ML20217L793
| ML20217L793 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/02/1998 |
| From: | Imbro E NRC (Affiliation Not Assigned) |
| To: | Schopfer D SARGENT & LUNDY, INC. |
| References | |
| NUDOCS 9804070386 | |
| Download: ML20217L793 (6) | |
Text
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UNITED STATES p
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g NUCLEAR REGULATORY COMMISSION o
WASHINGTON, D.C. 30006 4001 April 2,1998 gg i
Mr. Don Schopfer l
Verification Team Manager Sargent & Lundy 55 E. Monroe Street Chicago,IL 60603
- Dear Mr. Schopfer.
f The staff of the Special Projects Office (SPO) of the Office of Nuclear Reactor Regulation has -
reviewed your submittal dated February 25,' 1998, that enclosed for NRC approval, Revision 5 to the independent Corrective Action Verification Program (ICAVP) Audit Plan for Millstone Unit 3; Pl-MP3-04, Revision 4, "Frogrammatic Reviews;" PI-MP3-07, Revision 2, "Revew of Accident Mitigation Systems;" and PI-MP3-11, Revisions 5 and 6, " Discrepancy Report Submittal and Closure." Your cover letter stated that PI-MP3-06, Revision 2, was also.
enclosed, but it was not included in the submittal received by the NRC. Please provide this procedure revision for NRC review and approval if you intend to use it during performance of the ICAVP at Millstone Unit 3.
REVISION 5 TO THE UNIT 3 ICAVP AUDIT PLAN Based on the NRC's review of Revision 5 to the Audit Plan, the major changes in the plan relate to the addition of guidance regarding the classification of discrepancy reports (DRs) by significance level and clarifying the scope of the Independent Review Committee (IRC) DR resolution review regarding Level 4 DRs. The guidance regarding DR significance level classification is consistent with the NRC's expectations. Consistent with the significance of Level 4 DRs, it is acceptable for the IRC not to review Northeast Utilities' (NU's) resolution of these DRs provided the significance level is not changed as a result of NU's response.
No comments were identified by the SPO staff during its. review of Revision 5 to the ICAVP
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Audit Plan that require changes. As such, Revision 5 to the ICAVP Audit Plan, as enclosed with your February 25,1998, submittal, is approved for use during the ICAVP at Unit 3.
In the Audit Plan you provided a list of personnel used to conduct the ICAVP. This list indicated that three of your staff have not yet been interviewed by the NRC. At the earl'est convenience, you are requested to make arrangements with the SPO staff to conduct interviews with these individuals.
PI-MP3 04, REVISION 4
' As you indicated on the cover page to PI-MP3-04, Revision 4, the major change to this procedure related to clarifying the scope of corrective action implementation reviews consistent with the request of the SPO staff, in addition, other minor editorial changes were made that the O
SPO staff determined did no^ impact the guidance provided in PI-MP3-04.
9004070386 980402 PDR ADOCK 050004 3 P
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4-D. Schopfer Based on the SPO stafl's review, the guidance provided in Section 5.1.2, " Review Process,"
related to the additional corrective action reviews is adequate and consistent with the expectations provided to you by the SPO staff during previous teleconferences, meetings, and discussions. The guidance clearly indicates that the scope of the review will include start-up required items that involve engineering assessments, major calculations, significant procedure changes, significant Final Safety Analysis Report changes, training and personnel qualification requirement changes, new test procedures, inspection acceptance criteria changes, and major changes to design or installation specifications. As such, PI-MP3-04, Revision 4, as enclosed with your February 25,1998, submittal is approved for use during the Millstone Unit 3 ICAVP.
PI-MP3-07, REVISION 2 As you indicated on the cover page to PI-MP3-07, Revision 2, the major changes to this procedure related to allowing verifiers to limit the scope of the Tier 2 accident mitigation system review to those drawings that are applicable and appropriate for the systems under review; and to provide generic verification methodologies for certain types of critical characteristics. In addition, other minor editorial changes were made that the SPO staff determined did not impact the guidance provided in Pl-MP3-07.
The change to limit the scope of the Tier 2 accident mitigation system review to the applicable and appropriate drawings was determined to be a clarification of the scope of the review by the SPO staff. As changed in this regard, PI-MP3-07 provides the appropriate guidance for your verifiers during performance of the Tier 2 reviews at Millstone Unit 3.
The new Section 5.8 of PI-MP3-07, references four new attachments (Attachments 6.2 through 6.5). These attachments provide the methodology for verifying instrumentation actuation, pump flow, operator action, and for the emergency diesel generator, respectively.
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For the Tier 2 review, the instrumentation actuation verification methodology appropriately addresses verification of input assumptions, channel calibrations, response times (as required),
and device responses, and that the reactor protection system or engineered safeguards actuation system generates a signal to the appropriate end device. Also, the scope of the verification, as described in the notes, is consistent with the SPO staff's expectations for the level of review necessary for the Tier 2 accident mitigation system review. The pump flow verification methodology is adequate in that it verifies, using appropriate methods, the fluid source parameters, flow path, and pump performance. The operator action verification methodology includes a verification of instrumentation relied upon during the operator's action
. using the instrumentation actuation verification methodology previously discussed, a review of annunciator response guides and procedures, a review of emergency operating procedures, a review of abnormal operating procedures, and a verification of the reactor operator training records. As you noted in Attachment 6.5 to PI-MP3-07, the systems associated with the emergency diesel generator (EDG) were selected for the ICAVP Ter 1 review. As such, the EDG systems will receive a detailed design and licensing bases review. Included within this review is a review of the surveillance procedures and last test results and trending data related to assuring EDG availability, operability, sad emergency safeguards feature load sequencing.
D. Schopfer ' Based on the SPO staffs review of the changes to PI-MP3-07, Revision 2, no comments were identified that would require change and the revision is consistent with the SPO staffs expectations for the Tier 2 reviews. As such, as enclosed with your February 25,1998, submittal, PI-MP3-07, Revision 2, is approved for use during the Millstone Unit 3 ICAVP.
Pl-MP3-11, REVISION 5 The major changes made in Revision 5 to PI-MP3-11, were to change the guidance regarding IRC review of Level 4 DRs to be consistent with the changes made to the Millstone Unit 3' ICAVP Audit Plan and to provide additionalinstruction for the close out phase of the DR review-process. Other minor administrative changes were made that did not impact the overail processing of DRs related to technical review and were determined to be acceptable to the SPO staff.
Based on a review of the changes regarding Level 4 DR review by the IRC, the SPO staff determined that the changes were consistent with the changes made to the Millstone Unit 3 ICAVP Audit Plan and with the SPO staffs expectations. As such, these changes are approved for use during the Millstone Unit 3 ICAVP.
The additional guidance as written in Section 5.3.2, regarding the instructions to the initiator for responding to the question on whether the DR resolution is pending was not as explicit as expected by the SPO staff. The text provided below should be inserted in place of the text provided under" Resolution Pending?"in Section 5.3.2.
(NU has proposed to complete corrective actions prior to restart to resolve the discrepancy - for DRs required to be completed before restart (e.g., all Level 3 or higher DRs). S&L finds the planned corrective action acceptable, but needs to review the completed actions.) -
Contingent upon your incorporating the recommended chang'e to Section 5.3.2, the SPO staff finds Revision 5 to PI-MP3-11, as enclosed in your February 25,1998, submittal, acceptable for 1
use during the Millstone Unit 3 ICAVP.
PI-dP3-11, REVISION 6
' Revision 6 to PI-MP3-11, added guidance regarding the close out of DRs that will be deferred until after restart. - Section 5.3.3 of Pl-MP3-11 provided the instructions for review and disposition of NU's response to DRs that will be deferred. While consistent with the NRC's expectations, the guidance in PI-MP3-11 for evaluating NU's determination of which Confirmed DRs are to be resolved before restart should not be considered as the definitive criteria, but are rather to be used as guidance when making this evaluation. Based on a review of this submittal, the SPO staff determined that PI-MP3-11, Revision 6 is generally consistent with its expectations, and approved for use during the Millstone Unit 3 ICAVP contingent upon incorporating the following comments:
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' D. SchopfIr
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F Section 5.3.3 - Replace the first paragraph ("For certain Level 4 DRs...") with the following:
e NU will submit a standardized response for Confirma' Level 4 DRs that the d
corrective actions may not be completed until after restart. This response will state; Section 5.3.3.b. - Replace this paragraph (" Meets the deferral criteria...") with the following:
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- b. Does not meet any of the restart required criteria in Attachment 6.9. If it is determined that the condition (s) identified in the DR meets a restart required criteria, the DR resolution shall be returned as "Not Accepted" with comments clarifying why it is believed that the DR is not appropriate for deferral and the ICAVP Significance Level shall be raised to Level 3.
In applying this guidance, you should carefully consider those issues that raise questions with the design and licensing bases. The criteria provided in Attachment 6.9 to PI-MP3-11 generally define conditions that cross the threshold for ICAVP Significance Level 3 issues (system does not meet licensing and design bases but able to perform its intended function). It is the SPO staffs expectation that corrective actions that are required to restore or reestablish design or licensing bases requirements for discrepancies identified in all Confirmed Level 3 and higher DRs will be completed before restart. For Confirmed Level 3 and higher DRs, specific corrective actions may be deferred until after restart provided that they are not associated with correcting technical or regulatory issues with the licensing or design bases.
Consistent with the definition of ICAVP Significance Level 4 issues, Confirmed Level 4 DRs should generally be of such a nature that they may be deferred until after restart of the associated unit. In your review of Confirmed Level 4 DRs, if you determine a Confirmed Level 4 DR is required to be resolved before restart, you should raise the ICAVP Significance Level to Level 3.
If you have any questions or comments regarding the NRC's approval or comments on the above referenced revisions, please contact me at (301) 415-2951.
" *Niiinal Signed by:
Eugene Imbro, Deputy Director ICAVP Oversight Special Froject:: Office Office of Nuclear Reactor Regulation cc: See next page Docket 50-423 DISTRIBUTION:
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- See previous concurrence page DOCUMENT NAME: C:\\MYFILES\\lCAVP\\S&L\\REV5RVW2.S&L To rece6ve a copy of this document, Bruficato in the bou *C" e Copy without attachfenci"E" a Copy with attachionci '* Nae No copy OFFICE ICAVP/SPO f,
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N:rtherst Nucle:r En:rgy Company Millstone Nucimr Power Station
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Unit 3 cc:
Lillian M. Cuoco, Esquire Mr. William D. Meinert Senior Nuclear Counsel Nuclear Engineer Northeast Utilities Service Company Massachusetts Municipal Wholesale P. O. Box 270 Ebdric Company Hartford, CT 06141-0270 P.O. Box 426 Ludlow, MA 01056 Mr. Kevin T. A. McCarthy, Director Monitoring and Radiation Division Joseph R. Egan, Esquire Department of Environmental Protection Egan & Associates, P.C.
79 Elm Street 2300 N Street, NW Hartford, CT 06106-5127 -
Washington, DC 20037 Regional Administrator, Region i Mr. F. C. Rothen U.S. Nuclear Regulatory Commission Vice President-Work Services 475 Allendale Road Northeast Utilities Service Company King of Prussia, PA 19406 P. O. Box 128 Waterford, CT 06385 First Selectmen Town of Waterford Emest C. Hadley, Esquire Hallof Records 1040 B Main Street 200 Boston Post Road P.O. Box 549 Waterford, CT 06385 West Warenam, MA 02576 Mr. Wayne D. Lanning Mr. John Buckingham Deputy Director of Inspections Department of Public Utility Control Special Projects Office Electric Unit 475 Allendale Road 10 Liberty Square King of Prussia, PA 19406-1415 New Britain, CT 06051 Mr. M. H. Brothers Mr. James S. Robinson, Manager Vice President - Operations Nuclear Investments and Administration Northeast Nuclear Energy Company New England Power Company P.O. Box 128 25 Research Drive Waterford, CT 06385 Westborough, MA 01582 Mr. M. R. Scully, Executive Director Mr. Streeter Connecticut Municipal Electric Vice President-Nuclear Oversight Energy Cooperative Northeast Utilities Service Company 30 Stott Avenue P. O. Box 128 Norwich, CT 06360 Waterford, CT 06385 Mr. David Amerine Deborah Katz, President Vice President - Nucl ear Engineering Citizens Awareness Network and Support P.O. Box 83 Northeast Utilities Service Company Shelbume Falls, MA 03170 P. O Box 128 WateCrd, CT 06385
N:rthenst Nucle:r Energy Company Millstone Nuclear Power Station Unit 3 cc:
Mr. Allan Johanson, Assistant Director Mr. J. P. McElwain Office of Policy and Management Vice President (Acting) - Millstone 2 Policy Development and Planning Northeast Nuclear Energy Company Division P.O. Box 128 450 Capitol Avenue - MS# 52ERN Waterford, CT 06385 P. O. Box 341441 Hartford, CT 06134-1441 Mr. G. D. Hicks Unit Director-Millstone Unit 3 Citizens Regulatory Commission Northeast Nuclear Energy Company ATTN: Ms. Susan Perry Luxton P.O. Box 128 180 Great Neck Road --
Waterford,-CT 06385 -
Waterford, CT 06385 Senior Resident inspector The Honorable Terry Concannon Millstone Nuclear Power Station Nuclear Energy Advisory Council clo U.S. Nuclear Regulatory Commission Room 4035 P. O. Box 513 Legislative Office Building Niantic, Connecticut 06357 Capitol Avenue Hartford, CT 06106 Legislative Office Building Captiol Avenue Hartford, CT 06106 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc.
Millstone -ITPOP Project Office P.O. Box 0630 Niantic, CT 06357-0630 Mr. B. D. Kenyon Chief Nuclear Officer-Millstone Northeast Nuclear Energy Company P.O. Box 128 Wateiford, CT 06385 Mr. Daniel L. Curry Project Director Parsons Power Group Inc.
I 2675 Morgantown Road Reading, PA 19607