ML20217Q748
| ML20217Q748 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/26/1997 |
| From: | Imbro E NRC (Affiliation Not Assigned) |
| To: | Curry D External (Affiliation Not Assigned) |
| References | |
| NUDOCS 9709030345 | |
| Download: ML20217Q748 (6) | |
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j August 26, 1997-e Daniel Curry, Project Director
- Parsons Power Group inc.
' 2675 Morgantown Road Reading, PA 19607
Dear Mr. Curry:
- The staff of the Special Projects Office (SPO) of the Office of Nuclear Reactor Regulation (NRR) has reviewed the sampling criteria for the Independent Corrective Action Verification Program (ICAVP) Tier 3 Change Process Review that you provided in your July 25,1997, submittal. In parallel with the review of your submittals, the SPO staff also reviewed the July -
22,1997. August 4,1997, and August 18,1997, submittals by Sargent & Lundy LLC (S&L) that provided its sampling criteria for the ICAVP Tier 3 Change Process Review being performed at Millstone Unit 3. The purpose of performing these reviews in parallel was to ensure that a consistent approach to sample selection will be used at both Millstone Units 2 and 3. The
. Enclosure provides the results of the SPO staffs review and specific comments on your
- submittels.
- Unless otherwise noted in the comments in the Enclosure, your sampling criteria are approved
- for use during the ICAVP Tier 3 review at Millstone Unit 2. For areas where comments were noted in the Enclosure, you are requested to evaluate each of the comments and incorporate
~ them into your sampling criteria as appropriate.
If you have any questions or comments please contact me at (301) 415-1490.
Sincerely, lh*ugeneNro,deiuty Director.
s ICAVP Oversight -
Special Projects Office
- Office of Nuclear Reactor Regulation -
Enclosure:
As stated.
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DISTRIBUTION:
Docket Files (Docket 50-336)
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Northeast Nuclear Energy Company Millstone Nuclear Power Station Unit 2 cc:
Lillian 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 Hartford, CT 061410270
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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. Atlan Johanson, Assistant Director ABB Combustion Engineering Office of Policy and Management 12300 Twinbrook Pkwy, Suite 330 Policy Development and Planning Rockville, MD 20852 Division 450 Capitol Awnue - MS 52ERN Mr. D. M. Goebel P. O. Box 341441 Vice President - Nuclear Oversight Hartford, CT 06134-1441 Northeast Nuclear Energy Company P. O. Box 128 Regional Administrator, Region I 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. L. Bowling, Jr.
Waterford, CT 06385 Millstone Unit No. 2 Nuclear Recovery Officer Deborah Katz, President Northeast Nuclear Energy Company Citizens Awareness Network P. O. Box 128 P. O. Box 83 Waterford, CT 063855 Shelburne Falls, MA 03170 Mr. J. K. Thayer Mr. Wayne D. Lanning Recovery Officer - Nuclear Deputy Director of Inspections Engineering and Support Special Projects Office Northeast Nuclear Energy Company 475 Allendale Road P. O. Box 128 King of Prussia, PA 19406-1415 Waterford, CT 06385 Mr. M. R. Scully, Executive Director Burlington Electric Department Connecticut Municipal Electric clo Robert E. Fletcher, Esq.
Energy Cooperative 271 South Union Street 30 Stott Avenue Burlington, VT 05402 Norwich, CT 06360
Northeast Nuclear Energy Company Millstone Nuclear Power Station Unit 2 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 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 Office Building 9 Susan Terrace Capitol Avenue Waterford, CT 06385-3515 Hartford, Connecticut 06106 Mr. Don Schopfer Mr. Evan Woollacott Vice President and ICAVP Manager Co-Chair Sargent & Lundy Nuclear Energy Advisory Council 55 E. Monroe Street 128 Terrys Plain Road Chicago,IL 60603 Simsbury, CT 06070 Ms. P. Loftus Director-Regulatory Affairs for Millstone Station Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385 Mr. N. S. Carns 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 The comments discussed below were developed following the review of your July 25,1997, submittal.
I Specific comments are directed at the sample selection criteria desenbed in Sections 2,3,4, and 5 of your submittal. When evaluating the comments, you should also consider the impact on the other sections of your submittal and your audit plan and implementing procedures to ensure any changes made are consistent throughout.
- 1. INTRODUCTION 1.3 SAMPLE SPECIFICATION /lDENTIFICATION We had requested that samples be taken from each of the four time 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 time period, we do not see a need to expand the sample in other time periods 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.
- 2. ENGINEERING 2.7 ENGINEERING WORK REQUESTS Since Engineering Work Requests (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. The sample size (32 total examples) you proposed selected from each discipline is acceptable.
2.8 VENDOR TECHNICAL MANUAL UPDATES 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) Although the title to this paragraph indicates your review will be of updates to vendor technical manuals, it is not clear from the text that your review will be limited to changes to these manuals. For the purpose of the ICAVP, your review should focus on changes made to the vendor technical manuals to provide additional assurance that these changes do not effect the licensing and design bases of the equipment.
- 3. INFORMATION AND RECORDS MANAGEMENT 3.1 SOFTWARE DESIGN AND CHANGE CONTROL A review of this area is beyond what the staff had defined as within the scope of the ICAVP.
3.2 ELECTRONIC DATABASE CHANGE CONTROL / DATA QUALITY With the exception of the review of the Master Equipment Parts List (MEPL), a review of this area is beyond what the staff had defined as within the scope of the ICAVP. 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 ("Q') to not being required to satisfy QA Program requirements ("non-Q'), rather than the control of the MEPL database. In line with your methodology for sample selection, an initial sample size of 32 (two from each of the four time periods from each of the four disciplines)is acceptable.
Enclosure
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4 3.3 DOCUMENT CONTROL AND RECORDS MANAGEMENT A review of this area is beyond what the staff had defined as within the scope of the ICAVP.
- 4. PARTS PROCUREMENT / SUPPLY 4.1 COMMERCIAL GRADE DEDICATION in your sample criteria, you had proposed a review of equipment dedications performed by equipment vendors. Equipment dedicated by the vendor would be purchased by the licensee as "Q' equipment in a process similar to that used for the purchase of other safety-related equipment.
Consequently, a review of equipment dedications performed by equipment vendors was not contemplated by the staff as being within the scope of the ICAVP. Your review should concentrate on the process used by the licensee to dedicate equipment that they purchase as "non-Q.' An appropriate initial sample size would be 32 examples of commercial grade dedications (2 components from each discipline for each five year period).
4.2 EQUIVALENCY SUBSTITUTION An initial sample of 32 examples of equivalency substitutions, 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,
- 5. OPERATIONS & MAINTENANCE A review of operations, maintenance, and surveillance procedures is being performed under the Tier 1 reviews for the selected systems to provide assurance that the procedures are not in conflict with the design and licensing bases. This will provide an adequate sample for the purposes of the ICAVP. The Tier 3 review should be directed towards sampling changes to operations, maintenance, and surveillance procedures for systems outside the scope of Tier 1 to provide assurance that the configuration of the plant has not been unknowingly changed through other change processes, such that it is in conflict with the design and licensing bases. Consequently, your proposal to review procedures regarding conduct of operations and maintenance under Tier 3 is not necessary.
5.1 PROCEDURE AND ASSOCIATED TRAINING SAMPLE SELECTION 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 site 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.
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- 2. A minimum of four Abnormal Operating Procedures 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.
- 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 Test (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.
5.2
- A8ME SECTION XI REPAIR AND REPLACEMENT -
The sample for ISI/IST is defined above. - This review should be diracted towards repairs, replacements, and modifications made under the ASME Section XI program. As an initial sample, select five significant examples from each of the four time periods specifed for components currently installed. The sample should include examples from each of the five major mechanical component types referenced in your submittal (if available) for each of the four approximately five-year periods since the start of commercial operation (20 total examples).
5.3 TEMPORARY CHANGES, INCLUDING JUMPER, LIFTED LEAD, AND BYPASS-CONTROL
. Approved as modified by the following comments:
- 1. Select 'he sample of temporary alterations from safety-related and/or risk-significant systems outside the ICAVP Tier 1 systems. Emphasis should be given to those temporary modifications i
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 terrporary alterations to introduce design or licansing 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.)
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