles Brinkman, Manager Northeast Nuclear Energy Company Washington Nuclear Operations P.O. Box 128 ABB Combustion Engineering Waterford,CT 06385 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Mr. J. A. Price Unit Director- Millstone Unit 2 Senior Resident inspector Northeast Nuclear Energy Company Millstone Nuclear Power Station P.O. Box 128 4 c/3 U.S. Nuclear Regulatory Commission Waterford, CT 06385 P.O. Box 513

- N'c ntic, CT 06357 4

b ' Northeast Nuclear Energy Company MiHetone Nuclear Power Station Unit 2 oc:

Mr. B. D. Kenyon Chief Nucler Omcor Millstone Northeast Nuclear Energy Company P.O. Box 128 '

Waterford,CT 06385 Citizens Regulatory Commission ATTN: Ms. Susan Perry Luxton 180 Great Neck Road  :

Waterford,CT 06385 Deborah Katz, President '

Chizens Awareness Network '

P. O. Box 83 Shelburne Falls, MA 03170 L

The Honorable Terry Concannon '

Co-Chair Nuclear Energy Advisory Council i Room 4035 Legislative Office Building CapHol Avenue

.. Hartford, CT 06106 I Mr. Evan W. Woollacott I Co-Chair Nuclear Energy Advisory Council 128 Terry's Pirin Road Simsbury, CT 06070 Little Harbor Consultants, Irm.

~ Millstone ITPOP Project Office P. O. Box 0630 Niantic, CT 06357-0630 Mr. Don Schopfer Verification Team Manager Sergent & Lundy 55 E. Monroe Street -

Chicago,IL 60603 1

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