ML20216B598

Forwards Revised Spo Comments Re Tier 3 Sample Criteria for Plant,Units 2 & 3

ML20216B598
Person / Time
Site:	Millstone
Issue date:	08/29/1997
From:	Imbro E NRC (Affiliation Not Assigned)
To:	Schopfer D SARGENT & LUNDY, INC.
References
NUDOCS 9709080094
Download: ML20216B598 (6)

Text

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' August 429,1997 er l Mr. Don Schopftr Vsrification Tsam M nager

_Sargent & Lundy 4 f 55 E. Monroe Street -

Chicago, IL:i 60603 -

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Dear Mr. Schopfer; s

10n August 26,L1997, the staff of the Special Projects Office (SPO) of the Office of Nuclear Reactor Regulation (NRR) issued you a letter providing approval of the sampling criteria you had proposed for the Tier 3 review for the Independent Corrective Action Verification Program (ICAVP) you are performing at Millstone Unit 3a in the enclosure to that letter, the SPO staff provided comments that it requested you incorporate into your sampling criteria. The SPO

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staff's comments were intended to provide a consistent basis for sample selection for the Tier 3 -

t reviews being conducted at both Millstone Unit 2 and Unit 3 After the August 26,1997,- letter was issued, the SPO staff identified that some of the l

comments it had provided to you were not consistent with those provided to Parsons Power -

l Group inc. (Parsons) for its Tier 3 review at Millstone Unit 2. Specifically, comments regarding -

the number of items to be sampled for material, equipment, and parts list (MEPL) dedications; commercial grade dedications; and like-for-like replacements were not consistent. The SPO staff has also provided additional information regarding your proposed selection criteria on setpoint changes.

The Enclosure to this letter provides the revised SPO comments on your proposed sampling criteria. You are requested to use this Enclosure to incorporate the SPO staff's comments on your proposed ICAVP Tier 3 sampling criteria and disregard the SPO staff's comments provided in the enclosure to the August 26,1997, letter.

If you have any questions or comments please contact me at (301) 415-1490.

Sincere lgriginal Signaa y a Eugene Imbro, Deputy Director ICAVP Oversight-Special Projects Office Office of Nuclear Reactor Regulation

Enclosure:

As stated

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Nodheast Nuclear Energy Company Millstone Nuclear Power Station Unit 3 cc:

Lilian M. Cuoco, Esquire Citizens Regulatory Commission Senior Nuclear Counsel ATTN: Ms. Susan Perry Luxton Northeast Utilities Service Company 180 Great Neck Road -

P. O. Box 270.

Waterford, Connecticut 06385 i

Hartford, CT 06141-0270-Mr. F. C. Rothen Mr. Kevin T. A. McCarthy, Director Vice President - Nuclear Work Services Monitoring and Radiation Division Northeast Nuclear Energy Company Department of Environmental P.O. Box 128

' Protection Waterford, CT 06385 79 Elm Street Hartford, CT 06106-5127 -

Charles Brinkman, Manager-Washington Nuclear Operations Mr. Allan Johanson, Assistant Director ABB Combustion Engineering Office of Policy and Management 12300 Twinbrook Pkwy, Suite 330 Policy Development and Planning Rockville, MD 20852 Division l

450 Capitol Avenue - MS 52ERN Mr. D. M. Goebel P. O. Box 341441 Vice President - Nuclear Oversight l

- Hartford, CT 06134-1441 Northeast Nuclear Energy Company P. O. Box 128 Regional Administratar, Region l Waterford, CT 06385 U.S. Nuclear Regulatory Commission 475 Allendale Road Senior Resident inspector King of Prussia, PA 19406 -

Millstone Nuclear Power Station -

clo U.S. Nuclear Regulatory Commission First Selectmen P. O. Box 513 Town of Waterford Niantic, CT 06357

- Hall of Records 200 Boston Post Road Mr. M. H. Brothers Waterford, CT 06385

-Vice President - Millstone Unit 3 Northeast Nuclear Energy Company -

Deborah Katz, President P. O. Box 128 Citizens Awareness Network Waterford, CT 06385 P. O. Box 83

' Shelbume Falls, MA 03170 Mr. J. K. Thayer

~ Recovery Officer-Nuclear Mr. Wayne D. Lanning

_ Engineering and Support Deputy Director of Inspections Northeast Nuclear Energy Company -

Special Projects Office P. O. Box 128 ~

475 Allendale Road.

Waterford, CT 06385 King of Prussia, PA 19406-1415 Burlington Electric Department Mr. M. R. Scullf, Executive Director clo Robert E. Fletcher, Esq.=

Connecticut Mur icipal Electric 271 South Union Street Energy Coopera'ive Burlington, VT 05402 30 Stott Avenue Norwich, CT 06360

- Northeast Nuclear Energy Company Millstone Nuclear Power Station Unit 3 cc:

Mr. William D. Meinert

_Mr. John Buckingham Nuclear Engineer Department of Public Utility Control Massachusetts Municipal Wholesale Electric Unit Electric Company 10 Liberty Square P. O. Box 426 New Britain, CT 06051 Ludlow, MA 01056 Mr. James S. Robinson Ernest C. Hadley, Esq.

Manager, Nuclear investments and 1040 B Main Street Administration P. O. Box 549 New England Power Company West Wareham, MA 02576 25 Research Drive Westborough, MA 01582 Joseph R. Egan, Esq.

Egan & Associates, P.C.

Mr. B. D. Kenyon I

2300 N Street, NW President and Chief Executive Officer Washington, D.C. 20037 Northeast Nuclear Energy Company P. O. Box 128 The Honorable Terry Concannon Waterford, CT 06385 Co-Chair Nuclear Energy Advisory Council Mr. John C. Markowicz Room 4035 Nuclear Energy Advisory Council Legislative uffice Building 9 Susan Terrace Capitol Avenue Waterford, CT 06385-3515 Hartford, Connecticut 00106 Mr. Daniel L.- Curry Mr. Evan Woollacott Project Director Co-Chair Millstone Project Nuclear Energy Advicory Council Parsons Power Group Inc.

128 Terrys Plain Road -

2675 Morgantown Road Simsbury, CT 06070 Reading, PA 19607 Ms. P. Loftus Director - Regulatory Affairs for Millstone Station Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385 Mr. N. S. Cams Senior Vice President and Chief Nuclear Officer Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385

COMMENTS ON THE TIER 3 SAMPLE CRITERIA REVISION 1 The comments discussed below were developed following the review of your July 22,1997, August 4, and August 18,1997, submittals. When evaluating the comments, you should also consider the impact on your audit plan and implementing procedures to ensure any changes made are consistent throughout. Samples should be taken from each of the two periods of approximately five years back to initiallicensing. However, if examples of the process under review do not exist or are not retrievable for a particular period, we do not see a need to expand the sample into the other period to maintain the total sample size. The NRC will consider the need to expand the sample size of any of the topic areas described in the Tier 3 program based on the results of the initial sample.

DESIGN CHANGE NOTICES (DCNs), NOT ASSOCIATED WITH MODIFICATIONS The sampling methodology is acceptable as presented with the following comments: (1) DCNs to instrumentation and control (l&C) drawings, calculations, and specifications should be included in l

the Tier 3 review; (2) Two examples each of DCNs related to drawings, calculations, and l

specifications should be selected for each of the four engineering disciplines for each five-year l

period, if available (total 48 examples).

MATERIAL, EQUIPMENT, AND PARTS LIST (MEPL) DEDICATIONS The sampling methodology is acceptable as presented with the following comments: (1) include in your review, MEPL dedications on mechanical, electrical, l&C, and structural components; (2) the MEPL review should focus on the appropriateness of changes to component classification from requiring the component to satisfy the requirements of the licensee's Appendix B Quality Assurance (QA) Program ('O') to not being required to satisfy QA Program requirements ("non-Q"); (3) you had proposed 33 examples of MEPL dedications based on a set number for each year of operation,

'however, to ensure a broad MEPL review two examples from each of the four disciplines for each of the two five-year periods is acceptable (total 16 examples).

1 PROCEDURES The sampling methodology is acceptable as presented with comments as follows. The scope of the review of procedures changes extends back to initial operation. As you are aware, a review of prior procedure changes that have been superseded is not necessary. It may not be possible to find changes to procedures that date back to initial operation and this should not be the determining factor in selecting the sample to be reviewed. The sample size should be based on the following guidance with a consideration, at least in a qualitative manner, of the risk significance of the procedure. In selecting each of the examples to be reviewed as indicated below for each procedure type, the engineering judgement of the reviewers should be used to assess whether a change is significant. The thoroughness of review of each change should be commensurate with its technical significance.

1. A minimum of four Operations Procedures should be selected and all of the changes to those procedures should be reviewed. The number of Operations Procedures to be reviewed will be increased, as necessary, to capture at least 10 significant changes.

2. A minimum of four Abnormal Operating Procecures should be selected and all of the changes to those procedures should be reviewed. The number of Abnormal Operations Procedures to be reviewed will be increased, as necessary, to capture at least 10 significant changes.

Enclosure

3. A minimum of four Emergency Operating Procedures should be selected and all of the changes to those procedures should be reviewed. The number of Emergency Operating Procedures to be reviewed will be increased, as necessary, to capture at least 10 significant changes.

4. A minimum of four Surveillance Procedures should be selected and all of the changes to those procedures should be reviewed. The number of Surveillance Procedures to be reviewed will be increased, as necessary, to capture at least 10 significant changes.

5. A minimum of four Inservice Tes:(IST) and four Inservice inspection (ISI) Procedures should be selected and all of the changes to those procedures should be reviewed. The number of ISI/IST Procedures to be reviewed will be increased, as necessary, to capture at least 10 significant changes for each.

6, A minimum of four Maintenance Procedures should be selected and all of the changes to those procedures should be reviewed. The number of Operations Procedures to be reviewed will be increased, as necessary, to capture at least 10 significant changes.

COMMERCIAL GRADE DEDICATION The sampling methodology is acceptable as presented with the following comments: (1) your review should concentrate on the process used by the licensee to dedicate equipment that they purchase as "non-Q;" (2) the samples should include reviews from various engineering disciplines (mechanical, electrical, l&C, and civil / structural) responsible for conducting commercial grade dedications and; (3) an appropriate initial sample size would be two commercial grade dedications from each discipline for each five-year period (total 16 examples).

LIKE-FOR LIKE REPLACEMENTS The sampling methodology is acceptable as presented with the following comment: (1) an initial sample of 16 examples of like-for-like replacements, as described above for commercial grade dedications, is sufficient for this area. As with any of the areas described in the Tier 3 program, the NRC will consider the need to expand the sample, based on the results of the initial sample.

I NON-CONFORMANCE REPORTS (NCRs) AND ENGINEERING WORK REQUESTS (EWRs)

DISPOSITIONED USE-AS-IS The sampling methodology is acceptable as presented with the following comments: (1)in addition to the review of NCRs dispositioned use-as-is, you should include a separate review of EWRs; (2) since EWRs are not dispositioned "use-as-is," we request that your sample focus on EWRs, that have not been implemented but, if implemented, would have addressed recurring problems or minimized operator work arounds; (3) samples should be taken from each of the four principle engineering disciplines (mechanical, electrical, I&C, and civil / structural) responsible for dispositioning NCRs and EWRs and; (4) two examples from each o'the four principle engineering disciplines should be selected for both NCRs and EWRs for each five-year period if available (total of 16 examples of NCRs and 16 examples of EWRs).

SETPOINT CHANGES The sampling methodology is acceptable as presented with the following comments: (1) For Unit 2, about 10 licensee organizations were identified with responsibility for setpoint changes. The sampling criteria for Unit 2 is to select two examples of setpoint changes from each of these 2

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organizations for each of the four five year periods or a total of 80 setpoint changes. Similarly, the examples of Unit 3 setpoint changes should be distributed among each of the organizations responsible for setpoint changes with about 20 setpoint changes for each five-year period or a total of 40 changes.-

VENDOR TECHNICAL INFORMATION CHANGES The sampling methodology is acceptable as presented with the following comments: (1)in your sample criteria for selecting vendor technical manuals you should consider, at least in a qualitative manner, the associated component's contribution to risk; (2) if available, one vendor's manual should be selected for a mechanical component, an electrical component, and an instrumentation or control component and; (3) for each vendor's manual selected, all of the changes to the manual should be included in the sample of changes reviewed (total of 3 vendor's manuals to review all associated changes).

TEMPORARY ALTERATIONS Approved as modified by the following comments:

1. Select the sample of temporary alterations from safety-related and/or risk significant s stems outside the ICAVP Tier 1 systems. Emphasis should be given to those temporary modifications that have been installed for extended periods.

2. Samples should be selected from currently installed temporary alterations and from those that have been removed or made into permanent changes (those that have been closed)

3. During plant system walkdowns, any apparently undocumented temporary alterations should be included in the review and should be assessed for the potential of the temporary alterations to introduce design or licensing basis changes to the facility.

4. The sample size should include about 5 examples of currently installed temporary alterations (if available) and for the closed temporary alterations, four examples should be selected for each year from the preceding five years (total of 25 temporary alterations).

ASME SECTION XI REPAlR AND REPLACEMENT As noted in section 6.2.2.C oi Project Instruction PI-MP3-04, revision 2, " Programmatic Reviews,"

you indicated that the review of past change processes would include as applicable, the proper application of ASME Section XI requirements for repairs and replacements. You also indicated in your August 4, and August 18,1997, submittals that review of ASME Section XI repair and replacement requirements would be performed in coniunction with reviews of NCRs and vendor manual changes. The review of repairs, replacemerr,s, and modifications should include those made under the ASME Section XI program. If the samples of other past change processes do not include sufficient examples of ASME Section XI repairs, replacements, or modifications additional examples should be selected. As an initial sample size, five significant examples for each of the two five-year periods for components currently installed should be included. The sample should include examples from each of the five major mechanical component types (pumps, valves, piping (including in-line components), piping supports, and pressure vessels) for each of the two approximately five-year periods of operation (10 total examples).

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