ML20128L902

NRC Insp Manual Chapter 2535, Design Verification Program

ML20128L902
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Issue date:	03/24/1989
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PROC-890324, NUDOCS 9610150230
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NRC INSPECTION MANUAL RSm CHAPTER 2E25 i i

DESIGN VERIFICATION PROGRAMS 2535-01 PURPOSE i

To describe the techniques to be used in the performance of the Independent i Design Verification Program (IDVP), the Engineering Assurance Procram (EAP), j and the design review aspects of the Readiness Review Program (RRP) for cu- l clear power plants as well as the NRC oversight and essessment of these programs.

2535-02 OBJECTIVE The objective of the IDVP, the EAP, and the design review aspects of the 4 Readiness Peview Program is to gain additional assurance that the design 1 process used for the facility effectively implemented NRC regulations and other licensing design commitments made by the applicant. In the programs, the Applicant centracts with an independent desigr organization to perform the review or perforcs the review with in-house but "off project" personnel.

The fiRC staff overviews the review for adequacy. The objective of this Man-ual Chapter is to provice cuidance on the NRC oversight and assessment of these programs. These are multidisciplinary technical reviews to verify the cuality of design products and, inferentially, the entire f acility design.

2535-03 DEFINIT 10fiS fpplicant or Licensee. Entity that has filed ar application f or a construc-tion permit or an operating license.

Readiness Review Progran (RRP). Formal essessment submitted incrementally by

'tlle applicant and evaluated by the f'PC staff that determines that reculatory design, construction, and operation requirenents and licensee comaitments an being implemented and that the nuclear power plant will be recdy to operett sofely.

Readiness Review fiodules (PRM). Basic units of the work breakdown structure into which the total task of constructing a nuclear plant is divided and sub-uitted by the licensee to f!FC for review, comment and/or approval as early ir the licensing process as possible. A Lesign Review t'cdule is initiated tc review the design prrcess for constructing e nuclear power plant.

9610150230 961009 '

PDR ADOCK 05000245 H PDR Issue Date: 03/24/Ei

Independent Design Verification Prroram (IDVP). Multidisciplinary desigr reviews of nuclear power plants similar tc that perfcrmed by the NRC staff in the IDI Program. The principal cifference from the IDI program is that the i

applicant hires an independent cor. tractor to perform the IDVP and the NP.C 4

i staff evaluates the program rather than performing a direct iRC inspection.

i Engineering Assurant.e Program (EAP). Continuing series of technical audits l

of the design product and design process ccnducted by persons independent of i tbc project who are intended to assess the quality of the overall facility j design. The reviewers may be from the original design organization se long 4

as they'e applicantare independent of the original design This,process. and the fact th6t th is in day-to-day control of the audit process, are the l primary differences between an EAP and an IDVP.

i Design Reviewer. Individual (s) and organization (s) who perforn the IDVP, I IlP and RRP design reviews for the applicant. '

NRC Action Item. A matter identified by the NRC review tean relevant to the reviewer's program plan, implementation of that program, or the design reviewer 's audit observation reports and/or associated corrective actions.

Design reviewer response and NRC evaluation of response are required.

Audit Observation Report (A0R). A report which reports an apparent error, inconsistency, or procedural violation with regard to licensing commitments,  !

specifications, procedures, codes, or regulations and which is idtntified by the design reviewer.

i Potential Enforcement Finding (PEF). An applicant's apparent noncompliance with specific regulatory recuirements or specific licensing commitments that is identified during the review.

2535-04 RESPONSIBILITIES ANP AUTH0P.ITIES 04.01 Design Review Aspects of the Peadiness Peview Program

• 1

a. Program Manager (designated by the EDO). Assigns module review activities and coordinates related efforts, reviews report of the l results of NRC evaluatien of design aspects of Peadiness Review l Podules and incorporates evaluation of design aspects into the module review report. '

b. Director, Division of Reacter Inspection and Safeguards (DRIS), NRR.

Administers the design review aspects of a readiness review program, including forwarding reports of NRC evaluations of design aspects of readiness review modules to the Program Manager,

c. Chief, Special Inspection Branch (RSIP.). NRR. Implements the design review aspects of a readiness review program as Primary Peviewer and as such:

Performs prinary review activities for design and design process verification sections of the module.

Designates NRC staff and contractors to review the design review sections of the module.

Issue Date: 03/24/89 -F- F535

a Ccordinates the work of the review effort prescr ibed hereir with past or ongoing design verification reviews at the same plant to avoid unwarranted duplication.

Prepares reports of f1RC evaluations of design aspects of Retdiness Peview liocules.

f4.02 Independent Des'en Verification Prograrn and the Engineering Assurance Program

u. Director. Divisior, cf Reactor Inspection and Safety, fiRP. Approves applicants' propcsals to participate in IDVPs or EAPs for . specific facilities on the basis of t!RC staff evaluations of the proposals ar.d information received from fiRC offices at headquarters and in the regions. Administers llRC staff review of the IDVP and EAP and issues the results of inspections either dircctly or through the Director of the appropriate Division of Reactor Projects, Office of f!uclear Peactor Regulation and issues the design verification inputs to SERs.

b. Director of Appropriatt Civision of Reactor Projects,llRR. Issues to the applicant fiRC inspection reports of IDVPs and EAPs. Incorporates IDVP and EAP inputs into the relevant SER.

c. Chief. RSIB, flRR. Implements i;RC staff reviw of the IDVPs and EAPs, including preparation of inspection reports and preparation of design verification inputs to SERs.

d. Regional Offices. Assist the NRR staff as needed, in manager.ent of Tollowup actions resulting fron the IDVPs and EAPs, including enforcement action.

1

?E35-05 BACKGROUtlD The ahcVe applicant-initiated design reviews addressed in this charter and the Integrated Cesign Inspections (IDIs, see chapter 2530) conducted by the NRC staff were inititted following the mirror image design error at the Diablo Canyon project. It was determined that some licensee quality assur-ance programs anc hRC inspections had not been effective in discovering design errors because the quality assurance (QA) audits looked only at the process anc not at technical content. To ensure that near-term operatino licensee (llTOL) plants did not have undiscovered problems in their designs, a series of short-tern actions were initiated. Each hTOL was requested to provide additicr. assurance that their f acility design complied with hRC regulatory recuirerrents and TSAR commitments through the conduct of a tech-nical review of the desicr. To add greater credibility to these reviews, f!PC requested that they te perforned ty organirations totally independent of the applicant and its design contractors. These prograus became known as IDVP's.

IIRC clic began to perform a liriited number of oirect inspections cf the tech-nical adequacy of designr, through its IDIs(Ref: f4anual Chapter 2530). The IDVP's were a necessary addition to compensate for the lack of technical audits of design products ir, cpplicant QA programs. For plants not yet in the last stages of the licensing process, sufficiert time remained te include technical audits cf design prcducts ir applicant QA programs. These took the form of Engineerinc Assurance Programs or the design review module portion of  ;

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2535 '- Issue Date: 03/?4/8o l

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Readir.ess Review Programs. Applicants could choose to perforn these reviews with in-house personnel, provided that the reviewers were not placed in the i position of reviewing their own work. These reviews must be independent of the project cost and schedule considerations, wnich is the same requi remer,t that has always been applied to regular applicants' QA organizations. Appli-cants are free to contract with independent organizations for their design reviews but are not required to do so. This Chapter, then, describes the 4 techniques applicants may use to perform technical audits of their facility design as part of their overall program to assure quality.

2535-06 CONCEPT OF READINESS REVIEW, INDEPENDENT DESIGN VERIFICATION AND ENGINEERING ASSURANCE FR0GRANS 06.01 Design Review Aspects The performance of these programs at nuclear facilities are comprehensive examinations of the development and implementation of the design for selected systems of the facility being inspected. Conclusions about the overall design process may then be drawn based on the results of the design review for the sample selected. The programs are multidisciplinary reviews inclu-3 ding, as a ninimum, areas such as mechanical systems, mechanical components, electric power, civil and structural design, and instrumentation and control.

4 The primary focus is on assessment of the implemented design control process for the organization and subcontractor. The process is evaluated by examin-ing actual design details. If errors are found in the design details, the design process is evaluated to see if the error resulted from an isolated raistake or if it reflects e more fundarental weakness in the design process.

Also the pervasiveness of a design error or weakness is evaluated including inspecting that aspect of design in other sectors of the plant design. An evaluation is performed to identify consistent design process weaknesses in the design process such as lack of FSAR control lack of verification of design calculations cr lack of documentatier of engineering judgment made in the design process.

a.

A comprehensive review is performed for a specified sample system (s) that typi cally has some er all of tne following characteristics:

1. essential to plant safety

, 2. designed mostly by the architect-engineer (AE)

3. a clearly defined design basis

4. generally representative of safety-related features in other

sy stems i

5. design involving internal interfaces between the major technical discipline arcas listeo above and external interfaces with the

' nuclear steam supply sy stem (NSSS) vendor, component ver. dors, and engineering service organizations f.

for IDVP ano EAP, major portions cf the selected systen(s) already installed in the facility.

Issue Date: 03/24/89 e. - 2535

. - . . - - - -. _ = , -_- -. -_ - . . -

l b. Some evaluaticn will be conducted beyond the sample system (s), as needed, to test specific areas or functions.

I c. An evaluation should be made of any program weaknesses identified by preceding audits of the same facility that could have root causes in j the design or the design process.

d. The review covers topics such as

1. validity of design inputs and assumptions

2. validity of and conformance to design specifications

3. velidity of analyses

4. system interface requirements l

5. inadvertent synergistic effects of changes

6. proper component classification

7. revision control

8. documentation control

9. verification of the design and design changes

10. verification of the as-built condition 2535-07 PROGRAM GUIDAriCE 07.01 Program Scope and Schedule. The f!RC staff review of a program should be a multidisciplinary euluation of the total design process and should focus primarily on the potentici creas of concern within each of the disci-I plines. The NRC staff responsibilities include:

a. Review and approval of the applicant's IDVP, EAP, RRM program plans.*

! b. Inspection of the independent reviewer's procedures and preparations for the IDVP, EAP, or RRii.

c. Inspection of the design reviewer's implementation of the program plan approved by the NRC.

d. Inspection of audit results (cbservation reports) and the corrective I actions taken or proposed,

e. Submittal of a SER input based on the NRC assesscent of the IDVP and l EAP results.

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f. Sut,mi t report of f.RC evolut.tions of design aspects of RRf1 to the FRP Program.

• 1DVP, EAP, and/or RRif program plans will be called the design review (DR) medule program plan.

l 2535 Issue Date: 03/N/89 1 _

i A typical IDVP, EEP, or RRli schedule is as follows:

flRC Staff Activity Time Allocation

)

1. Evaluate Design Review Proposed i

' 4 weeks Program Plan and necessary revisions

2. NRC approves program plan 2 weeks

3. Inspect reviewer's procedures and preparation 2 days

. f or the DR (2-4 weeks af ter program approval) in each major technical discipline

! 4 Inspect implementation of the design 2 weeks review when sufficient work has been completed to enable a meaningful preliminery assessment and prepare report

5. Inspect independent reviewer's audit 2 weeks results including justification for audit observation reports and prepare report l 6 Inspect corrective actions taken or proposed 2 weeks to correct design process and/or design adequacy deficiencies l

7. a. Prepare and submit SER input based on NRC 4 weeks staff assessment of the ICVP or EAP results l b. Prepare and submit evaluation of design i

aspects of RRii submitted by applicant

8. Identify PEFs to region for followup Concurrent with activity 7 above 1

07.02 Inspector Assignments. NRC staff and consultant assignments to a DR program inspection shall be based on the expertise needed to implement the scope of the inspection (s) planned. The NRC inspectors including consultants should have an appropriate degree of "on the board" nuclear power reactor I

design experience in the technical discipline for which they ,re a responsible in the NRC review. All consultants and their employers on the NRC review team will be required to sign the " Agreement" and "Information Concerning Potential Provision should Conflictbeof made, Interest" whereforms possible, enclosed as Appendix for continuity of inspector B to(sthisinchap)ter.

each technical discipline from inspection of initial program preparation through evaluation of audit observation reports and corrective actions.

07.03 NRC Program Oversight Planning, Preparation and Irplementation

a. The objectives of the NRC review planning, preparation, and implementation are:

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Issue Date: 03/Pa/89 2535

- - . - - _ _ ~ _ . _-- - . - - .-- . . . . . . . . - - . - . _- _.

1. Readiness Review - Design Review Objectives (a) Verify that the applicant's design program verification activities are accurately described in the readiness review module.

(b) Assure that the applicant's readiness review verification activities are sufficient to provide a competent verifica-tion of the program for all design aspects included in the module subject.

(c) Determine the completeness, accuracy, and responsiveness nf the findings and the open items reported in the module for design and design process verification.

2. IDVP and EAp Review Objectives (a) Ensure that the program plan submitted by the applicant has sufficient scope and depth to eneble the reviewer to:

(1) Verify that regulatory requirenents and design bases as specified in the license application, are correctly implemented in specifications, drawings, calculations, and procedures.

(2) Verify that the correct design information has been provided to the responsible design organizations.

(3) Verify that design engineers have sufficient technical i

guidance and experience to perform assigned engineer-ing functions. <

(4) Verify that design controls, as applied to the orig-inal design, have also beer applied tc design changes, including field changes.

(b) Verify that the procedures and review plans developed by the design reviewer have sufficient scope and depth to enable the design reviewer to implement the program plan as approved by the NRC staff.

(c) Verify, during the course of the program, that the program is being implemented in accordance with the program plan approved by fiRC.

(d) Ensure the results of the progran, including all audit observations made by the design reviewer, open itens established by either the reviewer or the fiRC staff and resultant follow-up of the applicant's corrective actions.

3. To familiarize the fiRC staff and consultant reviewers with the design review organization chosen by the applicant and their principal technical auditors in each of the major disciplines.

The !!RC inspectors should evaluate the cualifications of the applicant's design reviewers. The evaluation should include interviews as well as review of incividual resunes and certifi-cations.

2535 Issue Date: 03/?4/89

4 To - review the individual review plans of the design reviewers The level of detail required in these review plans should be in balance with the experience level of the design reviewers. In other words, the more experienceo design reviewers should need less detailed review plans to perform their audits. The review plans should be technical discipline specific and should show t the technical depth and scope of the independent design organi- '

zation's audit of the following key design elements: j (a) FSAR compliance l l (b) NSSS criteria compliance l (c) calculations l (d) drawings l (e) diagrams and schematics l (f) specifications g equipment qualification h vendor documents (i) design change control (including field changes)

(j) hazards analyses (pipe whip, jet impingement and ficoding)

(k) use of problem reports (LERs. IE Bulletins)

(1) interfacing between technical disciplines l (m) interfacing between design organizations (applicant AE, AE consultants and subcontractors, vendors)

5. To make specific technical discipline assigr,ments to inspection team members.

6. To define review and inspection schedules.

l To familiarize the NRC inspection team members with the latest l 7. i version of the documentation that defines the design (such as the FSAR, design procedures, specifications, design criteria, and drawings).

8. To indoctrinate the NRC inspection tean members to IDVP, EAP and RRt1 concepts.

b. Before the start of each inspection, the team leader should address plans for the inspection, background and guidance material, significant items pertinent to licensing, and cesign-related items identified by the regional offices and the NRR. A design work inspection cutoff date should be established for the inspection and l it should be the same date as the approval date of the sample system (s) to be audited. The inspection work product expected from each inspector needed for the inspection report should be delineated to enable the inspector to organize his individual inspection plan.

c. The NRC inspection team members should use the following materials in evaluating the formulation, implementation and results of the IDVp. 4 EAp or RRM.

1. Applicant's program plan

2. Final Safety Analysis Report (FSAR)

3. Probabilistic Risk Assessment (pRA ) Report (where availeble)

Issue Date: 03/24/89 2535

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4. NRC Safety Evaluation Report (SER) l

5. Inspection history including:

(a) Previous major NRC inspection 9 .esign or construction, obtaining information on any ; % 1 ems requiring further investigation during the program (s).

(b) Special NRC audits and reviews in design and engineering.

i (c) Vendor Program Branch and regional audits of AE, NSSS, and vendors involved in design and engineering.

(d) Systematic Assessment of Licensee Performance (SAlP) re-j ports.

(e) Institute of Nuclear Power Operations i;NPO) evaluations of

design or engineering. '

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! (f) Inspection reports of site design activities including i those of the resident inspector.

(g) Major utility audits in design or construction.

i j, 6. 10 CFR 21 and 50.55(e) reports  ;

7. NRC/ applicant correspondence (questions and answers, principal meetings or special studies, and licensee or AE correspondence listing principal commitments and action items in response to NRC concerns ,

8. Construction status information (stage of completion will dic-tate the scope and types of inspections and evaluations appro-priate for a particular discipline)

d. Additional guidelines to be considered in the NRC inspection team members implementation of their oversight responsibilities generally and for each technical discipline are provided in Appendix A to this chapter.

07.04 NRC Review and Oversight Documentation All NRC inspection team members should remain with the team for the duration of the NRC review of :n IDVP, EAP or a RRM. Team members will conduct th; review with accompanying inspections in accordance with the prngram guidance provided herein. The NRC team members should evaluate the interface maintain- ,

ed between the independent design review organization and the applicant's architect / engineer's project design organization. The NRC . team members should ensure that adequate independence is maintained by the review organi-zation auditors in relationship with the applicant's/ architect engineer's project design organization. The provisions of this independence should be stated in the applicant's progran plan. The NRC team leader will conduct coordination meetings of all team members, as needed, to discuss status of activities and NRC actions items. As a result of such meetings, team members may be given additional assignments or their effort may be redirected.

2535 Issue Date: 03/24/89

i Documents pertinent to the NRC review that are provided to team members, although riot marked proprietary, may contain proprietary information. I r.

similar manner, documents such as specifications that are reviewed in the  ;

licensee's and/or independent reviewer's offices may contain proprietary in- 1 fcreation. All such material handicd curing the f:RC review will be treated as potentially proprietary. Team members will not make further copies or disclosure of documents received during the review /or inspections. All such documentation will be returned to the licensee when the review /or inspection is completed unless otherwise indicated by the licensee.

1 07.05 Entrance and Exit Interviews An entrance interview between licensee and reviewer management and all NRC I inspection tean membert shall be held before starting any orsite inspection.

The regional office shi11 be invited to be represented at this meeting. IP 30703, " Management Meeting Entrance and Exit Interviews," should be used as i guidance when conducting the entrance interview. 1 1

An exit interview shall be held between senior licensee and reviewer manage- l ment and senior f:RR managenent and inspection team. The regional office shall be invited to be represented at this meeting. The exit interview will be used to summarize the findings and to convey the significence thereof to l senior licensee and reviewer management. All NRC action items will be orally l communicated by the team leader to the appropriate licensee or reviewer contacts during the course of the inspection. The results of the inspection shall be discussed, but no written drafts of inspection findings shall be i given to the licensee.

07.06 Inspection 00cumentaticn l

The team will prepare an inspection report to be issued by the Director,  :

DRIS, that documents all NRC action itens identified during the inspection. '

The inspection report will conform to the requirements of NRC Manual Chapter 0610, " Inspection Reports." A typical format for a design verification in-spection report is provided in Appendix C, Part A of this mar.ual chapter.

No disclosure of inspection notes (preliminary or draf t inspection report materials developed by llRC team members) will be made, except to appropriate NRC staff (see below).

In accordance with NRR Cffice Letter No. 106 of December 7, 1987 and Rev. 3 .

of June 20, 1988, " Release of NRC Draft or Predecisional Docdments and Infor- l mation," from T. Murley and !!RC Bulletin No. 3203-25 of February 9.1988,

" Policy en Release of Draft and Predecisional Documents and Information,"

u r.de r no circumstances sFould draft inspection reports, either in their entirety or in part, be released to licensees or their agents or to any source outside the NRC without 'he express permission of the Director, NRR.

In the event any draft inspection ort is A dvertently or otherwise released contrary to this policy, we Director, NRR shall be promptly advised in writing. The Director, NRR will take or recommend action, as appropriate, including prompt notification to the ECO.

07.07 Inspection of Design Review Audit pesults and Associated Corrective Actions At the conclusion of an EAP, or RRM audit, the NRC staff will irspect the reviewer's audit results anc: associated corrective actions proposed or taken Issue Date: 03/24/89 2535

i

by the applicant and/or its contractors. The specific objectives of this inspection are to

)

4

a. Assess the design reviewer's audit obse-vation reports and ensure l they are adequately justified.

) b. Ensure the resolution of the audit observations are adequate.

c. Ensure proposed or initiated corrective actions are adequate.

d.

Verify that NRC guidance provided to the reviewer on program scope

and . implementation was incorporated into the program or otherwise satisfactorily resolved. The report of this inspection should i discuss the resolution of the items identified in the previous NRC 4

inspections of the program.

! e. Evaluate the program results in order to determine whether the i

program has provided adequate additional confidence that the design

, of the facility under review is in accordance with the FSAR, NRC regulations, and other applicant commitments.

l l 07.08 Inputs to a Safety Evaluation Report. For NT0L facilities, a SER j design verification input based on IDVP and EAP results is prepared by the i

NRC review team to be 4 nsmitted by the Director, DRIS to the Director of the appropriate Divisico of Reactor Projects as an input to part of a SER f Section 17.0 QUALITY ASSURANCE and Section 17.5 INDEPENDENT DESIGN VERIFI-l CATION. The major objective of this SER input is to provide a conclusion as

to whether the IDVP, or EAP has provided adequate additional confidence that the design of the facility under review is in accordance with the FSAR, NRC

! regulations and other applicant commitments. The format of a typical Design Verification Program input to a SER is provided in the SER input based on the 1 EAP of Milestone Unit 3, Ref. NRC letter dated November,1936. The major j sections of the SER are shown in Appendix C, Part B. 1 07.09 Input to Systematic Assessment of Licensee Performance (SALP). In accordance with the NRC 5 ALP program (NRC lianual Chapter 0516), the Team Leader is responsible for submitting SALP input to regional management.

This should be provided, as needed, or within 60 days of completion of the SER input to the appropriate region in the case of IDVP and EAP programs.

07.10 followup and Enforcement. The focus of the IDVP, EAP and RRM is the evaluation of the design process and the adequacy of the plant design, rather than enforcement. However, the appropriate Regional Branch Chief will be notified by the chief, RSIB of the potential enforcement findings (PEFs) ,

found during the course of any of these programs for regional followup. The ,

notification of PEFs to the region will include a preliminary determination I of an appropriate enforcement classification for each PEF. The NRC team  !

leader is responsible for ensuring that regional tracking numbers are l assigned to each PEF and other items stemmir.g from the program that require regional followup. During any program, situations may be encountered where the significance of a matter warrants consideration of prompt action (e.g.,

licensee stop work, NRR order, investigatien of wrongdoing). If so, management in NRR and the appropriate regional office will be promptly I

P535 Issue Date: 03/24/89

inforned and the first priority will be pursuing the matter until the question of prompt action has been resolved. In addition the NRC team e

leader will identify those audit observations which are appropriate for Vendor Program or regional programs followup.

END Appendices:

A. Additional Guidance for NRC Oversight Planning and Implementation.

B. Proprietary Agreement and Conflict of Interest Forms.

C. Typical Formats for Design Verification Program Inspection Reports and SER Inputs.

1

/

Issue Date: 03/24/89 253E

APPENDIX A l ADDITIONAL GUIDANCE FOR NRC WERSIGHT PLANT!!f;G AND IMPLEMENTATION A. PURPOSE To provide additional guidance for the NRC staff oversight planning and implementation to ensure an adequate design review.

B. GENERAL GUIDELINES These guidelines relate to Manual Chapter 2535 Section 06.03 covering the design verification program plan and the design reviewer's individual review plans.

1. Project Design Procedures Review Within each design discipline, ensure that the audit will review the project-specific specifications, instructions, and procedures that provide design criteria or guidance to design engineers.

The purpose of this review is to determine the extent of the formal guidance given to the engineers for performing design activities. The inspector should use the information from the review to highlight areas of limited or inadequate guidance to the engineers and for determining areas in which to focus the technical review.

2. Design Calculation Reviews Ensure that the independent review of engineering calculations and design details for each technical discipline:

a. Verify that design information is current and correct. This verification may require tracing back to the source of the input. Internal and external interfaces should be verified to ensure that all disciplines and design organizations for a project use a consistent and up-to-date set of design inputs and assumptions, e.g., where the output of one analysis becomes the input of a second analysis,

b. Verify shat the guidance provided by the project-specific procedures has been met.

c. Verify that assumptions used in the design calculations are based on sound engineering principles and practices.

d. Verify that the output information has been transmitted to the appropriate design organizations.

Appendix A, 2535 Al-1 Issue Date: 03/24/89

r -

e.

j Verify that the design information has been translated into project documents such as specifications, drawings, pro-cedures, instructions, and contracts construction. related to plant 3 f.

. Verify that design changes (including field changes) result in all affected elements of the design being evaluated; e.g., reanalysis may need to be performed commensurate with the original design.

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' Confirm that design verification (design review, alternate independent calculations, or qualification testing) is beino done. The extent of design verification is commensurate with the importance to safety, complexity, degree of standardization, s ta te-of-the-a r t , and similarity j proven designs. with i

l I

h. Confirm that calculational methods, using both hand j

' calculations controlled.

and computer programs, are being properly This confirmation includes computer program 4 verification and qualification (assuring that the computer program functions correctly in all modes and options and is used correctly in representing a physical process) and the j proper use and accuracy of inputs. Particular attention l

] should be given to the basis and validity of assumptions l

', identifying and assessing undocumented calculations or decisions, and confirming that as-built conditions are reflected in design analyses.

J

} C. i SPECIFIC TECHNICAL DISCIPLINE GUIDELINES 1

The NRC review should cover areas such as those described below. These  !

guidelines will vary for each plant inspected and as such are not intended '

to be a checklist.

1. Mechanical Systems Design Review Guidelines The overall riesign basis of the mechanical fluid system should be known by the inspection team. Particular attention should be given to the functional and performance requirements imposed on the system for the purpose of assuring reactor safety. To accomplish a review of the mechanical fluid system, it may be necessary to review how the licensee intends to neet the General Design Criteria as well as the system description for the selected fluid system.

a. If the selected fluid system is directly connected to or related in function and behavior to the reactor coolant l system, it will be necessa ry to review the requirements imposed by the. reactor coolant system. The associated perameters could include such items as temperature, pressure, flow rates, chemical characteristics as well as information related to redundancy, accident analyses, physical location and protection from or control of the surrounding environment. This portion of the review is a j i

i Issue Date: 03/E4/89 Al-2 Appendix A, 2535

a good opportunity to evaluate the interface between the NSSS (reactor system designer) and the AE (fluid system 3 designer). Review calculations that confirm that NSSS i requirements are met,

b. Identify a function which is related to the elected mechanical fluid system. Determine whether the design ensures that this function will be met during all plant i conditions. Various system parameters, such as temperature, pressure, flow rates, chemical composition, and action '

times, should be reviewed to verify proper design basis and to evaluate system interfaces. The system flow diagram ano supporting calculations should be reviewed te evaluate whether the design ensures that system functions will be met f under all anticipated conditions.

c. Review calculations which are important to the performance of the system to be inspected, e.g., net positive section head (NPSH) calculations for fluid sy stems , and flow calculations for systems such as auxiliary feedwater where  !

required flow rates are safety-related items,

d. Review the design methods and assumptions used in evaluating the effects of pipe rupture on targets. Interfaces are involved in reviewing the designs of protective structures, pipe whip restraints, break exclusion runs, . environmental effects of pipe rupture on essential electrical equipment and instrumentation, subcompartment pressurization, and inservice inspection of piping within protective structures or guard pipes.

e. Verify that the portions of the system penetrating the )

, containment bc cier are designed with isolation features that are accept:.b e for maintaining containment integrity for all operating and accident conditions. Check interfaces with the instrumentation and control functional area  !

relative to isolation valve actuation and control.  ;

f. Evalurte the classification of the structures related to the selected fluid system for conformance to the requirements for safety-related systems. Evaluate the spectrum of conditions that have been considered in the design of the structures. Evaluate the loading conditions that arise from events such as pipe rupture, loss of coolant accident (L6A), earthquakes, operational transients, reactor trip, loss, of component cooling, etc.

g. Verify the compatibility cf the materials and comparents of the selected fluid system with the prvice conditions, including normal ano accident conditions as well as the design life. Ensure that the fluid system's components have proper sa'cty and code classifications.

2. Mechanical Compcients Design Review Guidelines

a. Select a sar.ple of calculations to be reviewed. It should include the following items:

Appendix A, 2535 Al-3 Issue Date: 03/24/89

1 (1) piping analysis problems (2) major components attached to the piping problem such as a pump or tank (3) valves in the pipe run (4) pipe supports: rigid, snubber, and spring i

b. Review all input information used in the piping analysis.

This will require coordination with other team members to determine that the correct inputs are used. Also, to the extent possible, verify that the correct as-built informa-

• tion has been obtained from the field (see Inspection t i

Procedure 37051).

3 c. Review the model used in the piping analysis. This includes (thermal, deadweight, seismic, review of the analyses 1 performed (etc.), review of the computer programs and the analytical model for conformance with licensee commitments

' and procedures. Particular attention should be given to the model used for seismic analysis for the appropriateness of the boundary conditions assumed at anchors and supports.

, d. Review stress and support load summary sheets for correct load combinations as specified in the licensing commitments. I Also verify that these documents have been transmitted to the appropriate group for support evaluations. l

e. Review component design reports to verify that the basic premises are correct and that data are in conformance with licensee commitments. Review test qualification documents, if applicable, including correctness of the test parameters  !

for conformance with the licensee commitments. This review should verify that the loads from the piping analysis are included in the component evaluation. i

f. Review valve design reports for conformance with licensee  !

l commitments. Particular attention should be given to the operability evaluation for seismic events. Also, valve '

actuator qualification documentation should be reviewed for conformance with licensee commitments.

9 Review the loads used in the evaluation of pipe supports and l verify that these are the correct loads from the piping i analysis. Review the support analysis for conformance with l

licensee commitments and procedures. The load combinations should be checked for the correct specification of primary and secondary loadings.

l l

l Issue Date: 03/24/89 Al-4 Appendix A, 2535

h. Verify that integral attachments have been evaluated for their effects on the piping and that buckling of compression members has been considered. For spring hangers and snubbers, verify that thermal movements have been con-sidered. Review the attacnment to the structure and verify that the loads have been considered by the structural group.

3. Civil and Structural Design Review Guidelines

a. Identify the location of the fluid systems selected.

Include assuciated equipment, such as:

(1) pumps (2) tanks (3) power supplies (4) control systems (5) piping supports (6) heat exchangers There is no attempt in this guidance to evaluate the global behavior of the individual buildings or the foundations.

However, the load path of the structure or structural elements should be reviewed to ensure that the applied loads are properly carried through the structure or structural elements to the supporting points.

b. Verify that structural safety categories are consistent and correct. Consider the location and possible effect of non-safety-related items on the fluids system.

c. Review the safety categories defined in FSAR Section 3 and the classification of structures. Compare the safety .

categories of the mechanical fluid system selected against these criteria for compatibility.

d. Review the model and boundary conditions used in the structural analysis of the design configuration utilizing the output and information from other functional areas such as mechanical, electrical power, instrumentation and control, and systems design to verify the correctness. Also review the output provided from the civil structural area to the other disciplines. Assess the safety impact of these reviews.

e. Verily that all pertinent loads and load combinations are considered in : 'ie analysis of structural elements. in addition to the aiping system. Examine the sensitivity of the structural nalysis and design to changes in piping system loads, supports, and configurations as well as the influence on resulting structural deformations. Emphasis should be placed on the identification of the discipline boundaries and necessary interfaces in the design process.

Ascertain that the correct loads and load combinations have been used and that techniques for combining loads or load elements are correct.

Appendix A, 2535 Al-5 Issue Date: 03/24/89

f. Review samples of the design calculations based on the interncl forces resulting fren the analyses. Ascertain that the design techniques committed to in the FSAR have been or are being met. Also review specific areas of the design calculations.

1 i g. Review examples cf the design documents produced as a result I of the design calculations, such as detailed specifications, l drawings, and procedurcs.

h. Review examples where the basic design documents are used to produce prcduct, components, or elements thet will be integrated into the final structure. This review would include such items as fabrication and shop drawings, produced by a subcontractor, or installation procedures, defined by a supplier.

i. Review and evaluate the process by which design documents are checked and verified and the process by which the final documents are issued for use and construction.

j. Review and evaluate several types of design changes, such as those initiated by:

(1) design office (2) field engineering ,

(3) the licensee l (a) errors or interference in construction (5) errors in engineering

k. Review a r.d evaluate the acceptance process used in the civil / structural area for final acceptance of the structures or elements thereof. As-built information per Inspection Procedure 37051, should be used in this portion of the effort.

1. Review the seismic analysis of one seismic Ca tegory I structure that is associated with the sample system being inspected.

(1) Review seismic inputs, such as the developing of ground response spectra, artificial time-history generation.

(2) Review procedure of seismic modeling, including stiffr,ess, masses, damping values. Verify that the seismic mocel is representative of and consistent with the actual structural configuration.

(3) Peview the techniques dealing with modal comb'. nations, peak broadening, closely spaced modes, etc.

(4) Peview the adequacy of computer programs used for seismic analysis.

Issue Date: 03/E4/89 Al-6 Appendix A, E535 1

1

(5) Review the procedure for soil-structure interaction (SSI), if applicable, to ensure that the adequacy of the procedure and the methodology prescribed is consistent with FSAR commitments. l

4. Electric Power Design Review Guidelines 1

a. Identify all components of the mechanical fluid system selected that require electric power to perform their safety function (s). Determine whether the electric power system supplying power to each of these components will be capable of providing the required electric energy as needed by each component. Examine required voltage, current, and frequency maximums, minimums, and nominal (including transient values) and compare with power source voltage, current and frequency for several sample sets of conditions representative of maximum and minimum loads and expected pe urbations on the power source. Determine if requi ed power quality can be provided for the needed time of interest. A review of diesel-generator load sequencing of the selected mechanical fluid system components (requiring power to perform their safety function) should be performed.

b. Identify all components of the mechanical fluid system that require disconnection from their electric power source in order to perform their safety function. Review the control circuit for at least two such components to determine if it l meets its design requirements. Focus on time allowed for I disconnection f rom power source in the electric power system  ;

design and the corresponding time assumed in safety l analysis,

c. Examine the control relaying for at least two components of the mechanical fluid system that require power to perform their safety function and two that require power discon-nection to perform their safety function. Evaluate the documentation and actual installation of these circuits and <

assess the ability of the circuits to perform as required. l

d. For several samples of each kind of electric component (i.e., motors, valve operators, relayt, connections, cables), determine if the design meets acceptance criteria for performing the required safety function in the presence of the most severe environment specified in the component's uesign basis. Verify that acceptance criteria are consistent with licensee commitments.

e. Examine the physical arrangement of redundant electric power source components, including separation, barriers, and environmental controls, to ensure that single failures affecting such components will not cause the mechanical fluid systen to fail to be able to perform its safety function (s).

f. Examine the qualification documentation cf at least two motors, valve cperators, relays, connections / connectors, and cables to deternine if:

Appendix A, 2535 Al-7 Issue Date: 03/P4/89

(1) The test conditioni specified are consistent with predicted accident conditions at the equipment location.

(2) Required equipment performance is properly specified for the worst accident for which the equipment is required to operate.

(3) Test results show the equipment able to meet specified performance. under the design-basis conditions specified.

g. Compare procurement specifications for equipment examined.in item (f) above to determine if they are consistent with qualification specification for performance and environment.

h. Examine methods and procedures for providing electric power to operate electric equipment when the normal offsite source and the normal onsite eraergency source are unavailable.

Determine if these methods er procedures could compromise redundant power source independence or prevent supply of electric power tu one or more redundant loads.

i. Confiro the power distribution system to safety-related electric loacs has been adequately designed with regard to breaker, motor starter, and cable sizing, as well as breaker coordination. Review several sample calculations in this area.

j. For at least 2 electric loads, determine the basis for interruption of electric power in the case of an electric power demand in excess of the normal rating for the loads.

Deternine what basis was used to decide whether the system was designed to ensure the performance of the safety function or to protect the equipment in cases of overloads.

Review desigr' of electric motor-operated valves provided with torque switches used to cause motor shutdown when excess torque is detected. Determine the validity of basis' for torque switch settings. Review procedures for testing such switches.

k. Examine specifications for several items of electric equip-ment and compare to the expected environment in their designated location to determine if special environmental centrols should have been provided er if a different location should have been selected.-

1. Determine how the need for special environmental controls (e.g., battery room ventilation) on electric equipment was determined. Review design documentation (descriptions, drawings, etc.) to determine how the environment is to be maintained and how operating persernel are made aware of the needs for these special environmental controls.

Issue Date: 03/24/89 Al-8 Appendix A, 2535

4

5. Instrumentation and Control Design Review Guidelines

a. Select two different process measurements, such as flow, level, pressure, temperature, etc., associated with the mechanical fluid system selected and select two associated control (or non-safety measurement) systems. The selected measurements (at least one) should be selected from those that perform a safe ty function, such as reactor trip or actuation of one or more engineered safety features (ESFs).

b. Review all input information used for the design; it will be necessary to interface with the electrical power system design and the mechanical system design. Verify that the design input parameters meet the design requirements for the fluid system design. This should include the ranges of system process parameters required for normal and accident conditions.

c. Review the appropriate functional, wiring, and installation drawings to assure conformance to licensee commitments.

d. Select several field design change requests and verify that the vendor's design verification program is being effec-tively and accurately implemented. The inspector should review: the verification method; the precedure for imple-mentation; the authority for the design change, the associated equipment documentation, such as equipment specification purchase orders, IEEE Standards, Regulatory ,

Guides, " Approved for Construction" drawings, and the j as-built installation drawings that complete the design change cycle; the results of the functional tests af ter the compor' nts and systems have been installed; the documenta-tior assure that the field change had been evaluated for geneioI implications.

e. Review qualification documentation associated with safety-related instruments to determine compliance with regula-tions, regulatory guides, and national standards applicable to qualification.

f. Identify alarms or annunciators provided from the instru-mentation for the selected mechanical fluid system and review the bases for providing these alarms or annunciators, ,

their set points, and their locations.  !

g. Review the system description for any unusual operating requirements. Examples of these requirements could be:

special operation required of the systems during and after i an accident. capability of the systems to shut down the reactor from a remote location, or any special automatic or  ;

manual centrol features.

Appendix A, 2535 Al-9 Issue Date: 03/E4/89

^

s .

l ,

l

h. Verify that the instrumentation and control system detects and maintains essential parameters during all anticipated plant conditions. Check if the capability -to provide the required detection and control during loss of offsite pcwer, or other anticipated operational occurrences and accident conditions meets design requirements,

i. Assure that all logic functions, i.e., interlocks, automatic actuation and permissives, are properly implemented.

l - j . Assure that bypassed and inoperable status is indicated as l neces sary.

k. Review procedures and basis for developing set points- and fer ensuring that as-built deviations are considered.

END Issue Date: 03/24/89 Al-10 Appendix A, 2535 w % ,w.--- . e- - - , -

,- s APPENDIX B PROPRIETARY AGREEMENT AND CONFLICT OF INTEREST FORf1S I

PROPRIETARY AGREEMENT Proposed Consultant Consultant's Employer For proprietary and potentially proprietary information that is disclosed to me in connection with my work on the NRC's Program Name of the Plant name , I agree:

1. Not to make further disclosures.

2. Not to make further copies.

3. To return my copies to the NRC team leader upon completion of the Program unless copies were previously returned to the applicant I or applicable design organizations.

4. flot to make further disclosures or copies of inspection and/or review notes that contain potentially proprietary information. l l

SIGNATURE DATE Appendix B, 2535 B1-1 Issue Date: 03/24/89

INFORMATION CONCERNING POTENTIAL CONFLICT OF INTEREST (Program Name)

Proposed Consultant Consultant's Employer (Program Name of (Plant Name) does My)participationinthedoes

( not ( ) involve situations or relationships of the type set fo 41 CFR 20-1.5403(b)(1). In particular, I have ( ) do not have ( ) direct previous involvement with activities at the plant that I will be reviewing and have ( ) do not have ( ) conflicting roles which might bias my judgment j

in relation to my work for the NRC. In addition:

1. () I have not been previously employed by the Applicant or the Design Verification Reviewer to do similar design work.  !

l

() I have been previously employed by the Applicant or the Design '

Verification Reviewer. (State the nature of the employment.)

2. () I do not own or control significant amounts of Applicant or the Design Verification Reviewer stock. (State amount and nature of ownership)

() I own or control significant amounts of Applicant or the Design Verification Reviewer stock. (State the nature of the cwnership.)

3. () Members of my. present househcld are not employed by the Appli-cant or the Design Verification Reviewer.

() Members of my present household are employed by the Applicant or the Design Verification Reviewer. (State the nature of the employment.)

4. () My relatives are not employed by the Applicant or the Design Verification Reviewer in a management capacity.

() My relatives are employed by the Applicant or the Design Verifi-cation Reviewer in a management capacity. (State the nature of the employment.)

In the above statement, the " Applicant" is construed to mean the applicant

( ), the architect-engineer ( ), or the NSSS vendor ( ) for (Plant Name)

Signature Date i

l Issue Date: 03/24/89 B1-2 Appendix B, 2535

,' l APPENDIX C TYPICAL F0PMATS FOR DESIGN VERIFICATION PROGRAF!

INSPECTI0f! PEPORTS AMD SER INPUTS A. TYPICAL FORf1AT FOR A DESIGN VERIFICATION PROCRAM INSPECTION REPORT

1. Transmittal Letter. The transmittal letter should discuss all major items requiring applicant management attention and followup actions.

2. Cover Page. The cover page should provide basic identifying informa- l tion about the licensee inspected, facility inspected, place and time of inspection, and identification of inspection team members and responsibilities (see Exhibit 1 of IE MC 0610).

3. Inspection Report. The inspection report should have the following major sections.

(a) Background. The background should provide an overview of the progran status i nd a statement of the major milestones to be performed by the NRC staff during its review and evaluation of the progran.

(b) Purpose. Tnis section should state the purpose of the inspec-tion.

j (c) Personnel Contacted. This section should list the key licensee, design verification reviewer, and AE project personnel contacted during the inspection. ,

(d) General Conclusions. This section should provide a summary of the major conclusions of the inspection. A statement should be made as to whether the areas of the program inspected are adequate to meet the program. objectives, assuming satisfactory resolution of open items resulting from the inspection. l (e) Specific Comments. Specific comrrents on a technical discipline basis should be included as an attachment. The attachment i should typically consist of the following sub-sections; mechani- I cal systems, mechanical components. electric power, instrumenta-tion and centrol, and civil / structural.  :

)

Appendix C, 2535 Cl-1 Issue Date: 03/?4/89

~

l B. t TYPICAL FORf1AT FOR A DESIGN VERIFICATION PROGRAM SER INPUT SER S 17 CUALITY ASSURANCE t 17.5 Design Verification 17.5.1 _ Background.

This section should be a discussion of the  !

applicant's independent reviewer's progrem plan and NRC monitoring of the conduct of the audit.

17.5.2 Program Technical Audit. This section is a description of the implementation of the program by the design verification reviewer.

17.5.3 Conclusions of the Independent Reviewer.

17.5.4 Assessment by the NRC staff.

17.5.5 HRC staff conclusions.

END 1

l i

1 1

I l

l l

l Issue Date: 03/24/89 C1-2 Appendix C, 2535

TABLE OF CONTENTS INTRODUCTION 2545 Research and Test Reactor Inspection Program- 6/13/85 Operations Phase 39745 Organization, Logs and Records 1/01/77 40745 Review and Audit 1/01/77 40750 Class II Operations Procedure 1/27/84 40755 Class III Operations Procedures 1/27/84 41745 Requalification Training 1/01/77 42745 Procedures 1/01/77 60745 Refueling 1/01/77 61745 Surveillance 1/01/77 69745 Experiments 1/01/77 80745 Environmental Protection 1/01/77 82745 Emergency Plan 1/01/77 83743 Health Physics 1/01/77 86740 Transportation Activities 4/11/84 81401 Plans, Procedures, and Reviews (Safequards) 6/13/85 81402 Reports of Safeguards Events 6/13/85 81403 Receipt of New Fuel at Reactor Facilities (Safequards) 6/13/85 81411 Physical Protection for Nonpower Reactors with 11/04/85 Formula Quantities of Strategic Special Nuclear Material 81421 Phys. cal Protection of Mcderate Quantities of 6/13/85 Strategic Special Nuclear Material 81431 Physical Protection of Low Quantities of Strategic 11/04/85 Special Nuclear Material 81810 Protection of Safequards Information 10/01/82 85102 Material Control and Accounting 3/29/85 TI 2545/1 Physical Security In.spection Program for Nonpower 1/13/86

( Reactors T1 2545/2 Inspection Program for Construction, Operational 6/09/88 Readiness, Preoperational Testing, Startup Testing, and Initial Operation

~~~ ~ ~~ "~~~'~ ^

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p > > : a c g c:

jj ....,y IF ap .

lf amining design products and plant configurations. The approach on the part  ;

f the staff was not to specifically review design basis programs, but through

![ ,its ongoing inspection activities, shouid cases be found where licenses were j{ -

outside of their design bases, the staff would take enforcement action and require that the design basis be updated-and maintained. Further, NRC l modified its enforcement policy guidance to encourage the voluntary j' identification of past design, engineering and installation issues.

3 In August 1992, the Commission also issued a policy statement which summarized l' existing requirements under the regulations and the Commission's expectations l concerning availability and adequacy of design basis information. In the a~

policy statement, the Commission emphasized the importance that modifications to a facility only be made after a thorough review has been conducted and an understanding of"the underlying design bases has been gained in order to ensure appropriate design margins are preserved.

As discussed in the 1992 policy statement, the staff planned to issue a generic letter which would request that each licensee voluntarily submit information about their programs related to assuring the design basis or their rationale for not implementing such a program. ~In 1993, NRC decided to take no action on issuance of this generic letter based on issuance of the policy statement which conveyed to industry the Commission's concern about the importance of maintaining the design basis evidence that licensees recognized the concern and were conducting such programs; and staff plans to continite design-related inspections. I i

Based on the NUMARC initiative the on-going utility programs to improve and '

maintain the design bases and the regulatory burden of team inspections reported in the 1991 Regulatory Impact Survey, NRC later reduced its effort on resource intensive team inspections in this area and shifted the balance to focus on operational safety. We continued for the intervening years to focus w at all plants on operational safety versus areas such as design basis. Then, in January of this year based on design and engineering information we obtained, NRC recognized that at Millstone the design basis was not being appropriately maintained or adhered to. At that time I directed a special 2

10

. . . , , 1 utility programa to improve and maintain the dasign basic 2

and the regulatory burden of team inspections reported in 3

the 1991 regulatory impact survey, NRC later reduced its 4

efforts on resource intensive design team inspections and 5

shifted the balance to focus on operational safety.

6 We continued in the intervening years to focus 7 at all plants on operational safety versus areas, such as a design basis. Then in January of this year, based on 9 design and engineering information which we obtained, NRC 10 rcccgnized that at Millstone the design basis was not 11 being appropriately maintained or adhered to. At that 12 time, I directed a special design and engineering 13 inspection be conducted at Millstone, led by Mr. Virgilio, r '

14 who is here today.

15 In summary, I wish to emphasize that the NRC 16 position has been and still remains, that it is the 17 responsibility of the individual licensees to have 18 appropriate documentation that defines their design basis 19 and to have procedures for performing necessary 20 assessments of design and procedure changes which are 21 required by NRC regulations.

22 The design deficiencies identified at the 23 Millstone station represent a significant breach in 24 confidence we had placed on Northeast Utilities to e

25 maintain the design and license basis.

NEAL R. GFH3SS COURT REPORTERS AND TRANSCRIBERS 1323

.... .. .RH . ODE ISLAND AVE., N.W.

l

1 10 l 1

1 utility programs to improve and maintain the design basis 2 and the regulatory burden of team inspections reported in i 3 the 1991 regulatory impact survey, NRC later reduced its 4 efforts on resource intensive design team inspections and 5 shifted the balance to focus on operational safety.

6 We continued in the intervening years to focus

) ,e nn erC44 7 at all plants on operational s?.fety9 areas 3 such as design JMI' 8 basis. Then in January of this year, based on design and 9 engineering information which we obtained, NRC recognized 10 that at Millstone the design basis was not being 11 appropriately maintained or adhered to. At that time, I l 1

12 directed a special design and engineering inspection be 13 conducted at Millstone, ied by Mr. Virgilio, who is here

' ~

14 today.

15 , In summary, I wish to emphasize that the NRC I 16 position has been and still remains, that it is the 17 responsibility of the individual licensees to have 18 appropriate documentation that defines their design basis 19 and to have procedures for performing necessary 20 assessments of design and procedure changes which are 21 required by NRC regulations.

22 The design deficiencies identified at the 23 Millstone station represent a significant breach in 24 confidence we had placed on Northeast Utilities to 25 maintain the design and license basis. " -

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISwSND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

_ . . _ . . _ _ _ _ . . _ _ _ _ . _. .._. _ . . . . . _ . _ _ _ , _ . m. . _. _ _ _ _.__ _ _._

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EDO Principal Correspondence Control FROMt DUE: 09/06/96 EDO CONTROL: GT96644 DOC DT: 08/14/96 FINAL REPLY:

Charlie and Susan Luxton Waterford, CT TO Chairman Jackson '

FOR SIGNATURE OF : ** PRI ** CRC NO: 96-0905 Russell I

DESC: ROUTING:

I MILLSTONE'S INDEPENDENT ASSESSMENT TEAM Taylor  !

Milhoan Thompson Blaha HMiller, RI Jordan, AEOD DATE: 08/23/96 ASSIGNED TO: CONTACT:

NRR Russell s_

SPECIAL INSTRUCTIONS OR REMARKS:

Put EDO and Chairman on for concurrence.

Chairman's Office to review response prior to dispatch.

NRR RECEIVED: AUGUST 26, 1996 NRR ACTION: DRPE:VARGA i NRR ROUTING: RUSSELL ACTION MIRAGLIA THADANI ZIMMERMAN DUE TO NRR DIRECTOR'S OFFICE GRIMES B0HRER gy ,

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. _ - . . _-.._. --_- - - -. -._...- -.- ..---~-....-

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i I

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-96-0905 LOGGING DATE: Aug 20 96 ACTION OFFICE: EDO ,

AUTHOR: CHARLIE & SUSAN LUXTON AFFILIATION: CONNECTICUT ADDRESSEE: CHAIRMAN JACKSON LETTER DATE: -Aug 14 96 FILE CODE: IDR-5 MILLSTONE  !

SUBJECT:

MILLSTONE'S INDEPENDENT A66ESSMENT TEAM ACTION: Direct Reply DISTRIBUTION: CHAIRMAN, COMRS SPECIAL HANDLING: SECY TO ACK CONSTITUENT:

NOTES: CHAIRMAN SHOULD REVIEW RESPONSE PRIOR TO DISPATCH DATE DUE: Sep 96 SIGNATURE: . DATE SIGNED:

AFFILIATION:

i i

l Ed Dif. E D ,

Date (^$[M m, vinu .

EDO ' GT96644