ML20137F157
| ML20137F157 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/21/1992 |
| From: | GILBERT/COMMONWEALTH, INC. (FORMERLY GILBERT ASSOCIAT |
| To: | |
| Shared Package | |
| ML20137F155 | List: |
| References | |
| NUDOCS 9704010002 | |
| Download: ML20137F157 (15) | |
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I NU HELB PR.OCESS:. :s;c :,
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- EVALUATION l'BERO'RT~ U . .
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e Mapping of the Northeast '
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Utilities HELB Soldtion N6.;mro5ess... . '
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Conducted and Prepared by:,. .
Gilbert /CbhiinbVswealth71n'c'.
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- t. TABLE OF CO? GENTS j I. Management Summary j II. Problems / Issues i ;
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- FoundationalIssues L
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- Opportunities Overview I
- DetailOpportunities Analysis !
e Issues Resolution Overview j
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- i CriticalSuccess Strategies j'
- HELB Program Interview Participants i J
4 III. RFP Descriptions 4 !
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IV. Models t
/-t V. Matrices i j VI. Process Documentation >
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l I. Management Summary Gilbert / Commonwealth has concluded an initial assessment of the NU HELB SOLUTION
' program processes. This report discusses the results of the O/C assessment and provides recommendations desigaed to enhance the NU process and methods.
The G/C analysis included reviews and interviews of HELB process efforts at CY, MP1, and MP2.
The bulk of documentation research focused primarily on the HELB efforts for MP1. The O/C assessment has identified key opportunities to significantly strengthen the NG HELB program. .
The assessment has also identified issues and problems with the current program which should be '
considered as priorities for resolution so that the HELB program provides NU with the most i effective return on its HELB investment.
j The O/C assessment has identified that the issues and problems with the current process are l grouped into three main categories, specifically Information Related Issues, OrganizationalIssues, i and Management Related Issues.Section II of this report delineates the specific issues and provides details appropriate for each.
O/C believes that the most significant challenges to success in the current program are related to establishment of a solid Licensing Basis documentation.
j The G/C team began the assessment with a review of the need for a HELB program. The G/C team concluded that the need for HELB progam has been highlighted by the emphasis placed on ;
it by the NRC. From an investment cost perspective, the cost to develop a pro-active HELB process will be an order of mghude less expensive than to defend every decision and action troin a " Troubled Plant" posture.
The O/C recommendations for strengthening the NU HELB program address: )
I. Management and Organization Strategies II. Licensing Documentation Strategies liL Event Resolution Strategies O/C believes that the comprehensive, validated knowledge base of the HELB program provides NU an excellent basis for enhancement and strengthening of the HELB program and process. ,
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FOUNDATIONALISSUE
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v> Why should NU establish a HELB Program?
Completing an orderly, controlled, planned HELB verification program appears to be the best approach to avoiding economic loss. Typically, plant outage time means significant replacement power cost to the utility.
HELB is a sensitive issue with the NRC, especially for MP-1. If another problem were to surfa the NRC may require shutdown of one or more units. Restart may be delayed until the completion of the HELB program. This will place HELB in a crisa mode increasing the cost exponentially.
MP-1 is currently operating on a JCO, which in theory is only valid through the next refueling outage. Evidence of significant progress on the HELB program may well be the minunum acceptable basis for restart (completion may be required). Commitments have been made to the NRC to do a HELB verification program in LER's.
A PRA approach to HELB may be possible. The cost of completing the HELB program in a managed, controlled manner may be comparable to the cost of a PRAjustification program prepared for the NRC. The HELB program has a very high probability of receiving NRC acceptance, but acceptance of the PRA is questionable (50%). Therefore, while PRA may be a useful better.
tool to maintain cost and solve problems the current mechanistic approach appears to be The mini-reviews performed on each unit left many unanswered questions related to HELB. The objective of the HELB program should be to close those issues and:
b e Document the design verification criteria for HELB and the basis for that criteria. NU management approval and NRC buy-in to the criteria are also needed.
Develop (revise) the minimum shutdown scenarios necessary for HELB, since the original shutdown scenarios used are not adequate based on plant operating experience.
Address HELB effects on modifications made, since the original design. This can best be accomplished by walkdown, since documentation searches are difficult (or impossible).
Control of the HFIR program through the Configuration Management (CM) program is essential to developing uniform " tools" to maintain the living HELB design. Also, the tools needed for HELB may be needed for other programs and small scope adjustments may be the most efficient way to produce these common tools:
Barriers Shutdown equipment data base Cable data base Breaklocation data base Our analysis has identified three key strategies to ensure an efficient HELB program.
I. Management and Organization Strategies Elevate project to a staff level and develop detailed plan for management of the n program.
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- 11. Licensing Documentation Strategies O
V e HELB criteria document and design basis document.
III. Event Resolutions Strategies Develop a HELB NERP (Nuclear Event Resolution Process) to eliminate " Crisis Management."
The above recommendation is an integrated program that will support the PEP (Performance Enhancement Program) objectives. The processes and tools resulting from this approach should be steps toward uniformity between plants and the Configuration Management program objective. !
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l-OPPORTUNITIES OVERVIEW ' -
A. Information Related Issues i i
- 1. HELB License Basis not yet defined )
- 2. Criteria Document does not match license submittals l 3. Basis for Criteria Document is unclear l 4. Output of HELB required by CM is undefined L 5. Criteria in document are not specific enough
- 6. Specific criteria are not traceable to source B. OrganizationalIssues l
l l 1. Process defined by Project Engineer for each unit l.
- 2. Conflicting agenda among participating organizations i 3. Program organized as a sequential steps process.
4 CM processes are not focused to support HELB C. Management Related Issues l
- 1. Program lacks "Results Measurement" processes
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f DETAIL OPPORTUNITIES ANALYSIS A1 The HELB program indicates that the licensing basis is defined, but documents do not support that this effort has been completed.
A licensing evaluation has been written for inside containment for all four units (including MP-3), but not for outside containment. A draft evaluation for outside containment for MP-1 has been written. Even though the licensing evaluation for MP-1 has not been finalized, the next sequential process that uses it as an input, Develop HELB Criteria, has been finalized. Licensing bases for MP-2 and CY were not available during our interviews.
A2 'Ihe common perception is that the Ebasco Criteria Document was based on the developed licensing basis, but analysis indicates that the Criteria Document does not match the available licensing submittals.
i HELB issues are discussed in the MP 1 Criteria Document, such as postulation of moderate i i
energy leakage cracks and use of NRC Generic Letter 8711 for identifying break locations, i even though these issues are not addressed in the draft licensing evaluation for outside containment. Also specific SEP issues for MP-1 discussed in the draft licensing evaluation ,
are not addressed in the Criteria Document. The MP-1 Criteria Document was approved in i January 1992 while the draft licensing evaluation was issued in November 1992. The draft i
licensing evaluation for MP 1 addressed the licensing bases for past NRC commitments but !
does not address a justification or reconciliation for the use oflater NRC guidance. The :
licensing basis evaluation states facts related to NRC commitments, but does not draw ,
conclusions to support the design criteria.
A3 The basis for the Ebasco Criteria Document is unclear (i.e. references to licensing f) v submittals, SEP, and SRP).
The MP-1 Criteria Document does not clearly identify the licensing commitments associated with criteria. The criteria in Section 4 of the MP-1 Criteria Document appear to come from )
a number of different versions of SRP's that are not discussed in the draft licensing !
documents as well as the original 1972 Giambusso letter requirements which were discussed.
J Many other criteria are listed for moderate energy piping which were never addressed in the l
originallicensing basis of the Giambusso letter, j
A4 The Configuration Management (CM) program receives substantial outputs from the HELB program, but CM has not defined what is needed from HELB.
The Licensing Basis should be a living document, such as a DBD, and made a part of the CM program. CM is not involved in defining the output documents to ensure there is !
commonality of approach and format between the projects. Commonality would help to make the use of these HELB documents for future modifications and maintenance easier for the organizations.
AS The criteria defined in the Ebasco document is not specific enough for the needs of the unit.
The Criteria Document covers HELB design concepts in general terms. There is not enough specific direction covering the application of these concepts to assure that the work being produced is appropriate for its intended use. Guidance via specific procedures on the major design concepts, such as blowdown and thrust loads and jet impingement, should be provided to cover all the projects. The procedures should have management review to ensure they p)
'y adequately address the issues but do not contain more conservatism or complexity than is necessary. Also, the Criteria Document does not address the relationships and
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responsibilities of the different organizations for the activities it describes. A flow chart or (7
b' logie diagram to define the interfaces would aid in understanding how the various organizations are supposed to function.
" The SEP issues should be added as a specific item to the Criteria Document to ensure that they are considered in the appropriate reviews and evaluations.
A6 Criteria Document sources are not clear enough to directly trace to licensing submittals.
The criteria appear to be at times hybrids of various NRC SRP's and originallicensing commitments. It appears that engineeringjudgement has been applied in defining some of the criteria. It is not clear what the basis was for some of these adjustments and how they ,
now relate to the originallicensing bases. A reference to the originallicensing bases and an explanation of the intent of the new criteria would help to ensure proper application.
4 B1 HELB program implementation is being done differently at each unit. Program management appears to be defined by project engineer for each unit.
J Individual Project Authorizations (PA) were written for each unit. These were developed by ;
the responsible project engineer to start the project and lacked commonality in the scoping of the program for each of the three units.
1 Each unit has a separate mini-review that addresses the LER concerns for HELB. This !
resulted in the reduction of commonality in approaches to defining the problems and j necessary resolutions.
A " Strategic Plan" was developed for all three units in November 1991, one year after the project had started. The plan is not detailed enough to adequately control the three separate projects as they are now being managed. Also the plan does not establish commonality of the projects or satisfy the need of a management tool to focus on the HELB l issues that need to be addressed in the program. Each unit's program contains different 4
l processes to address the same HELB issues, such as postulating break locations, assuring '
safe shutdown methods are available, and resolving identified discrepancies or deficiencies.
B2 The HELB program focus of the participating organizations (OPS, PRA, PLT SYS, Safety Analysis and Ebasco) varies widely and presents a built in conflict of agendas for HELB efforts. The Criteria Document does not constrain disparate organizations to perform in a common manner.
No criteria for defining EEQ data development methods is provided as part of the HELB issues program. Methods for calculating the break discharge rates for determining building pressure / temperature profiles are not clearly defined and conflicting opinions regarding this issue exist. There appears to be no project procedure or direction as to how to resolve this issue.
The current method for addressing discrepancies is causing budget overruns and delays.
There appears to be no ownership of the discrepancies uncovered on the projects, and each group appears to be trying to resolve the discrepancies using their own agenda. A i programmatic approach to the resolution of discrepancies is needed. t
- No definition of the process interfaces between the participating organizations appears to be in place. Communication between the organizations is dependent on the personalities of the p individuals involved. l
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B3 Development of HELB program treated as a series of sequential actions but would benefit
- substantially from a " Concurrent Engineering" approach.
1 It appears that not all of the organizations were involved from the beginning of the project l
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or are involved in all the processes throughout the project. Involvement throughout would !
ensure that the needs of the groups in the later processes are being addressed as their input !
processes are being developed. Defining the needs of the various groups and understanding !
- what the other organizations do with the output of the processes would help the efficiency of l the project and aid in the necessary communication between the organizations.
B4 Many of the evaluations performed in HELB rely upon "engineeringjudgement" and are
- unsupported by on-going processes to supply up-to-date as-built data. Although there is a CM program, there is not a mature CM process to support the HELB program.
Many of the processes use "engineerin controlled data from the CM program.gjudgement"instead of using the appropriate It appears that the processes rely on the engineer to i def~me the right information instead ofidentifying the controlled source documents which have been verified and kept up-to-date. This problem is caused by a lack of available CM sources.
C1 HELB program supervision does not actively measure results of activity to assure compliance with guidance and/or common actions for each unit.
No formal performance tracking system is in place on all three projects. There is no formal reporting process for the completion of the work. Lack of performance measurement leads to crisis management for completion of work. This is causing frustration on the working level with expressions of not knowing how to get help. Not having performance tracking
('] appears to be causing a lack ofincentive to perform to meet schedule and budget commitments.
i C2 The Configuration Management program does not act as a control or guide to the HELB program.
CM is not taking an active role in defining the format of output documents so that they conform to the CM program standards. New data bases should be in a format to be integrated into the CM system and to have commonality between the three HELB projects.
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i ISSUES RESOLUTION OVERVIEW '
-O A. Information Related Issues l
Issue 1. HELB Licensing Basis not yet defined. l n Resolution 1. Establish project task to develop the licensing basis from the existing submittals, including corporate concurrence and NRC approval.
i Issue 2. Criteria Document does not match the license submittals.
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, Resolution 2. Revise the specifications to Criteria Document vendor to require that the l boilerplate criteria be changed to match submittals. j Issue 3. Basis for Criteria Document is unclear.
1 Resolution 3. Revise specifications for Criteria Document so that vendor is required to supply a j l source traceability for each criteria in document. i i
Issue 4. Output of HELB required by CM is undefined.
} Resolution 4. Establish a project to define the CM information requirements across the wide spectrum of CM related data required for each unit. '
i Issue 5. Criteria developed for Criteria Document are not specific enough to be useful. ;
Resolution 5.' Develop detailed standards and methods to document HELB procedures so as to i
maintam consistency of the HELB program and the Configuration Management i program. !
Issue 6. The Criteria Document does not provide traceability to the source for specific
] criteria, only general criteria sources are quoted.
, Resolution 6. Modify document specification to require traceability of specific criteria to source.
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B. OrganizationalIssues Issue 1. Process defined by Project Engineers for each unit.
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Resolution 1. Establish management of program at a corporate level to provide a common l program framework for allunits.
l Issue 2. Conflicting agendas among participating organizations.
5 I l Resolution 2. Establish CM p,olicy at the program level and require various organizations to use l the program guidance.
l Issue 3. Program organized as a sequential steps process.
Resolution 3. Adopt a " Concurrent Engmeering" team approach to HELB solutions development.
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Inue 4. CM processes are not focused to support HELB.
i Resolution 4. Transfer project responsibility from line engiacering to become a CM project.
! C. Management Related Issues l
- i i Issue 1. Program lacks "Results Measurement" processes. !
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4 Resolution L Develop a definitive projed plan with milestone results matrix reportable to a l
- 1. project manager in the CM organization. ;
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t l Resolution 2. The HELB program should be viewed as a project with significant ties to the management of the plant configuration. Therefore, the project management of the
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CRITICAL SUCCESS STRATEGIES I. Management and Organization Strategies We suggest that HELB be elevated to a stafflevel project from its current assignment within a functional organization. The current functional management arrangement lacks the power and authority across disciplines needed to efficiently and effectively manage a large multi-discipline project. He current functional mar.ager has too many other responsibilities and is involved with too many other functional activities. He functional manager's lack of power and authority also results in a slow decision process related to the project.
We suggest that the project organization be restructured to facilitate " Concurrent Engineering" l methods. Expand the project team to assign responsibility for the project success to ,
representatives from all disciplines involved. Involving all disciplines m the development of the project plan will help promote ownership of and buy-in to the plan. Concurrent Engineering methods also provide a forum for project managed decision making and reduce the tendencies for diverse agendas across disciplines. Concurrent Engineering will also help establish and maintain consistency and commonality across units.
We believe the planning, scheduling, and tracking of the project should be enhanced. Periodic reporting of status and evaluation of the project plan should be performed to determine if I corrective action is needed. Having a detailed plan helps everyone to understand what is needed,
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when it is needed, who is responsible for providing it, and how much it should cost. The plan will '
also provide a baseline to determine what charges to make if corrective action is needed and to I evaluate the impact of deviations. A good, current project plan provides management with the information they need to understand and support a project.
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/] To be successful the HELB project must have very detailed definitiors of the deliverables controlled by the needs of the CM program. The CM program must be supported by HELB programs and processes. Determination of what " tools" must be developed, and if related " tools" should be included in the HELB program, should be based on CM plans. For example, the barriers program, that has been requested by the plant, may be a data base and drawing set best developed as part of HELB. The walkdown necessary to confirm the barriers may be handled separately, since the inspection criteria is quite different than the break interaction inspection.
However, the barrier technical requirements may be most efficiently developed by the HELB team.
II. Licensing Documentation Strategies In concert with the Performance Enhancement Program action plan for CM to reconstruct and maintain the design basis, we suggest that a design basis document be developed for HELB. Also, I a very detailed (working level) Criteria Document should be developed. Both documents would be living documents to guide and support the HELB solution process, then become living documents for the HELB design control process. By having NU management approval and NRC review, many of the delays and uncertainties of HELB will be eliminated.
We reviewed the Ebasco criteria for MP-1 and severallicensing basis evaluations and found that the criteria does not match the licensing basis. No basis is provided to support the criteria which incorporates some current methods laced with methods of the licensing basis. (e.g., no arbitrary intermediate breaks and a stress threshold from Giambusso). Some requirements are included that are not part of the licensing basis (e.g., moderate energy cracks). We suggest that the unnecessary conservatism be removed and the criteria be supported by an explanation of the basis for each element.
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! ^ Additional detailis needed to direct the HELB analysis process. Details covering how EEQ pressure and temperature profiles will be developed, how mass and energy releases will be calculated, and methods for evaluating shutdown should be included.
By developing a detailed criteria, everyone involved will understand what is required, thus reducing potential for rework due to errors and reducing the tendency to over-engineer the problem.
III. Event Resolution Strategies l
Nuclear Event Resolution Process (NERP) should be integrated into the HELB program so that l people knowledgeable in HELB requirements are evaluating the condition and developing the solution approach. A process for handling discrepancies as part of the HELB program is essential to orderly, efficient completion of the program.
Currently problems are handled outside the HELB program. They still cause disruption of the {
HELB work process and delays. The EEQ group spends 60% to 70% of their resources to address discrepancies.
! NERP should be based on a generic JCO. The mini-review provides a basis for such a JCO. We believe soine activities have used this approach for addressing discrepancies identified during the l development of DBD's. It may be necessary to report the discrepancies to the NRC and commit to a time for resolution or fix.
NERP will provide an orderly method for addressing discrepancies using knowledgeable people as part of the HELB plan, thus eliminating crisis management situations.
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, HELB PROGRAM ASSESSMENTINTERVIEW PARTICIPANTS C' Jack Barnett -
Engineer, NUSCO - Probabilistic Risk Assessment Dave Coleman -
Senior Engineer, NUSCO - Stress Analysis (MP1 HELB Project Engineer)
John Chunis -
Configuration Management Program Manager Eric DeBarba -
Vice President, NUSCO - Nuclear, Engineering Services Division Don Dube -
Supervisor, NUSCO - Probabilistic Risk Assessment Sima Frolov -
Senior Engineer, NUSCO - Stress Analysis (MP2 hELB Project Engineer)
Don Gerber -
Supervisor, NUSCO - Project Services Department Clint Gladding -
Manager, CYAF O Engineering Department Bob Harris -
Director, NUSCO - Engineering Department NirmalJain -
Senior Engineer, NUSCO - Safety Analysis Rick Kacich -
Director, Nuclear Licensing Department Mike Kai -
Supervisor, NUSCO - Safety Analysis (O
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Matt Kupinski -
Manager, NUSCO - Mechanical and Civil Engineering Branch l
Tom Mawson -
Supervisor, NUSCO - Stress Analysis Peter Miner -
Senior Scientist, Nuclear Licensing Department ;
Bill Noll -
Senior Engineer, Millstone 1 Engineering !
Department Mark Powers -
Senior Engineer, NUSCO - Engineering Mechanics Keith Sickles -
Senior Engineer, NUSCO - Stress Analysis (CY HELB Project Engineer)
Tom Starr -
Senior Engineer, NUSCO - Project Services l Department Bruce Tuthill -
Supervisor, NUSCO - EEQ Program Gerry Van Noordennen -
Supervisor, Nuclear Licensing Department Joe Evola -
Senior Engineer, Nuclear Safety Engineering i
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-_.___.__3 Docket No. 50-336 B16358 l
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1 Attachment 1 )
Enclosure 3
. -l Millstone Nuclear Power Station, Unit No. 2 l NUSCO MOV Program l
i March 1997 1