ML20199M088
| ML20199M088 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/30/1998 |
| From: | Travers W NRC (Affiliation Not Assigned) |
| To: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9802100118 | |
| Download: ML20199M088 (7) | |
Text
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ - _ - - - - - -
paMo oq%
g.-
unirso orars y
8 NUCLEAR REGULATORY COMMISSION WAsHINGloN D.C. 'Me4H001 Jamary 30, 1998 Mr. Martin L. Bowling, Jr.
Recovery Officer Millstone Unit 2 c/o Ms. Patricia Loftus
- Director-Regulatory Aftairs Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385
Dear Mr. Bcwling:
In order to reemphasize the objective of the Independent Corrective Action Verification Program (ICAVP), ated 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 tu 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 ' eing used by the staff to determine if ICAVP findings, which are being categorized l
s in one of four levels of significance, warrant en expansion of ICAVP scope.
As stated in the NRC Confirmatory Order of August 14,1996, the purpose of the ICAVP is to confirm the effectiveness of the licenwe's program in assuring that the plant's physical and functiona1 characteristics are in conformance with its licensing and design bases. Accordingly, 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 outside its licensing and design bases. The acceptance criteria being applied for the ICAVP are conformance with the plant's licensing and design bases. Nonconformances with the licensing and design bases are being assessed through thw identification of any ' defects,' identified during the ICAVP reviews,
. In addition to the identification of ' defects,' the ICAVP reviews include the identification and assessment of other errors that do not meet the definition of a 'oefect" (e.g., minor calculational errors). Although such findings do not involve nonconformance with the licensing and design bases, they are being reviewed to det: milne if any programmatic trends raise a question about conformance with the plant's licensing and design bases.
As a result of questions /concems 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 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 e Tvel 4) which would not question the licensing and design bases. As such, the condition resented by each level serves to I!!ustrate the type of findings which would result in the plant g
w wnn' h
~
p PDR a
NRC FHf CENTER COPY
2 being outside its licensing and design bases (Levels 1 3). These levels further indicate the praded signinoance the staff woJd associate with such findings. This is important sinos, given the technical complexity of the ICAVP reviews, the signincance of an identified ' defect" could very markedly The significanos levels developed by the NRC staff are viewed as appropriete for establish'ng a clear hierarchical grouping of the ICAVP findings.
In addition to the establishment of the graded signi6canos levels, the NRC staff developed a list %g 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 inherent in detailed licensing and design reviews does not lend itself to i
the establishment of automatic thresholds to trigger en expansion of ICAVP scope..The NRC's existing prooses 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 perfcrence.
The ICAVP oversight plan, as currently established, allows the NRC staff to make informed judgments based not only on an assessment of the individual issues, but also on the licensee's l
corrective actions for that issue including the identification of root cause(s) and causal factors J
- associated with the issue, the proposed resolution to the issue, the applicability of the issue to other systems, and broader prograramatic and operational implications. As such, an important element in the ICAVP process is the NRC steff's or ICAVP contractor's independent vertfication of corrective actions being taken by the licensee in response to ICAVP findings. This independent verification of the adequacy of corrective actions results in additionalICAVP evaluations of the plant's lioer. sing and design bases, in carrying out its evaluations of ICAVP findings and the licensee's corrective actions, the staff is using, in part, the requirements of 10 CFR 50, Appendix B, Criteria XVI, and the guidance contained in NRC Generic Letter No. 91 18 (GL-g1 18) Revision 1 dated October 8,1997.
Both Appendix B and GL-g1 18 address actions necessary for the resolution of degraded ard nonconforming conditions. These actions include evaluation for both operability and -
reportability to NRC, and prompt disposition of the finding using an offxtive corrective action
- program. An important element of effective corrective action, in accordance with Appendix B, is to ensure that the root cause is identitled 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 prooses being used by the NRC staff.
Laval 1'
. System does not meet licensing and design bases and cannot perform its
' intended function.
NRC Action: - Would likely result in selection of additional system (s) for ICAVP review
i i) i
+
l 3-i Addakal Discunnion.
i if olther the ICAVP contractor review or the NRC staff review w,,,T.i.s a Level 1 finding, the
_ NRC staff anticipates that, as a minimum, an additional system or syttoms will be added to the 1
ourrent scope of the ICAVP review. Following confirmation of a Level 1 Anding, the Special
' Projects Office (SPO) staff will immediately present the finding and recommendations for.
1CAVP scope expansion to the Director, OfRoe of Nuc'sar Reactor Regulation (NRR), and the
,[
Executive Director for Operations (EDO).- Expansion of ICAVP scope will involve an additional l
l system or systems review by the ICAVP contractor, the NRC s%ff, or both. Absent a negative l
~ determination by the EDO, the SPO staff will require the expansion of the ICAVP scope. The i
NRC staff determination and bases for requiring scopo expension will be communicated to the l
{
licensee by written correspondence.
I i
j Laval 2:
. Single train of redundant system does r,ot meet licensing and design bases and
{
cannot perform its intended function.
(
_ NRC Actiont Would likely result in expansion of ICAVP scope to svaluate for similar 1
nonconformance issues in other systems l;
Additional Discunnion:
l i
l If either the ICAVP contractor review or the NRC staff review confirms a Level 2 finding, the i
i NRC staff anticipates that the scope of the ICAVP would be expanded to, as a minimum, i
require the evaluation of similar operational, procedural, or design attributes in other safety.
related or risk-significant systems for potential ncaconformances. Follow 8ag confirmation of a
- Level 2 finding, the SPO staff will immediately present the finding and recommendations for
- lCAVP scope expansion to the Director, NRR. The extent of reviews required under any -.
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) en NRC staff assessment of the conective actions taken r
. by the licensee to address both the staffs specific finding and any broader programmatic F
implicationsc Absent a negative determination by the Director, NRR, the SPO staff williequire
[
the appropriate expansion of de ICAVP scope. The NRC staff determinstion and bases for requiring soope expansion will be communicated to the licensee by written correspondence.
6 Laval 3 :
System does not meet licensing and design bases but able to perform its g
Intend function.
c.
n
- NRC Action: Could result in expansion of ICAVP scope to evaluate for similar t
~
nonconformance issues in other systems Additional Docussion:
+
l
.if either the ICAVP contractor review or the NRC staff review confirms a Level 3 finding, the
. NRC staff will consider expanding the scope of the ICAVP to require the evaluation of similar Loperational, procedural, or design attributes in other safety-related or risk-significant systems for potential nonconbiT6ances. The SPO staff will present confirmed Level 3 findings and
-..., -,e.
n 6--,--.e..,
~
~&
- - - - - +
, - - - -.,..~.....~
,...e, N.
,,...v~,--+--m-na+-,,,
nw-.,-
,,---, -~,,,. - - -,, --,m w +
4 recommendatiorm regarding ICAVP expansion to the Millstone Restart Assessment Panel (RAP). The staff recommendation on possible ICAVP expension for individual findings will consider the specific finding, and the effectiveness of the liensee's corrective actions. The effectiveness of corrective actions will be independently verified by the NRC staff, or the ICAVP contreetor, and will consider the requirements of Appendix B, Criterion XVI, and the guidance of GL-gi 18; The staff expects that, for an Individual Level 3 finding, effective licenose corrective action to address both the specific
- defect,' as well as any broader impication for other systems, would lead to en NRC staff determination that the ICAVP need not be expanded.
Conversely, a negative determination on effective licensee corrective action would be expected to result in a decision to expand the ICAVP. The RAP decision 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 evaluating individual Level 3 findings, the NRC staff (Chief, ICAVP Branch, SPO, NRR), will periodically, at least biweekly, consider the collective group of confirmed Lev #13
' findings identified during the conduct of the ICAVP reviews. Negative trends established by these Level 3 findings, which raise a question about licensieg and design bwee 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 nonconformances in other systems. In its evaluation of possible trends, the NRC staff will consider whether or not (1) the findings represent a large fraction of Mems reviewed; (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, electrical, instrument and controls, or structural); and (4) the findings are concentrated in a particular type of document (e.gi, 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 l
by the Director, NRR. - The NRC staff determination and bases for requiring scope expansion will be communicated to the lioonsee by written correspondence, i
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 Discusalon:
~
Although they do not result in the plant being outside its licensing and design bases (i.e., the ICAVP regulatory standard /scooptance 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 2 question regarding the plant's licensing and design bases.' Confirmed Level 4 findings are being assessed initially by the contractors to determine if licensee corrective actions are appiopriate. The NRC staff, on an ongoing basis, is aise reviewing these findings for i
_.-._-..__.,_,.._._..._m
t
' identification of multiple examples of specific findings and correspondhg trends. In its evaluation oi 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 are 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, drawhg, 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 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 det6-nination and bases for requiring scope expansion will be communicated to the licensee by wri' ten correspondence.
Sincerely, I @ M @ h.
v,4 v William D. Travers, D'i ector
- y s.,
3
'~
Special Projects Office Office of Nucicar Reactor Regulation Docket No.: 50-245, 50-336, & 50-423 cc: See next page
. Distribution:
PUBLIC Docket File SPO R/F Elmbro PMcKee SReynolds PEselgroth DOCUMENT NAME:P: Letter.lCP (*see previous concurrence)
T3 receive a copy of this document, Indicate in the box "C" copy w/o attach /enci"E" copy w/ attach /enci"N" no copy OFFICE TA-SPO D:S P Nrp NAME RPerch/sr WT
( / h8 DATE 1/23/98*
OFFICIAL RECORD COPY
- Northeast Nuclear Energy Company Millstone Nuclear Power Station, Units,1,2, and 3 oc:-
Lillian M. Cuoco, Esqulre Mr. Wayne D. Lanning Senior Nuclear Counsel _
Deputy Director ofInspections Northeast Utilities Service Company Special Projects Omos
~ P. O. Box 270 475 Allendale Road Hartford, CT 061410270 King of Prussia, PA 19406 1415
, Mr. Kevin T. A. McCarthy, Director Mr. F. C. Rtahen Monitoring and Radiation Division Vice President Work Services Department of Environmental Northeast kuclear Energy Company Protection P.O. Box 128
- 79 Elm Street Waterford, CT 06385 -
- Hartford, CT 06106 5127
, Charles Brinkman, Manager Mr. AllanJohanson, Assistant Washington Nuclear Operations Director.
ABB Combustion Engineering
' Office of Policy and Management 12300 Twinbrook Pkwy, Suite 330 l
' Policy Development and Planning Rockville, MD 20852 l
Division l-450 Capitol Avenue - MS 52ERN Mr. D. M. Goebel i
P. O. Box 341441 Vice President-Nuclear Oversight l;
Hartford, CT 06134-1441 Northeast Utilities Service Company P. O. Box 128 Regional Administrator, Region l Waterford, CT 06385 L U.S. Nuclear Regulatory Comm!asion 475 Allendale Road Mr. M. L. Bowling, Jr.
King of Prussia, PA 19406 Recovery Officer Millstone Unit 2
- clo Ms. P.- A. Loftus First Selectmen D.:ector Regulatory Affairs Town of Waterford Northeast Nuclear Energy Company Hall of Records P. O. Box 128 200 Boston Post Road Waterford, CT 06385
-Waterford, CT 06385 Senior Resident inspector Mr. J. P. McElwein Millstone Nuclear Power Station -
Recovery Mioer-Millstone Unit 1 clo U.S. Nuclear Regulatory Commission
- Vice President (Acting) Millstone Unit 3 -
P. O. Box 513 Northeast Nuclear Energy Company -
Niantic, CT 06357 -
P. O. Box 1:18
. Waterford, CT 06385 Mr. David Amerine Vice President - Nuclear Engineering
. Debor.Ja Katz,9 resident and Support Citizens Awarea oss Network
~ Northeast Utilities Service Company P. O. Box 83.
P. O. Box 128
- Shelbume Falls, V.A 03170 -
._Waterford, CT 06385 x
.. _ _ _ _ _. _ _ _.. _.. ~..
\\
e
' Northeast Nuclear Energy Company Millstonsi Nucisar Power Station, Un!ts 1, 2, and 3 t.c:
Mr. M. H. Brothers Mr. Don Schopfer Vice President - Operations Verification Team Manager Northeast Nucisar Energy Company Sargent & Lundy P. O. Box 128 55 E. Monroe Street j
' Waterford, CT 06386 Chicago,IL 60603 Mr. M. R. Sculty, Executive Director Mr. P. D. Hinnenkamp I
Connecticut Municipal Electric Director-Unit Operations Energy Cooperative Northeast Ncclear Energy Company 30 Stott Avenue P. O. Box 128 Norwich, CT 06360 Waterford, Conaseticut 06385 l
Mr. William D. Meinert Mr. J. A. Price Nuclear Engineer Unit Director-Millstone Unit 2 Massachusetts MunicipalWholesale Northeast Nuclear Energy Company Electric Company ~
P. O. Box 128 P. O. Box 426 ~
Waterford, Connecticut 06385 Lud,ow, MA 01056 Mr. B. D. Kenyon Emest C. Hadley, Esq.
Chief Nuclear Omcor-Millstone 1040 B Main Street Northeast Nuclear Energy Company P. O. Box 54g P. O. Box 128 West Wareham, MA 02576 Waterford, Connecticut 06385 4
Joseph R. Egan, Esq.
Egan & Associates, P.C.
- 2300 N Street, NW-Washington, D.C. 20037.
Citizens Regulatory Commission
- ATTN: Ms. Susan Perry Luxton 180 Great Neck Road
- Waterford, CT 06385 l
Mr. G. D. Hicks Unit Director - Millstone Unit 3 Northeast Nuclear Energy Company P.- Of Box 128 l.
' Waterford, Connecticut 06385 l
L Little Harbor Consultants, Inc.
r
' Millstone - ITPOP Project Omce P. O. Box 0630 Niantic, CT 06375-0630 l
. Mr. Daniel L. Curry L
~ Project Director -
Parsons Power Group inc.
2675 Morgantown Road -
Reading, PA 1g607
.-