ML20248F407

Final Rept SL-5192, Independent Corrective Action Verification Program for Millstone Unit 3

ML20248F407
Person / Time
Site:	Millstone
Issue date:	06/01/1998
From:	SARGENT & LUNDY, INC.
To:
Shared Package
ML20248F400	List: ML20248F397 ML20248F407
References
SL-5192, SL-5192-01, SL-5192-1, NUDOCS 9806040233
Download: ML20248F407 (35)

Text

- - -

/M sarse Lundy m s,

INDEPEXDEXT CORRECTIVE ACTIox VERIFICATION PROGRAM FOR MILLSTOXE UXIT 3 Fina Report Executive Summary l e,

, .+ '., ,

cSL-5192:

f s y  %. *

.m F.j "F

• 4 1> ~

4MW~n 1998 '., ";. .

%?~.c? > < : c :e .a >  ::.

m',,

' y:u:+ ,  : ..>

y y  : - . .; c:

,'fd<.hyg <

c

' .' A 3

Q ,\ ,x '- :;&,;p ,. wq . t-

' ^ ~

p s.

's r > +

plq .nc sq .

h

, ",*Q~

.~ c

. , ~, %o my: fw ?f Xy,

%y 4a. ,, y

[m. :y;[glgM:: ,

a /gt.<Q ,_ 4 , Q;7 gy , 4:q n'+n sw m?m.a wfb:fypQ w, R;, a,

,wys een:w WL Ar gn a. 4-M ?n m~. %*m ", Rj,fy;f;n.n;

-s ~.m

%mq?ap.)u , w;r.u;. .~ .

m M- w,mw.a. .sen w/n,4n;,g w -u g&.,: gny?y Mgas. emq%m:&pk;

~i R 2mb

.w 19%e %w 2 %s 7Qya$ y,h n;p m,:m:

.nn fq&:,"s;&

w. <

.3 hp,piayjw q,pi;%:<Mtnyllysyn.

('. :t .p c M m ft: - - Q, sy g w%lf;gy g

i:

.py ~;g s j %y{t

,. 5 i; ,j g

F

^&@..g}l?hal,t'y2{f y.. 8 :a w y$p:g g:. * :f[4

.*I fc,pgg. fy ,,Q,}p&;0ia

. g jy%g@phfg*p&;;;;

t e,

J$

_['.[

f.p j.f.f,, 7'l ; %:: % f. Q; ,'- .;

4

,e  ;},) jk, r\c.g(f.

.. . . ; . .;,... . : :f

.. f.

, .. . - .y.. .

.. "; .:,n ., . ,

• 4 __

. .,..c,.

sf'

. a e .-

W 4

9806040233 980602 o -

PDR ADOCK 05000423 p PDR

j er e'

l l serse r Lundym vi <

. INDEPEXDEXT CORRECTIVE ACTION VERIFICATION PROGRAM FOR MILLSTONE UXIT 3 Final . Report Executive Summary

. S,C 519. 2V -

(p

" v.  ; ., e :y:

n

'r/a #., A. 1 dJune w

e, , n,y .w. ,, , y_.

.; r. ':c:p . ,-

y

%19985

- ~3

,V :,

.; ;; ;. w* r *

,G ,)::

i

., m~ .

, , ;k.; ',,, , , .. ;

N i $$N >' .

b$iiQ,p9: f* t.',,,,

Ih?% ;,> ;, ., b hk .... :'h$kl IWo D ' .l.jgl[6C.

.,1 i ~L* tn ".g t> h:'

% 1,l % 5MS f,lll

• v a l't:l

/i 0; u $ , W.! ~ FM,9W

$95'g .

.< . 43 mp'd% A. %h! ' +M, v, ' '.1,?

q m.r.q gy;:X :M $lQ2g &s;%:yp'< WWmc q[V,& v

fQAyhqi:%qs%y;;.4?pt;ff::;5g m y+<h q.nc? w ,

a e u

f q8a% s

-d 9 y. %Loi4; :nt,u: w hm.% m. y

[:C'g ptEMr V;& g! ;- l>> W . gy,4$,4$w

. a" ,: p %wa pmgr w w&

e ws fn;g:w.n;L A . g. T'q.pBfQ;.

S nys a;@h,,p.SdQ;.mg%:y%f -n. ad

1. 2;

,JijIi{&S' phN i.G4@ntawgp;$ADjg;yty[y.

ggh.7,0;p?3-;J:s. Di T! ,e.%g5M,lMlp '

ig.usp% gyp;th, ' -

n;j. tv h ;p;pyre .4 by.

y hhkh, w...; hbkk.h,,

iff;[f .pfj:piby%. h] @ H . .,thj

./ ,,w

<-o--

m., .j.;,.;gn.

. ,. . y . 3 , .

. s. o p.., p,.

g. . .,J. a... -

.;kh u,,,,%

1

,..' ;^ 3 g,;

&.1 .,..-w. -:

s[.

j'. -

/

• j s .

j i k

9806040233 980602 PDR ADOCK 05000423 -

p PDR

. . . . __m -

[' 1.1-1 sargerk k Luncfy*'a SL-5192 l z ;

l j

i l

i Section 1 EXECUTIVE

1.1 BACKGROUND

On August 14, 1996, the Nuclear Regulatory Commission (NRC) issued a Confirmatory Order directing Northeast Utilities (NU) to establish an Independent Corrective Action Verification Program (ICAVP) for Millstone Units 1,2, and 3 to confirm that the plant's 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 aree Millstone units. The order stipulated that the

!CAVP 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 re5iew 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 11c (S&L) as the independent third party to conduct the ICAVP review for Millstone Unit 3. S&L has completed the ICAVP and is issuing this report to describe the scope 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.

sirs!-5192. doc /050898

d' 1.2 1 g'2 g sar gemk t_ undy"a E"

)/

J

l l

1.2 OBJECTIVES The objective of this project was to implement the Independent Corrective Action Verification Program (ICAVP) at Northeast Utilities Millstone - Unit 3 in accordance with the NRC's confmnatory order of August 14, 1996.

The ICAVP provided an independent verification of the adequacy of resultz, of the Configuration Management Program (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.

sMst-5192. doc /050898

t

{:

/

I 1.3-1 Berge tundy="

SW2 qp l

l-.

l 1

1.3 SCOPE The scope of work for the ICAVP as described in the NRC's confirmatory order of August 14,1996, to Northeast l

Utilities included the following tasks:

• A review of engineering design and configuration control processes.

'e 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. l l

l e 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. l 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 oversight inspection plan required a review of accident mitigation systems that

! would assess the critical design characteristics to ensure that these systems and co.nponents can perform their specified safety functions.

l Sargent & Lundy implemented 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 I review process verified that the selected systems are capabk of performing their functional i

requirements as specified in the design and licensing basis documentation. A total of 15 plant systems were selected for review in the Tier 1 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:

e QSS/RSS - Quench Spray and Recirculation Spray Systems l

• . SWP - Service Water System

. ?X)X - Diesel Generator and Auxiliary Support Systems l- - - -

L 1.3-2 .

b y ,, SL-5192 i

e HVX - Reactor Building Ventilation, Supplementary Leak C >llection and Release, and l Emergency Generator Enclosure Ventilation 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

1

• A verification of current as modified plant conditions against the design bases and licensmg  ;

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 l

! conformance with the design output documents.

I

• 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 ,

contaal in the licensing and design bases to compare them with those identified in the operating, i maintenance, ating, and training procedures. l

• 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 actic. s 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 plant 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. .

{' .iros192.doomsos9s

1.3-3 SL-5192 hs t_uncfy"

• L i 1.3.2 Tier 2 Review Process The Tier 2 review process was designed to verify that the accident mitigation systems 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 mstmmentation 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 the:r 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 revinved 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 of licensing and design basis maintenance.

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

sir %).$192. dodo 30898

1.4-1 sgensk Luncfy* 5 a 1.4 ORGANIZATION Figure 1.4-1 mws 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 ne Sargent & Lundy management team fLr this project consisted of the Project Director, Bryan Erler; the Verification Team (Vf) 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.

s 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 responsible 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 the fmdings produced by the VT and, upon acceptance, submitting them to the Internal Review Conunittee. He also retumed 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 for preparing the final report documenting the work of the VT. The Yf Manager also served the role of S&L spokesman with respect to communication with the NRC and, when necessary, to NU.

skW-5192. doc /030898

1.4-2 SL-5192 sar gem\'d) Lundy"*

1 The Chairman of the Internal Review Committee was responsible nor coordinating the actisities of that group. The roles and responsibilities of the Internal Review Committee are described below in Section 1.4.3 of this report.

1.4.2 Verification Team The VT was the core of the organization and was the group that perfonned the actual review of the design and licensing bases and the effectiveness af the NU corrective actions. The VT was organized 6to four functional groups. Each subgroup was headed by a Lead Engineer and was responsible for a portion of the overall verification program. The 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 8 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 teamed, and discuss other project issues.

Teamwork, frequent communications, and meetings were fundamental attributes for the conduct of the ICAVP.

1.4.2.1 System Review Group The SRG performed 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, potential synergistic effects of the modifications, and appropriate design document controls.

sIrti-$192.dod0$0898

/

/1 1.4-3 sar ge $(t_ undy'" 02 i

%7 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 Programmatic Review Group The PRG was responsible for the review of selected NU processes for changing the facility design and for changing characteristics, procedurts, or practices for maintaining, operating, testing, and trammg to ensure the adequacy of,the change process. The PRG was also responsible for the review of NU's corrective actions 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 requirements and post-modification testing requirements to confirm that they were adequate to verify system performance.

1.4.2.4 Accident Mitiration Systems Groun The ARG group w 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 mitigation systems and their critical characteristics to ensure that the systems could perform the safety functions specified to mitigate the FSAR accident scenarios.

1.4.3 Role of the Intemal Review Committee The Intemal Review Committee provided an S&L management technical oversight role. It also helped provide consistency in the review results. The committee consisted of four very senior personnel within the organization that have specialized expertise in the areas reviewed. The IRC Chairman was responsible for obtaining the IRC's m9muteno

/

/ f4 1.4-4 4'

• SL-5192 Sae gere arm t_ undy * *

• Sp f

/'

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 cecepted by the VT. The IRC also made specific recommendations regarding the scope and methodology of the verification process as the work progressed.

i ahl-5192. doc /030898

/

Project Organization Figure 1.4-1 SL-5192

%e u n W "a

)

Northeast t

utiliti.. NRC System AL AL B. A. Erier Project Director Quality Assurance A. K. Singh D. K. Schopfer

---~~~

IR Committee Verification Chairman Team Manager IR Committee System O&M and Accident Programmatic Review Lead Testing Mitigation Review Lead

. . Gmn Review Lead Review Lead A. A. Neri T. J. Ryan W. G. Schwartz K. M. Bass R. D. Rahoja

. l D. P. Galle Physical Configuration Review Lead R. E. Kropp a w.5192.+ e50s9:

~ 1.5-1 s.,,ge Wny* SL-5192 L

1.5 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.

• lhe 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 instnictions:

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 Trammg 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 File Index 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 assure that the observations and conclusions were a result of our own independent assessment and not influenced or biased by susm.dovo30s9s

w 2 5-2 r fl Sarge M n Lundy*

outside organizations. To maintain this assurance of independence, communications with outside organizations were in accordance with PI-MP3-01, "ICAVP Communication Protocol."

1.5.1 System Reviews The selected systems were reviewed by the SRG as part of the Tier i 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 requirements of the system.

Following the identification of the system requirements, the SRG performed the 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. His review included mechanical, electrical, I&C, and structural calculations, piping analyses, and equipment EQ/SQ reports.

• An upper-tier drawing review including P&lDs, electrical schematics, electrical single-line drawings, instmment 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 and 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 his 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 scope of the sBal-5192. doc /050898

1.5-3 f' Lundy"*

SL-5192 sargers3 g/

./

)

modification review included all major modifications (DCRs), Minor Modifications (MMODs), and all DCNs generated to support the 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.

The SRG also performed a detailed review of the changes to licensing documents that were generated for each modification to en .: 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 ard 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 strti-3192. doc /030898

g 1.5-4 k( & 4 SL-5192 Sergent Sm, Lundy"'

Y r

I

)

posted against 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&lDs and schematics.

1.5.4 Operation & Maintenance and Testing Review The operating & inaintenance and testing review was performed by the ORG as part of the Tier I review scope in accordance with PI-MP3-06. This review focused on determining whether the system operating procedures, maintenance procedures, surveillance procedures, and training documents conform to the systems design and licensing bas 6s. This review was also designed to verify whether post-modification tests for plant modifications to the selected systems were adequate to maintain the design and licensing bases.

1.5.5 Corrective Action Review The Tier 1 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 nonconfonning 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 resiew 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. 'Ihe reviews were performed in accordance with PI-MP3-04.

1.5.6 Corrective Action Implementation Review The Tier 1 corrective action implementation reviews were conducted by the PRG, SRG, and ORG to determine 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 signi5cance, and the implementation review was conducted on significant corrective actions in accordance with PI-MP3-04.

str'el-3192. doc /050898

4 1.5-5 SL-5192 ser ge Wncey" =

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. He 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 basis (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. TN current MP3 process procedures were evaluated for content and completeness. This evaluation determmed 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 maintained consistent with the licensing bases. The evaluation was based on guidance provided in the following documents:

• - Regulatory Guida ' .33, Quality Assurance Program Requirements (Operation) e NRC Inspection Manual e INPO guidelines e INPO 87-006, Report on Configuration Management in the Nuclear Industry e NF.I guidelines

{

u wei-5192.docm50s9s

/'

1 1.5-6 bI'5192 Elemenck) \' Lundy"'

) /

'Ihe adequacy of NU's implementation of tL- change process procedure was also evaluated. Since the system review assessed the technical adequacy of the change (modification), the programmatic review only evaluated the procedural adequacy of the change. The evaluation determined whether the current procedure was followed, whether the required checklists were accurately and completely filled in, and whether all other documentation was complete and accurate.

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 were selected from various systems other than the ICAVP-selected systems in order to maximize plant coverage. 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 v.n ,onducted 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 a a condition, such as an error, otaission, 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 systera design bases and the FSAR, the es-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 the conclusion.

slrtl-3192. doc /050898

t-

/

L r 1.5-7

) il Lurtdy"' SL-5192

- hw. q I

Significance Levelt I through 4 were assigned to each DR by the Initiator. The Significance Levels were dermed as follows:

! 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 potential j to simultaneously affect redundant trains.

l 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.

l 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 ,

significantly affect the results of a calculation or inconsistencies between 1 documents of an editorial nature.

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

The VT Group Lead reviewed each DR with the VT memSer 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 l NU corrective action document. Once initiated, the DR could either be accepted and signed by the VT Group I

Lead, be returned to the VT member for additional information or investigation, or be deternuned to be not valid.

For any DR detennined to be not valid, the justification for this decision was documented on the DR and the DR l 1

was accepted (electronically) by the VT member and the VT Group Lead. If valid, the VT Group Lead forwarded 4

the DR to the VT Manager.

'Ihe 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 anothen 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 retumed 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.

sval 5192. doc /050898

h

/#

~~

I.5-8 w Sgd 4 t.mndy"* SL-5192

• t v 8 /

5

=

The VT Manager submitted accepted DRs to the IRC for their review. They reviewed the DRs for extent of the 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 I not valid, or accepted the DR as written, whereupon the IRC Chairman signed the DR and returned it to the VT

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

~

All DRs were transmitted to the NRC, NEAC, and NU when the above process was completed. 'Ihe 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.

Therefore, 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 Intemet bulletin board when received and was submitted to the VT member who initiated the DR, the VT Group Lead, and the VT Manager for review and assessment. If the proposed resolution for Level 1,2, or 3 DRs was determined acceptable, it was forwarded to the IRC for 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 Intemet 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 retumed to NU with an explanation and the bases for why the team did not consider it to be adequate. The acceptance of the NU resolution or explanation of S&L's inadequate determination was sent in pruai!el to the NRC and NEAC and was skW-5192. doc /050898

ef

pkt '

1.5-9 samentA, t_uncty"= SL-5192 Y

/lM posted on the Internet bulletin board. NU reviewed the S&L basis for rejectien and submitted a second respanse to the VT. When required, meetings were held between NU and the VT to reach an understanding and resolution of a particular issue. These meetings were requested and held in accordance with the established protocol.

slitl-3192. dodo 50898

s____-.______-_____ _

%W JL

{

L

.c dJoaass 1,go m q! 2ae m S*N* ouqa naiqopogoit AD "

• r

i

1 11 4

l

.~'

, ' s ,2 e

- i

-, - l t -.

'.! t

'{

, . ,-s 3

, . 85

,'~

o

- . t. - - - - -

t

_ i-s

,a ,

.~._

. - . . - i, ---

' t .

i _EMVW t

t t t ~

-7l=J'fl"

- .C'

,, ~

A..' -

-- L -

l t t t I

-o.

,j.

' ue e ,.--..=.

_e.*.'=**o**

!j ~ -.

% rJ . -.- - . t

. i t t t l I

o o.n l

, - --~

- p,.,.,.q -

A -

' 4 t

, ~~- -, _

--/ "5 e

~~

t t a_~ gm ag sa a ey

- - v g 133 u.a I! s.e n i

v

[_ 7

~

. i,

- am t

N- .

at.

ji t '

a.

e.

t

(

d " M- ".".* 8 8**

J. ,

bi

'c

".*.*.ml~.~.~4 l l

A

,ba i>

(

'/s i <.

" W-st6Tponos0963

[

Figure 1.5-1 SI 5192 ANSTEC APERTURE CARD l l

1 Also AvausNe on Aperture Card 1

4 4 9 c .= =:=-

~

4 4

- a g__ ._ _.L. ,

4 it 1L 1' iP 4 1r

e. ..

- =-

6 ._j._

1

. _ _ . _ _1_ _

i_

1 4

• / 1

.,  ?

=

Q?oloo(40253- O

.J

/

4 Process Findings Figure 1.5-2 sarge t_u ncfy ", and Resolutions SL-5192

, initiate Discrepancy Concu Report (DR)  :

l VT Invalid h

No/More Review DR info Required VT Mgmt I

is DR Valid & DR not 5 Adequate? Vaha Yes

= _

No#. tore Review DR info Required IRC s DR Valid & DR not Adequate? Valid v

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

on Electronic BB VT Manager Provide DR Response to S&L NU

+

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 /

rm Finr+mnie RA Comments

• W Mgmt IRC

'For Level 1,2 and 3 DRs Only NU Nc Response to DR uste Yes Document Acceptance

& Submit to NRC/NEAC/NU &

Post on Electronic BB m W3tagswmeliptvgi4 2 ved VT Mgmt shti-5192. doc /050898

FAG 1.6-1 k, B2 sar gek)39, L. undy"*

1.6 RESULTS 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 22 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 22 discrepancies, 21 have been confirmed to date and I (DR-MP3-0328) has been submitted to the NRC for resolution. Of the 21 confirmed level 3 DR's, DR-MP3-676 closure is pending receipt of calculations from NU. The remainder of the discrepancies identified were of low significance calculation documentation or procedural compliance type errors that do not place the systems outside of their design basis (NRC Significance Level 4). Of these Level 4 DR's, all are closed except DR-MP3-726 which is pending receipt of calculation from NU.

Three DR's (DR-MP3-272, 514 and 580) were closed because NU was in compliance with their licensing basis.

However, S&L had comments regarding the technical adequacy of the licensing basis. S&L comments regarding the adequacy of the licensing basis have been referred to the NRC.

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 muumal duplication in the summary on the following page.

slrtl-5192. doc /050898

1.6-2 Sar genei4 [' Lundy... SL 5192 Level 3 - Level 4 -

Review Process Confirmed Confirmed Total Tier 1 System Review 13' 371" 384 Configuration Review 1 127 128 OM&T Review 1 19 20 Modification Review 2 20 22 Corrective Action Review 2 32 34 Tier i Subtotal 19 569 588 Tier 2 Tier 2 Subtotal 0 23 23 Tier 3 Process Review 2 3 5 Process Implementation 1 4 5 Past Change Review 0 5 5 Out of Scope Corrective 1*" 6 7 Action Reviews

~

Tier 3 Subtotal 4 18 22 Total 23 610 633

• DR-MP3-328 is unresolved and has been submitted to the NRC for closure. DR-MP3-686 final closure is pending receipt of calculations from NU.

" DR-MP3-726 final closure is pending receipt of calculations from NU.

• • • DR-MP3-624 is also included in the Corrective Action Review count above.

strW-$192. doc /050898

/ 1.7-1 sar ger*' ail h' 5% Luncly*

SL-5192 y72

1.7 CONCLUSION

S The conclusions summarized below are based on the confirmed Significance Level 3 and Level 4 DRs.

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

. The NU CMP has been effective in identifying and resohing 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 venf small in comparison to the number of design and licensing requirements that were verified on the selected systems.

. The selected systems and the Chpater 15 accident litigation 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 efTective configuration control of their design and licensing bases in the future.

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

1.7.2 Tier 1 The Tier I 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.

1.7.2.1 System Review The system review was performed in five separate tasks: Design and Licensing Basis Documentation Review, Calculation Review, Drawing Review, Component Review, and Topical Review. Separate conclusions are provided in Section 2.4.3 of the full report for each of the five major system review tasks.

Our overall conclusions from the system review is that the plant's licensing and design basis is supported by the plant's design output documents and design process documents. We also conclude that the plant's upper-tier str\d 5192. doc /050898

f g(f 1.7-2 nar SL.5192 sargenc Lundym l

system-level engineering drawings and the plant's 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 where improvements could enhance NU's configuration control going forward:

• The PMMS and PDDS databases contain sufficient number of errors and omissions so as to render the data suspect for design input.

e The component procurement specifications and vendor drawings have not been consistently kept up-to-date.

. The number of instances where incorrect design inputs were used indicate a calculation control problem. This concern is limited to mechanical system sizing calculations and electrical system calculations. This condition apper.rs 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.

. A high number ofminor discrepancies were identified in both old and recently revised mechanical system sizing calculations. While none of these discrepancies affected the calculation results or impacted compliance with the licensing and design basis, overall quality could be improved.

. FSAR sections regarding filtration system compliance to RG 1.52, Revision 2, are incomplete and should be revised to more clearly define the systems DB/LB.

• DBSDs for the HVAC systems she.ld be revised to more clearly define the systems DB/LB, particularly exceptions to m:nor requirements of RG 1.52 and ANSI N509 and N510 standards.

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 plant's physical drawings are generally in conformance with the upper-tier system-level engineering drawings. A high number of low significance documentation issues and material condition issues, which do not place the systems or plant configuration outside ofits design or 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:

sirbl-3192. doc /050898

I -

1.7-3 Sar gent k Luncty"' SL-5192

)

I .

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

Undocumented attachments to supports (approximately 42 occurrences). Although, none of the undocumented attachments affected the structural adequacy of the support and many resulted I from original design and construction, the fmdings indicate that NU should review their control mechanism to prevent recurrence.

. 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 systems are operated and maintained within the Design and Licensing 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 and Level 4 Discrepancy Reports with NU's methods and schedule for testing as well 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 meets the intent of the generic letter. S&L agrees with the NU's assessment, provided the agreed to enhancements are incorporated into the current program.

Level 4 Discrepancy Reports were reviewed to determine whether a trend existed across multiple systems. Our review did not identify any such trends. The Level 4 DR's were found to be of limited significance, many involving typographical or administrative issues. NU corrective actions indicated that appropriate actions were to be taken to correct the errors.

I I

I . _ , _ s,s

/( 1.7-4 sargent k t_uncsy"= SL-5192

%p of

/

l

' The review of specific system requirements combined with the generic reviews of operations, maintenance and training provide reasonable assurance that the selected systems have been operated and maintained within the Design and Licensing Basis and that such performance can reasonably be expected to continue into the future.

1.7.2.3.2 GeneralConclusions An overall observation regarding maintenance, surveillance / calibration, and testing and operr.tions is that some of the processes in use place a very high reliance on the skill and performance of individuals. 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 perfonnance 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 recoveiy.

'1.7.2.4 Modification Review

'Ihe design a plant modification implemented after receipt of the plant's operating license was technically adequate an ' figuration control was adequately maintained. Additionally, we conclude that the identified modifications have been installed and implemented consistent with the design package and tlw 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 The number and nature of the discrepancies found in the review of the NU corrective action plans for self-identified UdP-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 was a small fraction of the total number corrective action problems reviewed, and based on the categories of discrepancy types identified, no adverse trends were found. In the review of implementation and completion of corrective sirW-5192. doc /0$0898

/

1.7-5 SL-5192 Sar'Oer  ;. Lu ndy 6 ' a l

/

W l

actions associated with established corrective action plans, a similar conclusion was reached. He valid discrepancies were 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 systems, 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 ar.d 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 Eeneral, NU has been adequately following the current procedures.

Only a small number of significance Level 4 discrepancies were found for the 11 change process areas covered in the Tier 3 review. In systems outside the scepe of the four ICAVP systems 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.

I sitti.5192. doc /050898

/

l - $$

M 1.7-6 sas ge kw uncly", SL-5192 jW )

i l

A review of out-of-scope corrective actions was performed in addition to the Tier 1 review of all CMP-related corrective actions. The results of this review were combined with ' ,e Tier 1 results for trending purposes, and no

' adverse trends were identified. Thus, except for the valid discrepancies identified, NU's corrective action plans for self-identified problems were adequate in correcting the Millstone Unit 3 licensing and design basis.

l l

l l

Wl-5192. doc /050898

/

1.8-1

%dg ww... SL-5192

+9 l

1.8 SARGENT & LUNDY QUALITY ASSURANCE DIVISION REPORT Sargent & Lundy (S&L) Quality Assurance Program Topical Report, SL-TR-1A, gives the responsibility of performing independent audits (to support 10CFR50, Appendix B, Criterion 18) to the Quality Assurance Division. The Quality Assurance Division performed three independent audits of the Millstone 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 technical accuracy thereof. The third audit reviewed project completion and close-out activities. The following paragraphs discuss cach 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 examir.e 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 ARG Assumption / Item document. The recommendation was to document the results of the walkdowns in more detail on the checklists. Appropriate corrective actions were taken by the Project Team and verified by QA.

MsL5192.&ct)$0898

[/

sorgov,c alik Lundyu.

4 1.8-2 M192 1 s y

/'

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

l 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 i

corrective action was necessary. Therefore, no findings were issued. l 1.8.4 Conclusion-The project complied with Sargent and Lundy's Quality Assurance Program, with the Millstone Independent  !

1 Corrective Action Verification Program Oversight inspection Plan, with the ICAVP Audit Plan, and with the Millstone Unit 3 Project Instructions. l i

l t

?

i-str%I-5192.dooV50898 I