ML20202A695
| ML20202A695 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/30/1998 |
| From: | Travers W NRC (Affiliation Not Assigned) |
| To: | Concannon T, Woollacott E CONNECTICUT, STATE OF |
| References | |
| NUDOCS 9802100130 | |
| Download: ML20202A695 (7) | |
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WASHINGTON, D.c. 30085 4 001 January 30, 1998 The Honorable Terry Concannon Nucle:r Energy Advisory Coancil Room 4035 Legis,lative Office Sullding Capitol Avenue Hartford, CT 06106 Mr. Evan Woollacott Nuclear Energy Advicory Council 128 Terry's Plain Road Simsbury, CT 06070
Dear Ms. Concannon and Mr. Woollacott:
In order to reemphasize the objective of the Indeoer. dent 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 i
I 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 stuff 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 ICAVP is to confirm the effectiveness of the licensee's program in assuring that the plant's physical and functional characteris;les are in conformance with itc 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 rtaff 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 nutside its licensing and design bases. The acceptance criteria being applied for the ICAVP are confermance with the piant's licensing and design bases. Nonconformances with the licensing and design bases are being assessed through the identification of any ' defects," identified during the ICAVP reviews.
In addition to the identification of ' defects,' the ICAVP reviews include the identification ana
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assessment of other errors that do not meet the definition of a 'dsfect' (e.g., minor calculational errors). Although such findings do not involve nonconformance with the licensing and design bases, they are being reviewed to determine if any programmatic trends raise a question about confom ance with the plant's licensing and design bases.
As a result of questions /concems from membero of the public, expressed in periodic br!efings held by the NRC, the NRC staff rieveloped four levels of s'gnificance which are being used to i
categorize findirigs from the ICAVP. The leve's illustrate findings (Levels 1,2, and 3) which Q
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4 2-would indicate nt noonformaince with the licensing and design bases (i.e., defects) and findings -
(Level 4) whloh would not question the licensing and design bases. As such, the condition represented b) each level serves to illustrate the type of findings which would result in the plant being outside its licensing and design bases (Levels 1 3). These levels further indicate the graded significance the staff would associate with such findings. This is important since, given -
the technical complexity of the ICAVP reviews, the signifloanos of an identified ' defect
- could vary markedly. The significanos levels developed by the NRC staff are viewed as appropriate for establishing a clear hierarchical grouping of the ICAVP findings.
In addition to the establishment of the graded significance levels, the NRC staff developed a Noting of likely or potential NRC actions corresponding to each significance level. A listing of predetermined NRC actions resul'ing from ICAVP findings has been requested by some.
However, the complexity inhoront in detailed licensing and design reviews does not lend itself to
- the establishment of automatic thresholds to trigger an expension of ICAVP scope. The NRC's existing process for performing these reviews, relying on established regulatory requirements and risk insights, ptovides for a broad consideration of possible ICAVP findings and is consis5nt in its use of the licensing and design bases as the regulaiory standard for measuring the licensee's performance.
l The ICAVP oversight plan, as currently established, allows the NRC staff to make informed l
Judgmenta based not only on an assessment of the individual issues, but also on the licensee's correctin actions for that issue including the identification of root cause(s) and causal factors associated with the issue, the proposed resolution to t",s issue, the applicability of the issue to other systems, and broader programmatic and operational implications. As such, an important -
element in the ICAVP process is the NRC staffs or ICAVP contractor's independent verifmation 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 evaluations of the plant's licensing and design bases, in canying out its ovaluations of ICAVP findings and the licensee's correc4ve actions, the staff is using, in part, the requirements of 10 CFR 50, Appendix B, Critoria XVI, and the guidance
- contained in NRC Generic Letter No. 91 18 (GL gi 18) Revision 1, dated October 8, igg 7, Both Appendix B and GL-gi 18 address actions necessary for the resolution of degraded and notwonforming conditions. These actions include evaluation for both operability and reportability to NRC, and prompt oisposition of the finding using an effective corrective action ~
program. An important element of effective corrective action, in accordance with Appendix 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 tms, is intended to better explain and document the process being used by the NRC staff.
Lavalt System does not meet !icensing and design bases and cannot perform its intended function.'
. NRC Action: = Would likely result in selection of additional system (s) for ICAVP review
3 Addnianal Discunnion:
If either the ICAVP contractor review or the NRC staff review conArms a Level 1 finding, the NRC staff anticipates that, es a minimum, an additional system or systems will be added to the current scope of the ICAVP review. Following conArmation of a Level 1 finding, the Special Projects Omos (SPO) staff willimmediately present the finding one ecommendations for
- ICAVP scope expansion to the Director, Omos of Nuclear Resclor 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 staff, or both. Absent a negative determination by the EDO, the SPO staff will require the expansion of the ICAVP scope. The_-
NRC staff determination and bases for requiring scope expension will be communicated to the licensee by written conospondence.
Mwal 2:
Single train of redundant system doe? not meet licensing and design bases and cannot perform its intended f motion.
RC Action: Would likely result in expansion of iCAVP scope to evaluate for similar nonconformance issues in other systems Addhinnal Discynalon:
If either the ICAVP contractor review or the NRC staff review confirms a Level 2 finding, the l
NRC staff anticipates that the scope of the ICAVP would be expanded to, as a minimum,-
require the ovatuation of similar operational, procedural, or design attributes in other safety. -
L related or risk-significant systems for potential nonconformances.' Following confirmation of a Level 2 finding, the SPO sta; willimmediately present the finding and recommendations for ICAVP 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) an NRC staff assessment of the corrective actions taken by the licensee to addrces both the staff's specific finding and any troeder programmatic.
implications. Absent a negative determination by the Director, NRR, the 8PO 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 correspondence, y
Laval 3 * -
System does not meet licensing and design bases but able to perform its intended functionc NRC Action: Could result in expansion of ICAVP scope to evaluate for similar nonconformance issues in other systems Addhional Discusalon:
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 operational, procedural, or design attributes in other safety-related or risk-significant systems O
4 for potential nonconformances. The SPO staff will present confirmed Le tal 3 findings and recommendations regarding ICAVP expansion to the Millstone Restart Assessment Panel (RAP). The staff recommendation on possible ICAVP expansion for individual findings will consider the specific finding, and the effectiveness of the licensee's corrective actions. The effectiveness of corrective actions will be independently verified by the NRC staff, or the ICAVP contractor, and will consider the requirements of Appendix B, Criterion XVI, and the guidance of GL-91 10. The staff expects that, for an individual Level 3 finding, effective licensee corrective 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 determination on effective licensee corrective action would be expected to result in a decision to exper d 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 pedodically, at least biweekly, consider the collective group of confirmed Level 3 findings iden'.fied during the conduct of the ICAVP reviews. Negative trends established by these Levv J 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 nonconformances in other systems, in its evaluation of possible trends, the NRC staff will consider whether or not l
(1) the findings represent a large fraction of items reviewed; (2) the findings are implementation i
I 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 strvetural); and (4) the finding ) are concentrated in a particular type of document (e.g.,
operating procedure, calculation, drawing, FSAR, maintenance procedure). Any decision to expand the scope, bcsed on negative trends associated with Level 3 findings, will be approved by the Director, NRR. The NRC staff determination and bases for requiring scope expansion will be communicated to the licensee by written correspondence.
Level 4:
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 ! Ang 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 initistly by the contractors to determine if liceNee corrective actions are appropriate. The NRC staff, on an ongoing basis, is also reviewing these findings for
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i 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 property performed); (3) the findings are concentrated in a particular discipline (e.g., mechanical, electrical, instrument and controls, or structural); and (4) the findings are concentisted 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 effedive, 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.
Sincerely, kW$1safd by,s William D. Travers, Director Special Projects Office Office of Nuclear Reactor Regulation Docket No. '. 50-245, 50-336, and 50-423 cc: See next page Distribution:
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Northeast Nuclear Energy Company Millstone Nuclear Power Stat',n, Units 1,2, and 3 i
CC' Mr. M. H. Brothers Mr. Don Schopfer Vice President - Operations Verification Team Manager Northeast Nuclear Energy Company Sargent & Lundy
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