ML20216B179

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Independent Corrective Action Verification Program for Millstone Unit 3,Interim Rept,Executive Summary
ML20216B179
Person / Time
Site: Millstone Dominion icon.png
Issue date: 05/08/1998
From:
SARGENT & LUNDY, INC.
To:
Shared Package
ML20216B176 List:
References
SL-5192-01, SL-5192-1, NUDOCS 9805150077
Download: ML20216B179 (35)
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Millstone Unit 3 Independent Corrective Action Verification Program Interim Report Executive Summary SL-5192 May 8,1998 Sar ge Lu ncly ' ' =

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independent Corrective Action Verification Program Interim Report Executive Summary Contents 1 Section Page 1 EXEC UTIVE

SUMMARY

.. . .......... ....... ...... ..... ......... ....... ........................... . .. . . .. . . .. .. . . 1.1 - 1 1.1 . Background..........................................................................................................................1.1.I 1.2 Objectives.......................................................................................................................... 1.2-1 Scope.............................................................................

1.3 .....................................1.3-1 l .3.1 Tier 1 Review Process .... ..... ... .... .. . . . ...... . .... . .. .... .. . . .... .. .. ....... .......... . ...... ... .......... ............. . . 1.3- 1 1.3.2 Tier 2 Review Process.......... .. ............... ...........................................................1.3-3 1.3.3 Tier 3 Review Process . . . .. .. ... ... . .. ....... . ...... ... ......... . ... . ..... . . . .................................1.3-3 1.4 Organization............................................................................................................................. 1.4-1 1 1.4.1 M anagem e nt Team . . ... . . . . . . . .. ... . . . . . . . . . . . ... . . .. . . . . .. . . . . . . . . . . . .. . . .. . . .. . . . . . .. . . . . . . . . . . . . . . .. .. . .. . .... . . . . . ... 1.4- 1 ,

l 1.4.2 Ve ri fi cat io n Te am .. . ... . . . . . . . .. . . . ... . . . . . . . . .. .. . . . . . . . . . .. . .. . . . . . . . . . . . . . . . . . . . . .. . . . . . .. . . . . . . . . . . .. . . . .. ... ..... . . . ... ... . 1,4 -2 l.4.2.1 System Review Group...... ................ ............................................................1.4-3 1.4.2.2 Programmatic Review Group. .................... ....................................1.4-3 1.4.2.3 Operations & Maintenance and Testing Review Group .............................. 1,4-3 1.4.2.4 Accident Mitigation Systems Group ......... ..................................... ................................ 1.4-3 l 1.4.3 Role of the Internal Review Committee ....... . ......... ..... .... ...................................1.4-4 1.5 Methodology........................................................................................................................1.5-1 1.5.1 S ys tem R e v iews . . . . ... . .. . . .. . . . . .. . . . . . . . . . .. . . .. . .. . . .. . . . .. .. . . . . . .. . . .. . . . . . .. . . . . .. . . .. . . . . . . .. . .. . . . . . . . .. . . . . .. .. . . . 1.5 -2 1.5.2 M od i fic ati o n R ev iews . . . . . . . ... . . . . . . . .. . . . .. . ... . . . .. . . . . . . ... .. . . . . . . . . . . .. . . . . . . . . . . .. . .. . . . .. . . .. . . .. .. . . .. ..... . . . . . . . .. .

1.5.3 Physical Configuration Walkdowns . ... ................................................ ............................. ... 1.5-3 1.5.4 Operation & Meintenance and Testing Review....... ........ .................................... ................. 1.5-4 1.5.5 Corrective Action Review..... .. . .................................................................................1.5-4 1.5.6 Corrective Action Implem entation Review ...... ................................ ..... ............. .. ............... 1.5-4 1.5.7 Accident Mitigation System s Review............................... ............................................. ......... 1.5-5 1.5.8 Progra m m atic Re v i e ws . .. .. . . . .. . . . . . . . . . . . . . . . . .. . . . . .... . . .. . . .. . . . . . . . . . . . .. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . 1.5-5 1.5.9 Processing Verification Team Findingt ........................................................................1.5-6 sir \si.5192. doc /050898

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Section Page  !

1.5.10 Review of NU Resolution to Verification Team Findings ............... ..... .. ... .. ..... . . .. .......... 1.5-8 l

4 1.6 Results...................................................-......................................................................... 1.6-1 l 1

l 1.7 Conelusions .. .. . ..... .... ........................................................................1.7-1 l l

1 1.7.1 Ov eral l Co n c l u s ion s . . . . .. . .. . .. . . .. .. . . ... . . . . . ..... .... . . . . . . . . . . . . . . . . . . . . . . .. .. . . . . . . . . . . . . . .. .. . .. . . . . . .. . . . . . . . . .. . .

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1.7.2 Tier 1.............................................................................................. .. . . . . . . . . . ... . .. . .. 1.7- 1 l 1.7.2.I System Review..... . ...................................................... ......... 1.7-2 1.7.2.2 Con figu ratio n R ev iew .. ........... .. .. ......... . . ... .. . ..... . .. ... .. .... .. ............ .... ... .. ....... 1.7-2 1.7.2.3 Operations & Maintenance and Testing Review............. ........ ..... .................. ....... 1.7-3 1.7.2.4 M od i fication Review ... ....... . .. ........ . .. ... ..... ........ .. . .... .. . . ...... .... ... ..... .......... 1.7-4 1.7.2.5 Corrective Action Review... ........ ... .........................................................1.7-4 i

1.7.3 Tier 2................................................. ...................................................................1.7-5 '

l.7.4 Tier 3.....................................................................................................................1.7-5 1.8 Sargent & Lundy Quality Assurance Division Report .... ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.8-1 i

1.8.1 Methodology.................................................................................................................1.8-1 l 1.8.2 A u d its .. . . . . .. . . . . . . . . .. . . . .. . . . . . . . .. . . ... . . ..........................................................1.8-1 1.8.3 A d d i ti on a l Rev i e w s . .... . . . . . . . . . . . .. . . . .. . . .. . . .. . . . . . . . . . . .. . .. . . .. .. . .. . . .. . . . . . . . . . .. . . . .. . .. . ... . . . ... . .. . . . .. . . . . . . . 1.8 2 1.8.4 Conclusion...................................................................................................................... 1.8-2 i

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  • Section 1 EXECUTIVE

SUMMARY

1.1 BACKGROUND

On August 14, 1996, the Nuclear Regulatory Commission (NRC) issued a Confirmatory Order directing Nonheast Utilities (NU) to establish an Independent Corrective Action Verification Program (ICAVP) for Millstone Units 1, 2, and 3 to confirm that the plants' physical and functional characteristics are in.

conformance with its licensing and design bases. The NRC issued this order to the licensee after identifying a significant number of design and configuration control issues at the three Millstone units. The order stipulated that the ICAVP review would begin after the licensee had completed the problem identification phase of the Configuration Management Program (CMP), a licensee effort to ensure that the design of the Millstone units was in conformance with NRC requirements and was accurately documented.

The order also required the licensee to obtain the services of an organization, independent of the licensee and its design contractors, to conduct the multi-disciplinary review of the Millstone units. The order added that the review was to provide independent verification that, for the systems selected, the licensee's CMP had identified and resolved existing problems, documented and utilized licensing and design basis, and established programs, processes, and procedures for effective configuration management in the future. The order also stated that the selection of the independent verification contractor had to be approved by the NRC.

On April 7,1997, the NRC conditionally approved NU's selection of Sargent & Lundy llc (S&L) as the independent third party to conduct the ICAVP review for Millstone Unit 3. S&L has essentially completed the ICAVP and is issuing this report to describe the scopt of review, results of the review, and conclusions regarding Millstone Unit 3 conformance to its licensing and design basis, the adequacy of the CMP, and the adequacy of programs, processes, and procedures for effective configuration management in the future. This interim report is being provided to support a briuing of the NRC. A final report will be issued after all items have been completed.

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1.2 OBJECTIVES The objective of this project was to implement the Independent Corrective Action Verification Program (ICAVP) at Northeast Utilities Millstore - Unit 3 in accordance with the NRC's confirmatory order of August 14, 1996. Tne ICAVP provided an independent verification of the adequacy of results of the Configuration Management Plan (CMP; implemented by Northeast Utilities (NU) to resolve existing design and configuration management deficiencies. The ICAVP was performed to independently verify that, for selected systems, NU's CMP identified and resolved existing problems, documented and utilized licensing and design bases, and established programs, processes, and procedures for effective configuration management in the future. The ICAVP was comprehensive, incorporating all of the appropriate engineering disciplines to ensure that NU has been thorough in identification and resolution of problems. The ICAVP review was conducted independently of Northeast Utilities and its design contractors, slAs!-5192. doc /050898 1

1.3-1 Wncey", SL-5192 1.3 SCOPE The scope of work for the ICAVP as described in the NRC's confirmatory order of August 14,1996, to Northeast Utilities included the following tasks:

  • A review of engineering design and configuration control processes.

. The verification of current as-modified plant conditions of the selected systems against the design bases and licensing bases documentation.

. The verification that design and licensing bases requirements for the selected systems are translated into operating procedures and maintenance and testing procedures.

The verification of the performance of the selected systems through a review of specific test records and/or observation of selected testing of particular systems.

A review of proposed and implemented corrective actions for design deficiencies identified by Northeast Utilities. This review covered the selected systems as well as other plant systems.

1 The NRC's December 19, 1996, oversight inspection plan provided further direction on the scope of the '

ICAVP. In addition to the above items, the overnight inspection plan required a review of accident mitigation j systems that would assess the critical design characteristics to ensure that these systems and components can perform their specified safety functions.

Sargent & Lundy impicmented the scope of work described above using a three-tier process. The three-tier process is described below.

1.3.1 Tier 1 Review Process The Tier 1 review process verified that the selected systems are capable of performing their functional requirements as specified in the design and licensing basis documentation. A total of 15 plant systems were selected for review in the Tier I scope. These 15 systems were selected from the list of 88 Maintenance Rule Group 1 and 2 systems. These 15 plant systems were grouped into four review systems as follows:

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+ HVX - Reactor Building Ventilation and SLCRS Systems Section 2.3 of this report provides a correlation between the 15 plant systems and the four review systems and describes the extent to which interfacing systems were reviewed. This review process included the following verification and review steps:

A verification of current as modified plant conditions against the design bases and licensing bases. This step included a review of calculations, analysis, specifications, and design output documents for the selected systems to verify consistency and conformance with the design and licensing bases. This review also included a physical walkdown of the selected systems to verify conformance with the design output documents.

  • A verification that the design and licensing bases are translated into operating, maintenance, and testing procedures. This step included a cross-check of functional and performance requirements contained in the licensing and design bases to compare them with those iden'tified in the operating, maintenance, testing, and training procedures.

. A verification of system performance through a review of specific test records for recently completed surveillance and post-modification functional tests.

  • A review of both the proposed and implemented corrective actions for deficiencies identified by NU during the CMP on the selected systems.
  • A technical review of all plant modifications to the selected systems that were prepared in the period between receipt of the operating license (OL) and the completion of CMP discovery.

The review of the pisnt modifications included the following steps:

A technical review of the changes contained in the modification packages to system-specific analysis and output documents and to topical engineering programs.

- Verification that current design output documents have incorporated the changes identified in the modification packages.

_ Verification that current system operating, maintenance, testing, and training procedures adequately reflect the modifications.

- Verification that the physical installation conforms with the modification package.

- Verification that the post-modification test procedures and test results demonstrate that the system is capable of performing its function.

_ Verification that no unreviewed safety question exists for the modification as documented in the 10 CFR 50.59 safety evaluation.

As directed by the NRC,10 additional QSS.'RSS system modifications prepared after CMP discovery, were included in the review scope.

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i 1.3-3 wncey"= SL-5192 1.3.2 Tier 2 Review Process The Tier 2 review process was designed to verify that the accident mitigation ystems are capable of performing their specified functions. This review included the identification of the accident mitigation systems and their critical design characteristics from Chapter 15 of the FSAR. Also included was a review of the associated sections of the Millstone Unit 3 FSAR that contain the design of the accident mitigation systems, including the electrical and the instrumentation and control design interfaces. The accident mitigation systems and their associated critical characteristics were compared with the plant design, operation, and performance data to provide a reasonable assurance that these system characteristics meet their design and licensing requirements as discussed in Chapter 15 of the FSAR. The review of the system critical characteristics ensured that the systems perform their specified safety function (s) to mitigate the consequences of the selected FSAR accident scenarios.

1.3.3 Tier 3 Review Process The Tier 3 review process involved an assessment of NU's current design control processes, a review of the adequacy of past design changes, and a review of NU CMP-initiated corrective actions outside the scope of the ICAVP-selected systems.

The current NU design change and procedure change processes were reviewed to determine whether they would adequately control plant configuration on a going-forward basis. In addition, recently implemented changes were reviewed to determine whether the procedures were being properly applied.

Past changes were reviewed in areas not generally covered in the Tier 1 reviews. The actual changes were selected from the entire population of changes made over the plant life from systems generally outside the Tier 1 scope. This review focused on the technical adequacy of the change and the adequacy oflicensing and design basis maintenance.

While the Tier i reviewed corrective actions on the ICAVP systems, the Tier 3 review inaded reviews of a sample of corrective actions on other plant systems.

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1.4-1 s.,,ge uncey", SL-5192 1.4 ORGANIZATION Figure 1.41 shows the project organization. This section describes how the organization functioned and the organizational interfaces. The roles and responsibilities of the different parts of the organization are described.

1.4.1 Management Team The Sargent & Lundy management team for this project consisted of the Project Director, Bryan Erler, the Verification Team (VT) Manager, Don Schopfer, and the Chairman of the Internal Review Committee, A.K.Singh. They were collectively responsible for ensuring that the project was properly planned and implemented, that it met the requirements of the NRC Confirmatory Order, and that the process and results were open and credible to the NRC and the public. ,

The Project Director had the overall responsibility for Sargent & Lundy's performance for the work. He was responsible for facilitating the resolution of any differences between the VT Manager and the Internal Review Committee. The Project Director along with the VT Manager were the primary external spokesmen for the ICAVP Team and met with and reported to the NRC, and to Northeast Utilities as required and as allowed by the approved protocol. He was available to the press, the media, and the public when requested by the NRC and NU.

The VT Manager was responsible for directing the development of the review. He was also responsibic for approving the plans and procedures for implementing the review, including recommending system selection criteria and the protocol covering communications between Sargent & Lundy project personnel and the other organizations. He managed the work through the technical leads on the VT. He was responsible for reviewing l the findings produced by the VT and, upon acceptance, submitting them to the Internal Review Committee. He also returned them to the VT Leads for additional information or further review. The VT Manager was responsible for distributing the findings, including posting them on the electronic bulletin board as established in the approved protocol after acceptance of the findings by the IRC. Similarly, the VT Manager reviewed, accepted, distributed, and posted the VT's evaluation of the NU responses to the findings. He was responsible i l

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for preparing the final report documenting the work of the VT. He VT Manager also served the role of S&L spokesman with respect to communication with the NRC and, when necessary, to NU.

The Chairman of the Internal Review Committee was responsible for coordinating the activities of that group.

The roles and responsibilities of the Internal Review Committee are described below in Section 1.4.3 of this report.

I 1.4.2 Verification Team ne VT was the core of the organization and was the group that performed the actual review of the design and licensing bases and the effectiveness of the NU corrective actions. The VT was organized into four functional groups. Each subgroup was headed by a Lead Engineer and was responsible for a portion of the overall ,

verification program. He functional groups included a System Review Group (SRG), a Programmatic Review Group (PRG), an Operations & Maintenance and Testing Review Group (ORG), and an Accident Mitigation Systems Group (ARG).

The VT was organized functionally in accordance with the review processes instead of by traditional engineering disciplines. However, this organization did not necessitate a strict compartmentalized group structure or review process. The VT groups functioned as a single project team with significant cross utilization of personnel among groups. The SRG and ORG personnel, for example, performed some review functions associated with the ARG and PRG. In addition, there was significant interfacing among the team members and the Review Group Leads. Periodic full project team meetings were held by the VT Manager in addition to periodic individual group meetings held by the leads. During the review and discrepancy resolution process, the VT Manager had frequent briefings with the VT leads to discuss potential findings, share lessons learned, and discuss other project issues. Teamwork, frequent communications, and meetings were fundamental attributes for the conduct of the ICAVP.

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1.4.2.1 System Review Groun The SRG perfonned an in-depth review of the selected systems. This group reviewed the current system output documents and analysis to verify conformance with the design and licensing bases. The SRG also reviewed design modifications to the selected systems made since receipt of the Operating License, focusing on the validity of the design process, identification of system interface requirements, potatial synergistic effects of the modifications, and appropriate design document controls.

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The SRG was also responsible for verifying that the current, as-built condition of the plant matched the current design output documents. This task included physical and functional walkdowns of the selected systems and was performed by the physical Configuration Review subgroup (CRG) within the SRG.

1.4.2.2 Proerammatic Review Group j The PRG was responsible for the review of selected NU processes for changing the facility design and for changing characteristics, procedures, or practices for maintaining, operating, testing, and training to ensure the adequacy of the change process. The PRG was also responsible for the review of NU's corrective actions l resulting from their configuration management plan review. This review was designed to determine the adequacy of the corrective actions.

1.4.2.3 Operations & Maintenance and Testine Review Group The ORG was responsible for reviewing system operating procedures, surveillance procedures, maintenance procedures, and training documents to confirm that the design bases and any changes made to the design bases were translated correctly into these documents. This group also reviewed the current testing requirernents and post-modification testing requirements to confirm that they were adequate to verify system performance.

1.4.2.4 Accident Mitiention Systems Group i

The ARG group was responsible for reviewing the accident analysis contained in the FSAR to determine the accident mitigation systems and their critical design characteristics. The ARG then reviewed the accident str\rl-5192. doc /050898

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- mitigation systems and their critical characteristics to ensure that the systems could perform the safety functions specified to mitigate the FSAR accident scenarios.

l 1.4.3 Role of the Internal Review Committee The Internal Review Committee provided an S&L management technical oversigi.t role. It also helped provide consistency in the review results. The committee consisted of four very senior personnel within the 1

organization that have specialized expertise in the areas reviewed. The IRC Chairman was responsible for obtaining the IRC's review of the planning documents and procedures for performing the verification program.

These documents and procedures included the audit plan, the protocol, and the individual procedures required for the work. The IRC reviewed the findings of the VT for extent and significance. The committee reviewed the responses by NU after they were accepted by the VT. The IRC also made specific recommendations regarding the scope and methodology of the verification process as the work progressed.

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Project Organization Figure 1.41 SL-5192 See W n ely "

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l Northeast Utilities NRC System 4L 4k B. A. Erler l

Project Director Quality Assurance A. K. Singh D. K. Schopfer

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IR Committee Verification Chairman Team Manager IR Committee System O&M and Accident Programmatic Review Lead Testing Mitigation Review Lead K. J. Green Review Lead Review Lead A. A. Neri T.J.Ryan W. G. Schwartz K.M. Bass R. D. RaheJa D. P. Galle Physical Configuration Review Lead R. E. Kropp str\st-5192. doc /050898

1.5-1 SL-5192 W n @ us 1.6 METHODOLOGY This section of the report describes the methodology S&L utilized to implement the three-tier ICAVP review scope described in Section 1.3 of this report. Figure 1.5-1 is a process flow diagram of the methodology. A general description of the methodology is provided in Subsections 1.5.1 through 1.5.10 below.

. The work implemented using the methodology described in the following subsections was classified as Nuclear Safety Related and was performed in accordance with the audit plan, S&L's Quality Assurance Program, and the following project instructions:

Project '

Instruction Title PI-MP3-01 ICAVP Communications Protocol

. PI-MP3-02 Review of System Design for Compliance with Design and Licensing Bases PI-MP3-03 Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control PI-MP3-04 Programmatic Reviews PI-MP3-05 Physical Plant Configuration Walkdowns PI-MP3-06 Operations and Maintenance and Testing Procedures and Training Documentation Reviews PI-MP3-07 Review of Accident Mitigation Systems PI-MP3-08 ICAVP Team Personnel Substitution and/or Addition PI-MP3-09 Preparation and Approval of Checklists PI-MP3-10 Differing Professional Opinions PI-MP3-11 Discrepancy Report Submittal and Closure PI-MP3-12 Project Fileindex The purpose of this project was to obtain an unbiased assessment of the Millstone Unit 3 configuration management and corrective action programs. Therefore, every reasonable effort was made to asse.<e that the observations and conclusions were a result of our own independent assessment and not influenced or biased by l

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  • SL-5192 outside organizations. To maintain this assurance ofindependence, communications with outside organizations were in accordance with PI-MP3-01, "ICAVP Communication Protocol."

j 1.5.1 System Reviews The selected systems were reviewed by the SRG as part of the Tier 1 review scope in accordance with PI-MP3-

02. System reviews were designed to verify whether the system's design was technically adequate and consistent with the licensing and design bases. The first step of the process was to review the licensing and design bases documentation to identify the functional, design, performance, operational, and testing ,

1 requirements of the system. Following the identification of the system requirements, the SRG performed the i four reviews described below to determine whether the current system design is capable of the functional and performance requirements identified in the design and licensing basis documentation and to check consistency between the various design output documents and design process documents.

  • A review of design process documents to verify the technical adequacy of each document and its conformance to the design and licensing bases. This review included mechanical, electrical, I&C, and structural calculations, piping analyses, and equipment EQ/SQ reports.
  • An upper-tier drawing review including P& ids, electrical schematics, electrical single-line drawings, instrument loop diagrams, and logic diagrams to verify that the system design is capable of performing the functional requirements described in the design and licensing bases and to verify that the drawings are consistent with the design process documents.
  • A component review to verify consistency between the licensing and design bases documents ar.:1 the design output documents such as component specifications, system calculations, plant databases, and vendor component drawings.
  • A review of hazards resulting from postulated pipe breaks in the selected systems including pipe whip, jet impingement, missiles, and flooding. This review was designed to verify whether the effects of these hazards on adjacent safety systems were included in the hazards analysis. In addition, the SRG evaluated the components of the selected systems to verify that they are capable of performing station blackout coping functions and Appendix R safe shutdown functions, if required 1.5.2 Modification Reviews This step reviewed the plant modifications issued after receipt of the operating license. The modification reviews were performed by the SRG as part of the Tier I review effort in accordance with PI-MP3-03. The strW5192. doc /0$0898

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scope of the modification review included all major modifications (DCRs), Minor Modifications (MMODs),

I and all DCNs generated to suppori ine DCRs and MMODs to the selected systems.

For each' affected design element, a VT member with the appropriate technical background performed a detailed review to verify whether the design element was adequately addressed in the modification. This review was designed to verify the technical adequacy of the design inputs, calculations, specifications, and design documents affected by the modifications. All reviews were performed by the SRG with the exception of procedure reviews, which were performed by the ORG. )

i The SRG also performed a detailed review of the changes to licensing documents that were generated for each modification to ensure that the modification was adequately incorporated into the FSAR, Technical Specifications, Environmental Plan, Security Plan, and Emergency Plan. The SRG also reviewed the 10 CFR 50.59 safety evaluations prepared for each modification to ensure the unreviewed safety question determination was thorough and well documented.

Finally, the SRG reviewed the installation and testing requirements including acceptance test criteria to verify that appropriate installation and testing requirements were specified. The ORG was responsible for verifying that satisfactory post-modification testing was implemented. In addition, the ORG reviewed the plant operating and maintenance procedures to determine whether they were appropriately modified to support the revised license and design basis of the plant.

1.5.3 Physical Configuration Walkdowns The physical configuration walkdowns were performed by the CRG as part of the Tier I review scope in accordance with PI-MP3-05. This review focused on verifying whether the current as-built condition of the plant matched the current design documents. A physical and functional walkdown of the selected systems was implemented. Modifications to the selected systems installed after receipt of the OL were also included in the walkdown effort to verify whether the as-built condition conforms to the modification documents and to verify whether the modification documents were accurately incorporated into the affected design drawings or were stM $192. doc /050898

i 1

1.5-4 E!iles g e WW"a SL-5192 h

posted agains the affected design drawings. A review of the lower-tier drawings, such as piping drawings, wiring diagrams, electrical physical drawings and cable schedules, was included in this effort to verify conformance to the upper tier P& ids and schematics.

1.5.4 Operation & Maintenance and Testing Review The operating & maintenance and testing review was performed by the ORG as part of the Tier 1 review scope in accordance with PI-MP3-06. This review focused on determining whether the system operating procedures, maintenance procedures, surveillance procedures, and trainir g documents conform to the systems design and licensing bases. This review was also designed to verify v', ether post-modification tests for plant modifications to the selected systems were adequate to maintain the design and licensing bases.

i 1.5.5 Corrective Action Review The Tier I corrective action reviews were conducted by the PRG to determine whether the actions planned by NU to correct previously identified problems were appropriate. As part of its CMP, NU performed a vertical slice' review of safety-significant systems and identified degraded or nonconforming conditions. For each of these degraded or nonconforming conditions, NU initiated corrective actions. In addition, NU implemented corrective actions for design deficiencies identified by the architect-engineer before initial operation (DDRs).

This review assessed the adequacy of all the corrective actions initiated by NU during the CMP for the ICAVP systems and for a selected group of DDRs on the ICAVP systems. The reviews were performed in accordance I with PI-MP3-04.

1 1.5.6 Corrective Action implementation Review

'Ihe Tier 1 corrective action implementation reviews were conducted by the PRG, SRG, and ORG to detennine whether the actions implemented by NU to correct CMP-identified problems were effective. All of the startup-required corrective actions on ICAVP systems were screened for their significance, and the implementation review was conducted on significant corrective actions in accordance with PI-MP3-04. I sir \st-5192. doc /050898

1.5-5

% Wncty "' SL-5192 1.5.7 Accident Mitigation Systems Review The Tier 2 accident mitigation system review was performed by the ARG in accordance with PI-MP3-07. The initiating events in the FSAR, as they apply to Millstone Unit 3, were reviewed to identify accident mitigation systems and components within the system. The reload analysis and the FSAR were used to identify the specific critical parameters that are required to mitigate the initiating events.

. The ability of the accident mitigation systems to support the critical characteristics (parameters) was verified using a documented system and component test, a surveillance test from the Millstone Unit 3 technical specification, or post-maintenance tests. Where appropriate, the critical characteristics (parameters) were also verified using the design calculations, specifications, and vendor documents for acceptability.

1.5.8 Programmatic Reviews The Tier 3 programmatic reviews were conducted by the PRG on a horizontal bases (across systems) to determine whether the NU change processes are effective and to evaluate NU corrective actions outside the ICAVP system scope. The programmatic reviews were performed in accordance with PI-MP3-04.

NU's current plant change processes were reviewed for both their adequacy with respect to industry standards and for the effectiveness by which they were implemented. Both design change processes and procedure change processes were included in this review. The current MP3 process procedures were evaluated for content and completeness. This evaluation determined whether the procedure exercised adequate control on the change process and invoked appropriate interface review to assure the plant design bases and configuration would be i

maintained consistent with the licensing bases. The evaluation was based on guidance provided in the following documents:

  • NRC Inspection Manual
  • INPO 87-006, Report on Configuration Management in the Nuclear Industry
  • NEI guidelines str\s!-5192. doc /0$0898

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The adequacy of NU's implementation of the change process procedure was also evaluated. Since the system review assessed the technical acequacy of the change (modification), the programmatic review only evaluated ,

I the procedural adequacy of the change. The evaluation determined whether the current procedure was followed,

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whether the required checklists were accurately and completely filled in, and whether all other documentation

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was complete and accurate.

l:

In addition to the process and implementation reviews noted above, selected past changes on a plant-wide basis were also reviewed. For each of the change processes not generally associated with modifications, a sample of changes made during each five-year interval following receipt of the OL was reviewed for their technical adequacy. The changes generally v are selected from various systems other than the ICAVP-selected systems in order to maximize plant coverabe. This review was designed to ensure that these past changes did not compromise the unit's design or licensing basis.

A sample of NU-initiated corrective actions was reviewed for systems outside the scope of the ICAVP systems.

The sample was selected by the NRC. The review was conducted in generally the same manner as the corrective action reviews previously described in Section 1.5.5.

1.5.9 Processing Verification Team Findings When a member of the VT identified an issue that did not meet the design basis requirements, that individual initiated a discrepancy report (DR) per PI-MP3-ll. Figure 1.5-2 of this report depicts the DR process. A discrepancy was defined as a condition, such as an error, omission, or oversight, that would prevent consistency among the physical configuration and information sources (e.g., documentation and databases), design bases, and/or regulatory requirements. Examples of discrepant conditions include a disagreement between the system design bases and the FSAR, the as-built configuration of a piping system and the piping analysis, or a change to maintenance procedures that should have been made due to a plant modification but was not. The DR documented the discrepant condition and the documents or walkdown reports that were reviewed to arrive at sir \st-5192. doc /050898

1 1.5-7

% Luncfy ", SL-5192 l

'the conclusion. Significance Levels 1 through 4 were assigned to each DR by the Initiator. The Significance Levels were defined as follows:  ;

i Significance Level 1 A discrepancy that identified that the system did not meet its licensing and design bases and could not perform its intended function, i.e., had the I potential to simultaneously affect redundant trains.

Significance Level 2 A discrepancy that identified that a single train of a redundant system did not meet its licensing and design bases and that the train could not perform its intended function.

Significance Level 3 A discrepancy that identified that a system did not meet its licensing and design bases but the system was capable of performing its intended function.

Significance Level 4 A discrepancy that identified that a system met its licensing and design bases; however, there were minor errors such as minor arithmetic errors that do not j

significantly affect the results of a calculation or inconsistencies between I documents of an editorial nature.

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

]

The VT Group Lead reviewed each DR with the VT member for technical adequacy, for completeness, and for

)

uniqueness of the specific issue to ensure that it had not already been addressed by another DR or by an l 4

existing NU corrective action document. Once initiated, the DR could either be accepted and signed by the VT l

Group Lead, be returned to the VT member for additional information or investigation, or be determined to be not valid. For any DR determined to be not valid, the justification for this decision was documented on the DR and the DR was accepted (electronically) by the VT member and the VT Group Lead. If valid, the VT Group Lead forwarded the DR to the VT Manager.

The VT Manager reviewed each DR with the Group Lead for technical adequacy, for completeness, and for uniqueness of the specific issue to ensure that it had not already been addressed by another DR or by an existing NU corrective action document. Once initiated, the DR could either be accepted (electronically) and signed by the VT Manager, be returned to the VT member for additional information or investigation, or be determined to be not valid. For any DR determined to be not valid, the justification for this decision was documented on the DR and the DR was accepted (electronically) by the VT member, VT Group Lead, and VT Manager.

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1.5-8 SL-5192

% Luncey "*

The VT Manager submitted accepted DRs to the IRC for their review. They reviewed the DRs for extent of the I condition to confirm that the VT had looked deep enough into the issue to ensure that the problem was fully scoped. In some cases, the IRC recommended that the VT look for similar conditions in other areas or systems.

The IRC requested that the VT member obtain additional information (in some cases), concluded that the DR was not valid, or accepted the DR as written, whereupon the IRC Chairman signed the DR and returned it to the i l

VT Manager for submittal. If the VT member, the VT Group Lead, and the VT Manager agreed with the i conclusion that the DR was not valid based on additional information, thosejustifications were documented on the DR and accepted by the VT member, VT Group Lead, and VT Manager.

All DRs were transmitted to the NRC, NdAC, and NU when the above process was completed. The DRs were transmitted in accordance with the approved protocol. In addition to expected monthly meetings with the public, an important part of this project was to keep the public informed of the status and results on an ongoing bases. 'Iherefore, all DRs sent to NU and the NRC were posted on the Internet via the World Wide Web

]

approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after their submittal to the NRC/NEAC/NU.

1.5.10 Review of NU Resolution to Verification Team Findings As shown in Figure 1.5-2, the handling of NU's proposed resolution of the VT findings followed a similar process as the generation of the findings, except that IRC review of resolutions for significance Level 4 DRs was not required. The NU resolution was posted on the Internet bulletin board when received and was sukidtted to the VT member who initiated the DR, the VT Group Lead, and the VT Manager for review and I assessment. If the proposed resolution for Level 1,2, or 3 DRs was determined acceptable, it was forwarded to the IRC 'or their review. Level 4 DRs did not require IRC review. If both the VT and the IRC (where applicable) found the NU resolution of the DR to be adequate, then NU, the NEAC, and the NRC were notified by the method established in the protocol. At this point, the acceptance of the NU resolutions to the findings was posted on the Internet bulletin board established for public access. If NU's resolution to the finding was not ;

considered adequate by the VT member, VT management, or the IRC (for the Level 1,2, or 3 DRs only), it was returned to NU with an explanation and the bases for why the team did not consider it to be adequate. The sMst-5192. doc /050898

1.5-9 SL-5192 e= s. Wncey 66.

acceptance of the NU resolution or explanation of S&L's inadequate determination was sent in parallel to the I

NRC and NEAC and was posted on the Internet bulletin board. NU reviewed the S&L basis for rejection and submitted a second response to the VT. When required, meetings were held between NU and the VT to reach an underste,.nding and resolution of a particular issue. These meetings were requested and held in accordance with the established protocol.

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Process Findings Figure 1.5-2

,,, and Resolutions Sle5192 initiate Discrepancy Concu

Report (DR) < -

VT Invalid h

ma,, Review DR info Required VT Mgmt

, is DR Valid & DR not n' valia Yes No/More Review DR info Required IRC is DR Valid & DR not Adequate? Valid u

Document Basis for Yes Not Discrepant 4 VT Submit DR to NRC/NEAC/NU & Post ,

on Electronic (IL VT Manager Provide DR Response to S&L NU i

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Review NU Response for Adequacy & post on Electronic BB VTNT Mgmt Document Reasons for

  • Inadequate / Submit to Review NU Response NU/NRC/NEAC & Post & VT Acceptance /

nn metmnic RA Comments

  • For Level 1,2 and 3 DRs Onty NU No Response to DR equate Yes

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Document Acceptance

& Submit to NRC/NEAC/NU &

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sir \si 5192. doc /050698

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.Y 1.6 RESULTS l

This subsection of the report provides a high level summary of the results of the ICAVP. The results are presented below in tabular form for each tier of the three-tier review process. The results for the Tier I and Tier 3 review processes are further subdivided by their major review tasks. The table provides a summary of the number of confirmed and unconfirmed DRs, by NRC Significance Level, against each review task and tier (unconfirmed DRs are those that are currently in the resolution review process). The table also provides a summary of the total number of DRs against each review task and tier and the total number of DRs by NRC Significance Level Category.

As can be seen from the table below, the ICAVP review did not identify any discrepancies that would prevent one or both redundant trains of a safety system from performing its safety function (NRC Significance Level 1 or 2). The ICAVP did identify 63 discrepancies where the system does not meet its design and licensing basis but is still capable of performing its intended function (NRC Significance Level 3). Of these 63 discrepancies, I 19 have been confirmed to date; the remainder are in the resolution review process. The majority of the discrepancies identified were of low significance documentation or procedural compliance type errors that do not place the systems outside of their design basis (NRC Significance Level 4).

DRs that documented discrepant conditions against more than one review task may be counted against each of the applicable review tasks and, therefore there is some minimal duplication in the summary on the following page.

sir \st-5192. doc /0$0698

1.6-2 Set ge Lundy 6 6, sir 5192 s

Level 3 - Level 3 - Level 4 - Level 4 -

Review Process Confirmed Unconfirmed Confirmed Unconfirmed Total Tieti System Review 5 35 316 80 436 Configuration Review 1 2 109 46 158 OM&T Review 3 0 36 0 39 Modification Review 1 3 11 17 32 Corrective Action Review 2 3 22 22 49 Tier 1 Subtotal 15 43 494 165 717 Tier 2 Tier 2 Subtotal 0 1 24 2 27 Tier 3 Process Review 2 0 3 0 5

)

Process Implementation 1 0 4 1 6 Past Change . Review 0 0 4 2 6 Out of Scope Corrective 1 0 5 2 8 Action Reviews Tier 3 Subtotal 4 0 16 5 25 l Total 19 44 534 172 769 str\st-5192. doc /050698

1.7-1 see Wncey"

  • SL-5192

1.7 CONCLUSION

S Since this is an interim report, the conclusions identified in this section are not final and may be affected by the resolution of the remaining Discrepancy Reports. As noted in the previous section, there are a number of DRs that have not yet been resolved. The conclusions in this report are based on the confirmed Significance Level 3 DRs and the total of the confirmed and unconfirmed (still in resolution process) Significance Level 4 DRs.

Where the interim conclusions are based on " Unresolved" Level 3 DRs (meaning that S&L and NU disagree on some aspect of a particular issue), it has been noted.

1.7.1 Overall Conclusions The overall conclusions from the ICAVP are as follows:

  • The NU CMP has been effective in identifying and resolving deficiencies in the Millstone Unit 3 design and licensing basis. The number of confirmed Level 3 discrepancies (i.e., DB/LB issues) identified during the ICAVP was very small in comparison to the number of design and licensing requirements that were verified on the selected systems.
  • The selected systems are considered to be in conformance with their design and licensing bases and are considered to be capable of performing their intended functions.

NU has established programs, processes and procedures to maintain effective configuration control of their design and licensing bases in the future. i l

These overall conclusions are supported by the results and conclusions of the individual Tier 1,2 and 3 reviews as described below.

)

1 1.7.2 Tier 1 The Tier 1 conclusions have been developed and are presented based on the review process described in Section 1.5 of this Executive Summary and in more detail in Section 2 of the full report.

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l 5192 La.s @ "*:

l 1.7.2.1 System Review He system review was performed in five aeparate tasks: Design and Licensing Basis documentation review, Calculation review,' Drawing review, Component Review, and Topical review. Separate conclusions are provided in Section 2.43 of the full report for each of the five major system review tasks.

Our overall conclusions from the system review is that the plants licensing and design basis is supported by the plants design output documents and design process documents. We also conclude that the plants upper tier system Level engineering drawings and the plants design process documents are technically adequate and that the design basis for topical areas is adequately implemented. A significant number of Level 4 documentation .

issues which do not place the systems or plant. configuration outside of its design or licensing basis, were identified during the review. The following Level 4 issues with a high occurrence rate are indicative of areas I where improvements could enhance NU's configuration control going forward:

l

  • - The PMM5 and PDDS databases containa sufficient number of errors and omissions so as to'

]

render the data suspect for design input. 'i 9 The component procurement specifications and vendor drawings have not been consistently kept up-to-date.

  • The number ofinstances where incorrect design inputs were used indicate a calculation control l problem. This concern is limited to mechanical system sizing calculations and electrical system calculations. This condition appears to be due to the fact that voided or superseded calculations are not adequately controlled (i.e., kept as active) and therefore can and are inadvertently used when new work is being performed.

c l*~ ' A high number of minor discrepancies were identified in both old and recently revised mechanical system sizing calculations. While none of these discrepancies affected the calculation ressilts or impacted compliance with the licensing and design basis, overall quality 1 could be improved. I 1.7.2.2 Configuration Review We conclude that the as-installed plant condition is consistent with the design output documents and that the installation of plant modifications after receipt of operating license was in accordance with the modification

' design packages. We also conclude that the plants physical drawings are generally in conformance with the upper tier system-level engineering drawings. A high number of low significance documentation issues and str\st-5192. doc /050698

l 1.7-3 Genr gan WrW ", sir 5192 l

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l material condition issues, which do not place the systems or plant configuration outside of its design or l licensing basis, were identified during the review. The following Level 4 issues with a high occurrence rate are indicative of areas where improvements could enhance NU's configuration control going forward:

  • Inconsistencies between the cable and raceway database (TSO2) and electrical design L documents related to cable tray cover data and conduit support data (greater than 200 l

occurrences were identified). The high number of discrepancies indicate the data contained in the database may not be accurate and as such, the data should not be used as approved design input without prior verification.

e Undocumented attachments to supports (approximately 125 occurrences). Although, none of l the undocumented attachments affected the structural adequacy of the support and many

resulted from original design and construction, the findings indicate that NU should review l their control mechanism to prevent recurrence.

l

  • Component tagging / labeling issues (approximately 160 occurrences). Additional controls to prevent future mislabeling / tagging should be considered.

1.7.2.3 Operations & Maintenance and Testine Review 1,7.2.3.1 System Conclusions Our review of the selected systems indicated that, in general, the system are operated and maintained within the

!. Design and License Basis. Some discrepancies were noted. However, this number represented a small fraction when compared to the number of requirements reviewed.

Sargent & Lundy identified Level 3 Discrepancy Reports with NU's methods and schedule for testing as well l as the population of heat exchangers included within the scope of the program for compliance with NRC

(

Generic Letter 89-13. NU has reported that they believe that their current program for Heat Exchanger Testing i

meets the intent of the generic letter. S&L currently disagrees with the NU responses and believes the current l Program is outside the License Basis. These DRs remain unresolved pending NRC review.

Level 4 Discrepancy Reports were reviewed to determine whether a trend existed across multiple systems. Our review did not identify any such ti:nds. The Level 4 DRs were considered to be unique events of either a typographical or administrative nature. NU corrective actions indicated that appropriate actions were to be l taken to correct the errors.

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The review of specific system requirements combined with the generic reviews of operations, maintenance and {

l training provide reasonable assurance that the selected systems have been operated and maintained within the i Design and Licensing Basis and that such performance can reasonably be expected to continue into the future.

)

l 1.7.2.3.2 GeneralConclusions An overall observation regarding maintenance, surveillance / calibration, and testir.3 and operQns is that some of the processes in use place a very high reliance on the skill and performance ofindividuals We have cited a number of examples of this in Section 2.6.3 of the full report. While this approach in and ofitself does not take the plant outside the Design or Licensing Basis, it does not provide some of the safeguards that a more procedure- or process-driven approach would provide. By taking an approach so highly reliant on the skill and knowledge of individuals with little process documentation, it becomes difficult for an organization to recognize when performance has drifted from the norm. The process / procedure-driven approach provides numerous measurable performance indicators that, when properly used, can provide indicators that are recognized early and allow for management recovery. q 1.7.2.4 Modification Review

' The design of plant modification implemented after receipt of the plant's operating license was technically adequate and configuration control was adequately maintained. Additionally, we conclude that the identified modifications have been installed and implemented consistent with the design package and the procedures in effect at the time of the modification. The changes were adequately reflected in the appropriate operating, maintenance and testing procedures, in the related training materials, and in the simulator configuration as appropriate.

1.7.2.5 Corrective Action Review

'Ihe number and nature of the discrepancies found in the review of the NU corrective action plans for self-identified CMP-related problems, when reviewed collectively, represented the types of errors that might be expected to be found in a program the size of the Millstone Unit 3 CMP. The number of valid discrepancies l

slAs!-5192. doc /050698

l 1.7-5

,,, SL-5192 was a small fraction of the total number corrective action problems reviewed, and based on the categort diserepancy types identified, no adverse trends were found. In the review of implementation and completic i corrective actions associated with established corrective action plans, a similar conclusion was reached. The valid discrepancies were mostly oflow significance, and based on the categories and numbers of discrepancies identified, no adverse trends were found. Thus it can be concluded that NU has adequately initiated and implemented actions needed to correct the licensing and design basis at Millstone Unit 3.

1.7.3 Tier 2 Based on the ICAVP review of all the accident mitigation sptems, the overall design operation and performance of these systems has been reasonably assured to be within the design and licensing bases. The review of Tier 2 systems covered the entire population of accident mitigating systems. Therefore, ICAVP review provides reasonable' assurance that these systems can perform their safety-related functions, as required, during a postulated accident.

1.7.4 Tier 3 Overall, the current Millstone Unit 3 change processes, as reviewed in the ICAVP, are adequate for maintaining the licensing and design basis of the plant on a going-forward basis. The procedural discrepancies found in this area were generally shown by NU to have no impact on the adequacy of past plant changes. The discrepancies have been resolved by procedure revisions made by NU that clarify any ambiguities that may have existed.

Regarding NU's current procedural conformance to their change process requirements, the ICAVP process implementation review has determined that, in general, NU has been adequately following the current procedures.

In the area of past changes made by NU in systems outside the scope of the four ICAVP systems, for *he 11 change process areas covered in the Tier 3 review, only a small number of significance Level 4 discrepancies were found. These discrepancies were not indicative of any negative trends, and it is concluded that, for the processes covered, NU has made changes that are technically adequate without adversely affecting the plant licensing and design basis.

. str\si-5192. doc /050698

1.7-6 Sar ger Luncly s t.

SL-5192 The review of out-of-scope corrective actions was done in addition to the Tier 1 review of all CMP-related corrective actions. The results of this review were combined with the Tier 1 results for trending purposes, and no adverse trends were identified. Rus, except for the valid discrepancies identified, NU's corrective action plans for self-identified problems were adequate in correcting the Mi!! stone Unit 3 licensing and design basis.

f' st%15192. doc /050698

1.8-1 i SL-5192 he t uncty",

1.8 SARGENT & LUNDY QUALITY ASSURANCE DIVIS!ON REPORT Sargent & Lundy (S&L) Quality Assurance Program Topical Report, SL-TR-1 A, gives the responsibility of performing mdep ndent audits (to support 10CFR50, Appendix B, Criterion 18) to the Quality Assurance Division. The Quality Assurance Division performed three independent audits of the Milletone Unit 3 Independent Corrective Action Verification Project. These audits were performed in accordance with S&L's implementing quality procedures.

1.8.1 Methodology -

Three audits were performed over the duration of the ICAVP, each with a different focus. The first audit examined the project administrative controls, which are necessary to perform unique functions under S&L's QA Program. The second audit focused on accomplishment of work and the technice.1 accuracy thereof. The third audit reviewed project completion and close-out activities. The following paragraphs discuss each audit individually.

1.8.2 Audits Audit MIL-001 examined personnel qualification and training, organizational structure, identification of the scope of the project, development of project-specific instructions, control of documents, and identification and control of records. Two findings resulted from this audit in the areas of records and training. Appropriate corrective actions were taken by the Project Team and verified by QA.

Audit MIL-002 reviewed the project's compliance with the project instructions governing work. In addition, a technical specialist was included as part of the audit team to examine the adequacy of the work produced. This audit resulted in one recommendation and two findings. The two findings dealt with the disposition on an invalid DR that did not address the problem statement, and the use of incorrect references on an in-process t ARG Assumption / Item document. The recommendation was to document the results of the walkdowns in more detail on the '.'ecklists. Appropriate corrective actions were taken by the Project Team and verified by QA.

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1.8-2 SI'5192 See Wncty "

  • Audit 98-A-002 concentrated on project close out activities, including completion of work and preparation of the final report. No findings or wcommendations resulted from this audit.

1.8.3 Additional Reviews A surveillance was performed of all of the DRs designated as invalid that had been generated by the project.

Three deficiencies were found and corrected during the surveillance. Because it was a 100% review, no further cotrective action was necessary. Therefore, no findings were issued.

1.8.4 Conclusion The project complied with Sargent and Lundy's Quality Assurance Program, with the Millstone Independent Corrective Action Verification Program Oversight Inspection Plan, with the ICAVP Audit Plan, and with the Millstone Unit 3 Project Instructions.

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