ML20114E778
| ML20114E778 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/10/1996 |
| From: | Annon M NORTHEAST UTILITIES SERVICE CO. |
| To: | |
| Shared Package | |
| ML20114E760 | List: |
| References | |
| PROC-960610, NUDOCS 9606270115 | |
| Download: ML20114E778 (310) | |
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The Configuration "~sinent Plan was spesifi5 ally developed to address the 10 CFR Licensmg (Basis abd. Esign Bases 50.54 f)letinsT 'Missues rsnedin the following y g
. Letter W.T. Russell (USNRC) to R.E. Busch (NU),
dated December 13,1995, Docket 50-245 Letter'.W.T RussellDocket dated March 7,1996, (USNRC)50-336to R.E. Busch (NU),
- Letter W.T. Russell (USNRC) to R.E. Busch (NU),
dated March 7,1996, Dockets 50-213 and 50-423
. Letter W.T Russell (USNRC) to R.E. Busch (NU),
dated April 4,1996, Docket 50-423 c
Millstone h)bh Connecticut Yankee SoRC. Mrg. No.: hdLcMb PoRC MgNo.: b- /
Date: .__4 95 Date 29- 96>
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l 9606270115 960625 i PDR ADOCK 05000423 F PDR Responsible Individual:
Level of Use . M. Annon l - Information
- Subject Matter Expert:
l M. Annon, B. Cox, J. Sauger
MP1, MP2, MP3, CY ,
NU Common Procedure Configuration Management Plan .
TABLE OF CONTENTS
- 1. BACKG R OUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
- 2. O BJECTIVE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
- 3. CONFIGURATION MANAGEMENT PLAN . . . . . . . . . . . . . . . . . . . . . . 4 3.1 Key Project Activities and Process Elements . . . . . . . . . . . . . . . . . . 4 3.2 Scope of Key Project Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.3 D eliverable s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 3.4 Project Orgamzation and Responsibilities . . . . . . . . . . . . . . . . . . . . 14 3.5 Project Process Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 3.6 Re fe r e n c e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
- 4. PLANT IMPLEMENTATION APPROACHES . . . . . . . . . . . . . . . . . . . . 21 4.1 Unit-Specific Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 4.2 Response Readiness Assessment Points . . . . . . . . . . . . . . . . . . . . . 21 4.3 Unit-Specific Implementation Plans . . . . . . . . . . . . . . . . . . . . . . . 21 ATTACHMENTS AND FORMS Attachment 1, " Millstone Unit 1 CMP Implementation Plan" . . . . . . . . . 22 Attachment 2, " Millstone Unit 2 CMP Implementation Plan" . . . . . . . . . 25 l Attachment 3, " Millstone Unit 3 CMP Implementation Plan" . . . . . . . . . 28 l
l Attachment 4, " Connecticut Yankee CMP Implementation Plan" . . . . . . 35 Attachment 5, " Definitions" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 Attachment 6, " Topical Areas" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 l
Attachment 7, " Graded System Selection" . . . . . . . . . . . . . . . . . . . . . . . . . 43 Anachment 8, " CMP Implementation Organi7ation" . . . . . . . . . . . . . . . . 44 Attachment 9, " Project Instruction Cross-Reference Table" . . . . . . . . . . 45 Attachment 10, " Configuration Management Plan Charter and Organizational bles" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 Attachment II, " Process Flow Chart" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 CMP Level of Use - .s
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- 1. BACKGROUND .
In unit-specific letters, the Nuclear Regulatory Commission (NRC) required that Northeast Utilities (NU) address design basis and configuration management for Millstone Units 1,2, and 3; and Connecticut Yankee (CY).
These letters requested that NU describe what actions will be taken to ensure that future operation of Millstone Units 1,2, and 3; and CY will be conducted in accordance with the terms and conditions of their unit operating license, the l Commission's regulations (including 10 CR 50.59), and their unit UFSAR. .
The letters are as follows:
. Letter W.I Russell (USNRC) to R.E. Busch (NU), dated ;
December 13,1995, Docket 50-245 [,
. Letter W.T. Russell (USNRC) to R.E. Busch (NU), dated March 7,1996, ;
Docket 50-336 l
. Letter W.T. Russell (USNRC) to R.E. Busch (NU), dated March 7,1996, l
Dockets 50-213 and 50-423 l
. Letter W.T. Russell (USNRC) to R.E. Busch (NU), dated April 4,1996, j Docket 50-423 The Configuration Management Plan (CMP) describes the activities required to )
address conditions identified in the 10 CFR 50.54(f) letters. The scope defined (
in this document has been presented for implementation by each of these units. !
Unit-specific CMP Implementation Plans are presented in Attachment I '
through Attachment 4.
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- 2. OBIECTTVE The objective of this Configuration Management Plan (CMP)is to define the overall process and each Key Project Activity necessary to meet the following Mission Statement: .>
i The project must be able to provide reasonable assurance that the future operation of each unit will be conducted in accordance with the terms and conditions of the unit's operating license, NRC regulations, and the unit's UFSAR.
Upon completion of the actions described in this CMP, Northeast Utilities shall have reasonable assurance that:
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- Adequate programs and processes exist to maintain control of these requirements on a going-forward basis.
- Conditions related to LB and DB issues leading to the NRC's 50.54(f) letters are understood and actions to prevent recurrence have been implemented or committed to in a prioritized manner.
This CMP provides the configuration management, LB, and DB-related inputs for an acceptable 50.54(f) response for each unit and provides tools which:
- Form the basis for future plant modifications, including 10 CFR 50.59 safety determinations, by defining the LB and DB.
- Function as a living record of the "As Configured" plant.
This CMP also clarifies the 1:rms LB, DB, and Engineering Design Bases (EDB) (defined in Attachinent 5) for use within this project. A sketch of the interrelationship of the LB, DB, and EDB is also presented in Attachment 5.
The CMP is a living document and will be expanded as necessary to meet the Mission Statement.
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- 3. CONFIGURATION MANAGEMENT PLAN - ,
This section briefly discusses the various aspects of this Project. Activities i necessary to complete the Project are discussed in Project Instructions ?
listed in Attachment 9. I 3.1 Key Project Activities and Process Elements The CMP shall be implemented in a phased approach. Phase I activities are focused on accomplishing the tasks necessary to support submittal of the appropriate 50.54(f) response letters. Phase 2 activities are focused on accomplishing the remainder of tasks associated with long-term t implementation of the CMP. The unit-specific schedules shall delineate that activities to be included in Phase 1 and Phase 2. l The essential process elements are defined by the Key Project Activities. '
Each Key Project Activity listed below shall be addressed by each unit; but .
the applicability and degree to which an activity is addressed may vary among !
the units. The degree to which a unit addresses an activity should be determined as outlined in Section 4.
Key Project Activities are:
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. Discovery of past and current practices, documents, and plant l
configurations that may challenge the integrity of the LB or DB, l
such as: t
. NCRs, PDCRs, maintenance history files, etc.- ;
- Completion of unit-specific assessments of documented deficient conditions identified by both internal and external l organizations, including those conditions leading up to the NRC's issuance of the 10 CFR 50.54(f) letters and team inspections conducted thereafter
. Identification of employee concerns regarding LB or DB issues
. Walkdowns and system readiness reviews l
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- Consolidation of two elements of the LB,in two phases:
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- Initially, documenting each unit's position on selected regulatory guidance documents
- Secondly, assembling the active commitments from correspondence i
- Performance of a graded system review to define the LB and DB for selected systems and Topical Areas
- Resolution of discrepancies identified during this Project
- Verification that appropriate plant operation procedures, practices, and policies exist to ensure current and future compliance with the LB and DB
- Generation of Design Bases Documents, System Descriptions, and UFSAR changes as appropriate
. Establishment or enhancement of appropriate configuration control or configuration management processes to ensure future maintenance of the DB and consolidated elements of the LB ,
- Integration ofindependent assessments into appropriate points in ;
this Project ,
- Identification and development of both the short-term and long-term communications and training required to :
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- Support conduct of this Project !
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- Increase employee awareness of root causes that led to issuance of the 50.54(f) letters
- Provide training to organizations (such as Operations and Technical Support) directly associated with the implementation of changes promulgated by this CMP !
l Attachment 11 outlines an overview of the process and the basic interrelationships of the Project Instructions used to implement the CMP.
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3.2 Scope of Key Project Activities 3.2.1 Discovery - As outlined in the unit-specific implementation plans (Attachment I through Attachment 4), existing plant conditions and documentation shall be reviewed and assessed to identify areas l
where there is a potential for variance from the LB and DB. '
- a. The following types of documents may change the configuration of the plant. Therf :e each document type should be reviewed to identify those that specifically affected the LB or DB, such as:
- NCRs
- PDCRs
- DCNs :
- PDCEs
- RIES
- EDCRs
- Bypass Jumpers
- Technical Specification changes I
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- b. Each unit shall complete a unit-specific assessment of the '
reasons for the following:
- NRC Inspection Reports related to LB or DB issues and internal notes, matrices, and findings of recent NRC.I,B or DB team inspections
- Last two (2)INPO Assessment Reports
- Relevant QAS Reports (audits, surveillances, etc.)
- NU internal self-assessments
- Applicable unit-specific audits and assessments
- ACR 7007 Event Review Team ReporI
- ACRs selected based on key word (license, design, l process, etc.) searches !
- PORC Subcommittee and Committee reviews of LB and i DB-related issues
- NSAB reviews of LB and DB-related issues
- NS&O communications on areas to be covered by the CMP.
Issues or reasons identified from the above sources shall be included in an overall matrix to facilitate categorization and "binnir;;l' Relative to items gleaned from sources including (but not limited to) ISEG, INPO, QAS and the NRC, issues currently considered closed shall also be included to support a broader consideration of causes and effectiveness of corrective measures.
Assessment Team conclusions shall be contained in a written report to the Management Quality Committee (MQC). The report shall make recommendations for appropriate adjustments to the plan. Each unit's report shall be provided to the remaining NU Connecticut nuclear units to facilitate a review of conclusions potentially applicable to one or more of the remaming units.
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- c. Any issue of concern related to this Project that is identified by i plant personnel based on individual knowledge shall be .
reviewed. The scope of this activity is issues which may potentially challenge the LB or DB. Each valid issue shall be I 1
treated as a discrepancy and resolved. -
l Each Unit Director should request that personnel throughout 1 cach plant organization identify any undocumented issues or I concerns which may potentially challenge the LB or DB.
- d. Walkdowns or system readiness reviews shall be performed as appropriate. These walkdowns or system readiness reviews may be pan of any of the following processes:
- Discovery process
- Discrepancy resolution process
. Validation process (to ensure necessary resolution activities are completed) 3.2.2 Licensing Basis - Elements of the LB s' hall be extracted from existing docketed information in two phases. Initially, references to selected regulatory guidance documents shall be reviewed and a position paper developed to document each unit's specific commitments to General Design Criteria (as applicable to the unit) and the Topical Areas outlined in Attachment 6, Section A.
Existing documented positions on the topics that were previously prepared and deemed adequate by the Unit Project Manager and the Manager, Design Engineering are acceptable in lieu of developin;; new documented positions.
Secondly, any written commitments that are docketed and in effect shall be located, the method of incorporation into plant practices identified, and the commitment incorporated into an NU established tracking system. Project Instructions shall delineate how these commitments are to be identified. .
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3.2.3 Graded system review - A review of plant systems shall be ;
performed based on a prioritized ranking (referred to herem as
" graded system review"), applying an established, uniform process to ensure compliance with the LB and DB. Systems should be selected based on the unit-specific Maintenance Rule Unit Basis i
Document (Refer To Reference 3.6.19 through Reference 3.6.22).
Attachment 7 contains a recommended group prioritization and additionalinformation for implementation of this approach.
To supplement the Maintenance Rule criteria, systems may be further l i graded on a unit-specific basis using additional criteria such as:
I - Risk significance
. Safety classification l
Based on the discovery process and root cause analyses, each unit '
l shall also make a determination as to the required degree of i
review needed for the LB and DB, plant configuration, and plant j operating processes and procedures. f a
In addition, Attachment 6 provides a list of topical areas which i
2 shall be included in this review on a unit-specific basis.
Each selected system and topical area shall be reviewed and-researched as specified in established Project Instructions to ensure compliance with the LB and DB. This review should use f
the UFSAR, DBDPs (where these exist), and other available ;
i information. A review of appropriate design data shall be .
performed to ensure the system or topical area meets DB requirements and is capable of achieving the specific values or -
range of values which constitute controlling attributes as
' reference bounds for design.
i Key system or component design attributes (such as safety analysis l
assumptions, including operator actions) shall be established.
i l Documents (such as calculations, specifications, and special tests) which confirm the ability of the system or component to meet these l
' key attributes shall be located and documented.
In addition, a separate review of the UFSAR shall be conducted to confirm the correctness of the UFSAR as it relates to the LB and DB. This review shall be integrated with the graded system review.
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3.2.4 Resolution - Discrepancies identified by this Project shall be a i
evaluated to determine the appropriate resolution. Resolution activities may entail document or plant changes, procedure ,
development or changes, analysis development, etc. Discrepancies shall be evaluated for impact on reportability and operability..y 3.2.5 Operation practices and policies - As the LB and DB are defmed for each system, operational controls (programs and procedures) which apply to that system shall be reviewed to ensure the system is operated in accordance with the LB and DB.
Unit Technical Specifications shall be reviewed to ensure LCOs require maintenance of key parameters, and that Surveillance Requirements do in fact demonstrate the ability to satisfy these key parameters. Surveillance procedures shall be reviewed to ensure Surveillance Requirements are properly implemented.
3.2.6 Design Bases Documents and UFSAR changes - Results of the graded system reviews shall be documented in controlled documents such as Topical Repons, Design Basis Documents, etc.
Discrepancies encountered in the UFSAR shall be addressed.
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3.2.7 Configuration controls l t eachand unit to managemen evaluate the adequacy of configuration contro istics are ting, sa ,
ensure the plant's physical and functional '
character maintained in conformance with the LB and training,LB and DB.
with the This activity shall include the following functions:
Identifv programs, processes,d asand procedures req l communicate changes among the designed, license , !
operated, and physical plant configurations. ,
Develop a Project Instruction to provide a consistent j i ams, approach to reviewing and evaluating control.
Evaluate configuration control ht term d identify and programs, proces procedures to identify any weaknesses; develop s t
tions.
solutions and long-term recommendati -
Develop criteria for ongoing configuration control performance monitoring. lbe ,
Short-term fixes (Phase h 1) to identified (Phase 2) to rall configuration provided, as well as long-term recomme ,
management process. d by the !
fthe Independent assessments - Activities shallbe estal 3.2.8 Director, Design Engineering, to assess bl the effectiv Project, to ensure compliance with the CMP and Instructions, and to verify the accura ;
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' Project Instructions shall identify specific activitie :
deliverables that require independent assessment. l r / '
Independent assessments i should be performe bject matter. The i teams who are not involved in the h specif c act who are experienced and knowledgeabled in t e su independent assessment shall i it focus on the effec ;
compliance with the process for the specific b ch act v y. r d tailed '
Independent assessments shall be performed Unit Project Manager on specific deliverables th !
independent review to assure accuracy. ,
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l 3.2.9 Short-term and long-term communications and training - '
Timely and effective communications are a necessary element of
- this Project in order to ensure that relevant information is ,
communicated within each plant organization, between plant l organizations, and to other organizations (including the NRC)as !
required.
This dissemination of information shall accomplish several important features of the CMP, namely:
- Use lessons learned and issues discovered in one unit to assess potential impacts on other units.
- Provide an organizational sense of common Project accomplishments and completion status.
Create a working-level understanding of the issues leading to issuance of the 50.54(f) letters, to provide input for training and preventive measures.
Each unit shall develop a Communications Plan to address specific activities, responsibilities, and schedules.
Another necessary element of this Project is training.
Short-term and long-term training needed to support conduct of this CMP and to prevent recurrence of conditions that led to issuance of the 50.54(f) letters shall be identified and This includes two major efforts:
- Assessment and conduct of short-term training of NU and contractor personnel involved in implementing various activities within the Project. Traming is to be conducted in accordance with NGP 2.26, " Departmental Training," and NTM-7.202, " Nuclear Training Manual."
Identification and development of long-term training for personnelinvolved in conduct of activities relating to contro and maintenance of the LB and DB.
A long-term traming plan should be developed and presented to the Engineering Support Personnel Training Nuclear Training Manual.
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3.3 Deliverables The deliverables for the three major functional areas of this effort are summarized below. Completion of these deliverables should be ,
accomplished in a phased manner, as outlined in Section 3.1. These /
deliverables shall be generated on a unit -specific basis, as defined in Attachment 1 through Attachment 4.
Deliverables Summary
. Design Engineering:
. Unit-specific assessments and (where applicable) root cause reports
. Licensing Commitments: Unit-specific position papers on selected regulatory guidance and an established database of licensing commitments that are docketed and currently in effect
. Design Bases: DBDs, Topical Area Reports,UFSAR Changes, and System Descriptions (as applicable)
. Engineering Programs: Program Docutnents
. Configuration Management:
- Linkage to ensure changes in one document are reflected in other affected documents
. Plant Validation and Readiness:
. Updated documentation resulting from verification of operational practices and walkdowns, surveillance procedures, setpoints, TRM, EOPs, AOPs, ACPs, P& ids, CWDs, etc.
- System Readiness Reviews (as applicable) 1 l
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3.4 Project Organization and Responsibilities The Project shall involve the following organization and responsibilities as outlined below, discussed in more detail in Attachment 10, and shown in the Attachment 8 organizational chart: ,j, l
i a Executive Committee !
The Executive Vice President, Chief Nuclear Officer (CNO) shall chair an executive committee that provides leadership and executive presence for the project to monitor the overall Project.
The Executive Committee shallinclude the following:
- Vice President, Nuclear Operations
- Vice President, Technical Services
- Vice President, Work Services
- Senior Vice President, Nuclear Safety & Oversight (NS&O)
NS&O provides input and oversight to the committee function, but is not part of the consensus decision-making authority, so as not to compromise the oversight role. NS&O provides separate oversight consultations to CNO based on independent assessments.
Vice President, Nuclear Operations and Vice President, Technical Services The Vice President, Nuclear Operations and the Vice President, Technical Services shall ensure that sufficient resources are provided to complete the CMP satisfactorily. In addition, they shall actively participate in establishing expectations for performance results with management, and in providing guidance and leadership.
- Unit Director ;
The Unit Director has primary responsibility for the success of the CMP; and shall co-chair the Management Quality Committee.
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- Director, Design Engineering The Director, Design Engineering has primary responsibility for the technical adequacy and conduct of the CMP; and shall y co-chair the Management Quality Committee.
- Configuration Management Manager The CM Manager is responsible for the development and implementation of the Configuration Management process review and improvement. The CM Manager shall coordinate implementation of the Plan to assure CMP actions are scheduled, responsibilities are assigned, and resources are available.
The following organizations shall be unit specific:
- Management Quality Committee (MOC)
The MQC shall be composed of the following:
- Unit Director
- Director, Design Engineering or designee
- A Licensing Manager or designee ,
- Nuclear Safety and Oversight Manager or designee NS&O provides input and oversight to the committee function, but is not part of the consensus decision-making authority, so as not to compromise the oversight role. NS&O provides separate oversight consultations to CNO based on independent assessments.
The MQC also fosters and reinforces a culture of quality and thoroughness for activities associated with this CMP. !
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- Unit Project Manager (UPM) i Day-to-day management of the Project is assigned to a UPM, who is responsible to assure the plan progresses satisfactorily.
The UPM is resporsible to ensure the scope and quality of w6rk l activities comply w;th this CMR The UPM shall assure plan actions are scheduled, responsibilities assigned, and resources available for each action.
- Plant Validation and Readiness Team (PVRT) ;
The PVRT is charged with the verification of operational ;
practices supportive of the LB and DB, system readiness reviews, and verification of physical plant configuration.
Each unit-specific PVRT shall be comprised of senior licensed ,
operators and augmented by technical experts as needed, as delineated in the appropriate Project Instructions. l
. Unit Design Engineering Manager The Unit Design Engineering Manager has primary responsibility for the technical adequacy of Uni: Design Engineering-assigned activities.
. Design EngineeringTeam (DET) i The DET shall focus on the development of the unit LB and DB consistent with definitions provided in this CMP. Each DET shall:
- Create manageable, traceable, and usable information suitable for inclusion in DBDs or similar documents for systems reviewed.
In a matrix arrangement for the Project, each DET shall include members of the unit's Design Engineering staff.
. Configuration Management Team (CMT)
Each CMT shall be comprised of personnel with the experience in l configuration management needed to:
. Identify processes and practices in need of improvement.
. Enhance the NU Nuclear Configuration Management Program.
. Develop or modify processes and procedures to implement, control, and maintain configuration management.
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3.5 Project Process Administration 3.5.1 Communications - Successful completion of the Project requires open, consistent, and timely communications among employees, k teams, regulators, and the public. A Communications Elan, 1 assigned response coordinators, shall be developed.
3.5.2 Personnel Qualification - Qualification requirements, including supporting training, for each aspect of the Project shall be identiSed as the Project Instructions are developed. Individuals supponing this effort shall complete these requirements prior to performing work governed by the Project Instructions. Completion of these qualification requirements shall be documented in accordance with NGP 2.26, "Depanmental Trainmg," and NTM-7.202," Nuclear
- Training Manual." and the documentation retained.
3.5.3 Reporting of Discrepancies - Discrepancies identified during the performance of this Project shall be assessed. Discrepancies which may challenge plant safety shall be evaluated for reportability and operability using the ACR process (Reference 3.6.16 or Reference 3.6.17).
3.5.4 Progress Repons - Project progress shall be reported periodically.
Progress reports shallinclude:
a Listiny, of deficiencies (ACRs, NCRs, LERs) generated as a result of the CMP
= Work accomplished within the reporting period
. List of completed deliverables
. Percent completion for major activities
- Discussion of schedule and cost vadances ]
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- Planned activities for the next reponing period
. Potential barriers to meintaining schedule.
These repons shall be prepared by Unit Project Managers. Reports l J
shall be addressed to the Vice President, Nuclear Operations with copies distributed to MOC members and Project panicipants.
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3.5.5 Tracking - Tracking shall be used to capture unresolved or open issues so they can be followed to completion.
3.5.6 Self-assessments - A self-assessment plan shall be developed and implemented into appropriate points within the Project. z These self-assessments shall focus on providing information to
- i assist in determimug the adequacy of Project activities. These i self-assessments should result in an increased confidence level that the process is working as intended or identification of those areas that require modification.
3.5.7 Perfonnance measurements - Each organization responsible for a !
Key Project Activity shall develop performance measurements or performance indicators appropriate to the activity. These performance measurements or indicators should, as a muumum, focus on the long-term quality of products related to LB and DB ,
activities, to help recognize trends (both positive and negative) resulting from implementation of this CMP on future LB and ;
i DB-related activities. These items are updated as required.
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3.6 References 3.6.1 Letter W.T. Russell (USNRC) to R.E. Busch (NU), Docket 50-245 3.6.2 Letter W.T. Russell (USNRC) to R.E.Busch (NU) Docket 50*336 3.6.3 Letter W.T. Russell (USNRC) to R.E. Busch (NU), Dockets 50-213 and 50-423 3.6.4 Letter W.T. Russell (USNRC) to R.E. Busch (NU), Docket 50-423 3.6.5 Letter WI Russell (USNRC) to W.H. Rasin (NUMARC) 3.6.6 NUREG-0824," Integrated Plant Safety Assessment Systematic Evaluation Program" 3.6.7 NUREG-0826," Integrated Plant Safety Assessment Systematic Evaluation Program" 3.6.8 NUREG-1397,"An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Power Industry" 3.6.9 NRC Inspection Manual
- Chapter 2535," Design Verification Programs"
- Inspection Procedure 93801," Safety System Functional i Inspection" i l
- Inspection Procedure 93807, " Systems Based I&C i Inspection" 3.6.10 NUMARC 90-12," Design Basis Program Guidelines" 3.6.11 NGP 2.26," Departmental Trammg" 3.6.12 NGP 3.2," Configuration Management" 3.6.13 NGP 3.15," Root Cause Evaluation Program" 3.6.14 NGP 4.03," Changes and Updates to Final Safety Analysis Reports for Operating Nuclear Power Plants" 3.6.15 NTM-7.202, " Nuclear Trainmg Manual" (NTM) 3.6.16 RP-4," Adverse Condition Resolution Program" (for Millstone) l
' CMP
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3.6.17 ACP 1.2-16.5," Adverse Condition Report Process Iaplementation" (for Connecticut Yankee) .
3.6.18 ACR 7007," Millstone Unit 1 UFSAR Inaccuracies" 3.6.19 Millstone Unit 1 Maintenance Rule Unit Basis Document 3.6.20 Millstone Unit 2 Maintenance Rule Unit Basis Document 3.6.21 Millstone Unit 3 Maintenance Rule Unit Basis Document 3.6.22 Connecticut Yankee Maintenance Rule Unit Basis Document 3 6.23 Letter from T. C. Feigenbaum (CYAPCo) to U.S. Nuclear Regulatory Commission," Reply to Request for Information Pursuant to 10CFR50.54(f) for Haddam Neck"
- f. s e.. CMP
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=
1
- 4. PLANTIMPLEMENTATION APPROACHES 4.1 Unit-Speci5c Implementation The process described in this CMP is flexible enough to allow each unit to implement each Key Project Activity to the level necessary to-
- Ensure future operation of the unit can be conducted in accordance with the terms and conditions of the license, NRC regulations, and the unit's UFSAR.
' To that end, the following flexibility is available:
- Each unit may tailor the criteria used to identify licensing commitments as part of the review of source documents.
- Each unit may establish its own set of systems for which DBDs are necessary, and develop its own schedule for creation of the final DBDs.
- Each unit may perform discovery activities only for those areas where questions exist about the level of accuracy.
- Each unit may prioritize resolution of discrepancies as appropriate for their operation.
4.2 Response Readiness Assessment Points Each unit may determine the appropriate time to submit its 50.54(f) response letter. This point is determined based on an acceptable level of completion of the functional elements of this CMP, rather than a specific point in time. ,
4.3 Unit-Spec 15c Implementation Plans Each unit shall prepare a unit-specific Implementation Plan to describe the level of implementation necessary for each Key Project Activity. For each activity for which it is inappropriate to perform the entire described scope, a >
brief discussion of the reason shall be provided.
CMP Levelof Use _' ~ .
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Attachment 1 Millstone Unit 1 CMP Implementation Plan (Sheet 1 of 3)
Oveniew:
The CMP will be implemented in two phases for Millstone Unit 1. Phase I is the.)
completion of the set of CMP activities that must be performed to respond to the 10 CFR 50.54(f) letter. Phase II is the completion of the remammg CMP activities.
NOTE The Unit 1 effort staned in January 1996 (Rev. O PCP). The existing QA DBVT database at Unit I will be used. A umt-specific Process Instruction will be written to suoport the review and categonzation (i.e., LB, DB of tes existing records in de database. Further, the existing database const a form of discovery and will be used with respect to determining system l operability to support plant evolutions while shutdown.
Step 3.2.1 Discovery I
This activity shall be implemented as described in the CMP.
Step 3.2.1.a. Document Review This activity shall be implemented as described in the CMP.
Step 3.2.1.b. Unit-Specific Assessments This activity shall be implemented as described in the CMP.
Millstone Unit 1 initiated ACR 7007 to perform a root cause analysis specific to the unit. Results from root cause analyses performed on the other three NU Connecticut plants shall also be ,
evaluated.
Results of these activities shall be used to make appropriate modifications to this CMP Implementation Plan.
Step 3.2.1.c. Employee Concerns This activity shall be implemented as described in the CMP.
r CMP a
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- . -. .-. -. - - - _ - . - . . =- - _ - - . .. __
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Attachment 1 Millstone Unit 1 CMP Implementation Plan (Sheet 2 of 3)
Step 3.2.1.d. Walkdowns or System Readiness Reviews This activity shall be implemented as described in the CMP. p System Readiness Reviews are the process whereby System Engineers and other team members ensure their systems can support long-term system operation. ;
)
The walkdown process presented in NUC PI 16, " Licensing Basis >
and Design Basis Walkdown," includes reviewing appropriate system documentation, restart criteria, field walkdowns, and other outstanding hardware or engineering issues (such as bypass jumpers, Trouble Reports, etc.). Walkdowns may be combined
- with system readiness reviews.
Step 3.2.2 Licensing Basis l This activity shall be implemented as described in the CMP. j Step 3.2.3 Graded System Review This activity shall be implemented as described in the CMP. Systems ,
reviewed shall be Group 1, Group 2, and Group 3 systems, as defined in j
Attachment 7.
i Step 3.2.4 Resolution This activity shall be implemented as described in the CMP. .
I Step 3.2.5 Plant Verification and Readiness Team This activity shall be implemented as described in the CMP.
i CMP Level of Use -. -
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Attachment 1 Millstone Unit 1 CMP Implementation Plan (Sheet 3 of 3)
I Step 3.2.6 Design Bases Documents and UFSAR Changes This activity shall be implemented as described in the CMP. Final .,
products associated with this CMP for Unit I shall include:
. Revised UFSAR, incorporating LB and DB.
l NOTE Design Bases Documents (DBDs) are detailed documents that bound the I LB, DB, and EDB for a system. System Descriptions (SDs) are less rigorous in nature, in that they are used for systems that may have little or no LB (that is, nonsafety or nonsafety significant systems). Both types of documents are source documents for design-related information associated with a system.
- DBDs shall be developed for Group 1 systems. DBDs shall also be developed for selected Group 2, Group 3, and Group 4 systems in a sequence that supports unit startup. SDs shall be developed to a level of detail appropriate for the system's safety significance for l those systems which will not have DBDs.
Step 3.2.7 Configuration Management This activity shall be implemented as described in the CMP.
1 Step 3.2.8 Independent Assessments This activity shall be implemented as described in the CMP.
Step 3.2.9 Short-term and bug-term Communications and Training This activity shall be implemented as described in the CMP i
r CMP Level of Use x: p ..THINK N ACI~ M Ew g a4 Rev. 2 24 of 54 Information -
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- Attachment 2 '
l Millstone Unit 2 CMP Implementation Plan f (Sheet 1 of 3)-
l .
Overview:
The CMP will be implemented in two phases for Millstone Unit 2, Phase I is the.'-
completion of the set of CMP activities that must be performed to respond to the l 10 CFR 50.54(f) letter. Phase II is the completion of the remaining CMP activities. ;
Step 3.2.1 Discovery i
i l
This activity shall be implemented as described in the CMP.
Step 3.2.1.a. Document Review This activity shall be implemented as described in the CMP. ;
i Step 3.2.1.b. Unit-Speci5c Assessments t This activity shall be implemented as described in the CMP and defm' ed in NUC PI-2," Unit-Specific Assessments." Millstone ;
Unit 2 initiated ACR 8761 to perform a root cause analysis specific to the unit. l Step 3.2.1.c. Employee Concerns
! This activity shall be implemented as described in the CMP.
Step 3.2.1.d. Walkdowns or System Readiness Reviews f i This activity shall be implemented as described in the CMP. System f i
readiness reviews are the process whereby System Engineers and other team members ensure their systems can support long-term system operaton.
The walkdown process presented in NUC PI 16," Licensing Basis :
i and Design Basis Walkdowns," includes reviewing appropriate system documentation, restart criteria, field walkdowns, and other '
outstanding hardware or engineering issues (such as bypass jumpers, Trouble Reports, etc.). Walkdowns may be combined with system readiness reviews. Walkdowns shall include (as a mmimum)
Group 1 systems, as defined in Attachment 7 and delineated below: l
- 120 Volt Vital RegInst AC ;
- 125 Volt DC ,
. 480 Volt I.oad Centers
. 480 Volt MCCs l
. Boric Acid .
4 t CMP ,
. Level of Use 4 Te "THNK' Ni'cr MEVIEW Rev. 2 lnformation 9 "~ 25 of 54
b d
Attachment 2 Millstone Unit 2 CMP Implementation Plan (Sheet 2 of 3)
Step 3.2.1.d. Walkdowns or System Readiness Reviews (Cont'd)
- Control Element Drive
- Containment Structure
- Containment Air Recire & Cooling
. Containment Isolation 4
- Containment Spray a CVCS (Volume portion)
. Diesel Generator
- EBFS
- ESAS
- ESF Room Recirculation
- HPSI
- NI Linear Power Range
. RBCCW
- Rcactor Coolant l
- Reactor Pressurizer
= Reactor Protection
- Refueling Water Storage Tank and Containment Spray
. SafetyInjection Tanks
. Station Electric Service 4.16KV If a significant discrepancy (such as a reportability issue, operability determination, challenge to plant safety, etc.) is discovered in a Group 1 system, the discrepancy shall be reviewed for generic implications.
If necessary, applicable systems from Group 2 shall be selected.
CMP "n Rev. 2 Level of Use '5 top 'THINK %ACT MEVIEW
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- Attachment 2 Millstone Unit 2 CMP Implementation Plan (Sheet 3 of 3)
Step 3.2.2 Licensing Basis This activity shall be implemented as described in the CMP.
9 Step 3.2.3 Graded System Review This activity shall be implemented as described in the CMP. Systems reviewed shall be Group 1 systems, as defined in Attachment 7.
Step 3.2.4 Resolution This activity shall be implemented as described in the CMP.
Step 3.2.5 Plant Verification and Readiness Team
.This activity shall be implemented as described in the CMP.
l Step 3.2.6 Design Bases Documents and UFSAR Changes This activity shall be implemented as described in the CMP. Final products associated with this CMP for Unit 2 shall include:
- Revised UFSAR, incorporating results of LB and DB definition and reviews of systems and topical areas a Design Basis Documents which shall encompass the results of reviews of systems and topical areas Step 3.2.7 Configuration Management This activity shall be implemented as described in the CMP.
Step 3.2.8 Independent Assessments l
This activity shall be implemented as described in the CMP.
Step 3.2.9 Short-term and IAng-term Communications and Training This activity shall be implemented as described in the CMP.
l 1
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Attachment 3 Millstone Unit 3 CMP Implementation Plan l (Sheet 1 of 7) 1 Overview:
The Millstone Unit 3 CMP will be implemented in two phases. Phase I is the :. ) l 1
completion of the set of CMP activities that must be performed to respond to the 10 CFR 50.54(f) letter. Phase II is the completion of the remaining CMP activities.
4 Phase I activities consist of three major areas, namely:
. Configuration control of programs, processes, and procedures l
i . Walkdowns and System Readiness Reviews (" horizontal slice")
- Licensing and Design Basis (" vertical slice")
i j The extent of activity in each of these three major areas is described below:
- Configuration Control of Programs, Processes, and Procedures Configuration control of programs, processes, and procedures shall be evaluated to identify any weaknesses. Short-term solutions and long-term recommendations
' shall be developed. Each weakness and each associated corrective action shall be identified and reported. .
Phase I includes completion of the short-term solutions, as described in NUC PI 10, " Configuration Management."
- Walkdous and System Readiness Reviews (" horizontal slice")
Walkdowns and system readiness reviews are the processes whereby System Engineers and other team members ensure their systems are screened for outstanding work activities and ensure that their systems can support long-term operation.
Phase I includes walkdowns or system readiness reviews for the Groap 1 systems, l
as described in NUC PI 4, "Walkdowns," and NUC PI 5, " System Readiness Reviews." Walkdowns for Phase I shall be integrated with the Phase I 'Nertical slice" described below and shall include the range of requirements from licensing basis to the "as-configured" plant.
PDCR walkdowns are included as described in Section 3.2.3.
i I -
+
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I '- 28 of 54
Attachment 3 Millstone Unit 3 CMP Implementation Plan (Sheet 2 of 7)
Local 10 ,
(Jait 3 Groep1 Syssess 3322 Aumhary Feeowater: Auxikary Foodwater 3304A .
CVCS: Charging Pp 3330D CVCS: Charyng Pp Coohng 3304 CVCS: Chem & Volume Control 3312A Contamment Contarnment isolaeon 3405 ESAS: EGLS 3407A ESAS:Westrem 7300 Racks 3307A ESF - tW_en: Accumulators 3308 ESF - h-- : .. HPSI 3307A ESF - Injechon:LPSI 3307C ESF - trgecten: RWST & Rectrculanon 3306 ESF - n,ecaon Reorculanon Spray 3307B ESF - e' ^- n: Resicual Heat Removal 3330E ESF - in,ecaon:St Pp Coohng 3309 ESF - Quench Spray; Quench Spray 3344A Elecincal- AC:Vrtal 480 Vol!
3344B Electncal- AC:Vr.at MCCs 3345B Electnca! - AC: Vital 120 VAC 33458 Electncal- AC:Vrtal120 VAC inveners 3343 Electnca:- AC: Vital 4160 Vott 334SC Eiectnca!- DC: DC 125 VUC - Control 3347B i Eectnca! - Gen.: NormalTransformer 3347A Electncat - Gen.: Reserve Transformer 3314H Emergency Desel: EDG Rm. Ventdaton 3346A Emergency Desel: Engine 33460 Emergency Desel: Fuel Oil 3346A Emergency Deset: Generator 3346A Ec.,v.ncy Desel: Lube Oil 3346A Emery. -.cf Desel:Starnng Air 3321A Feoowater. Feed Pump 3321A Feoowaten Foeowater 3316A Main Stoom: Main Steam 331(A Main Steom: Steam Generator f 3347 Normal Power System 3330A-RPCCW. RPCCW 3301 Reactor Coolant. Reactor Coolant 3406 ,
Reactor Protecton: SSPS 3326 Service Water: Service Water 3312A Structures Containment Stvc1ure
.' CMP Level of Use /
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1 Attachment 3 Millstone Unit 3 CMP Implementation Plan (Sheet 3 of 7)
- Licensing Basis (" vertical slice")
l Phase I includes a "venical slite" review of the LB and DB of selected systems. 4 This review shall be integrated with the other Phase I activities (configuration I control and walkdowns). Results of the vertical slice review shall be used to ass the effectiveness of design and configuration controls. LB and DB shall be traced into the "as-configured" plant. The vertical slice team shall specify those key attributes of the selected systems that require confirmation by the walkdown team.
. Validation Revised programs, processes, and procedures shall be validated by testing against the results of the horizontal and vertical slice reviews. For example, past discrepancies discovered in the vertical slice review or recent NRC inspection issues shall be used to confirm that revisions made to programs, processes, and procedures as a result of this CMP would have prevented the past discrepancie I
l l
l l
l l
I I
1 ,
CMP Level of Use sTop
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30 of 54 1
Attachment 3
~
Millstone Unit 3 CMP Implementation Plan (Sheet 4 of 7) !
- I 1
Step 3.2.1 Discovery Y
Step 3.2.1.a. Document Review This activity shall be implemented as desented in the CMP. The Phase I document review shall be completed as part of the LB review (step 3.2.2) and graded system review (step 3.2.3). The Phase 11 document review shall be completed as pan of the FSAR review identified in step 3.2.6.
Step 3.2.1.b. Unit-SpeciSc Assess:nents This activity shall be implemented as described in the CMP and completed as part of Phase 1. Results from the Key Audits and Assessments Review shall also be evaluated.
Step 3.2.1.c. Employee Concerns This activity shall be implemented as described in the CMP.
Step 3.2.1.d. Walkdowns and System Readiness Reviews This activity shall be implemented as described in the CMP and completed as part of Phase I. Walkdowns and system readiness reviews shall be conducted during graded system reviews (step 3.2.3) to allow discovery of any open issues which may affect plant safety.
)
1 l
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.[. Rn. 2 Level of Use w . ww w tam Information % M of 54
1 l
Attachment 3 i Millstone Unit 3 CMP Implementation Plan (Sheet 5 of 7)
Step 3.2.2 Licensing Basis This activity shall be implemented as described in the CMP as pan of the "venical slice" confirmation of the LB and DB for selected systems to) support Phase 1. The following summarize the rationale supponing the justification for the vertical slice review:
- The MP3 FSAR was developed and issued in accordance with the standard format and content of Regulatory Guide 1.70. The NRC reviewed this report using their Standard Review Plan and issued i
the MP3 license based on this review. The format and review l provide for a consistent and thoroughly documented design basis.
l
- During MP3 licensing, several internal FSAR reviews were completed for confirmation of FSAR, and Technical Speci5 cation accuracy.
- The original Architect Engineer and NSSS supplier have provided design support to MP3 since plant stanup. Also, many individuals ;
involved in the construction phase continued on the unit through i
the present 10 years of operation. This ongoing suppon has '
provided continuity with the original design basis.
- A sort of ACRs related to the FSAR shows no adverse trend of discrepancies related to FSAR accuracy which would result in unsafe plant operation. ,
- A sample review of LERs shows no adverse trend of discrepancies related to FSAR accuracy which would result in l
unsafe plant operation.
A venical slice of the LB and DB shall be reviewed as specified in NUC PI 15," Selected Millstone Unit 3 System Reviews," as pan of the Phase I review. Systems included in this review shall be selected based on their contribution to plant risk. System selection shall include sufficient scope to encompass systems with major contribution to the plant Core Meh Frequency.
I This venical slice review shall be performed by an Independent Review l Team (independent from the established Project Team), which reports to the Director, Design Engineering.
4 The scope of LB review is covered in NUC PI 15," Selected Millstone Unit 3 System Reviews" (venical slice reviews).
i CMP Level of Use 'sTOP i J.i
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Attachment 3 Millstone Unit 3 CMP Implementation Plan (Sheet 6 of 7) i Step 3.2.3 Graded System Review l
l This activity shall be implemented as described in the CMP as part offhe Phase I review by performing walkdowns and system readiness reviews. This l approach is based on the justification provided in Sectior,3.2.2 and shall be
- confirmed by the "venical slice" review.
l Walkdowns and system readiness reviews are the processes whereby System l Engineers and other team members ensure their systems are screened for !
i outstanding work activities. These processes include reviewing appropriate system documentation, restart criteria, work orders, and other outstanding hardware or engineering issues (such as bypass jumpers, Trouble Repons, etc.); and performing field walkdowns.
l As a confirmation that configuration controlissues do not exist at MP3, l closed PDCRs shall be walked down for comparison of"As Built" conditions i and design drawings. PDCRs selected for DB walkdown shall be reviewed and approved by the MOC and shallinclude those Group 1 systems which l (upon review) should have resulted in an FSAR change.
1
! Systems selected for walkdowns and system readiness reviews are based on attributes contained in the Maintenance Rule Unit Basis Document.
The systems are grouped in accordance with Attachment 7.
l Group 1 systems shall be subject to walkdowns and system readiness reviews. The system readiness review shall include an examination of design changes performed on the subject syc.em, and a review of AWOs performed on the system since 1983. If a significant deficiency (such as l reportability issue, operability determination, challenge to plant safety, l etc.) is discovered, the deficiency shall be reviewed for generic implications. If necessary, additional Group 2 systems shall be selected.
l If any deficiency is discovered in this additional review of Group 2 systems,
! the review effort shall be expanded to include Group 2 systems and
! additional PDCRs. Any deficiency discovered in this additional review shall result in the review of two additional Group 3 systems.
i l Step 3.2.4 Resolution
'Ihis activity shall be implemented as described in the CMP.
l
< CMP Level of Use ,::
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- s ci "iNvied Rev. 2 Information 5 Ms 33 of 54
Attachment 3
. Millstone Unit 3 CMP Implementation Plan (Sheet 7 of 7)
Step 3.2.5 Plant Verification and Readiness Team This activity shall be implemented as described in the CMP as part of the Phase 11 review. A review of the FSAR shall be completed to verify "
operating practices are in accordance with the LB and DB.
Step 3.2.6 Design Bases Documents and UFSAR Changes This activity shall be implemented as described in the CMP by performing walkdowns and system readiness reviews as part of the Phase I review. Any PSAR discrepancies identified as a result of this CMP shall be corrected in accordance with existing procedures.
As part of Phase II, a complete review and comparison of the FSAR to the LB and DB, plant design changes, DBDPs, etc., shall be completed.
Existing DBDPs shall be upgraded to DBDs as part of Phase II, as follows:
- Validate existing DBDPs so they are qualified Design Inputs.
- Summarize the original license basis, SER, and subsequent commitments and Amendments to form a single-source LB.
Step 3.2.7 Configuration Management This activity shall be implemented as described in the CMP as part of Phase I and Phase II. Where the process or procedure corrections will not be in place prior to completion of Phase I, interim configuration management controls evaluations shall be performed to ensure that sufficient interim controls are in place to avoid future configuration control issues.
Step 3.2.8 Independent Assessments This activity shall be implemented as described in the CMP and shall be completed for Phase I and Phase II activities.
Step 3.2.9 Short-term and lang-term Communications and Trainin_r shall be This activity shall be implemented as described in the CMP a.
completed for Phase I and Phase II activities.
I i
i CMP Rev. 2 Level of Use ..
~5 TOP ~THINK 1JACT - _' REVIEW t
- y of g Information .
Attachment 4 Connecticut Yankee CMP Implementation Plan (Sheet 1 of 3)
)
} Overview:
I The CMP will be implemented in two phases for Connecticut Yankee. Phase I is%e completion of the set of CMP activities that must be performed to respond to the 10 CFR 50.54(f) letter. Phase II is the completion of the remaining CMP activities.
Step 3.2.1 Discovery This activity shall be implemented as described in the CMP.
Step 3.2.1.a. Document Resiew This activity shall be implemented as described in the CMP.
Step 3.2.1.b. Unit-SpeciSc Assessments This activity shall be implemented as described in the CMP.
Step 3.2.1.c. Employee Concerns !
This activity shall be implemented as described in the CMP.
Step 3.2.1.d. Walkdowns or System Readiness Reviews This activity shall be implemented as described in the CMP.
The walkdown process for LB and DB attributes presented in NUC PI 16," Licensing Basis and Design Basis Walkdown," shall include (as a minimum) Group 1 systems, as defined below and described in Attachment 7:
. 4160 VAC
- 480 VAC
. Charging
- Containment
- Containment Ventilation
- Control Air
= DC Distribution
= Emergency Diesel
P . _y.J.
mm Rev.2 Information 35 of 54
Attachment 4 i
Connecticut Yankee CMP Implementation Plan (Sheet 2 of 3)
Step 3.2.1.d. Walkdowns or System Readiness Resiews (Cont'd) i Intake (SW) ,
- Pressurizer
- Reactor Protection
- Refuel Water Storage Tank
- Safety injection (actuation)
- Semi-vital AC
- Senice Water
- Vital Distribution If a significant deficiency (such as reportability issue, operability determination, challenge to plant safety, etc.) is discovered in a Group 1 system, the deficiency shall be reviewed for generic implications. If necessary, systems from Group 2 shall be selected as applicable.
Step 3.2.2 Licensing Basis This activity shall be implemented as described in the CMP.
Step 3.2.3 Graded System Review This activity shall be implemented as described in the CMP Systems reviewed shall be Group 1 systems, as defined in Attachment 7.
Step 3.2.4 Resolution This activity shall be implemented as described in the CMP.
1 l
7 CMP Level of Use N -- .. .
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Attachment 4 Connecticut Yankee CMP Implementation Plan l
(Sheet 3 of 3) i Step 3.2.5 Operation Practices and Policies Y :
This activity shall be implemented as described in the CMP.
)
Step 3.2.6 Design Bases Documents and UFSAR Changes This activity shall be implemented as desented in the CMP. Final products associated with this CMP for CY shall include:
- = For Group 1 systems, documented Design Basis and DBDs l l
Step 3.2.7 Configuration Management This activity shall be implemented as described in the CMP.
Step 3.2.8 Independent Assessments This activity shall be implemented as described in the CMP.
Step 3.2.9 Short-term and Long-term Communications and Training This activity shall be implemented as described in the CMP. i i
l i
- ~ CMP E -! - . . _
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lnformation x 07 of 54
Attachment 5 Definitions ,
l (Sheet t of 4)
- Licensing Basis (LB):
- The set of applicable NRC requirements :
- Written commitments that are docketed and in effect
- The design bases Definition:
Licensing Basisfor each unit is that set of requirements that includes the applicable NRC regulations and licensee commitments that ensure the unit's operation in confonnance with the operating license, the unit's design basis in accordance with 10 CFR $0.2, NRC regulations includmg 10 CFR 50.59, and the unit's UFSAR.
Discussion: " Applicable NRC requirements" include regulations contained in 10 CFR parts 2,19,20,21,30,40,50,51,54,55,70,72,73, and 100 and appendices thereto; orders; license conditions; exemptions; and technical specifications. " Written commitments" are statements made in docketed correspondence such as responses to NRC bulletins, generic letters, and enforcement actions, as well as commitments contained in NRC safety evaluations (SERs) or licensee event reports (LERs). "In effect" clarifies that commitments may be superseded by later commitments or correspondence, or by properly implemented changes in plant configuration.
NUREG-1397 summarizes the licensing basis as "the NRC requirements imposed on the plant that are currently in effect." For this CMP and associated Project 17structions," Licensing Basis" and "LB" shall refer to the set of applicable NRC requirements and written commitments that are docketed and in effect. " Design Bases" are defined and identified separately.
Examples:
~
- The unit complies with Regulatory Guide 1.27," Ultimate Heat Sink for Nuclear Power Plants."
. The unit commits to having a third RO on shift.
- To prevent recurrence of this event, the unit has installed an additional check valve.
Sketch of relationship of EDB, DB, and LB:
( E h LB )
CMP Level of Use .. s . .- _' - Rev. 2 STOP THINK UACT ' REVIEW Inforrnation j,
. 38of54
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i Attachment 5 Definitions (Sheet 2 of 4)
~
- Design Bases (DB): j
- Information which identifies the specific functions to be performed by 3a l structure, system, or component The specific values or range of values chosen for controlling parameters as reference bounds for design Citation (10 CFR 50.2):
Design bases rneans that infonnation which idennfles the specificfuncuans to be perfonned by a structure, system, or component of a facili.y, and the specific value or range of values chosen for controllingparameters as reference boundsfor design.
These values may be (1) restraints derivedfrom genen.lly accepted " state of the an" practicesfor achievingfunctionalgoals, or (2) reparements derivedfrom analysis (based on calculation and/or experiments) of the effects of a postulated accidentfor which a structure, system, or component must meet itsfunctional goal.
Discussion: The " design bases" apply onk to those systems, structures, or components which are necessary to assure (i) the integrity of the reactor coolant boundary, (ii) the capability to shut down the reactor and maintain it in a safe shutdown condition, and (iii) the ca,, ability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those discussed in 10 CFR 100.
NUREG-1397 offers the clarification that the design bases include only those constraints that form the bases for the NRC's safety judgement. Design information which does not meet the 10 CFR 50.2 definition of" design bases" may be part of the Engineering Design Bases.
Design bases information is information that would be considered " design inpu This includes details about how a system, structure, or component satisfies regulatory and safety requirements, and specific performance values.
Values used for design bases may be restraints derived from generally accepted
" state of the art" pracaces at rhe time ofdesign for achieving functional goals; or requirements derived from analysis of the effects of a postulated accident for which a stmeture, system, or component must meet its functional goal.
Examples:
= Each system has two independent subsystems, each capable of performing the functional requirements.
- 2,750 gpm must be supplied to mitigate the consequences of . . . .
Sketch of relationship of EDB, DB, and LB:
(E LB )
^
,A-4 CMP
~ ~ - -_
Level of Use 'THINK MCT BEVIEW Rev. 2
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Informat. ion oN ' 39 of 54
Attachment 5 Definitions (Sheet 3 of 4) I l
- Engineering Design Bases (EDB):
- Information which describes a system, structure, or component .,.,
- Operating values or parameters which are not reference bounds for design l
- Information which identifies functions important for economic, maintenance, installation, or other nonsafety function of design basis systems, structures, or components
- Information and operating values describing the functions of nonsafety systems
- Calculations, descriptions, and other " outputs" Citation (NUREG-1397)
The entire set of design constraints that are implemented, includmg those that .tre.
(1) pan of the Licensing Basis andform the bases for NRC's safetyjudgements; and (2) those that are not included in the Licensing Basis but are implemented to achieve cenain economies of operation, maintenance, procurement, installation, or construction.
Discussion: For this CMP and associated Project Instructions, the EDB is that :
information contained in item (2) of the citation; that is, the EDB encompass '
the important design information which is not part of the Design Bases.
The EDB encompass design features as well as functional requirements for the 1
systems, structures, and components. The EDB also include supporting ,
calculations.
Examples:
~
- A bypass line is installed so on-line maintenance may be performed.
- The pump is capable of delivering 3,500 gpm. 1
l lists detailed Bechtel field installation and QC attributes. Many of these l
attributes are part of the engineering design bases, not the design bases.
l Sketch of relationship of EDB, DB, and LB:
( E h LB ) l l
! CMP Level of Use fg 3,cgK.. ' di:T V$iew Rev. 2 Information J 4 40 of 54
Attachment 5 i
Definitions (Sheet 4 of 4) l
- 50.54(f) - Refers to 10 CFR 50.54(f)
- ANI - American Nuclear Insurers ;,
- DBD - Design Basis Document
- Docketed information - Information formally submitted to the NRC or formally l
received from the NRC
- Essential Design Documents (NUREG-1397) - Those design documents that demonstrate that structures, systems, and components addressed by Technical Specifications will perform their active safety function and support er demonstrat the conservatism of Technical Specification values. Additionally, essential design documents are those necessary both for use by engineering to support plant l
operations in responding to plant events and for use by operators to quickly respond to plant events. Examples include but are not limited to electricalloa lists, setpoint lists, valve lists, instrument lists, fuse lists, breaker lists, EEQ lists, diesel generator load sequencing, P& ids, flow diagrams, schematics, and break and fuse coordination studies.
- FSARCR - Final Safety Analysis Report Change Request
- ISEG - Independent Safety Evaluation Group
- RATI - Readiness Assessment Team Inspection
- SEP - Systematic Evaluation Program (for CY and MP1)
!
- SRP - Standard Review Plan
! l l
}
CMP L. 2 . .
l Level of Use Information w
~p _ m ev.2 41 of 54
_. ._ . ~ . - - . . - . . - - - - . - . . - . - . .- ._ . - . - . -.
Attachment 6 Topical Areas (Sheet 1 of1)
A. The following topical areas shall be addressed on a unit-specific basis:
j
. ATWS
. Control Room Design Review
. EEQ
. Erosion / Corrosion
. External Events / Hazards (Tornado, EQ, Flood)
. Generic Letter 89-10 (MOV) .
- HELB/MELE
- Inservice Inspection
. IPEEE
- Master Equipment and Parts List (MEPL)
. Regulatory Guide 1.97 Compliance
. Safe Shutdown /10 CFR 50 Appendix R Compliance
. Separation / Independence / Diversity
. Setpoint Control
. Single Failure
. Station Blackout i
. 10 CFR 50 Appendix J Compliance .
i
- USI A46
. Heasy loads B. Additional topical areas from the following may be identified during CMP implementation:
. Code of Federal Regulations
- NRC Generic Letters, Inspection and Enforcement Bulletins
. Regulatory Guides
. SEP Topics !
. Standard Review Plan i TMI ActionItems b CMP Level of Use ., SToE THINK <%CT TEVIEW Rev. 2 Informat. ion 42 of 54
I Attachment 7 Graded System Selection (Sheet 1 of1)
The Maintenance Rule Unit Basis Document contains a tabulation which states whether each system is (or is not) safety-related, accident mitigating (Chapter 15),
referenced in EOPs; and whether the system causes a scram, or is risk significantbr in-scope. This tabulation provides a basis for grading systems for this CMP.
Recommended groupings and the scope of each grouping are as follows:
Group 1: All systems that are both safety-reled and risk-significant Group 2: All remaining systems that are either safety-related or risk-significant Group 3: All remaining systems considered in-scope to the Maintenance Rule Group 4: All remaining systems The relationship of these groups is shown below:
Vaintenance Ru e Attriautes
' . . =
Group 2 w
& i6 cant g safew Aaleted Egni6 cant s
9 s
\ ,
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- i CMP Level of Use ggg . ~ THtNK SAcT -
~
%EviEff Rev. 2 Information
~
43 of 54
l 1
I Attachment 8 l CMP Implementation Organization (Sheet 1 of 1) l I
'k Executive Executive Vice President Committee VP Nuclear Operations SVP Nuclear Safety &
Oversight Director Design VP TechnicalServices Engineg VP Work Services l Independent h Assessment Unit Director *
- Co- chairs Team Management Director, 2 Quality '
Design Engineering
- Conimittee NS&O Representauve h car Licensmg Representative ,h y Unit Project Manager I Urut Design Configuranon Engineering Management Manager Manager 17 QAS Process Unit Project Manager Monitoring >
MP1 MP2 52 MP3 TrauunS Lsaison CY }
' V V___________..______ '
m wa V
V l Root Cause l Con 5guranon Design J Management y Engineenng Team I
l PVRT l sr Operations Maintenance I&C f
Iacensing
'P Design Bases Eng. Programs Chemistry Identification Identification Commitment I.zad GTS 1.zad Lead System Engineering CMP
~.-
Rev. 2 Level of Use SToP ' THiNK
' *ACT TEVIEv/
44 of 54 gnformat. ion - + ~' w
Attachment 9 Project Instruction Cross-Reference Table (Sheet 1 of1)
Topic Project Instruction (s)
Section See section 3.2.1.a. through section 3.2.1.d. below 3.2.1 >
Discovery f
3.2.1.a. Document Identification NUC PI 1 and Retrieval f
3.2.1.b. Unit-Specific Assessments NUC PI 2 and NGP 3.15 3.2.1.c. Employee Concerns NUC PI 3 Walkdowns or System a NUC PI 4, " Millstone Unit 3 Walkdowns" 3.2.1.d. NUC PI 5, " Millstone Unit 3 System Readiness Readiness Reviews Review"
- NUC PI 16, " Licensing Basis and Design Bases Walkdowns" {
3.2.2 Licensing Reviews NUC PI 6 3.2.3 Graded System Review NUC PI 7 3.2.4 Resolution Included in NUC PI 14 3.2.5 Plant Verification and NUC PI 8 Readiness Team a NUC PI 9 for DBD portion; 3.2.6 Design Bases Documents and UFSAR Changes
- UFSAR changes covered in NGP 4.03 and NUC PI 13 3.2.7 Configuration Management NUC PI10 3.2.8 Independent Assessment NUC PI11 3.2.9 Short-term and
- NUC PI 12 for communications Long-term . Training addressed in NTM-7.202 and Communications and NGP 2.26 Training 3.5 Project Process NUC PI 14 Administration Attachtnent Selected Millstone Unit 3 NUC PI 15 3 System Reviews Level of Use m .STOP THINK
.'t ACT- . . .
MEVIEW CMP Rev. 2 g 45 of 54 i
- - - - - - - - - _ _ _ _ _ _ _ _ - _ _ _ J
Attachment 10 Configuration Management Plan Charter and Organizational Roles (Sheet 1 of 8)
~
Implementation of this CMP requires management focus and constancy of purpose.
With the four Connecticut nuclear plants being addressed through this project, the opportunity for diversity in response and end products exists. Vrith this possibilig in mind, the project is being structured to minimize this possibility through a combination of the Configuration Management Plan, Project Instructions, and the establishment of Committees and Key Functional Areas.
This document establishes the charter, roles and responsibilities, and hierarchy for the different committees charged with management oversight of the project. These '
committees are:
l
- Executive Committee
- Management Quality Committee In addition, the charter, roles, and responsibilities for the following Key Functional Areas are also presented:
- Unit Project Manager
- Design Engineering Team
- Unit Licensing Bases Area
- Configuration Management Team
- Plant Verification and Readiness Team CMP Level of Use gcg g NK TACT StEVIEw Rev. 2 Information ,
3' 46 of 54
Attachment 10 Configuration Management Plan Charter and Organizational Roles (Sheet 2 of 8) l Executive Committee !
J
- )
- 1. DESCRIPTION This committee is comprised of the Executive Vice President (Chairman);
Vice President, Operations (Vice-Chairman); Vice President, Technical '
Services; Vice President, Work Services; and Senior Vice President, Nuclear Safety and Oversight.
- 2. CHARTER Develop the vision and objectives for the CMP. Review the overall Project plan.
Develop expectations for oversight, management, and the use of key performance indicators for measuring project progress against a set of standards.
Foster and reinforce a culture of quality and thoroughness. On a periodic basis, monitor individual functional area performance through direct observation.
Ensure constancy of purpose and approach is maintained among the four Connecticut nuclear units.
- 3. ROLES AND RESPONSIBILITIES 3.1 Provide leadership and executive presence for the project. (LEAD) 3.2 Review the plan for completing the CMP. (PLAN) 3.3 Ensure project activities represent a prudent and practical approach.
(DO) 3.4 Monitor key activities to assure adherence to CMP objectives.
(MONITOR) 3.5 When required, ensure adjustments are factored into project plan.
(ADJUST) ,
- 4. HIERARCHY Reports to: President, Northeast Utilities Direct Reports: Management Quality Committee
! CMP Level of Use 'sToP' %!NK mACT BEVIEW Rev. 2 gnformation
?i 47 of 54
Attachment 10 Configuration Management Plan Charter and Organizational Roles (Sheet 3 of 8)
Management Quality Committee l
n L DESCRIPTION This committee is comprised of the Unit Director (Co-Chairman), Director of Design Engineering (Co-Chairman), a Nuclear Licensing Representative, and a Nuclear Safety and Oversight Representative (non-voting member). The Unit Project Manager is also a non-voting member of this comminee and prepares agendas and minutes for each meeting.
- 2. CHARTER Foster and reinforce a culture of quality and thoroughness. On a periodic basis, monitor individual functional area performance through direct observation.
- 3. ROLES AND RESPONSIBILITIES 3.1 Review CMP Implementation Plan (and changes thereto). (PLAN) I 3.2 Provide leadership and focus for the unit-spe. aic effort. (DO) 3.3 Through direct observation of key project activities, ensure focus and direction are maintained in accordance with the CMP, Project Instructions, and the unit-specific implementation plan. (MONITOR) 3.4 Unit Director ensure that activities associated with this project are integrated into the overall unit startup plan (where applicable).
(MONITOR) 3.5 Unit Director and VP, Nuclear Operations meet periodically to ensure constancy of purpose and consistent approach for the overall plan.
(MONITOR) 3.6 Using Nuclear Safety and Oversight and industry experience reports (generated by visiting other plants), institute process improvements supportive of the Nuclear Excellence Plan. (ADJUST) l
- 4. HIERARCHY Reports to: Executive Committee Direct Reports: Unit Project Manager CMP Level of Ur,s .,1 -
- Rev. 2
'5 TOP m 'TH:NK .6ACT ~ m Ew gnformat. ion a s 48 of 54
Attachment 10 Configuration Management Plan Charter and Organizational Roles (Sheet 4 of 8)
I Unit Project Manager
- 1. DESCRIPTION p The Unit Project Manager implements the Project Instructions and the unit-specific implementation plan. In so doing, the Unit Project Manager ensures compliance with the CMP.
- 2. CHARTER Directly responsible for implementing the CMP. Balance the requirements of maintaining a unit focus while ensuring that a consistent approach is used for the four Connecticut nuclear units.
- 3. ROLES AND RESPONSIBILITIES i
3.1 Establish unit-specific implementation plan. Develop budget and staffing requirements. Work with assigned functional area leads to establish project schedule. (PLAN) 3.2 Develop agenda and meeting minutes for Management Quality Committee meetings. (DO) 3.3 Prepare routine re: ports (based on project-specific Key Performance Indicators) for management. (MONITOR) 3.4 Ensure program requirements for training, compliance with CMP, PIs, and i umt-specific implementation plan are met. (ADJUST) i t
- 4. HIERARCHY Reports to: Management Quality Committee Direct Reports: r
- Unit Plant Verification and Readiness Team Lead
- Unit Design EngineeringTeam Lead l
l t
h
/.
g.. egg Level of Use g7. .<g' Ew Rev. 2 lnformatIOD MN 8^
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49 of 54
Attachment 10 Configuration Management Plan Charter and Organizational Roles (Sheet 5 of 8)
Design Engineering Team
- 1. DESCRIPTION In a matrix arrangement reporting to the Unit Design Engineering Manager, this Team is led by an individual experienced in the Design Engineering discipline.
A comparatively large group, this area includes groups focused on specific design features for systems (mechanical, electrical, and I&C) as well as program requirements such as HELB, SBO, electrical separation, etc.
- 2. CHARTER Using design records, locate, categorize, and classify items in accordance with t
definitions and instructions contained in the CMP and Pls.
Based on this effort, establish LB ar.d DB for identified systems.
- 3. ROLES AND RESPONSIBILITIES 3.1 Review Project Instruction and establish schedule. (PLAN) 3.2 Determine the technical adequacy of the unit's Design j Engineering-assigned activities. (DO) 3.3 Confirm or modify LB and DB for in-scope systems as follows: (DO) 3.3.1 Discover design-related information for in-scope systems.
3.3.2 Classify information, generate, and validate (as appropriate) the following:
. Topical papers for key regulatory guidance (separation, HELB, etc.)
. FSARCRs as required
. DBDs (after systems are reviewed) 3.4 Evaluate program impacts by system for inclusion in DBDs. (MONITOR)
- 4. HIERARCHY Reports to: Unit Project Manager and Unit Design Engineering Manager Direct Repons: Group Staff
- h n l CMP Level of Use .a . . . w n ..
7H:NK mA VACT,- REVIEW Rev. 2 gnformation pP , ;. d. MN k 50 of 54
I l
- Attachment 10 Configuration Management Plan Charter and Organizational Roles (Sheet 6 of 8)
Unit Licensing Bases Area
.,3
- 1. DESCRIPTION i This functional area is comprised of a lead Licensing representative and NU '
Licensing and contractor personnel. This functional area is charged with identifying licensing commitments that establish or modify design bases for the unit.
- 2. CHARTER Using the LIST database, review all licensing correspondence and docketed coriespondence to or from the NRC.
Working with the Project Instructions, screen information contained in the database to develop commitment data associated with the LB and DB.
- 3. ROLES AND RESPONSIBILITIES ,
3.1 Using the LIST database, identify key regulatory guidance related to LB ,
and DB. !
3.2 Assist in the development of unit-specific position papers on selected '
regulatory guidance documents.
3.3 Using the LIST database, identify LB and DB commitments.
3.4 Assist in determining and identifying implementing documents for LB and DB commitments.
- 4. HIERARCHY Reports to: Design EngineeringTeam 1. cad Direct Reports: Group Staff l l
< CMP Level of Use . 2 m o .n. ~e.
Rev. 2 l
^STOP THINK M CT .' REVIEW gnformat. ion pq r
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51 of 54 1
Attachment 10 l Configuration Management Plan Charter and Organizational Roles (Sheet 7 of 8)
Configuration Management Team y
L DESCRIPTION This team represents a consistent approach to configuration management for the four Connecticut nuclear units. The team is comprised of a Manager who is a recognized leader in the configurat:on management field, and individual unit representatives who are familiar with NU programs, processes, and procedures; and with configuration management concepts.
- 2. CHARTER Provide controls necessary to ensure the following:
- Physical and functional attributes of NU nuclear plant structures, systems, and components are consistent with the established design configuration.
- Plants are designed, maintained, and operated consistent with LB and DB.
- Information describing these attributes is readily accessible and adequately controlled.
- 3. ROLES AND RESPONSIBILITIES 3.1 Review programs, processes, and procedures to assure good configuration management controls are employed; recommend and implement shon-term enhancements as needed.
3.2 Recommend strategies and approaches for long-term improvements to the Configuration Management Program.
3.3 Monitor effectiveness of the Configuration Management Program and propose additionalimprovements as needed.
- 4. HIERARCHY Reports to: Director, Design Engineering Direct Reports: Group Staff ;
I l
Level of Use e- A. 2. .- .
, j _. NP "STOP 7MNK '2^ACT ~ TiEVIEW Rev. 2 gnformation t p, ,
52 of 54
Attachment 10 Configuration Management Plan Charter and Organizational Roles (Sheet 8 of 8)
Plant Verification and Readiness Team
- 1. DESCRIPTION v>
This team represents an operations-focused team charged with venfymg that plant operational practices are reflective of the design bases. This team is a multi-disciplined group of senior representatives (from Operations, j
Maintenance,I&C, Chemistry, GTS, and System Engineering) experienced with l
the operation and maintenance of the unit.
I
- 2. CHARTER Recognizing that Operations is the end effecter for implementation of design requirements into plant operation, establish the baseline relationship between the design bases and operational controls.
Provide assistance to Engineering in establishing how integrated system operation affects the design bases.
Ensure sufficient diversity exists at each team meeting to support full and complete discussions of operational practices as they relate to the design bases.
- 3. ROLES AND RESPONSIBILITIES 3.1 Directly verify that operational controls exist for design bases attributes.
3.2 Ensure any UFSAR changes or revisions represent operational practice and can be interpreted in a consistent manner by the Operations staff.
3.3 Working with the Configuration Management Team, identify potential ,
operations-generated change agents that could impact the Configuration Management Model.
3.4 Following discovery, lead o; aility reviews of systems required to be operable to support on-gou.g unit actisities.
3.5 Direct system readiness reviews and recommend for approval.
3.6 Direct and manage structured walkdowns and physical plant verification effons.
- 4. HIERARCHY Reports to: Unit Project Manager Direct Reports: Group Staff I
CMP Level of Use Nd ~
Th Vbesi
- Rev.2 Information f f% 53 of 54 l l
Attachment 11
, Process Flow Chart (Sheet 1 of1)
NOTE: The following are used on a NUC PI 1. NUC PI 6, continual basis throughout the process:
" Document " Licensing Reviews"
- NUC PI 3 .
Identification &
- NUC PI 11 P Retrieval"
- NUC PI12 Position Ucensing
" System NUC PI 4,"Walkdom ns," Readiness NUC P12, or Review"
" Unit-Specific NUC PI 16,"LB & DB or NUC EN Assessments" Walkdowns" * (Later)
- d w d d 9r y NUC PI 7. " Graded System Review" 4-' ,
NUC PI 10, h l " Configuration Management,"
NUC PI 8,
( " Plant Verification & Phase 1 Phase 2 Readiness Team" h
FinalSystem Package from NUC PI 7 NUC PI 13, NUC PI 9, "UFSAR I 1P I " Design Basis Changes" Documents"
,, . & Phase 1is complete. 2
- w w I r , l l !
- l l
l v 6 Completion of remaining a w w CMP ac:ivities.
- As applicable on E a unit-speciSc basis Phase 2 is complete.
- e 1. y Level of Use -c /
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' REVIEW Informat. ion -
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( NORTHEAST UTILITIES NUCLEAR s:, c^4 ~s MA 1 CY
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NUC PI1 '%<
Rev.O This Project Instruction (PI)is part ofimplementation of the Configuration Management Plan (CMP).
- h. .
Approval Effective v
~
Mtg. No. Date Date Millstone SORC pg,jc,7 g,jg9j CY PORC __
MP1PORC MP2 PORC .
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MP3 PORC i _
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( Responsible Individual:
Level of Use D. Sipple Information Subject Matter Expert:
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MP1, MP2, MP3, CY I Project Instruction Document Identification and Retrieval .
TABLE OF CONTENTS 1 l
- 1. INSTRU CTI ON S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Establishing Document Identification and Retrieval Team . . . . . . . 2 1.2 Training Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Document Identification and Retrieval . . . . . . . . . . . . . . . . . . . . . . . 3 1.4 S creening Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1.5 D elive rable s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
-i .~6___:Discriipan~cies ..
...r.r. ;~. .... n. _ . .. _ ;..: ..... o
- 2. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ,
- 3. CO MMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 j
- 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 A'ITACHMENTS AND FORMS f
Attachment 1, " Process Flow Chart" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Attachment 2, " Plant Design Change Information Locations" . . . . . . . . . . 9 Attachment 3, " System Program Information" . . . . . . . . . . . . . . . . . . . . . . 10 Attachment 4, " Plant Design Information" . . . . . . . . . . . . . . . . . . . . . . . . . 11 l
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- 1. INSTRUCTIONS This Project Instruction provides direction to identify and retrieve (obtain) documents that potentially affect plant con 6guration. These documents are for the systems (and programs) included in the reviews, as outlined in the CMP, on a unit specific basis. Attachment 2 through Attachment 4 list the types of documents identified and retrieved.
Deliverables from performance of this PI (identified in Section 1.5) are used in further evaluations covered in other PIs.
The document review process may be accomplished on a system basis or other logical basis as determined by the Unit Project Manager or project team.
Attachment 1 contains a process flow chart for this PI.
1.1 Establishing Document Identification and Retrieval Team 2
Design 1.1.1 ESTABLISH a Document Identification and Retrieval Team.
Engineering Lead or System Team Leader 1.2 Training Requirements Design 1.2I1 VERIFY Document Identification and Retrieval Team are trained Engineering On the following:
. Overall CMP effort and applicability of this PI to the effort
. PI deliverables and the importance of producing quality deliverables to the success of the overall CMP effort
. Available resources (such as LIST program, PMMS, etc.)
used to aid in identifying required information
. Departmental interface contacts assigned to assist in this effort
. Applicable interface procedures (such as those controlling processes for nuclear records)
- T V" + w T[ ** y
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1.3 Document Identification and Retrieval NOTE
- 1. Attachment I shows the process flow chart.
- 2. Areas to be searched for various types of information are shown on Attachment 2. The term " Plant Design Change" (PDC) is used to encompass all of these various document types.
- 3. Attachment 3 and Attachment 4 show tymes ofinformation included under generic terms " system program iformation" and " plant design documentation."
~
- 4. Step 13.1 through step 13.4 may be performed in any order for assigned system.
Document 13'.1 Refer To Attachment 2 (for types and locations of PDCs) and identification t IDENTIFY and OBTAIN applicable PDCs for the assigned and Retrieval Team Dtem.
13.2 IDENTIFY and OBTAIN procedures and logs that install bypass
. jumpers from the following departments:
.I&C
- Generation Test Services
. Maintenance
= Engineering -
. 133 Refer To Attachment 3 and IDENTIFY and OBTAIN applicable program information.
13.4 Refer To Attachment 4 and IDENTIFY and OBTAIN applicable plant design documentation as required for the assigned system.
13.5 SORTitems by system, as applicable.
13.6 IE item affects more than one system, COPY item as needed to address all affected systems.
13.7 COMPILE a Document Review List and a system documentation
. package and FORWARD the list and package to the assigned
- reviewer for screening review.
nformation
'b V {"~ K ~V fif" 0 jgqq jpg jp%s P 3 of11
1.4 Screening Review
~
NOTE Step 1.4.1 and step 1.4.2 are performed concurrently..
System Team 1.4.1 REVIEW each document on the Document Review List and Engineer or PERFORM the following for each document:
Technician
- IE the PDC document is closed, Go To step 1.4.2.
- IE the PDC document is open, PERFORM the following:
- Refer To NUC PI 14," Project Process Administration," and ENTER the open PDC in the discrepancy database.
1.4.2 COMPILE system design document file and/or database and
(
ROUTE to Graded System Review Team (GSRT).
1.43 IE additional support system information is requested by.
NUC PI 7, " Graded System Review," Go To Section 13 and INITIATE the identification and retrieval process for the applicable portion of the supporting system.
NOTE Document identification and retrieval' process is now complete for the assigned system.
f 5 h 8 NUC PIl Level of Use ,ygv g7 yg.Tdn/~ Rev.0 Information ,
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1.5 Deliverables NOTE -
The results of this PI are used during performance of other portions of CMP implementation.
System Team 1.5.1 VERIFY the following deliverables result from the performance Engineer or of this PI:
Technician
- A system design document file and/or database for each applicable Maintenance Rule system
. Listing of open PDC documents I
i I .
1 i
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1.6 Discrepancies
~
NOTE Resolution of discrepancies is addressed in NUC PI 14, " Project Process Administration."
system Team 1.6.1 IE required, Refer To the applicable procedure and INITIATE an Engineer or ACR for each identified discrepancy:
Technician
- RP-4," Adverse Condition Resolution Program" (for Millstone)
- ACP 1.2-16.5," Adverse Condition Report Process Implementation" (for Connecticut Yankee)
. t t
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.- 2. REFERENCES I 2.1 Configuration Management Plan (CMP) 2.2 RP-4," Adverse Condition Resolution Program" 2.3 ACP 1.2-16.5," Adverse Condition Report Process Implementation"
. (for Connecticut Yankee) 2.4 NUC PI 6," Licensing Review of Correspondence" 2.5 NUC PI 9," Design Bases Documents" i 2.6 , NUCPI14,"ProjectProcess Administration"
- 3. COMMITMENTS None
- 4.
SUMMARY
OF CHANGES 4.1 OriginalIssue i
A A A A NUC PI1 Level of Use .et_.
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Maintenance Rule System" 46 r
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PDCRs, PDCEs, Tech Spec Procedures RIES Plant Design
, EDCRs, DCNs, and with Bypass Documentation .
DCRs, FSAR Calculations Changes Jumpers [ C RESTART i
'F 'F process for applicable portion
~
1F of support system J 2 A i SystemProgram I PERFORM screening review. '
Information REVIEW PDCs and IDENTIFY design I documents.
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NUC PI1processis complete NO y for assigned system.
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Attachment 2 !
Plant Design Change Information Locations (Sheet 1 of1)
Unit trackinglogs Project
& file cabinets Assignments PDCRs !
PDCEs Tech Spec ,
NuclearRecords EDCRs i and FSAR - _ Nuclear Records '
Nuclear Vault DCNs changes Nuclear Vault i Documentation Control DCRs Documentation Control Cales Implementingdephent Unit trackinglogs records & file cabinets LIST Program Licensing files Project Assignments l
(
Operation Bypass Work Orders Jumper Logs OPS procedures
& instructions Bypass Nuclear Records l RIES TechnicalSupport (EOPs, ONPs, ops, SPs. Jumpers l SPROCs, etc.)
l Implementing depart:nent Unit trackinglogs procedures & instructions (including SPROCs &
surveillances) .
l l .
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Attachment 3 System Program Information (Sheet 1 of1) 1 ControlRoom Design Reg Guide 1.97 Review Compliance EEQ Safe Shutdown 1
i ExternalEvents/ Hazards 10 CFR 50 Appendix R l (Tornado, EQ, Flood) Compliance Erosior/ Corrosion Station Blackout 0 Master Equipment & Program Setpoint Control Parts List (MEPL) Documentation Generic Letter 89-10 10 CFR 50 Appendix J (MOVs) Compliance IGT R/MELB HeavyIAads InserviceInspection USI A46 IPEEE 5.
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Attachment 4 Plant Design Information (Sheet 1 of1)
FSAR . Tech Specs
- SEP SERs Plant Design System Speci5 cations Documentation P& ids EquipmentSpecifications VTuing Diagrams Vendor Manuals Logic Diagrams i
Vendor Records Calculations
- Only applicable to Millstone Unit I and Connecticut Yankee
& A 4 i NUC PI1 Level Of Use s- A-
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MACT# REVIEW Rev. O gnf0TmatlOn pq-( jggg j;pg. p; g gg 17
0 NORTHEAST UTILITIES NUCLEAR a: ^
, CY . - .
PROJECT INSTRUCTION $9 K?
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, NUC PI 2 %x, Rev.O This Project Instruction (PI) is part ofimplementation of the Configuration Management Plan (CMP).
A proval Effective Mtg. No. ate Date Millstone SORC gf,jg g g,g,gg g,j 7_g CY PORC MP1PORC MP2 PORC MP3 PORC i
Responsible Individual:
Level of Use G. Pitman lnformation Subject Matter Expert:
G. Pitman 1
Documentation of Training Requirements (comm 3.2)
(Sheet 1 of 1)
R Document InformationiA m WAIA "
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Document Titie: l/M d4(ht fA*1)inMb.
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/Dif5culty of procedure or task 6nsequence ofincorrect procedure performance A.dvice of Nuclear Training Department Name of person contacted at Training Department: h [Cwd c Required for new documenu and revnions only
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Training to be done by Nuclear Training before effective date. t
@ Training to be done by Department or Nuclear Training Department within 60 days of Effective Date and prior to performance of procedure. ;
~
C Familiarization required Methods to Provide Familiarization:
prior to Effective Date. . Department meeting Familiarization required, no a Pre-shift briefing impact on Effective Date. - Pre-work bn.efing No familiarization or . Document Acknowledgement Sheet training required.
Target Group Requidng Training or Familiarization: Enter information pertaining to who requires tramtng or familiarization, which parts of the procedure are applicable, special instructions, etc.
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Approved By: 2h# bb Department HeMr Responsible Individual Date ,
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MP1, MP2, MP3, CY Project Instruction ,
Unit-Specific Assessments TABLE OF CONTENTS
- 1. INSTRU CTI ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Unit-specific Category 'B' ACR Generation . . . . . . . . . . . . . . . . . 2 1.2 Training Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Scope of Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.4 R.eview Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1.5 Review of Key Indicators of Engineering Performance . . . . . . . . . . 5 1.6 Completion of Unit-Specific Assessments . . . . . . . . . . . . . . . . . . . . 5
- 2. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
- 3. C OMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
- 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1
i A A i NUC PI 2 Level of Use .m J. -- ,,-[1,
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- 1. INSTRUCTIONS l l
~
This Project Instruction provides a structured and consistent methodology for i the completion of unit-specific assessments as specified in the CMP. The scope l includes an in-depth assessment to determine the reasons for issues identified l
over the last 2 years (at a minimum) by the NU Connecticut units, Regulators, ;
and other industry organizations. The period to be covered by this assessment '
shall be specified by the appropriate Unit Project Manager (UPM).
Upon completion of each unit's assessment, the other UPMs shall review the other unit reports to identify issues which may be common to one or more of the other Connecticut units. This action could result in changes to the scope of unit-specific CMP activities.
1.1 Unit-specific Categor) 3' ACR Generation NOTE
- 1. ACR 7007 satisfies this requirement for MP Unit 1. +
- 2. The requirement to complete a root cause analysis for these Category 'B' level ACRs may be waived by the Unit Director (MOC) ,
as specified in NGP 2.40," Issues Management and Action Tracking,"
if there would be no value added.
i Unit Projed 1.1.1 INITIATE a Category 'B' ACR to address Licensing Basis (LB) l Manager and Design Bases (DB) issues for the unit. ,
1.2 Training Requirements !
i i 1.2.1 ENSURE all Assessment Team personnel involved in i implementing this PI are trained in the followmg.
. The Configuration Management Plan, including the !
appropriate unit-specific Implementation Plans l
- PI 14," Project Process Administration" !
- PI 2," Unit-Specific Assessments" l L
evel of Use 4
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1.3 Scope of Assessment Assessment 1.3.1 ESTABLISH and DOCUMENT the time frame selected for -
Team assessment of documentation.
NOTE It is the intent that this collection ofinformation be unit-specific, relating to LB and DB issues.
1.3.2 PREPARE h listing of documentation to be evaluated including, but notlimited to, the following: j NRC Inspection Reports related to LB or DB issues and internal notes, matrices, and findings of recent NRC LB or DB team inspections Last two (2)INPO Assessment Reports ISEG Reports relating to process and LB and DB issues
- Relevant QAS Reports (audits, surveillances, etc.)
- NU internal self-assessments
- Applicable unit-specific audits and assessments
- ACR 7007 Event Review Team Report
- ACRs selected based on key word (license, design, process, etc.) searches ,
- NSAB reviews of LB and DB-related issues
- NS&O communications on areas to be covered by the CMP.
1.3.3 FORWARD the results of step 13.1 and step 1.3.2 to the UPM for approval.
lUPM l* 1.3.4 APPROVE the results of step 1.3.1 and step 1.3.2 and RETURN to Assessment Team Leader.
Assessment 1.3.5 ASSIGN documents to the appropriate Team member for Team Leader completion of the review process specified in Seuion 1.4.
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1.4 Review Process Assigned 1.4.1 For each document selected for LB and DB review, PERFORM -
Reviewer the following:
- a. REVIEW the document.
- b. IE the document contains no information useful to the assessment, CLASSIFY the document as "Not Applicable."
- c. IE the document is selected for further review, PERFORM the following:
- 1) COMPLETE a detailed review of the document.
- 2) IDENTIFY and EXTRACT findings, issues, recommendations, etc.
- d. COMPILE the extracted information, including the following: ,
. Source document identification (title, uniqueness number, source, revision and/or issue date)
- Description (using exact wording) of stated or implied findings, issues, or recommendations 1.4.2 As part of the review, CATEGORIZE findings and COMPILE a matrix ofidentified issues against the appropriate ACR 7007 I
categories and others as necessary. (Example: separate bins for 10 CFR 50.59, Appendix R, calculations, configuration control, etc.)
1.4.3 PROVIDE completed matrix to UPM.
lUPM l 1.4.4 REVIEW completed matrix for information on which documents were reviewed and, of those, which were relevant.
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1.5 Review of Key Indicators of Engineering Performance Assigned 1.5.1 COMPILE a set of documents containing key indicators of .
Reviewer engineering performance including, but not be limited to, the j following:
Measures of Performance - Nuclear (the color book) i
. LevelII Measures of Performance 1.6 Completion of Unit-Specific Assessments 1.6.1 Using the compilation ofinformation assembled through completion of activities covered in preceding sections of this PI, ASSESS the adequacy of unit-specific CMP scope.
1.6.2 PROVIDE a comprehensive final report containing conclusions and recommendations relating to concurrence with or appropriate modifications to the CMP scope to the UPM (for ultimate presentation to the unit MQC) and to the UPM at each of the other Connecticut units.
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. 2. REFERENCES 2.1 NGP 2.40," Issues Management and Action Tracking" 2.2 Configuration Management Plan t 2.3 RP-4," Adverse Condition Resolution Program" (for Millstone) .
i 2.4 ACP 1.2-16.5," Adverse Condition Report Process Implementation" (for Connecticut Yankee) 2.5 NUC PI 6," Licensing Reviews" ,
2.6 NUC PI 14, " Project Process Administration" ,
- 3. COMMITMENTS None
- 4.
SUMMARY
OF CHANGES j 4.1 OriginalIssue j
~
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A proval Effective j s
ate Date Millstone SORC pg.jg7 g,jg,9g CY PORC _
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, . . MP1, MP2, MP3, CY :
( Project Instruction -
Employee Concerns t
TABLE OF CONTENTS i i
i
- 1. INSTRUCTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 !'
1.1 Unit Director Appeal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.2 Confidential Employee Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 ,
1.3 Open Employee Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.4 Disposition of Employee Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . 3 !
-- - 21.5Miscrepancies . . . . m . n .=. . . r . . . . . . . w . . .=.r. . . . . . . . . . .w i= 4* -- -
1.6 ~ ~ Resolution Appeal Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 i
- 2. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 t
- 3. COMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 :
- 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 I. A~ITACHMENTS AND FORMS -
( Attachment 1, " Employee Concern Log" . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 -
Attachment 2, " Sample Response Memorandum" . . . . . . . . . . . . . . . . . . . . 7 l
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, 1. INSTRUCTIONS
!('
i \
This Project Instruction provides a consistent approach to the solicitation, -
review, and disposition of employee concerns (both open and confidential),
l including those applicable to issues raised by the 10 CFR 50.54(f) letters .
addressed by the CMP. For the purposes of this PI, the term " employee" includes all personnel, both direct (NU) and contract personnel. I
- 1.1 Unit Director Appeal Each Unit 1.1.1 ISSUE an appeal to employees throughout the organization, Director requesting that individuals review their files and identify any issue requiring resolution. +
1.2 Confidential Employee Concerns
__ l Employee l?_T_1.23 ~
IFdesired,ReTer_.lo theWEmpToyeFCon~cern3s--~im -
ogr and
_~ '
~ IDENTIFY employee concern confidentially. ;
l sr. VP. 1.2.2 Refer To the NU Employee Concerns Program and REVIEW Nuclear and PROCESS confidential employee concerns.
l S1fety &
Oversight 1.3 Open Employee Concerns i
I NOTE Committee members are identified by title in the CMP.
l Employee l 1.3.1 INITIATE open (nonconfidential) employee concerns by contacting applicable Project personnel, including but not limited.to the
._ . following:' ~~~~'3 - - "-
- Supenisor i
. Unit Project Manager Member of the Management Quality Committee ;
.. Member of the Executive Committee j l All Personnel l 1.3.2 For employee concerns identified, ROUTE the concern to applicable Unit Project Manager for disposition.
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. 1.4 Disposition of Open Employee Concerns
('-
NOTE .
Confidential employee concerns are dispositioned by the NU Employee Concerns Program. Open employee concerns are processed as discrepancies (Refer To Section 1.5).
Urut Project 1.4.1 DISPOSITION each open employee concerns as follows:
Manager NOTE The Employee Concern Log may be maintained manually or electronically.
- a. MAINTAIN'an Employe6 Conc ~errilogTReTer To ~~
Attachment I for suggested format) containing the following information (as applicable or available) for each concern:
. Initiator's name
. Date received i .
Subject (scope of concern, system ID, key word summary)
! - Project database log number used to track the concern
. Comments Resolution memo data (memo number and date sent) l
- b. Refer To NUC PI 14, " Project Process Administration," and j ENTER employee concern into the discrepancy database.
~
- c. ACKNOWLEDGE each employee concern, using a memo format similar to that shown in Attachment 2.
i 1
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1.5 Discrepancies
(-- NOTE Resolution of discrepancies is addressed in NUC PI 14, " Project Process Administration."
" 1.5.1 IE required, Refer To the applicable procedure below and Unit Project Manager INITIATE an ACR for each identified discrepancy:
- RP-4, " Adverse Condition Resolution Program" (for Millstone)
. ACP 1.2-16.5, " Adverse Condition Report Process
_._ Implementation",(for Connecticut Yankee) _ _ , _ ,_ ,_
1.5.2 VERIFY each concern (discrepancy) is evaluated and resolved as I specified in NUC PI 14, " Project Process Administration."
1.6 Resolution Appeal Process 1 Employee l 1.6.1 IE identified concem was not resolved satisfactorily by actions in Section 1.5, IDENTIFY the concern for resolution using the NU Employee Concerns Program.
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- 2. REFERENCES
{- 2.1 Configuration Management Plan (CMP) .
2.2 NU Employee Concerns Program 2.3 RP-4, " Adverse Condition Resolution Program" (for Millstone) 2.4 ACP 1.2-16.5," Adverse Condition Report Process Implementation" (for Connecticut Yankee) 2.5 NUC PI 14, " Project I recess Administration"
- 3. COMMITMENTS N/h -. _ . - - . _ . - _ .._ ._
- 4.
SUMMARY
OF CHANGES 4.1 OriginalIssue t
( ..
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Attachment 1 Employee Concern Log (Sheet 1 of1)
( Initiator Date Project Database -
Resolution Memo No. &
Name Received Subject Ieg No. Comments Date Sent i
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Attachment 2 -
Sample Response Memorandum (Sheet 1 of 1) g TO: Date:
s .
FROM:
Unit Project Manager
SUBJECT:
Employee Concern On mm/ddlyy, I received your issue regarding subjed. I would like to thank you for bringing this issue to my attention.
This issue has been entered into the 50.54(f) database (log number #####).
This issue has been assigned to Responsible Individual's name ior resolution as
..._.. _. pmof the 50.54(f) project- _
_u.__.. .__
Should you have further concerns or would like additionalinformation regarding this specific concern, please do not hesitate to contact me.
( c: Project file Responsible Individual
_. . : :. . . _ .- -.~ ..
1
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NUC PI 4 Rev.1 This Project Instruction (PI) is part ofimplementation of the !
Configuration Management Plan (CMP). l Approval: -
PORC Mtg. No: 3-9(c-lof ate: ~3-2-V-T(a Effective Date: b-M ~
, Responsible Individual:
Level of Use T. Paulantonio lnformation Subject Matter Expert:
T. Paulantonio
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Project Instruction l Millstone Unit 3 Walkdowns -
F TABLE OF CONTENTS
- 1. -< IN STRU CTI ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Establishing Walkdown Teams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.2 Walkdown Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 -
1.3 Inspe ction Ite ms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.4 Discrepancies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
- 2. R EFER ENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
- 3. CO MM ITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ,
- 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ,
ATTACHMENTS AND FORMS Attachment 1, "PDCR Walkdown Checklist" . . . . . . . . . . . . . . . . . ..... 16 Attachment 2," Materiel Condition / Housekeeping Walkdown Checklist" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Attachment 3, "VSRT Walkdown Checklist (from NUC PI 15)" . . . . . . . 22 Attachment 4, " Guidelines for Identifying Potential Seismic >
Interaction of Temporary Equipment and
- Proper Locations for Restramts" . . . . . . . . . . . . .. . . . . . 23 l I
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1 INSTRUCTIONS l i
The intent of this Project Instruction is to perform the following for eacn -
Group 1 system identified in the " Millstone Unit 3 CMP Implementation Plan" attachment to the CMP:
Walkdowns of selected PDCRs (Refer To Attachment 1)
System walkdowns for housekeeping and materiel condition (Refer To Attachment 2) ,
System walkdowns to verify selected design basis attributes and inspection criteria provided by NUC PI 15," Selected Millstone Unit 3 System '
Reviews" (Refer To Attachment 3) l This PI provides guidance for performing consistent and comprehensive visual inspections of systems and surrounding areas required by the CMP for materiel l condition to provide the following: l l
Discovery of discrepancies i -
Resolution of discrepancies l l t
i This PI provides guidance on the attributes to be investigated during the walkdown process and the documents necessary to record the walkdown results.
! As applicable, the system attributes prepared in NUC PI 7," Graded System l Reviews," and/or NUC PI 15 should be utilized in the walkdowns.
Certain conditions may restrict accessibility for inspection. Consideration should be given to ALARA issues, safety, and plant conditions. Incomplete inspections due to restricted accessibility are documented in the Final System ,
Readiness Report. !
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1.1 Establishing Walkdown Teams NOTE
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Training for this PI will be conducted concurrent with training for '
NUC PI 5," System Readiness Review," for Millstone Unit 3. ,
l SRT Leader l 1.1.1 ASSEMBLE walkdown team that typically includes the following:
System Review Team (SRT) Leader l
= Design Engineer Designer (as needed) i Maintenance and Operations personnel (as needed)
NOTE The SRT Leader and Design Engineer have completed initial engineering c ualifications. Based upon their current job descri 3 tion and assigned i
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c uties and responsibilities, they are generally qualtied to perform system readiness and PDCR installaticn walkdowns. Specific traming in the CMP Walkdown Process will ensure their ability to meet PI objectives. Other team members, as assigned, require only those skill sets related to their specific job descriptions.
lUPM l 1.1.2 VERIFY walkdown team is trained and qualified in those skill sets related to their specific job descriptions for this PI. !
l system 1.1.3 MAINTAIN records of qualification status. l t Review Administrative (SRA) group i
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1.2 Walkdown Process l
This section outlines the general approach to the walkdown process. -
Inspection items to be addressed throughout walkdowns are contained in
. Attachment 1, Attachment 2, and Attachment 3. '
l SRT Leader l 1.2.1 DETERMINE approach to be used to perform walkdown, either:
Focus on where to start walkdown, considering major system components and (if applicable)long-standing issues.
Entire Walkdown Team performs preliminary walkdown to identify discrepancies. .
Smaller groups within the Walkdown Team perform a series of walkdowns, with each walkdown having a particular focus.
NOTE ,
i Only accessible portions of the system are walked down, giving consideration to ALARA issues, safety, and plant conditions. ,
i 1.2.2 EXAMINE as-built condition of assigned systems, structures, or components.
1.2.3 DOCUMENT results of each walkdown (including any access restrictions or other issues impacting the inspection, or any deficiencies noted) on applicable form as specified in step 1.3.1:
IE a PDCR: Attachment 1 IE housekeeping / materiel condition: Attachment 2 IE an NUC PI 15 design basis walkdown: Attachment 3 l l
1.2.4 REVIEW walkdown findings.
- a. IE any discrepancies are identified, Refer To Section 1.4 for processing.
1.2.5 FORWARD copies of all walkdown attachments and Ur> resolved Item Reports (UIRs)(from NUC PI 5,' 'illstone Unit 3 System Readiness Review") to the System Review Administrative (SRA) group.
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lSRA l 1.2.6 RETURN each completed Attachment 3 to the " Vertical Slice" l
Team for review.
1.2.7 FILE walkdown attachments in System Readiness file.
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1.3 Inspection Items NOTE
- 1. For the purposes of this PI, any ins "N/I"is treated as a discrepancy. pection item marked "Unsat" or
- 2. Reasons recorded in the " Notes" section for discrepancies are " keyed" to the inspection item by noting the inspection category designator, i followed by the specific item number. Example: On Attachment 1, a '
pump seal or packing discrepancy is coded "C3," and a specific reason for "Unsat" or "N/I" status is recorded.
Walkdown 1.3.1 Throughout performance of this section, DOCUMENT Team inspection results on the applicable attachment as follows:
IE no discrepancy is noted, CHECK " SAT."
IE a discrepancy is noted, PERFORM the following:
CHECK "UNSAT."
- Refer To NUC PI 5," System Readiness Review," and COMPLETE Block I of UIR.
IE inspection item does not apply to the inspection in progress, CHECK "N/A."
IE inspection item is not accessib'e, CHECK "N/I" and PROVIDE information in the " Notes" section about the reason for not inspecting the item.
NOTE For PDCRs, only those attributes of Attachment 1 that apply to a specific PDCR will be walked down. >
l SRT Leader l 1.3.2 Refer To Attachment 1 and PLACE a check mark in the 'R' column next to each PDCR inspection item to be inspected.
l walkdown 1.3.3 INSPECT identified PDCR inspection items and MARK results '
Team ofinspection on Attachment 1 as outlined in step 1.3.1. l Level of Use d
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F' NOTE
- 1. Inspections may be performed in any order.
- 2. Poor housekeeping may lead to loss of Foreign Material Exclusion (FME) control
- 3. Some " general housekeeping" issues are also safety or fire hazard issues.
., 4. Poor materiel condition may be symptomatic of more severe problems.
1.3.4 INSPECT the general housekeeping of the area and MARK the results of inspection on Attachment 2 as outlined in step 1.3.1 for any problems, including the following:
Cleanliness issues (debris, contamination, spills, etc.)
Storage of materials or tools (inappropriate, inadequate, etc.)
NOTE Steps 1.3.5 through 1.3.10 provide additional inspection attributes which may be considered by the Walkdown Team during their materiel condition or housekeeping walkdowns.
1.3.5 INSPECT the materiel condition of the area and MARK the results of inspection on Attachment 2 as outlined in step 1.3.1 for problems in any of the following areas:
Ccmponent identification (signs or labels missing, incorrect, out c; date, or unreadable, etc.)
l Painted surfaces (wearing thin, flaking, rusted, areas or l components not painted, etc.)
Covers (component or drain covers not in place, etc.)
Bearing housings for pumps and motors (abnormal sounds, smells, or temperature; vibration to the touch, etc.)
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NOTE Leak detection may be accomplished using any of the following:
- Visual: drips, puddles, stains, boron deposits
- Temperature: touch or pyrometer
- Audible: stethoscope (if needed) i j
Seal integrity (leaks of any kind: packing, stem, seal, flange, pipe, seat, body-to-bonnet, etc.)
I Lubrication (improper level, detected using sight glass, bull's l eye, flow indicator, dip stick, grease cup, valve stem, etc.)
Valve condition (bent stem, bottomed or corroded packing gland, engagement of fasteners, abnormal flow noise, etc.)
Handwheel or operator condition (broken; missing key, setscrew, or pin, etc.)
Dampers (linkages bent, broken or disconnected; cleaning or adjustment required, etc.)
Filters, screens, louvers (plugged, missing, dirty, loose, etc.)
Fan belts (loose, protective covers loose or missing, wear dust on sheaves or guard, etc.)
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Gauges or instruments (inoperable, out of calibration, physical l damage, inconsistent readings, etc.)
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Instrument sensing lines (damaged, crimped, disconnected, etc.)
Drains (plugged, screens or grates missing, etc.)
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Piping (loose, damaged, missing, insulation damaged or missing, hangers disconnected or missing, heat tracing damaged, etc.)
Heat transfer (surfaces dirty or fouled, etc.)
Environmental qualification (boundaries disturbed, etc.)
Area lighting (insufficient, blown bulbs, etc.)
Indicating lamps (missing, burned out, covers missing, improper indication for known conditions, improper labels, etc.)
Electrical control panels (covers missing, open or unlatched doors, pinched wires, foreign material, water or moisture noted, missing bolts, abnormal sounds or smells, etc.)
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Cables or leads (unsecured, worn, frayed or cut insulation, loose terminations, potential heat damage, cables hanging outside of cable tray, improper electrical train separation, etc.)
Motors or generators (excessive noise or vibration, dirty armature or windings, ground straps loose or disconnected, etc.)
Preservation of equipment (excessive rust, material wastage, i impact of surrounding conditions, etc.)
Equipment skid or foundation bolting (loose or missing, etc.)
Record attached TR tags and forward information to WP&OM
=
Modifications (temporary alterations not on drawing, partial modifications, unauthorized modifications, etc.)
Chemicals (unauthorized use, improper storage, etc.)
Components fabricated from elastomers or otherwise subject to aging (for signs of degradation) l o mat on
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NOTE Safety and fire hazard inspections are for both personnel safety issues and plant safety issues. Some " general housekeeping" issues are also safety or
. fire hazard issues.
1.3.6 INSPECT the area for safety or fire hazards an.1 MARK the
" results ofinspection on Attachment 2 as out!!ned in step 1.3.1 for problems in any of the following areas:
Doors or hardware (broken, loose, or missing; etc.)
Fire or flood barriers (inappropriate breaches, etc.)
Grounding devices (broken, loose, or missing; etc.)
Equipment guards (broken, loose, or missing; etc.)
Extraneous trash or matenal (stored in areas not reserved or suitable for storage, untreated lumber or other fire hazard, etc.)
Storage lockers (not clean, neat or properly restrained, etc., as defined in Attachment 4)
Floor drains or sumps (dirty or plugged, etc.)
Temporary equipment such as hoses, extension cords, ladders, or gas bottles (present but not in use)
Neatness of piping, supports, or walls (tape or other foreign material present, etc.)
Pathways or stairwells (obstructed, tripping or fall hazard, etc.)
Eyewash stations, emergency showers, and fire extinguishers (not accessible, not operational, not properly charged, etc.)
Insulation or lagging (missing or not in good condition, crushed, damaged, etc.)
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1.3.7 INSPECT the area for damage and MARK the results of inspection on Attachment 2 as outlined in step 1.3.1 for problems in any of the following areas: .
Thermal insulation (missing or not in good condition, crushed, damaged, etc.)
Hangers (bent or broken, etc.)
Equipment anchorage (stressed or loose, etc.) i Piping (excess motion or vibration; evidence of water hammer, water slugs, or other severe transients, such as damaged !
supports, pulled out concrete anchors, bent or deformed !
components, or unusual noise; etc.)
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Tubing or conduit (damaged, etc.)
Area or component general condition (unusual noises, excessive vibration, excessive temperature, relay chatter, discolored fluids, arc paths, etc.) ;
Valves (indications of flow through closed valves, external leakage of fluids, etc.)
1.3.8 INSPECT general condition of piping and MARK the results of inspection on Attachment 2 as outlined in step 1.3.1 for problems in any of the following areas:
Valve operation (cycling or chattering, cavitation noise, etc.)
Location relative to other components (interference with other components, impact of vibration of equipment to which pipe is attached, etc.)
Piping integrity (excessive motion, leaks, evidence of rubbing or external corrosion causing wall loss, etc.)
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1.3.9 INSPECT general condition of pipe supports and MARK the results of inspection on Attachment 2 as outlined in step 1.3.1 for problems in any of the following areas: .
General condition of supports, with problem areas including (but not limited to):
i Excessive motion Degradation of fasteners, springs, clamps, or other components; dented, cracked, broken, or out of adjustment components; etc.
Missing, detached, or loose components Indications of scaling that may reduce the load bearing l capacity of the support i
l Arc strikes, weld splatter, paint, scoring, roughness, or general corrosion on close tolerance machined or sliding surfaces Unusual concrete or grout deterioration (such as crosion, l corrosion, chipping, cracking, or spalling) l 1
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Electrical motors, heaters, panels, and breakers are inspected for proper i installation and to detect conditions that may lead to equipment or personnel damage.
l 1.3.10 INSPECT general condition of electrical equipment and MARK
., the results ofinspection on Attachment 2 as outlined in step 1.3.1 for problems in any of the following areas:
Conduit, panel, and junction box covers (not properly in place or not capable of providing normal access)
Cable trays and covers (missing covers)
Local panel and floor penetrations (not properly sealed as required)
Local instruments and indicators (damaged or not in service)
HVAC belts or motors (excessively noisy); fan coils and
' motor intakes (dirty)
Wire insulation (damaged)
Motor air intakes (clogged or obstructed) i i
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1.4 Discrepancies l SRT Leader l" 1.4.1 REVIEW walkdown results and GENERATE UIRs. .
1.4.2 IE required, Refer To RP-4," Adverse Condition Resolution Program," and INITIATE an ACR for each applicable discrepancy that may affect operability or reportability.
1.4.3 DEVELOP recommended resolution for UIR as specified in PI 5.
1.4.4 REVIEW walkdown results and generated UIRs with the Coordinator, SRT.
1.4.5 FORWARD reviewed UIRs to the SRA.
lSRA l 1.4.6 ASSEMBLE walkdown UIRs for inclusion in Preliminary Readiness Report as specified in PI 5.
1.4.7 FILE original UIRs in the System Readiness file.
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- 2. REFERENCES l
2.1 Configuration Management Plan (CMP) ,
2.2 RP-4," Adverse Condition Resolution Program" 2.3 System Engineer Handbook Section 6.4,"Walkdown Guidelines" i 2.4 NUC PI 5," System Readiness Review" 2.5 NUC PI 7," Graded System Reviews" i 2.6 NUC PI 15," Selected Millstone Unit 3 System Reviews" l l
2.7 NUC PI 16," Licensing Basis and Design Bases Walkdowns" ;
- 3. COMMITMENTS t None i :
- 4.
SUMMARY
OF CHANGES ;
4.1 Added numbers to Attachment 1 for consistency with NUC PI 16 ['
Attachments.
4.2 Added NOTES before step 1.3.1 for consistency with NUC PI 16.
4.3 Added amplifications and corrections of originalinformation based on i procedure use. )
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Attachment 1 PDCR Walkdown Checklist I
(Sheet l of 4)
Design Document # Date:
System # _ Time:
R Item Sat Unsat N/A N/I A All Equipment:
- 1. Labeling and component identification installed and correct.
- 2. Equipment covers and safety guards installed.
- 3. As appropriate, equipment operation access platforms are installed.
- 4. Manufacturer's equipment tags and name plates installed and legible. l
- 5. Bolting tight with proper hardware installed.
- 6. General component installation per design drawings.
Components installed in a manner that provides access for operation and 7*
maintenance, and does not present a personnel safety hazard.
- 8. Existing components, systems, or structures undamaged.
- 9. Construction debris removed and proper cleanliness level established. >
B Valves:
- 1. Valve glands and packing installed. ,
- 2. Live load packing adjusted per manufacturer's recommendations.
- 3. Pressure relief / safety valve / rupture disks settings per design (as indicated on attached valve tags).
- 4. Pressure relief / safety valve / rupture disks discharge piping properly secured and discharge flow is directed in a safe manner.
- 5. Valve orientation correct (including check valves and non-return valves).
- 6. Valve hand wheels installed.
- 7. Manual valves have sufficient clearance to be operated.
- 8. Locking device provided for those valves / breakers / switches required to be locked in a certain position.
- 9. Valves have manufacturer's labels and/or tags installed.
- 10. Solenoid valves installed with correct porting.
- 11. Solenoid valves have proper voltage rating.
- R = Required Sat: Satisfactory N/A: Not Applicable Unsat: Unsatisfactory N/l: Not inspectable l Notes:
Level of USe Information
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Attachment 1 PDCR Walkdown Checklist (Sheet 2 of 4)
R Item Sat Unsat N/A N/I C Pumps, Fans, Compressors:
l'. Pumps, fans, compressors aligned and coupled, and coupling guards installed.
- 2. Pumps and fans oriented correctly.
3s Pump seals and packing installed.
- 4. Pump seal / bearing cooling lines installed.
- 5. Pump sealleakoff lines or baseplate drain lines installed.
D Mounting and Supports:
- 1. Equipment mounting bolts installed and tight.
- 2. As required, equipment base plate grouted.
- 3. Bolts and concrete anchors have thread engagement per design requirements.
- 4. Pipe hangers, conduit supports, cable tray supports, and instrument line supports installed per design requirements.
- 5. Support and hanger accessories installed per design requirements. (clips, U-bolts, etc.)
- 6. Snubbers installed per design requirements and setpoints verified.
- 7. Hanger spring cans installed and adjusted per design requirements.
- 8. Adjustable struts installed and adjusted per design requirements.
- 9. Seismic anchors and restraints installed per design requirements.
- 10. Temporary supports removed.
E Instrument:
- 1. Instrument sensing lines connected per design requirements and are tight.
- 2. Equipment mounted instrumentation installed per design requirements.
- 3. Phy:ical protection for instrumentation installed per design requirements.
- 4. Instrument tubing and fittings installed per design requirements.
- 5. Surge suppressors for instrumentation installed per design requirements.
R = Required Sat: Satisfactory N/A: Not Applicable Unsat: Unsatisfactory N/l: Not inspectable l Notes:
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Attachment 1 PDCR Walkdown Checklist (Sheet 3 of 4)
R ltem Sat Unsat N/A b'/I F Electrical Equipment:
- 1. Electrical Environmental Qualification (EEO) related equipment installed per Design requirements.
- 2. Electrical equipment, raceway, and cable installed to Electrical Design
,, Requirements (e.g., for MP3 Standard ElectricalInstallation Specification SP-ST-33-076)
- 3. Electrical connections made up and tight.
- 4. Panel wiring neat and orderly.
- 5. Conductor identification tags installed.
- 6. Train separation per design requirements.
- 7. Cable tray wiring neat and orderly.
l 8. Permanently lifted or abandoned lead have been marked and documented.
I 9. Mechanical protective devices for electrical conductors insta!!ed per design I requirements.
! G Heat Tracing, Insulation, Painting:
( 1. Heat tracing installed per design requirements.
! 2. Painting and other protective surface coatings satisfactorily installed.
l 3. Insulation installed per design requirements.
j H HVAC Equipment:
- 1. Ventilation system filters and absorber units installed and properly j oriented.
- 2. Fire dampers properly oriented and installed.
i l 3. Fusible links installed and are of the proper temperature range.
l l 4. Ductwork access doors installed.
- 5. Equipment condensation drains installed.
l R = Required Sat: Satisfactory N/A: Not Applicable Unsat: Unsatisfactory N/l: Notinspectable l Notes:
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Attachment 1 PDCR Walkdown Checklist (Sheet 4 of 4) r R Item Sat Unsat N/A -N/I I Piping:
- 1. Restricting orifices and flow elements installed.
- 2. Flow elements oriented correctly.
- 3. Fluid system permanent filters installed.
T. Startup filters or strainers installed and identified.
- 5. Permanent piping spool pieces (to replace startup 61ters or strainers) are available for installation.
- 6. Original material / weld identification numbers are legible.
- 7. Welding dams or purge paper used during piping installation removed or identified (so they can be removed after turnover). !
- 8. Temporary vent paths used for welding (i.e., valve bonnet or check valve intervals removed) have been restored.
- 9. Fire barriers, cable tray separators and covers, and other fire protection features / equipment installed per Design requirements.
- 10. Security barriers and cther physical security measures properly installed.
These attributes to be veri 5ed during walkdown by a representative of the Station Security Department. !
J Lubrication l
- 1. Lubrication reservoirs installed and at proper operating level. ;
- 2. Equipment properly lubricated and lubrication records available.
K Cathodic Protection
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- 1. Cathodic protection installed per dd;n r quirements. l
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Insulating flanges installed per design re[uirements.
2.
- Sat: Satisfactory N/A: Not Applicable Unsat: Unsatisfactory N/l: Not inspectable Notes:
Walkdown
Participants:
l SRT Leader: Date:
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Supervisor: Date:
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Attachment 2 Materiel Condition / Housekeeping Walkdown Checklist (Sheet 1 of 2)
System # Date:
Area: Time:
. Item Sat Unsat N/A N/I
- 1. Lagging / insulation
- 2. Tags / labels
- 3. D,irt/ dust / debris j 1
- 4. Tubing (tight, supported)
- 5. Leaks (oilAvater/ boric acid) l i
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- 6. TR tags ;
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- 7. Abandoned equipment l l
- 8. Room temp / humidity / quality I
- 9. Ventilation (dust)
- 10. Concrete (spalling/ cracks)
- 11. Drains (blocked / dirty)
- 12. Lighting
- 13. Painting (rust / wear) ,
14 Holes in wa'Is & floors
- 15. Abandonedcables ,
- 16. Cables coiled
- 17. Groundingwires
- 18. Conduit damage
- 19. Hanger / supports / installation i
- Sat: Satisfactory N/A: Not App!! cable Unsat: Unsatisfactory N/l: Not inspectable Notes:
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Attachment 2 ,
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- Materiel Condition / Housekeeping Walkdown Checklist ;
(Sheet 2of 2) l Item Sc.t Unsat N/A N/I !
- 20. Safety equipment (fire, eye wash, ladders) l 1
- 21. General equipment arrangement (professional / sloppy work) l
- 22. Erosion
- 23. Corrosion '
- 24. Overloads l
- 25. Excessivevibration
- 26. Fatigue
- 27. Work emironment
- 28. Safety hazards
- 29. Cleanliness / housekeeping
- 30. Improper use of tape, restraints or barriers
- 31. Physical obstructions affecting operability
- Sat: Satisfactory N/A: Not Applicable Unsat: Unsatisfactory N/l: Not inspectable Notes:
i Walkdown
Participants:
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SRT Leader: Date:
l Supen/isor: Date:
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Attachment 3 VSRT Walkdown Checklist (From NUC PI 15)
(Sheet 1 of 1) l Design Document # Date: ,
System # Time: ,
i Item # Item Sat Unsat N/A N!! l i
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- Sat: Satisfactory N/A: Not Applicable Unsat: Unsatisfactory N/l: Not inspectable Notes:
Walkdown
Participants:
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j SRT Leader: Date:
i Supervisor: Date:
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Attachment 4 Guidelines for Identifying Potential Seismic Interaction of Temporary Equipment and Proper Locations for Restraints I (Sheet 1 of1)
Type ofItem Recommended Location of Restraint Ladders, Gas Cylinders
- If greater than 4 ft. in height, use two restraints (tall, slender, free-standing items) positioned at intervals approx.1/3 the height.
If less than 4 ft in height, use single restraint positioned at approx. center of gravity.
Storage Lockers, Tool Boxes, Desks
- Provide one restraint at approx. center of (unanchored item roughly box type shape height is gravity.
greater than base dimensions) .
Or provide hard anchorage at item's base.
Storage Lockers, Tool Boxes, Desks
- Pravide one restraint at approx. center of -
(unanchored item roughly box type shape height is gravity.
less than base dimensions) .
Or pnvide hard anchorage at item's base.
Rolling Carts, Dollys, Wheeled Test -
Lock Wheels or provide wheel chocks or travel Equipment, Wheeled Storage Lockers, etc. stops to prevent uncontrolled rolling.
(unanchored items on wheels or round shaped - Or (if restraints are used), use two and restrain items capable of rolling) in opposite directions to prevent walking on radius of restraint.
- Also consider potential for toppling and sliding
. conditions, as described above.
Portable Jib Cranes or Rotating Booms + Secure the component to prevent swinging.
(items with unsecured components which are pendulum hung or pinned)
A A A NUC PI 4 Level of Use ,cgggy ,7ggj7 qgy,.gg%g g,y, 3 Information jg p;;% [% fi 23 of 23
f NORTHEAST UTILITIES NUCLEAR S .
PROJECT INSTRUCTION e
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v j NUC PI 5 y;:9'4 Rev.1 This Project Instruction (PI) is part of implementation of the Configuration Management Plan (CMP). l r
Approval:
/ Unit D~ ic PORC Mtg. No: 3-M/ DJ' Date: 92UD Effective Date: fM 'N Responsible Individual:
Level of Use T. Paulantonio lnformation Subject Matter Expert:
T. Paulantonio
MP3 Project Instruction ,
Millstone Unit 3 Systern Readiness Review TABLE OF CONTENTS
- 1. IN S TRUCTI ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Tra in ing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 System Readiness Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.2
- -- ~
1.3 Preparation 2nd Processing of Unresolved Item-Reports . . ; a;. : 16 1.4 . Preparation of Preliminary System Readiness Report . . . . . . . . . . 18 1.5 System Readiness Review Team Status Reports . . . . . . . . . . . . . . 19 1.6 Preparation of Final System Readiness Report . . . . . . . . . . . . . . . 20 1.7 Preparation of System Readiness Memo . . . . . . . . . . . . . . . . . . . . . 21
- 2. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 22
- 3. COMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
c.
22
- 4.
SUMMARY
OF CHANGES . . . . . . >. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A'ITACHMENTS AND FORMS Attachment 1, " System Readiness Checidist" . . . . . . . . . . . . . . . . . . . . . . . 23 Attachment 2," Unresolved Item Report" ......................... 24 Attachment 3," Preliminary System Readiness Report Format" ....... 26 Attachment 4, " System Readiness Report Format" . . . . . . . . . . . . . . . . . . 27 Attachment 5," System Readiness Memo Format" . . . . . . . . . . . . . . . . . . 28 Attachment 6, "D efinitions" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
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- 1. INSTRUCTIONS
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This PI defines the process for assessing and documenting the readiness of a system or subsystem to support plant operation or mode change as part of the unit's restart effort. This PI applies to systems designated in the CMP.
Goals of the System Readiness process for a system or subsystem are:
- All unresolved items are dispositioned by the Plant Verification and Readiness Team (PVRT).
- System or subsystem will not experience any events during plant startup.
- System or subsystem will have an 0% unplanned unavailability for the first l 120 days of an operating cycle.
This PI also provides guidance on documenting and processing discrepancies identified during the walkdown or the system readiness process. This reporting process shall also be used to document discrepancies identified by review processes required by the CMP.
The following attitudes and actions apply throughout performance of this PI:
- SOLICIT support from all site departments.
- RESPECT and RESPOND to all inputs to the process.
- PROVIDE feedback on the applicability of inputs provided.
Additionally, personnel involved with implementing this PI are to perform self-assessments of effectiveness at this PI as designated by the UPM, and provide feedback on needed improvements to the System Readiness Administrative (SRA) group.
All walkdowns shall be attended by one of the following:
- UPM or alternate as designated
- SRT Coordinator
- Supervisor, Technical Support Engineering NUC PI 5 Level of Use _ . . . . . _ d. _
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Roles and responsibilities for this PI include:
. Unit Project Manager (UPM)
. Approves all UIRs generated
= Approves System Readiness Reports. Submits the System Readiness Memo to the Management Quality Committee (MQC) for approval. l l
. SRT Coordinator - Participates in system walkdowns and reviews System l Readiness Reports and UIRs generated. l . ..
Supervisor, Technical Support Engineering - Substitutes as needed for the Coordinator, SRT for systems under his or her cognizance.
. System Readiness Team (SRT) - Performs the review process of documents and plant equipment. Each SRT includes the following members as determined by SRT Leader:
- SRT Leader (System Engineer) i
. Design Engineer
- Operations (as required)
- I&C (as required)
- Electrical Maintenance (as required)
- Mechanical Maintenance (as required)
- Chemistry (as required)
= Health Physics (as required) 1 4 -
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- SRT Leader (System Engineer) - Performs the following: l
- Reviews each discrepancy generated on the Unresolved Item Report (UIR) for his or her system.
- Performs system walkdown on each assigned system and performs l l System Readiness Review Process outlined below.
- Prepares and presents Preliminary System Readiness Report to l the PVRT.
- Documents assessment results on Final 'System' ' '
Readiness Rep
~ '
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for 15resentation 16 UPM.' "
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- Plant Verification and Readiness Team (PVRT) - Performs the following: r
- Verifies the validity of the Unresolved Item Report (UIR).
- Assigns the UIR to the proper category (FSAR, procedure, etc.)
. Assigns the proper completion milestone (Startup, next RFO, etc.)
- Assigns the priority (non-startup items) ;
- Develops recommended resolution to the UIR.
The PVRT forwards the UIR package to the UPM for final disposition and approval. Once approved, the UIR is returned to the SRA.
PVRT members are identified in NUC PI 8," Plant Verification and Readiness Team."
- System Readiness Administrative (SRA) Group - Maintains the status of UIRs. Processes the necessary reports and forms associated with the readiness effort. Provides documents needed to perform system readiness reviews. Ensures each final disposition document for each UIR is identified on the UIR.
- Management Quality Committee (MQC)
- Approves specific design changes that will be walked down as a l result of SRT review.
- Approves each System Readiness Memo.
- Reviews UIR summary. ,
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1.1 Training NOTE The SRT Leader and SRT Design Engineer have completed initial !
l engineering qualification. Based on their current job descriptions and assigned duties and responsibilities, they are generally, qualified to perform desi n basis document reviews. Specific traimng in this PI ensures their abil to meet the stated objectives. Other assigned SRT members require only hose skill sets related to their specificjob descriptions.
SRT Leader - - 1.1.1 - OBTAIN training required to enable the SRT members to --~ - -
and Design
- achieve the following objectives as applicable to their specific job Engineer descriptions:
- Apply the system readiness review process to identify readiness discrepancies.
- Understand all terms used in the system readiness review process.
- Identify necessary input, format, and routing of system readiness review.
- Understand what documents constitute the plant design.
- Determine that FSAR change requests are in place and i spelled out in PDCR.
- Determine that design changes are incorporated into plant design.
- Determine when a system, subsystem, train, component, or device is OPERABLE.
- Evaluate materiel conditions as specified in NUC PI 4, "Walkdowns."
- Determine that PDCR field implementation is complete as l specified in NUC PI 4, " Millstone Unit 3 Walkdowns."
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l 1.2 System Readiness Review Process The System Readiness Review Process centers on performing a i comprehensive review of the attributes listed on Attachment 1," System l Readiness Checklist," from the perspective of materiel condition and the l following design change issues:
- Design changes for the system have been incorporated m ,
appropriate Licensing documents. l
- Walkdowns of plant design (performed as specified in NUC PI 4, l "Walkdowns") demonstrate proper field installation.
. .. , ,s... . . . . ,
= PDCR testing (performed by IST, surveillance, special, or preoperational test) ensures system readiness and functionality of the design changes affecting Licensing documents. l Any discrepancy found during any phase of the process shall be documented on Attachment 2," Unresolved Item Report (UIR)."
Preparing and processing UIRs are described in Section 1.3 of this PI.
As the initial review of each category is completed, the "R" (Review) box l on Attachment 1 is marked off. As each category assignment is l completed, the SRT Leader marks off the "C" (Completed) box, signifying l the following:
l - Review of the category is complete.
- All unresolved items that may affect the ability of the system to achieve its intended mission have been dispositioned (completed, l
closed out, evaluated for impact on declaration of operability of availability, deemed administrative in nature, or deemed to have no impact on startup of the unit, as applicable).
When each review team completes the document resiew phase and a preliminary system walkdown, a Preliminary System Readiness Report (Attachment 3)is generated and submitted to the PVRT. The PVRT identifies the completion milestone associated with each open item and approves the report. This preliminary report is then submitted to the UPM for approval.
When all open items required for startup are completed, the Final System Readiness Report (Attachment 4) is generated, approved by the PVRT l
and UPM, and presented to the MQC.
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NOTE ,
- 1. Actions are the responsibility of the SRT Leader unless otherwise noted.
- 2. Bulleted items correlate to headings presented in Attachment 1. Some efforts (such as reviews) may be performed concurrently.
- 3. The scope of the fmal walkdown may be expanded at the discretion of the SRT Leader to address special issues such as verification of separation criteria, HELB or EQ requirements, etc.
- AWO Review ..
- a. PERFORM comprehensive review of closed AWOs (except PM- and SV-type AWOs) to identify where design l changes may have occurred and PERFORM the following for those AWOs which could affect Licensing documents:
- 1) IDENTIFY whether the associated design change is reflected in the Licensing documents. The design change may be defined in the following documents as appropriate: PDCR, DCN, PDDS, RIE, PMR, DDR, E&DCR, Unsat items, DMR, PDCE, DCR, design calculation, setpoint change, AGPL, etc. [
- 2) REVIEW post-modification test, plan as specified in this PI under" System Testing." I
- b. ASSESS all open backlog AWOs with scheduled start dates prior to the plant startup date plus 120 days, and PERFORM l the following for those AWOs:
- 1) REVIEW database listing of the backlog AWOs.
- 2) DISPOSITION each AWO with the appropriate actions to be taken (reschedule, cancel, etc.) and reason for actions.
- 3) INCLUDE the backlog review and action taken on the >
System Readiness Report.
- c. IDENTIFY to WP&OM any open AWOs that may affect system readiness which should be scheduled for completion now. l
- d. For AWOs that are not needed prior to startup, LIST and briefly STATE the AWO problem description, including an evaluation of why there is no impact on system readiness.
- e. MARK block on Attachment I to signify review completion.
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- f. UPDATE PMMS as required to reflect recommended actions l l WP&OM l in open AWOs. .
- g. CLOSE AWOs upon completion.
. Design Changes !
- a. PERFORM comprehensive review of design change l documents implemented against the system, as a result of AWO review process.
- b. IDENTIFY those design changes that may affect the FSAR and PRESENT the list to MQC for walkdown approval. -
.s.. . ,
- c. REVIEW the list of design changes affecting the FSAR and :
lMoc l .
APPROVE the list for SRT review and walkdown.
i
- d. PERFORM the following with approved design change list:
l SRT l
- 1) REVIEW identified documents to ensure the design change is incorporated.
- 2) REVIEW the test plan and VERIFY the plan validates :
the functionality of the design change at the component, i system, and intrasystem level as applicable.
- 3) Refer To NUC PI 4," Millstone Unit 3 Walkdowns," and PERFORM a complete walkdown of each design change. l l l
- e. IDENTIFY plant design discrepancies. l
- f. MARK block on Attachment I to signify review completion. i
- NCR Resiew ,
- a. PERFORM comprehensive review of NCRs with dispositions of "use- as-is," " repair," or " admin," and IDENTIFY those NCRs that may have changed plant design documents or j procedures as applicable.
- b. REVIEW each affected design document or procedure to ,
ensure NCR is reflected.
- 1) IE any dispositioned NCR is not reflected in affected l i design document or procedure, IDENTIFY as a discrepancy using Attachment 2," Unresolved Item Report."
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- c. VERIFY there are no undispositioned NCRs for the system open greater than 60 days. .
- d. VERIFY there are no open NCRs that affect system readiness.
- e. MARK block on Attachment 1 to signify review completion. i
. Trouble Reports
- a. REVIEW open TRs to determine impact on system readiness.
discrepancy using Atta~chineht2, " Unresolved Itein ' ~ 1 Report." l
- b. MARK block on Attachment 1 to signify review completion.
- Maintenance Rule Implementation
- a. EVALUATE system for compliance with Maintenance Rule. j
- b. REVIEW action plans for Al systems for startup completion requirements.
- c. IDENTIFY issues that could cause the system to not be AVAILABLE for the entire fuel cycle and VERIFY corrective actions are taken by responsible department. ;
I
- d. MARK block on Attachment 1 to signify review completion. ;
- EWR Review
- a. PERFORM comprehensive review of open EWRs and EVALUATE the effect of not implementing the request prior to startup.
- b. ASSESS the current applicability of each EWR.
- d. IE EWR is not needed prior to startup, ROUTE to Resource l Allocation Committee (RAC) for processing.
- e. MARK block on Attachment 1 to signify review completion.
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- Jumper Bypass Review
- a. EVALUATE the impact of each installed jumper bypass on system readiness.
- b. VERIFY anyjumper bypass that may impact system readiness is removed.
- c. LIST all remaining jumper bypasses, PROVIDE evaluation of why there is no aggregate impact on system readiness on the system readiness report.
' '~
- d. MARK block on Attachment 110 signify review completiorf
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- Operability Determinations orJCOs
- a. REVIEW all outstanding Operability Determinations against the system.
- b. VERIFY one of the following:
- All identified actions requiring work or corrective action are complete and full qualification is restored.
- In-place compensatory actions are still appropriate and operator burden has been reviewed.
- c. RT:. COMMEND closure of unnecessary ODs.
- d. MARK block on Attachment 1 to signify review completion. ]
l
- Control Room Panel Deficiencies i
- a. EVALUATE remaining open deficiencies to ensure they will not impact readiness goals.
- b. MARK block on Attachment I to signify review completion.
- Operator Burdens:
- a. REVIEW Operator Burdens for impact on system readiness.
- b. MARK block on Attachment 1 to signify review completion.
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- Pre-outage Work List
- a. REVIEW Engineering " Pre-outage Work List."
- b. VERIFY all work or commitments are resolved.
- c. MARK block on Attachment 1 to signify review completion.
. Work Not Performed (Rejected OSCRs)
- a. PERFORM comprehensive assessment of system work or design items not performed during the outage, including work ' ' -
or PMs
' ' ~ - ' -
- - deferred to alater time. -
- b. DETERMINE impact of not performing the work or item on system performance and system OPERABILITY.
- c. IE any work or item should be completed now, PREPARE an OSCR and PROVIDE recommendation for completion outlining the potential risk involved with delaying the work.
- d. MARK block on Attachment I to signify review completion.
- A/R Review
- a. REVIEW the Open A/R List for items that:
- Are required to be completed prior to startup.
- Were generated to close a ACR that is required to be completed prior to startup.
- b. PERFORM comprehensive assessment of A/Rs that may affec1 system readiness.
- c. For A/Rs that are not needed prior to startup, LIST and PROVIDE evaluation of why there is no aggregate impact on system readiness on the system.
- d. MARK block on Attachment 1 to signify review completion.
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- ACR Review
- a. PERFORM comprehensive assessment of the effect of each open ACR on system readiness.
- b. IDENTIFY any items required to be resolved prior to startup.
- c. EVALUATE ACRs that have been dispositioned but whose i disposition is not implemented for impact on system readiness. j
- d. MARK block on Attachment I to signify review completion. l ;
" ~ ~ ' ~
.' Punchlist Evaluation '
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- a. REVIEW the following punchlists as applicable: ,
i a Fue1 Load .
t
= NRC Inspection Items
- Startup
- Abnormal Plant Conditions
- b. DETERMINE the effect of punchlist items on system readiness. ;
- c. VERIFY items that affect system readiness are dispositioned. l t
- d. MARK block on Attachment 1 to signify review completion. I i
I NOTE ;
i The preliminary system walkdown will satisfy the requirements of final walkdown unless additional system work is performed. ,
l
=
SRT Leader
- Preliminary System Walkdown and Design Engineer a. Refer To NUC PI 4,"Walkdowns," and PERFORM a
" Preliminary" system walkdown for materiel condition / l housekeeping.
- b. DOCUMENT each discrepancy on Attachment 2, !
" Unresolved Item Report." ;
- c. MARK block on Attachment I to signify review completion. I
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- Surveillances
- a. VERIFY the responsible department has completed all required surveillances.
- b. For Tech Spec systems, CHECK that the remaining interval between surveillance performance will not be impacted by the :
duration of the upcoming cycle, to ensure systems will be OPERABLE instead of AVAILABLE during the cycle.
- IE any surveillance is required prior to startup to ensure system OPERABILITY during the cycle, LIST by i surveillance number.
' - . JE any open surveillance will not impact system -
OPERABILITY during the cycle, LIST by surveillance number and PROVIDE justification of why system readiness is not impacted.
- c. MARK block on Attachment 1 to signify review completion.
i NOTE For routine maintenance and minor modification activities, the ISI, IST, i
and surveillance test programs suffice. However,if there is a concern '
regarding system reaomess due to an extended shutdown duration or as deemed necessary by the SRT Leader, a system preoperational test may be required to validate system functionality and demonstrate system ability to meet readiness goals.
- System Testing
- a. EVALUATE PDCR test plans from MQC approvallist for l adequacy.
- b. PREPARE UIR as necessary to document any discrepancies. l
- c. DETERMINE the extent of system testing to be performed, depending on the scope of work, design changes performed on the system, and duration of the outage.
- d. DETERMINE and DOCUMENT whether test is to be performed during unit startup.
- e. VERIFY required system testing is performed and results are satisfactory.
- f. MARK block on Attachment 1 to signify review completion.
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- LER Review
- a. PERFORM comprehensive assessment of LER commitments or open items for impact on system readiness. l
- b. MARK block on Attachment 1 to signify review completion.
. Long-standing System Issues
- a. IDENTIFY all outstanding issues on the " Top 10" listing or Operator Burdens that impact system readiness.
']
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' b. ASSESS impact on system re'adiness.
- c. MARK block on Attachment I to signify review completion.
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- Other System Issues
- a. ADDRESS review of special issues specific to this system as determined by SRT Leader.
- b. MARK block on ' Attachment 1 to signify review completion. :
t
. Final System Walkdown f
- a. IE any of the following apply, a " Final" system walkdown is performed by the SRT: l
= Work was performed on the system as a result of an .
identified discrepancy. l
- Work was outage related.
- Specific walkdowns are requested (from NUC PI 15,
" Selected Millstone Unit 3 System Reviews," vertical slice review, etc.).
- b. Refer To NUC PI 4, "Walkdowns," and PERFORM a " Final" system walkdown.
- c. DOCUMENT discrepancies noted on Attachment 2,
" Unresolved Item Report."
- d. ASSESS impact of each item on system readiness.
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- e. IE any item requires action prior to startup, INITIATE an OSCR. .
- f. . SUMMARIZE any open iterus or items noted during either the " Preliminary" or " Final" system walkdown.
- g. hiARK block on Attachment 1 to signify review completion.
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i 1.3 Preparation and Processing of Unresolved Item Reports l 1.3.1 COMPLETE Block #1 except for Log #.
l originator l" 1.3.2 PROVIDE discussion of item in Block 2.
1.3.3 IE known, PROVIDE recommended disposition in Block 3.
l" 1.3.4 REVIEW UIR.
l SRT Leader 1.3.5 IE known, PROVIDE recommended disposition in Block 3.
- -~- .
1.3.6 PRESENT UIR to PVRT.
1.3.7 1DENTIFY UIR disposition category from the following: l l PVRT l
- Materiel Condition - walkdown-related l
- Configuration - Design Basis, DCM, Licensing
- Admin - Programs and Procedures
- Training - Industry and internal issues
. VOID - Item is not a discrepancy !
1.3.8 Refer To WC I," Work Control" (Att) and ASSIGN priority.
1.3.9 IDENTIFY completion milestone from the following:
. Startup (for all Priority 1 and Priority 2 items and other items
- as desired)
- Other (as appropriate with milestone schedule) 1.3.10 DETERMINE and RECORD final disposition of UIR. l !
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l 1.3.11 PERFORM applicable action:
- IE action is required, IDENTIFY final disposition document f required to close UIR from the following:
- ACR
- TR
- NCR A/R (other) . . . . , . , .. . ,
- IE no action is required, MARK N/A. l 1.3.12 FORWARD UIR to UPM for approval.
lUPM' f 1.3.13 REVIEW UIR and dispositions, and APPROVE.
1.3.14 FORWARD to SRA for processing.
lSRA f 1.3.15 GENERATE required final disposition document. .
1.3.16 SEND copy of UIR to driginator or Supervisor.
1.3.17 FILE signed original UIR in System Readiness file.
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1.4 Preparation of Preliminan System Readiness Report NOTE Preliminan, System Readiness Report format is shown in Attachment .
This report is prepared after all"R" boxes of Attachment 1 are marked completed.
PREPARE Preliminan System Readiness Report package, which lSRA f 1.4.1 includes the following:
- UIR Summary Report
. UIRs l
. Walkdown Checklists
- Summary Report of Review Items 1.4.2 PRESENT Preliminary System Readiness Report (Attachment l SRT Leader f and package) to PVRT.
1.4.3 REVIEW Preliminary System Readiness Report and PERFORM l i lPVRT l the following: )
- a. DISPOSITION any open UIRs in package. l :
- b. IDENTIFY applicable category.
- c. IDENTIFY completion milestones.
- d. INDICATE the disposition document required.
- e. APPROVE Preliminary System Readiness Report (Attachment and package) and PRESENT to UPM for approval.
lUPM l 1.4.4 APPROVE Preliminan System Readiness Report package and FORWARD approved package to SRA.
ISRA ) 1.4.5 UPDATE UIR database to reflect approval of UIRs in l Preliminary System Readiness Report package.
1.4.6 FILE Preliminary System Readiness Report package in System Readiness file.
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. _ . - ,.-~.. .-- - _ . - - . . ~ - _ . - . - - - . _ . . - - . . - - - - -. . - - . . . . . .
1.5 System Readiness Review Team Status Reports 1.5.1 REQUEST status reports of open items.
[UPM f 1.5.2 Routinely PREPARE status reports (unless otherwise noted) for ,
lSRA f the following: l
- Open items
- Startup open items (by system)
- Other reports as requested by UPM . . . .
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1.6 Preparation of Final System Readiness Report I
NOTE 1 Final System Readiness Report format is shown in Attachment 4. This report is generated based on Attachment 1 information.
l: 1.6.1 VERIFY all "C" boxes on Attachment 1 are marked and allitems l HSRT Leader required for startup are resolved.
! 1.6.2 PROVIDE brief",Overall Summary" of the following.:
- System OPERABILITY or AVAILABILITY status
- Major factors affecting system readiness
- Aggregate assessment of all open items 1.6.3 PROVIDE summary of review results for each issue.
1.6.4 PROVIDE detailed assessment of the aggregate of all open ,
items.
1.6.5 PRINT the System Readiness Report and SIGN.
1.6.6 PRESENT Final System Readiness Report to SRT Coordinator for approval.
1.6.7 REVIEW and APPROVE Final System Readiness Report.
SRT Coordinator 1.6.8 PRESENT Final System Readiness Report to UPM for review and i
approval.
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1.7 Preparation of System Readiness Memo NOTE System Readiness Memo format is shown in Attachment 5. This memo is generated based on Attachment 1 information.
1.7.1 WHEN the System Readipess Report is approved, PREPARE a l NSRT Leader l" " System Readiness Memo" as follows:
- IDENTIFY the system being turned over. . .. .
- IDENTIFY system OPERABILITY or AVAILABILITY status.
- PROVIDE summary of findings and evaluation results.
- PROVIDE assessment of the aggregate of all open items. ,
- IDENTIFY any open items that will be tracked on the startup punchlist to support startup, including an analysis of the significance of each item and why it is considered a hold.
UPM & 1.7.2 PRINT the memo and SIGN.
SRT Leader 1.7.3 SUBMIT System Readiness Memo to MQC for review and lUPM l approval.
l 1.7.4 DISTRIBUTE the memo.
l SRA TRANSMIT the following to Nuclear Records: l 1.7.5
- Original System Readiness Memo a Final System Readiness Report
- Contents of System Readiness file, including:
- 1) Approved UIR originals
- 2) NUC PI 4 Walkdown Checklists (applicable Atts)
- 3) Miscellaneous items added by the SRT Leader
- A J. NUC PI 5 Level of Use __ _. ,- ,~ J _ . ,, a .
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- 2. REFERENCES 2.1 Configuration Management Plan (CMP) 2.2 WC 1," Work Control" 2.3 NUC PI 4,"Walkdowns" 2.4 NUC PI 8," Plant Verification and Readiness Team" l 2.5 NUC PI 15," Selected Millstone Unit 3 System Reviews,"
1 -
- - -- ~
- 3. --COMMITMENTS -
None
- 4.
SUMMARY
OF CHANGES 4.1 Amplified instructions for performing System Readiness Reviews. Added Operator Burdens to Attachment 3 and added associated instructions.
4.2 Deleted references to integrated database.
Level of Use d
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Attachment 1 System Readiness Checklist (Sheet 1 of 1)
SYSTEM NO.
C* Activity Description R*
AWO Review !
Design changes to ensure the following:
O Implementation is complete.
O Retestingmethodisadequate.
NCR Review TR Review . , <
, ~ -
- Maintenance' Rule Implementation
.EWR Review l I Jumper Bypass Review I
Operability Determinations or JCOs ControlRoom Panel Deficiencies i Operator Burdens Pre-outage Work List l Work not performed (rejected OSCRs) l A/R Review l ACR Review Punchlist Evaluation Preliminary System Walkdown Surveillances i
i System Testing LER Review Abnormal Plant Conditions Long-standing System Issues Other SystemIssues FinalSystem Walkdown
- R = Reviewed; C = Completed i SRT Leader: Date:
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l Attachment 2 i Unresolved Item Report (Sheet 1 of 2) l 6
SUBJECT FOR RESOLUTION UNIT 1 2 3 CY UIR LOG NUMBER ORIGINATOR DATE SYSTEM 1 SOURCE DOCUMENT Primary Secondary Reference Date DESCRIPTION OF UNRESOLVED ITEM O CONTINUATION SHEET DISCUSSION DETAILS i 2
)
I O CONTINUATION SHEET DISCUSSION BY Lead Engineer Review RECOMMENDED DISPOSITION DETAILS 3
O CONTINUATION SHEET DISPOSITIONER DATE l CATEGORY O MATERIAL CONDITION O CONFIGURATION O ADMIN O TRAINING O VOID COMPLETION MILESTONE PRIORITY O START-UP O OTHER 1 2 3 4 l 4 FINAL DISPOSITION PVRT APPROVAL DATE UPM APPROVAL DATE FINAL DISPOSITION DOCUMENT DOCUMENT COMMENTS GENERATED O N/A NUMBER ,
- O NCR O AR (other)
FINAL ROUTING DISTRIBUTION: 10 Data Base Clerk (O Incator 10 NDS UIR REVIEWED & CLOSED (Onginal) lDATE A A A i NUC PI 5 Level Of Use ,qggy. yggg7 g7., dei ~ Rev.1 InfOrmatiOn p.q jp:; pq jj;.4 g g9
l Attachment 2 Unresolved Item Report Continuation Sheet l
i (Sheet 2 of 2)
Continuation Sheet fon O Description O Discussion O Disposition -
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I Attachment 3
~
Preliminary System Readiness Report Format (Sheet 1 of1)
SYSTEM NO. ,
UIR Summary:
AWO Review:
Design Changes (PDCRs):
NCR Review: :
TR Review:
Maintenance Rule Implementation:
, , . EWR. Review:. . - -.
Jumper Bypass Review:
Operability Determinations or JCOs:
Control Room Panel Deficiencies:
Operator Burdens: l Pre-outage Work List:
Work Not Performed (Rejected OS CRs):
A/R Review:
ACR Review: t Punchlist Evaluation: .
Preli ninary System Walkdown:
Surveillances:
System Testing: !
LER Review:
Walkdown Checklist: r SRT Leader:
PVRT Approval: ,
UPM Approval:
L Basis /
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Attachment 4 System Readiness Report Format (Sheet 1 of 1)
SYSTEM NO. .
Overall Summary:
AWO Review:
Design Changes (PDCRs):
NCR Review:
TR Review:
Maintenance Rule Implementation:
EWR Review: . .
. . , m Jumper Bypass Review-Operability Determinations or JCOs:
Control Room Panel Deficiencies:
Operator Burdens: l Pre-outage Work List:
Work Not Performed (Rejected OSCRs):
A/R Review:
ACR Review:
Punchlist Evaluation:
Preliminary System Walkdown:
Surveillances:
System Testing:
LER Review:
Abnormal Plant Conditions:
Long-standing System Issues:
Other System Issues:
Final System Walkdown.
SRT Leader:
SRT Member:
SRT Member:
SRT Member:
PVRT Approval:
UPM Approval:
- 4 NUC PI 5 Doc ent sto f "$ W fcy' '7NVIEy7 Rev.1 N PTA W 27 of 29
Attachment 5 System Readiness Memo Format (Sheet 1 of 1)
TO: Date:
MQC Chairperson FROM: Memo No.
Unit Project Manager SRT Leader
SUBJECT:
[ System Description]
This memo documents an independent assessment of the readiness of the[ subject system] to support plant operation. This memo also presents a status of open items and provides a su'mmary of changes to the system due to shutdown activities.
[Present here the major open items of the system so as to capture system statusfrom a readiness perspective. Include the "Overall Summary"sectionfrom the readiness report, which presents the status of open items against the system and why those items do not affect system readiness. Also provide a summary ofdesign changes that have been ;
incorporated into the system.]
If there are any question on the status of the[ subject systemJ , please contact me at
[ extension].
Approved by: Date:
MQC Chairperson (Unit Director) cc: Unit Director Director, Nuclear Engineering Manager, Operations Manager, Work Planning Manager, Design Engineering Manager, I&C Manager, Maintenance Manager, Technical Support Shift Manager System Readiness File Nuclear Records
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.. . . - . . . . . - . . ~ - . _ - - . _ - . _ - . - - . . . . ..- . . .
i Attachment 6 Definitions (Sheet 1 of 1)
- A/R - Action Request
- AVAILABLE - Status of a system, subsystem, train, component, or device that is in service or can be placed in a functional or OPERABLE state within a time frame i
needed for prevention or mitigation of an accident.
i
. AVAILABILITY - A system, subsystem, train, component, or device has l AVAILABILITY when it is AVAILABLE.
. EWR - Engineering Work Request - . - , - - ~
l
- OPERABLE or OPERABILITY - A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing each of its specified functions, and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication, or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. l
- OSCR - Outage Scope Change Request
- System Readiness - Term used to describe system OPERABILITY or AVAILABILITY status.
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hTC PI 6 Rev.0 This Project Instruction (PI)is part ofimplementation of the Configuration Management Plan (CMP).
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Millstone Connecticut Yankee Seabrook SORC. Mrg. No.: PORC. Mtg. No.: SORC. Mtg. No.:
Date: Date: Date:
Effective Date:
~
- Responsible Individual:
Level of Use S. strout Information Subject Matter Expert:
S. Strout L - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _
MP1, MP2, MP3, CY NU Common Procedure Licensing Reviews TABLE OF CONTENTS
- /
- 1. IN STRU CTI ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Quality and Training Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.2 Development of Unit-Specific Positions on Regulatog Guidance . 3 1.3 Identification of Commitments and Verification of Compliance . . 7 1.4 . D elive ra bl e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
- 2. REFEREN CES . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
- 3. CO M M ITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
- 4. SUM MARY OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ATTACHMENTS AND FORMS Attachment 1, " Process Flow for Identification and Consolidation of Regulatory Requirements " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Attachment 2," Process Flow for Identification of Commitments and Verification of Compliance" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Attachment 3, " Proposed Format for Position Papers" . . . . . . . . . . . . . . . 19 Attachment 4," Threshold for Commitment Identification" . . . . . . . . . . . 20 A A p. 5 NUC PI 6 Level of Use Rev.0 lnformation ,qgr jgy4( wgr j91% sqg%(ySgr fjf jPtqg 1 of 22
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- 1. INSTRUCTIONS This PI provides a structured methodology for compiling two elements of the Licensing Basis (LB) for Millstone Units 1,2, and 3; and Connecticut Yankee. l i
1.1 Quality and Training Requirements :
-, NOTE The LIST database is not QA controlled; however,it does have network "
controls and cannot be modified by users. Since this database was developed from controlled files and is fully searchable, it will be used for identifying documents related to any selected issue. Hard copy of all !
correspondence is available for review.
1 1
Unit Project 1.1.1 ENSURE all personnel involved in implementing this PI are Manager trained in the following:
. Configuration Management Plan Use of LIST software (demonstration)
= ' Regulatory Compliance Manual, Chapter 4," Current Licensing Basis" .
= NEI " Guideline for Managing NRC Commitments" 1.1.2 Licensing team members shall have general knowledge of regulatory correspondence, plant design change processes, and plant procedures. Specific unit familiarity is not required.
NOTE i Section 1.2 and Section 1.3 need not be performed sequentially; that is, not all regulatory guidance position papers need to be developed prior to identifying commitments contained in other docketed correspondence or verifying compliance with those commitments.
1.1.3 Go to applicable section:
= IE developing position papers: Section 1.2
- IE identifying commitments or verifying compliance with commitments contained in other docketed correspondence:
Section 1.3 Level of Use ,gy d
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1.2 Development of Unit-Specific Positions on Regulatory Guidance NOTE Unless otherwise noted, the term " Licensing personnel" is used generically to indicate any licensing team personnel assigned to any unit.
1.2.1 DEVELOP a list of topics and regulatory guidance documents which require position papers. The regulatory guidance '
document list shallinclude:
. General Design Criteria (as applicable to the unit) !
- - ATWS
- Control Room Design Review EEQ
. Erosion / Corrosion .
. External Events / Hazards (Tornado, EQ, Flood)
. HELB/MELB
- Inservice Inspection
. IPEEE
- Master Equipment and parts List (MEPL)
- Regulatory Guide 1.97 Compliance
. Safe Shutdown /10CFR50 Appendix R Compliance l
. Separation / Independence / Diversity
. Setpoint Control
. Single Failure ,
. Station Blackout
. 10CFR50 Appendix J Compliance
. USI A46
. Heasy loads A A A A NUC PI 6 Level of Use ,fpr sqg7 ygg7.g.E Rev.0 Information wu e m ,pmra pg 4s ,am s of 22 g
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Unit ucensing 1.2.2 DETERMINE which documents of the following document types Lead require position papers for each individual unit and INCLUDE applicable documents on the Regulatory Guidance Documents -
List for that unit:
- Code of Federal Regulations (CFR)
= Division 1 Regulatory Guides
= TMIitems specified in Unit Orders a Source document for all key topical areas listed in the CMP
. Standard Review Plan
. Selected Generic Letters
- Selected IE Bulletins
- SEP Topics (for MP1 and CY)
- Other TMIitems
. Selected codes and standards ,
. Issues unique to the unit 1.2.3 ROUTE completed Regulatory Guidance Documents List to the applicable Unit Project Manager (UPM) for review and approval.
l* 1.2.4 REVIEW and APPROVE Regulatory Guidance Documents List.
lUPM Ucensing 1.2.5 WHEN the Regulatory Guidance Documents List is approved by personnel the UPM, IDENTIFY unit documents which address each guidance document as follows:
- a. PERFORM searches of LIST database using key words selected from the document name and subject.
- b. DETERMINE the set of documents to be reviewed, using the results of the searches.
- c. IDENTIFY the key words used for each search, PRINT and MAINTAIN the results of the searches.
- d. PROVIDE the list of documents to be reviewed for each guidance document to the Design Engineering Team (DET).
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i at to a guidance docum:nt as follows:
[DET f 1.2.6 DETERMINE commi .
- a. REVIEW each referenced document and DEVELOP other references as needed to determine the level of commitment to the guidance document.
NOTE :
Section 1.8 and Section ?.0 of the MP3 UFSAR provides examples of the minimum level of detail required for the position papers. Attachment 3 contains additional information on recommended format. For MP1 and CY, the SEP provides a starting point for the position papers.
- b. PREPARE a position paper on the guidance document and the application of the document to the unit, including:
- Name of the guidance document
- Whether or not the unit is committed to the document, in ;
whole or in part ,
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- Primary discipline affected:
- Mechanical
- Electrical
- I&C
< Operations
- Administration l
- Structures
- Chemistry l
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- Radiological /HP l
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- Speciel l
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- List of applicable source documents
! c. SIGN the position paper and FORWARD to a Second l Reviewer.
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second 1.2.7 REVIEW the position paper for adequacy, completeness, and Reviewer correctness. .
- a. IE acceptable, SIGN position paper and FORWARD to UPM. l
- b. IE not acceptable, RETURN position paper to preparer with comments.
Unit Pr ect 1.2.8 REVIEW the position paper for adequacy, completeness, and Manager correctness.
- a. IE acceptable, SIGN position paper and FORWARD to Design Engineering Manager..
- b. IE not acceptable, RETURN position paper to p:eparer with comments.
Design 1.2.9 REVIEW the position paper for adequacy, completeness, and Engineering correctness.
Manager
- a. IE acceptable, SIGN position paper and FORWARD copy to MQC.
- b. IE not acceptable, RETURN position paper to UPM with comments.
Design 1.2.10 VERIFY the position papers for each unit are assembled into a Engineering single controlled document.
Manager 1.2.11 IE at any time this document requires change or revision, VERIFY a 10 CFR 50.59 evaluation is performed on the proposed change or revision.
NOTE It is recommended that an independent review or assessment be performed on approved position papers before the position papers are used as part of the NUC PI 7 renew.
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I 1.3 Identification of Commitments and Verification of Compliance NOTE Attachment 4 provides a definition of" commitment" and describes how this definition is to be implemented at each NU Connecticut unit.
ucensing 1.3.1 DEVELOP the potential source documents list as follows:
pesonnel
- a. COMPILE a listing of all scurce documents for the selected calendar year as follows:
- 1) SEARCH on <date YY> for all four units (all four
" Unit" buttons pressed).
- 2) SORT on date.
- 3) PRINT comprehensive potential source documents list.
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NOTE I The following list may not be comprehensive, and may be expanded as reviews are performed and other types of documents are identified that are clearly not commitment documents.
- b. ELIMINATE documents on the potential source documents
., list that are not commitment documents as follows:
- 1) REVIEW eachlisted document, and MARK through and INITLE any document that is clearly:
- Fee invoices or payments
- Operator qualification or requalification test schedules or results
- Fitness for duty reports (annual or individual)
- Requests for site access for NRC employees or contractors l
- Notices of meetings or workshops
- Proposed rules and comments on proposed rules -
- Property insurance correspondence
- Annual submittal of Q A Topical, Security Plan, or Emergency Plan
- Other types of documents, as directed by the UPM or Licensing Lead
- 2) PERFORM an on-line screening review of the remaining documents to determine whether any additional documents may be eliminated.
- 3) On the printout, MARK through and INITIAL any document that is eliminated by on-line review.
- 4) REQUEST confirmatory review of the potential source documents list by a Second Reviewer.
secona 1.3.2 VERIFY only noncommitment documents on the potential source Reviewer documents list are marked through and initialed, and FORWARD the source documents list to appropriate Licensing Lead.
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NOTE .
Each unit team shall review all documents specifically assigned to its unit.
- The multi-unit documents shall be distributed as work load permits.
1.3.3 SEPARATE remaining documents on the source documents list Ucensing Lead ., into logical " working set lists" and ASSIGN sets to Unit Licensing personnel.
1.3.4 REVIEW documents listed on the assigned " working set list" and Unit ucensing personnel IDENTIFY all commitments contained in each document as follows:
- a. OBTAIN a copy of the document.
- b. Refer To Attachment 4 and NOTE the threshold on the document.
- c. REVIEW the document and IDENTIFY (by circling) each commitment made within the document as follows:
- Refer To Attachment 4, IDENTIFY the commitment type and NOTE on the document.
l
= IDENTIFY each unit the commitment affects and NOTE on the document.
- Based on the threshold, DETERMINE whether a commitment record is needed and NOTE on the document.
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NOTE For commitments that affect multiple units, a separate commitment record is prepared for each affected unit. THE COMMITMENT RECORD DATABASE HAS NOT YET BEEN DEVELOPED, SO THIS PI l REFLECTS USE OF A PROCESS THAT DOES NOT SPECIFICALLY REQUIRE A DATABASE. i
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Ucensing d. IE applicable (as determined in step 1.3.4.c.), PREPARE a personnelor commitment record for each commitment, containing the Data En,try following:
Technician
= Unit number
- Identifier information (from, to, subject, and date) !
- Text of the commitment and all necessary information from the source document to proside an understanding of the commitment by an individual who does n61 have the source document available, using the following guidelines:
- COPY the commitment as close to verbatim as possible.
- PLACE all clarifying text in square brackets.
Example: [ clarifying text) actual commitment [ clarifying text]
- System name or number (if known) ;
- Commitment owner (either system engineering or I appropriate supervisor if other department)
- Preparer's name
- e. REQUEST confirmatory review by a Second Reviewer.
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l NOTE .
For multi-unit source documents, the Second Reviewer shall be from a
. different unit team than the preparer.
second f. VERIFY that a commitment record is prepared for each j Reviewer identified commitment and for each unit affected by a commitment; and that each commitment record contains required information for each commitment.
- g. VERIFY status of commitment record is "OPEN" and l l RELEASE commitment for compliance verification. !
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NOTE The following list may not be comprehensive, and may be expanded as reviews are performed and other types of potential closure or '
incorporation processes are identified.
Unit Ucensing 1.3.5 EVALUATE compliance with each commitment identified in personnel step 1.3.4 as follows: -
- a. REVIEW text of the commitment record and DETERMINE how the commitment may have been closed or incorporated, including the following potential closure or incorporation processes:
Later correspondence
- Procedure change or revision or new procedure (including procedures that,in the reviewer's opinion, should address the commitment)
Training changes a Hardware changes (PDCR)
- Maintenance activities
- b. EXAMINE each potential closure or incorporation document to determine whether the commitment is adequately addressed.
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- c. IE adequately addressed, PERFORM the following:
. NOTE in the commitment record how the commitment is addressed.
- . JE the commitment is addressed by one or more procedures, AND the reference is properly identified as a commitment in each procedure, CHANGE status of commitment record
,, to " ACTIVE."
NOTE Procedure changes are initiated using the applicable procedure:
- For Millstone: DC 2," Initiating and Revising Millstone Procedures and Forms"
- For CY: ACP 1.2-6.5," Station Procedures"
- IE the commitment is addressed by one or more procedures, AND the reference is not properly identified as a commitment in any of these procedures, PERFORM the following:
- Refer To applicable procedure and INITIATE a change to each procedure that does not contain the reference to add the commitment reference to the Basis Document.
CHANGE status of commitment record to
" WORKING."
- IE the commitment is closed or superseded by later correspondence, PERFORM the following:
- NOTE the closure or superseding correspondence in the commitment record.
CHANGE status of commitment record to " CLOSED."
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- d. IE not adequately addressed, PERFORM the following:
- VERIFY status of commitment record is "OPEN." ;
NOTE Resolution of discrepancies is addressed in NUC PI 14, " Project Process
,, Administration."
- JE required, Refer To the applicable procedure and INITIATE an ACR for each identified discrepancy:
- RP-4," Adverse Condition Resolution Program" (for Millstone)
- ACP 1.2-16.5," Adverse Condition Report Process Implementation" (for Connecticut Yankee)
- e. REQUEST confirmatory review of the commitment record by Second Reviewer.
second f. VERIFY the commitment record for each commitment Reviewer contains applicable information, based on review results. ,
commitment 1.3.6 REVEW each assigned commitment and DETERMINE owner adequacy and completeness of references. ACCEPT commitment .
if adequate.
ucensing 1.3.7 REPEAT steps of 1.3.5 as needed to resolve unaccepted Lead commitments. i NOTE It is recommended that an independent review or assessment be performed for commitments at this time.
74 A ! A NUC PI 6 Level of Use information
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1.4 Deliverables Ucensing 1.4.1 VERIFY the following deliverables result from implementation Lead of this PI- .
- Controlled document for each unit containing position papers i on all selected regulatory guidance documents ;
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- Database of all active commitments for each unit !
a Listing of all commitments no longer in effect (for historical purposes)
- Discrepancies for commitments for which compliance could l not be identified.
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- Level of Use =
4 x' THIN K'u ,1 a;$- >4' .-
NUC PI 6 Rev.O
- *STOP~ /CT' ' REVIEW lnf0Tmat.lOn i;;4 j;;;.4n jA5 rf7 ,a
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l-_
- 2. REFERENCES l 2.1 Configuration Management Plan (CMP) i l
2.2 RP-4," Adverse Condition Resolution Program" 2.3 ACP 1.2-16.5," Adverse Condition Report Process Implementation" (for Connecticut Yankee) 2.4 NUC PI 14," Project Process Administration" 2.5 Regulatory Compliance Manual, Chapter 4," Current Licensing Basis" 2.6 NEI " Guideline for Managing NRC Commitments" 2.7 MP3 UFSAR, Sections 1.8 and 3.0
- 3. COMMITMENTS None
- 4.
SUMMARY
OF CHANGES 4.1 OriginalIssue t
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- Level of Use j; A /s ji NUC PI 6 idp ShigP wMp~ 'MEVT Rev.0 Information p j, y X //44 15 of 22 i
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Attachment 1 Process Flow forIdentification and Consolidation of Regulatory Requirements (Sheet 1 of1) .
l DEVELOP unit-specific list of guidance. l 9r l IDENTIFY correspondence regarding this guidance. l 1P REVIEW allidentified documents and DETERMINE commitment to the guidance.
Mr l PREPARE position paper. l
'F l REVIEW position paper. l wn Ll RETURN to
[egn{ Acceptable? r1 preparer.
Yes' A
T wr g yn L RE'nJRN to l REVIEW position paper. j y Acceptable? r preparer.
UPM 2 Yes 1
'P Design g, w RETURN to Engneering l REVIEW position paper. Acceptable? r UPM.
Manager Yes j
mr ASSEMBLE position papers into controlled document and MAINTAIN controlof position papers.
i A A A NUC PI 6 Level of Use , r% ~ & r #-
,e* STOP > THINK- ~' i ACT- ' REVIEW Rev. 0 lnformat. ion ;;pg f;;a;.:
yg4,, y g yin;n, , p +. 16 of 22 l
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I Attachment 2
-. Process Flow forIdentification of Commitments and Verification of Compliance (Sheet 1 of 2) .
Identification of Commitments Licensing DEVELOP 4-unit potential source documents list.
Per.*sonnej I
ELIMINATE documents that are clearly not commitment sources.
I I
Second -
VERIFY only noncommitment documents are Reviewer ehmmated from source documents list. ,
I Licensing SEPARATE source documents list into " working set lists" Lead and ASSIGN sets to Unit Ucensing personnel.
for each document Unit IDENTIFY all commitments, type, and threshold in Licensmg each document on assigned working set list.
Personnel i ,
IDENTIFY which units are affected by each commitment.
t I
Licensingpersonnel or Data Entry Tech PREPARE a commitment record for each commitment and for each unit to which the commitment applies.
I Second Reviewer VERIFY commitment record is prepared for each relevant commitment in assigned working set list; and each ,
commitment is adequately described in commitment record. l RELEASE record for verification of compliance. l NUC PI 6 LeveIof Use $
m.'STOP
. . m _'TH:N,K "
[
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_/ ._
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- u. c r y m_ yy y 17 at 22
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l Attachment 2 Process Flow for Identification of Commitments and i Verification of Compliance (Sheet 2 of 2) ,
For each commitment Verification of Compliance
...................................................................... i
- UnitLicensing DETERMINE potentialclosure personnel or incorporation documents.
l Commitment No !
- VERIFY status '
l adequately INITIATE resolution.. .
is .'OPEN."
addressed? !
Yes I
Committnent No appropriately INITIATE change to CHANGE status add commitment to to 'H annotated in document? document. " WORKING."
Yes I Commitment Yes NOTE closure or CHANGE status .y closed or superseding document to " CLOSED."
, l superseded? in commitment record. !
No Y I CHANGE status to " ACTIVE."
i Second
! Reviewer VERIFY commitment status.
e
- Y
- Commitment !
Owner ACCEPT commitment.
i Level of Use . _u--
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Attachment 3.
~
Proposed Format for Position Papers (Sheet 1 of1)
Guidance Document Identification Information:
. PROVIDE document number, name, and revision or date (if applicable).
Examples: GDC 14," Reactor Coolant Pressure Boundary" R.G.1.27, " Ultimate Heat Sinks for Nuclear Power Plants" Rev. 2, January 1976 Synopsis of Guidance:
PROVIDE a one or two paragraph synopsis.
Unit-specific Position on Guidance:
DESCRIBE level of commitment to guidance, using the following phrases where possible:
- Complies with . . .
- Meets the intent by . . .
- Provides equivalent . . .
- Is committed to . . .
- Is committed to except for . . .
!
- Is not committed to . . .
- Is committed only to . . .
l ADDRESS recognized system variations (if stated).
ADDRESS time variations (if stated).
IDENTIFY the primary discipline affected by the guidance.
l Source Documents:
LIST all documents used to develop the position.
SignofTs:
l l VERIFY position paper is signed and dated by the the following:
- Preparer
- Independent Reviewer
- Unit Project Manager l
- Design Engineering Manager i
j 4 A ! 4 NUC PI 6 1 Level of Use ,_% A_,.!:u__ur_
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Attachment 4 Threshold for Commitment Identification (Sheet 1 of 2)
NGP 4.01," Communications with the Nuclear Regulatory Commission," defines a commitment as:
':4n explicit statement to take a specific action agreed to or volunteered by NU that has been submined on the docket to the NRC, by designated Nuclear Group management in writing."
ThTs definition leaves substantial room for interpretation. For example, does a statement that an action has becn completed constitute a commitment?
NOTE If a tjuestion exists as to which category a commitment belongs, the commitment is treated as a Type 'A' commitment for identification.
Statement,s regarding action taken in scheduled established programs are not commitments.
For this Project Instruction, the following are considered commitment types: 1
. Type 'A': Stated action taken (or promised to be taken) that changes the design or operation of the unit; or stated actions taken relied upon by the NRC Staffin an SER (that is, commitments that potentially change the LB or DB)
= Type 'B': Stated action taken (or promised to be taken) that restores the unit design or operation to the condition bounded by the LB or DB at the time the statement was made, excluding statements regarding actions taken via established programs.
- Type 'C': Promised er requested submittal of information to the NRC or other agency 5 A A NUC PI 6 Level of Use [
y g , , g 7 ,, @ ~ ' E N T Rev.0 Information ;C a ,b
- 4,,. .M4 r y5 K, 90 of 22
Attachment 4
~
Threshold for Commitment Identification (Sheet 2 of 2)
Examples of commitment types:
l Type 'A': ;
. We have installed a higher capacity . . . ;
l . , We will revise Technical Specification Section . . .
. We have initiated a procedure upgrade program.
. We will establish administrative controls until the modification can be installed.
Type 'B': -
l
- The leaking valve will be repaired during the next outage.
! - The system was restored to OPERABLE status.
! - The drawing was corrected.
l Type 'C':
- Please provide a response to this Notice of Violation in 30 days.
- We will submit the results of our analysis prior to startup.
All" types" of commitments shall be identified on the documents during the review.
However, commitment records are created only for commitments which exceed the following thresholds:
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A A /' A NUC PI 6 Level of Use ,e.gp7 cg7 ,gy,sSET Rev. 0 Information jpg p,g jpg jy n.c( 21 of 22 i
- For correspondence dated back to 1/1/94: Threshold 1:
- Any commitment which meets any of the above " type" definitions
- - For correspondence dated from 12/31/93 back to 1/1/84: Threshold 2:
- All Type 'A' and Type 'B' commitments except those Type 'B' commitments which have a completion date or associated event that has passed
. Any Type 'C' commitment with a completion date of 1996 or later
. For correspondence dated from 12/31/83 back to initial licensing: Threshold 3:
- All Type 'A' commitments except those which have a completion date or associated event that has passed
. Any Type 'B' and Type 'C' commitment with a completion date of 1996 or later 4 A 1- A NUC PI 6 Level of Use -ggpr mg7. mc,$dr'EE Rev.0 Information g pq pg p .-c- 22of22
~f.
fyR j, u NORTHEAST UTILITIES NUCLFA,Ri: 5 CY -
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PROJECTINSTRUCTION , '
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Rev.O is part ofimplementation of the This ProjectManagement Configuration Instruction (PI) Plan (CMP).
Approval Effective
- m Mtg. No. Date Date Millstone SORC gg,gq g ,gg,97, CY PORC MP1PORC MP2 PORC MP3 PORC I
i Responsible Individual:
Level of Use
- E Mattioli
! Subject Matter Expert:
! lnformation E Mattioli/J. Scarfoss
MP1, MP2, MP3, CY _
Project Instruction Graded System Review .
TABLE OF CONTENTS
- 1. INSTRUCTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
~. 1.1 Training Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.2 Establishing System Review Team . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1.3 Licensing Basis Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.4 Design Basis Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.5 Self- Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ....... 9 1.6 Validation Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1.7 System Package Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.8 Discrep ancies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 2.
COM MITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 3.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4.
ATTACHMENTS AND FORMS Attachment 1, " Documentation of System LB and DB" . . . . . . . . . . . . . . 16 Attachment 2," Typical Attributes to Determine DB" . . . . . . . . . . . . . . . . 20 Attachment 3, " System LB and DB Package" . . . . . . . . . . . . . . . . . . . . . . . 24 l l
Attachment 4, " System Review Matrix" . . . . . . . . . . . . . . . . . . . . .. . . . . . 25 Attachment 5, " System Review Process" . . . . . . . . . . . . . . . . . . . . . . . . 27 1
. & A f it NUC PI 7 i Level of Use ~7 E - v"4 a - ,"WACT)4% 'RinnEW e- Rev. 0 9 ROP' THINK' lnformat, ion q jpg peg 1of28 p%d;
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- 1. INSTRUbrIONS )
i The objectives of this Project Instruction (PI) are:
- \
- Determine the Licensing Basis (LB) and Design Basis (DB) for systems as identified in the Configuration Management Plan (CMP). i
- Categorize NUC PI 1," Document Identification and Retrieval,"
information in order to support preparation of documents in accordance with NUC PI 9," Design Basis Documents," and NUC PI 13, "UFSAR
- " Changes."
- Review appropriate system design data (i.e., NUC PI 1 information) to ensure the system meets DB requirements.
This PI provides a consistent approach to determine and/or confirm the LB and DB for each system reviewed. This system review is accomplished using results from performance of the following:
- NUC PI 1, " Document Identification and Retrieval"
- NUC PI 6," Licensing Reviews"
. Other PIs as noted throughout Attachment 5 contains a flow chart of the system review process.
The term " system" as used in this PI includes the systems committed to in the unit-specific CMP Implementation Plans and Topical Areas defined in the CMP attachments.
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I 1.1 Training Requirements .
" ENSURE all personnel involved in implementing this PI are
. Unit Project 1.1.1 l Manager trained in the following: ,
- Configuration Management Plan
- RP-4," Adverse Condition Resolution Program" (for Millstone)
.-' . ACP 1.2-16.5, " Adverse Condition Report Process '
Implementation" (for Connecticut Yankee)
- NUC PI 1," Document Identification and Retrieval"
. NUC PI 6," Licensing Reviews"
. NUC PI 8," Plant Verification and Readiness Team" l
- NUC PI 16, " Licensing Basis and Design Basis Walkdowns" I
Design 1.1.2 ENSURE all personnel involved in implementing this PI are Engineering qualified (based on their resume or current job description) and Manager are provided specific training on this PI to ensure their ability to meet procedure objectives.
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I 1.2' Establishing System Review Team
" Refer To the unit-specific CMP Implementation Plans Jesig 1.2.1 i
Eng nineering attachments within the CMP and ASSIGN a System Review Team l -
Lead (SRT) Lead to each listed system.
1.2.2 REVIEW each assigned System and/or Topical Area and l SRT Lead l DETERMINE which disciplines need to be'part of each SRT.
1.2.3 ASSIGN members to SRTs based on disciplines required for each Design.
Engineering System or Topical Area.
Lead i
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1.3 Licensing Basis Determination
. NOTE
- 1. Specific instructions are contained within this PI to ensure that additionalinformation is properly reviewed as the information becomes available.
- 2. Attachment 1 provides a documentation outline for reviews performed by this Pl. Associated procedure steps are noted in Attachment 1 for
. each documentation requirement in the outline.
" Those NUC PI 6 items identified as applyi,ng only to a saecific System 3.
~ 3p ical Area are not required to be reviewed for applicability by r System Review Teams.
- 4. 11 at anytime during performance of this PI a discrepancy is found, Section 1.8 provides instructions for handling the discrepancy.
1.3.1 OBTAIN documentation resulting from NUC PI 6, " Licensing l SRT Lead f Reviews."
1.3.2 REVIEW NUC PI 6 results to determine the following:
lSRT f
. Which unit LB requirements are applicable to the system being reviewed and the reason why the requirement is applicable.
. Which unit LB requirements are not applicable to the system being reviewed and the reason why the requirements are not applicable.
1.3.3 INITIATE an Attachment 1 and DOCUMENT results of step 1.3.2 for each LB document reviewed. .
NOTE The system LB is defined as that portion of the unit LB that is applicable to the system under review.
1.3.4 ASSIGN system LB to the appropriate SRT member for DB f determination.
- a. DOCUhENT assignments on Attachment 1.
i h A A $ NUC PI 7 Level of Use _'STO R ,P~ .. 'THINK'm.,_a_#..,'_a>_
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1.3.5 Using the system LB, PERFORM a group review to accomplish l SRT l the following for each LB document reviewed and DOCUMENT l results on Attachment 1:
- ESiABLISH communication among the SRT members. -
- IDENTIFY " hand-offs" between SRT members (such as discipline).
- ELIMINATE duplication of efforts (such as screening for topicalissues).
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15 Design Basis Determination .
NOTE .
Design Basis consists of:
. System Design Basis
- Component Design Basis
- Structure Design Basis
= Portions of supporting systems required to meet a System Design Basis l
1.4.1 EVALUATE each assigned system LB (from step 1.3.4) to l SRT Member l" establish DB.
- a. DOCUMENT results on Attachment 1.
l 4 1.4.2 Using the DB from each assigned system LB, PERFORM a group l SRT ~' review and ENSURE DB determination has fully captured all discipline or generic issues.
- a. DOCUMENT results on Attachment 1.
1.4.3 Refer To NUC PI 1," Document Identification and Retrieval," -
I SRT Lead l and OBTAIN documentation pertaining to the System or Topical l
Area being reviewed.
1.4.4 REVIEW System or Topical Area documentation and l SRT l l
CATEGORIZE information as follows:
- Information that is DB (Category 1) j Information that is EDB (as defined in the CMP) which supports the DB (Category 2) ,
. Remaining EDB information (Category 3)
- Other information (Category 4) i g7qg%7.'dsr$ Rev. 0 A A NUC PI 7 i
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j' . 1.4.5 OBTAIN the following from UPM:
- Categories to be reviewed (from step 1.4.4)
- Depth of review required for each category as specified within the CMP
- IE applicable, any actions resulting from NUC PI 2, l
l " Unit-Specific Assessments" t .
NOTE Category 1 and Category 2 information support the Design Basis. When documentation that supports the DB has been identified, the Design Basis i
(as described in the NOTE before step 1.4.1) has been determined.
1.4.6 REVIEW information contained in Category 1 and Category 2 lSRT l:
for the following and DOCUMENT results on Attachment 1:
- Does the information support the DB?
- Does the information identify additional DB or modify DB?
l l 1.4.7 IE review ofinformation contained in Category 1 and Category 2 identifies additional or modified DB, IDENTIFY additional or modified DB on Attachment 1 and Go To step 1.4.2.
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1.5 Self-Assessment <
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I 1.5.1 IE directed by UPM, Refer To NUC PI 14, " Project Process 3RT Lead l" Administration," and PERFORM a self-assessment to ensure I consistency and completeness among systems. '
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j4 1.6 ' Validation Process ,
1.6.1 Refer To NUC PI 16,"Walkdowns," and PERFORM the 4
JaT Member f following to confirm the plant configuration supports the DB . .
i l developed for the assigned System or Topical Area:
- REVIEW walkdown checklists completed to date.
i
. IDENTIFY need for new and/or additional walkdowns. ,
1
-' . WHEN complete, REVIEW new and/or additional walkdown :
4 checklists.
, i NOTE :
Validation of DB may be accomplished using either the ACCESS database 4 or the hardcopy method, as specified in NUC PI 8.
i 1.6.2 REQUEST performance of NUC PI 8," Plant Verification - ,
Readiness Team," to validate DB determined in step 1.4.6. ;
l= 1.6.3 COLLATE information from SRT members.
' the DB noted in Section III of Attachment 1. [
1.6.5 DETERMINE whether additional information has been generated from NUC PI 6 and NUC PI 1. !
1.6.6 IE additional information has been generated, DOCUMENT ;
additionalinformation on Attachment 1 and PERFORM ,
l applicable action:
I
. For Licensing Basis information, Go To Section 1.3.
. For Design Basis information, Go To Section 1.4.
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1.7 System Package Documentation .
l
_SRT l: 1.7.1 REVIEW each completed Attachment I and PERFORM the ;
followmg: .
l
- a. DETERMINE all DB associated with the System or Topical !
Area under review.
- b. INITIATE Attachment 4 for the System or Topical Area
, under review. i
-a ;
- c. LIST DB on Attachment 4. :
NOTE t
Review or performance ofitems shown on Attachment 4 is considered complete only after all of the following are resolved:
= Identified discrepancies l Required procedure changes t Required document changes (other than procedures) 1.7.2 COMPLETE Attachment 4 for each DB identified in step 1.7.1 as follows: ,
- a. For each item reviewed and/or performed and completed, .
INITIAL the appropriate box. !
- b. For each item reviewed and/or performed but not completed (open issues), PERFORM the following:
- 1) INDICATE a numerical value in the appropriate box. )
- 2) IDENTIFY the numerical value and each associated open issue on Sheet 2 of Attachment 4.
- c. For each item not required to be reviewed and/or performed, ENTER "N/A"in the appropriate box.
l SRT Lead j' 1.7.3 REVIEW all open issues identified on Sheet 2 of Attachment 4 and PERFORM the following for each item: j
- a. IDENTIFY and RECOMMEND action on those open issues which must be completed prior to completion of this PI.
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- b. ENSURE all open issues are being tracked as specified in
~
NUC PI 14, " Project Process Administration."
1.7.4 REVIEW Attachment 4 and PERFORM the following: ,
i DEL l
- a. ENSURE Attachment 4 is complete.
l b. IDENTIFY those open issues which must be closed prior to completion of this PI. i l
! '., c. ENSURE necessary resources are available to support timely i l closure of open issues. l t
l
! d. ENSURE all open issues are being adequately tracked as l
! specified in NUC PI 14," Project Process Administration."
i
' 1.7.5 PREPARE a System LB and DB Package, consisting of the l SRT Lead l:
- following
- System Review Matrix (Attachment 4)
- All Attachment 1 information, consisting of the following:
- 1) Verified and Validated System LB
- 2) Verified and Validated Component, Structure, and System DB
- 3) Verified and Validated System or Components required !
to support the DB
- 4) Description of supporting design information that has been reviewed
1.7.6 SUBMIT system package to Unit Project Manager (UPM).
ji A 4 A NUC PI 7 Level of Use y g g m g r- Q F Y 'Es" Rev.0 lnformation jpg jpg P% P%( 12 of 28 1
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NOTE
~
The UPM approved System Package is a controlled document and is .
controlled as specified in NUC P114, " Project Process Administration."
i lUPM l 1.7.7 REVIEW and APPROVE System Package.
, 1.7.8 ENSURE System LB and DB Package are available as QA j .,, documentation as required to support implementation of the I following:
i
- NUC PI 9," Design Bases Documents" f
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6 Level of Use d 1 $ . . NUC PI 7 Information ,?p" gy ,ryyye ML _jpeq ,MAcT'y Rev. 0 33og2g ,yg,.'~5Evl
1.8~ Discrepancies NOTE ,
Discrepanciesare tracked and remain as open items until resolved.
. Resolution of discrepancies is addressed in NUC PI 14," Project Process Administration."
l SRT Member l 1.8.1 IE required, Refer To the applicable procedure and INITIATE an ACR for each identified discrepancy:
. RP-4," Adverse Condition Resolution Program" (for Millstone)
. ACP 1.2-16.5, " Adverse Condition Report Process Implementation" (for Connecticut Yankee) i l
Level of Use 2 /t A A NUC PI 7
,egbF' 'dF 7'$7dn Rev.0 Information jpg jpD /PQ fi 14 of 28
i
- 2. REFERENCES
- l 1 2.1 Configuration Management Plan (CMP) i
~
2.2 RP-4," Adverse Condition Resolution Program" (for Millstone) ;
2.3 ACP 1.2-16.5, Adverse Condition Report Process Implementation !
(for Connecticut Yankee) 2.4 NUC PI 1, " Document Identification and Retrieval" ;
2.5 NUC PI 2," Unit-Specific Assessments" j l :
2.6 NUC PI 6," Licensing Reviews" :
l 2.7 NUC PI 8," Plant Verification and Readiness Team" l
2.8 NUC PI 9," Design Bases Documents" lr l o 2.9 NUC PI 10," Configuration Management" ;
2.10 NUC PI 13,"UFSAR Changes" ,
i l 2.11 NUC PI 14," Project Process Administration" l 2.12 NUC PI 16," Licensing Basis and Design Basis Walkdowns"
- 3. COMMITMENTS Nonc
- 4.
SUMMARY
OF CHANGES .
4.1 OriginalIssue i
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Attachment 1 )
Documentation of System LB and DB (Sheet 1 of 4) f System orTopical Area:
System No. (if applicable):
LB' Document reviewed (documentation from NUC PI 6):
( .
i
! Applicability Determination and Reason (from step 13.2):
0 Yes O No O Not Sure (White Paper required to determine applicability) t i
Applicable Discipline (from step 13.4):
Prepared By: Date: l SRT Lead Review: Date: .
Level of Use k
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Attachment 1 Documentation of System LB and DB (Sheet 2 of 4)
System or Topical Area:
System No. (if applicable):
NOTE If similar topics are being covered, multiple documents may be listed below.
I. LIST LB documents reviewed and group review results for each (step 1.3.5):
NOTE Attachment 2 attributes are used to help develop the DB.
II. LIST DB from assigned System LB (step 1.4.1 and step 1.4.2) and IDENTIFY each DB as a system, component, structure, or support:
Prepared By: Date:
Level of Use d d /' d NUC PI 7
~Esify m
" "VRisi?"~
F'
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Attachment 1 Documentation of System LB and DB
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(Sheet 3 of 4) .
System or Topical Area:
System No. (if applicable):
III.' LIST documentation from NUC PI 1 or other sources that supports DB identified in Section II of Attachment 1 (step 1.4.6):
Document Remarks
.,, DB IDENTIFY below any new DB added to Section III and any DB from Section II which has been modified as a re: uit of the NUC PI 1 review (step 1.4.7):
t Prepared By: Date:
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4 Attachment 1
. Documentation of System LB and DB
- (Sheet 4 of 4) l System orTopical Area
l
{ System No. (if applicable):
! IV. A'ITACH the following:
i s
4
- NUC PI 16 walkdown checklists (step 1.6.1)
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- NUC PI 8 requests and results (where applicable) (step 1.6.2)
{
4 IV.A. DOCUMENT any additions or modifications to the DB noted in Section III of this Attachment (step 1.6.4):
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! IV.B. DOCUMENT additional information from NUC PI 1 or NUC PI 6 which affects the
] System LB or DB (step 1.6.6):
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l Attachment 2 Typical Attributes to Determine DB I (Sheet I of 4) .
A The following is a list of typical design attributes and controlling design parameters that could form the Design Basis: .
J Electrical
. Diesel Generator sizing
- Safety-related power cable sizing l
~
-6afety-related system voltage profile
]
- Safety-related system short circuit analysis l :
. Diesel generator performance
- Safety-related bus transfer analysis
= 480V MCC and switchgear protection and coordination
- Class IE battery sizing
. Unintermptible power supply sizing
. Low voltage and DC cable sizing
- Class IE AC/DC system protection and coordination
= Safety-related instrument setpoint and accuracy calculations i
- Control loop response time calculations I
- Electrical separation analysis
- Raceway fill and loading j
Nuclear i
- Control Room toxic gas
- Tornado loadings and external missiles
- External flooding effects
- Pipe break effects (pressure, temperature, flooding, rupture)
- Equipment environmental qualification (harsh and mild environments)
- Systems required to mitigate design bases accidents (DBAs)
- Radiation source terms for DBAs
- Containment analytical mode;
- Post-accident conditions
- Offsite dose analysis for normal operation and DBAs Level of Use ghs 7 37{ p- g7 0 lnformation jpg jpg pq jp: 20 of 28
- , _ . . __ . _ _ _ m _ _
Attachment 2 Typical Attributes to Determine DB (Sheet 2of 4) .
Nuclear (Continued)
- Control Room shielding and operator doses
- Personnel radiation doses during DBA recovery activities
- Airborne radioactivity transport from a fuel handling DBA
- Loss of Spent FuelPool cooling
.- " Ultimate heat sink capacity analysis
. Control Room habitability during blackout (air temperature)
. Anticipated transient without scram (ATWS) events
- Pipe break discharge flow
- Secondary containment air pressure control analysis
- Heat load determination analysis
- Heating, ventilation, and air conditioning (HVAC) system failure modes and effects analysis
- HVAC instrumentation setpoints
- Control Room enclosure air infiltration
- Battery compartment hydrogen accumulation
- HVAC design analysis
- Reactor transient analytical models
- Reactor Coolant System transient analysis
- Pipe flow hydrodynamic loads analysis
- Piping network dynamic flow analysis ,
- Valve operability analysis
- ASME Code of record calculations
- Computer code certification documents
- Thermal analysis of components, supports, and structures
- Component minimum wall thickness calculations k A NUC PI 7 Level of Use A .m . i-. .
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Attachment 2 Typical Attributes to Determine DB (Sheet 3 of 4)
Civil .
- Category I reinforced concrete structures analysis
. Category I steel structures analysis
- Civil structure dynamic / earthquake analysis
. Dynamichtress analysis of substructures
. - tynamic/ stress analysis of containment nozzles, etc.
- Tornado analysis of structures
- Category I weld evaluations
- Category structure block walls
- Component seismic / structural qualification
- Pipe rupture restraints
- Bolt anchorage in Category I structures
- Probable maximum flood analysis
- Platform steel, cranes, monorails, doors, ladders ,
- Heavy loads analysis ;
- CategoryI piping analysis
- Seismic analysis of electrical conduit
. Instrument line analysis
- Category 1 supports (pipe, duct conduit, tray and instmmentation, and NSSS supports)
- Penetration qualification
- Earthquake ground motions
- Category I foundation analysis l
l i
Level of Use y h7 {,g sq p, 7 .g. vfo Information jpyg gpq jpg fJM 22 of 28
Attachment 2
. Typical Attributes to Determine DB (Sheet 4 of 4)
Mechanical .
- Piping minimum wall thickness
- Pump net positive suction
- Pump total system head a Valve pressure drops (Cv)
- ~ " Tank nozzle / branch line reinforcement
- Heat transfer (sizing of heat exchangers, condensers, heaters, etc.)
. Pump /systern performance
- Pressure / vacuum relief valve sizing
. Sump capacity
- Cooling water flow rates
- Equipment performance calculations
- Corrosion / erosion allowances
- Tanks (volume, wall thickness, etc.)
. Pipe sizing / flow
- System design / operating pressures and temperatures .
- Pump brake-horsepower requirements
- Valve actuation times and check valve closure I
Instrumentation and Controls
- Safety-related instrument range and span .
- Safety-related instrument setpoint and uncertainty calculations
- EMI/RFI analysis
- Instrument time
- Safety-related to nonsafety-related equipment isolation
- Safety train separation l
A d 8 d NUCPI7 Level of Use gpr ,rg7 gp. MEW Rev.0 l Information jy9 jperg /F% /F% 23 of 28
Attachment 3 System LB and DB Package (Sheet 1 of 1) i Cover Sheet System orTopical Area:
System No. (if applicable):
SRT Leader:
-/
SRT Member Discipline e
Package contains the following (CHECK applicable column):
Description Yes No Attachment 4, System Review Matrix ,
All Attachment 1 information, including: {@@fiffg
- a. Veri 5ed and Validated System LB
- b. Veri 5ed and Validated Component, Structure, and System DB
- c. Veri 5ed and Validated System or Components required to support the DB
- d. Description of supporting design information that has been reviewed
l Reviewed By DEL: Date:
Approved By UPM: Date:
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Atta. .sent 4 System Review Matrix (Sheet 1 of 2)
System No.(if applicable):
System or'Ibpical Area:
tJcense Basis Consistency Plant Documentation Agreement Design Basis Consistency 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 5 6 7 8 9 10 Il 12 13 14 Design Basis 1 2 3 4 I I l I I I .
I I I I I l I 1 l . l I I I I l l 1 I I I Date:
Prepared By:
Date:
Reviewed By:
Date:
Appr'oved By DEL:
Column Codes:
11 - Drawings 16 - PDCRs 2i - NRC Insp Findings 26 - Thch Reqmts Manual 1 - Performance Reqmts 6 - Equipment Certs 12 - Specifications 17 - Other ' 22 - GLs. ins, IE Bull's . . . 27 'Thmporary Meds 2 - Regulatory Reqmts 7 - Safety Analysis 13 - System Description 18 - FSAR 23 - Other
- 28 - Walkdowns 3 - Codes 8 - Stress Reports 14 - DDDPs 19 - Tbch Specs 24 - Procedures 29 - Thch Specs 4 - Standards 9 - Vendor Information 15 - Equipment List 20 - License Commitments 25 - Sury.'Thsts & Insp's 30 - Other
- 5 - Calculations 10 - Evaluations
- If"Ottier" box is used, IDENTIFY document reviewed or function performed.
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Attu .icnt 5 I System Review Process (Sheet 1 of 2)
QJJJECTIVES s
- Determine LB and DB for system as identified in CM P.
- Filter and sort NUC PI 1 information in order to facilitate performance of NUC P19 (DBD) and NUC PI 13 (UFSAR).
- Review appropriate design data to ensure the system meets DIl requirements.
SIE SYS/ TOPIC DEL Sys/lbpje Lead llEL LB -
--> Establishmake sp -> NameSRT i
) Review unit LB and determine Assign Sys/ DETERMINED of SRT. Members. I applicability to Sys/lbpic LU.
Topic Lead Document results.
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_I I Refer Tb NUC PI 14 for gui<tance NUC PI 6 g l g w/ discrepancies during this process. J Provide unit LB.
4 SIE UPM -
SIE g ele - Determine: 4 Sys/Ibp DB Screen & filter
+ Component DB --> NUC PI 1 info. reviewed and depth of review.
+ Establish communication between SRT.
Identify handof fs between disciplines.
- Structure DB = identifyNUCPI2 issues.
- + Elimmate duplication of efforts.
System / Components req'd to meet DB NUCPI1 Provide appropriate sys design data.
SIE -
. Review designated NUC PI 1 info. "
Sheet 2 +- . Review any applicable NUC PI 2-generated issues.
. Ensure data supports DII.
4 4 A NUC PI 7
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Ath .cn( 5 System Review Process (Sheet 2of 2) .
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- Self-assessment *
- "Y.b,e,p,ef f ,03mef., j seef1 .
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SYSTEM OR l SRT SRf - Compiete SRT - Complete review and evaluation y TOPICAL > Validation > System Review Matr,ix.
AREA DB Process , oflicense commitments DETERMINED
" " for system against DB. q7 REsULB neoussrs accuests SM' Lead -
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NUC PI 6 and NUC Pt 1 - closed prior to completion of this Pl.
Review DB to Review DIl to plant Identify any additional Ensure all open issues are tracked.
plant processes. configuration. documentation generated
~ by these PIs.
DEL - Ensure the fol wing:
UPM - = Attachment 4 is complete.
Review and approve System Package. p
- All open issues required to be cl9 sed prior
+-- Frepare LB and DB to mmpletion of this PI are identif;ed.
- Ensure System Package is available as System Package and a OA document for implementation
- Open issues can be closed.
submit to UPM.
of NUC PI 9 and NUC PI 13. + Open issues are tracked.
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i NUC PI 8 -
Rev.O This Project Instruction (PI)is part ofimplementation of the Configuration Management Plan (CMP).
Millstone fn$fl 3l onnecticut Yankee SORC. Mtg. No.: k5'8 PORC. M:g. No.:
Date: O* O b"N Dee:
Effective Date:
Responsible Individual:
Level of Use _ D. Reed Information Subject Matter Expert:
D. Reed. _
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MP1, MP2, MP3, CY '
NU Common Procedure Plant Verification and Readiriess Team .
TABLE OF CONTENTS 1.. . , IN STRU CTION S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Team M akeup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.2 Team Reviews Using ACCESS Database . . . . . . . . . . . . . . . . . . . . . 5 1.3 - Review of Existing Operational Controls Using ACCESS Database 8 1.4 Design Engineering Activities Using ACCESS Database . . . . . . . . 9 1.5 . System Record Disposition Using ACCESS Database . . . . . . . . . 10 1.6 Team Reviews Using Hardcopy . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.7 Review of Existing Operational Controls Using Hardcopy . . . . . . 13 1.8 Design Engineering Activities Using Hardcopy . . . . . . . . . . . . . . 14 1.9 System Record Disposition Using Hardcopy . . . . . . . . . . . . . . . . . 15
- 2. REFEREN CES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
- 3. COMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
- 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 ATTACHMENTS AND FORMS Attachment 1," Plant Verification and Readiness Team Review Process Flow Chart" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 8 A A 8 NUC PI B
- a. ,%s% .N_.
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- 1. INSTRUCTIONS ,
This Project Instruction provides details for the Operations Plant Verification and Readiness Team (PVRT) evaluation of the adequacy of existing operational ~
controls (programs and procedures) with respect to the Licensing Basis (LB) and Design Bases (DB) of the unit.
Each Unit Project Manager (UPM) has the authority to d'ecide the vehicle used for docurnenting and maintaining LB and DB information for the unit in accordance with NUC PI 14, " Project Process Administration." It is acceptable to use either {
one or a combination of the following documentation vehicles on the unit:
I
- ACCESS database method - The ACCESS database developed for this project is a QA database controlled by Northeast Utilities (NU). This i database is subject to quality requirements, including complete documentation and a Verification and Validation process. Software l security exists such that when a record is entered, it cannot be modified without management approval.
l
- Hardcopy method - Based on the scope and level of detail required for an l individual unit, the UPM may decide to use a hardcopy method for i documenting the LB and DB, and for tying operational controls to the LB i and DB.
l l
l Information jpg pq pq4 p;% 2 of n
i 1
- i 1.1 Team Makeup _
NOTE i
4 Step 1.1.1 delineates PVRT membershic . Names in boldface type are mandatory members,who may act as chairperson for the review session.
denotes mandatory members who may not act as An asterisk chairperson. A (*)ll other titles are optional members.
1.1.1 ASSEMBLE a PVRT consisting of the following:
Unit Proje Manager
- Two Operations personnel from the following options:
. Two with a current SRO-license on the specific unit
. One Shift Manager / Unit Supenisor (SM/US) and one previously-licensed SRO with greater than 18 months of unit-specific Operations experience
. One Shift Manager / Unit Supenisor (SM/US) and any other person authorized by the UPM
- One I&C representative
- One Maintenance representative
- One Generation Test representative
- One responsible System Engineer *
- Responsible Design Engineering Lead * .
- One NSSS site vendor representative
- One representative with both Engineering and Operations
. background (such as Unit STA)
- One Operations Training Representative A A A A NUC PI 8 Level of Use ,,A,- x- n ~
A -K*m*i?ACT'tA'REvieN . ~Rev. O 379g s7 gig nformat,on i gag jg; jj j g;4 3 of 17
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I NOTE It is acceptable to use eith'er one or a combination of documentation '
vehicles on any unit.
I 1.1.2 SELECT documentation vehicle to be used and DOCUMENT decision in project file.
- 1.1.3 Go To applicable section:
. IE design information for review by PVRT has been entered into ACCESS database: Section 1.2
- IE design information for review by PVRT consists of hardcopy records: Section 1.6 i
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- l 1.2' Team Reviews Using ACCESS Database
~
NOTE ,
i
- 1. Section 1.2 through Section 1.5 of this PI utilize the ACCESS 4
database. Reviews and actions are documented in the appropriate fields unless otherwise noted.
- 2. A system design entry consisting of a single sentence which does not identify the system component (design review item) being discussed is 2 .-' not acceptabfe.
1.2.1 PROVIDE system LB or DB requirements using the ACCESS
. Design Engineering database " System Description" fields as follows: ,
- VERIFY each entry (paragraph or sentence) contains sufficient detail to ensure the following:
- Design review item is readily identifiable.
- Any assumptions (such as valve or switch lineup, ,
operating bounds, etc.) are clearly noted.
- VERIFY LB or DB requirements that require operational controis are clearlyidentified. Examples:
I - IDENTIFY differences in component applications, such t as an alarm that provides component protection vs. one i that is relied on to meet LB or DB requirements.
- SPECIFY that a piece of equipment is expected to be '
operated in a certain way.
NOTE .
i The Responsible Design Engineering Lead is an individual assigned by the Unit Design Engineenng Manager to coordinate activities for the CMP on an assigned system.
l chairpemon [ 1.2.2 WHEN design information is ready for review, COORDINATE the responsible Design Engineering Lead (DEL) and System Engineer (SE) for a presentation to the PVRT.
- O Information p% Pg /% p% s of17
I NOTE Exarnples of other operations-focused experu to be involved in team .
reviews include Chemistry, Health Physics, Emergency Planning, etc., as deemed necessary by the Chairperson.
1.2.3 Prior to convening a team review session, IDENTIFY any other i operations-focused experts needed to aid in interpreting and ,
' investigating adequacy of existing operational controls, and '
REQUEST each group send a representative to the meeting.
1.2.4 WHEN team review session is convened, VERIFY at least the minimum team is present. :
1.2.5 Using an LCD video projector or computer terminals, DISPLAY each record for review and discussion by the PVRT.
1.2.6 Throughout the review process, using the " Discussion" field in lPvaT f ACCESS database, RECORD key discussions and decisions i l
relative to the item. ,
1.2.7 Refer To Attachment 1," Plant Verification and Readiness Team Review Process Flow Chart," and REVIEW record.
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NOTE
'Ihe term "DBVT" denote's a field in ACCESS database used by the Plant -
Verification and Readiness Team.
1.2.8 PERFORM applicable action:
l Chairperson l
. IE the record is determined to be a design statement of fact
., (no operational controls exist or are required), CHECK
" Closed" radio button under DBVT Status. No further reviewis required.
IE the record contains sufficient information such that a member of the PVRT can conduct research and determine the adequacy of operational practices, ASSIGN resolution to PVRT member and CHECK "Open" radio button under DBVT Status.
IE the record does not contain sufficient information such that a PVRT member can conduct research and determine the adequacy of operational practices, PERFORM the following:
- ROUTE record to Design Engineering for additional detail.
. CHECK "New" radio button under DBRT Status.
- IE the record does not reflect current operational practice or plant configuration, PERFORM the following:
. CHECK "New" radio button under DBRT Status.
. CHECK "Open" radio button under DBVT Status.
. DOCUMENT concern or question in " Discussion" field of ACCESS database, to be answered by Design Engineering.
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1.3 - Review of Existing Operational Controls Using ACCESS Database _
1.3.1 WHEN assigned a record for review, PERFORM the following:
, .svRT f
- a. DETERMM whether one or more specific procedures exist that addu : the13 or DB requirement.
b.- IEprocedre reference exists, IDENTIFY and RECORD the following ir. ACCESS database for each reference:
1
-'
- Procedure Number l
- Revision number reviewed ,
t
- Change number reviewed
- c. RECORD whether existing procedures adequately address ,
the LB or DB requirement in the " Disposition" field of ACCESS database. ;
I
- d. IE operational reference does not exist .QR existing procedures do not adequately address the LB or DB requirement, [
IDENTIFY the need for procedure development or the l recommended procedure or plant modification in the
" Discussion" field of ACCESS database. l i
i 1.3.2 WHEN assigned record review is complete, CHECK
" Completed"boxin ACCESS database. ,
i jg A A A WC PI S Level of Use
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1.4 Design Engineering Activities Using ACCESS Database ,
1 NOTE .
The term "DBRT" denotes a field in ACCESS database used by the Design Basis Review Team.
1.4.1 On a daily basis, RUN a " Query by Example" (QBE) of ACCESS l DEL f database for assigned systems to look for all"New" records in the "DBRT" field.
1.4.2 For each new record found, PERFORM the following:
- a. READ the specific question or comment identified by the PVRT in the " Discussion" field.
- b. ASSIGN a System Design Team member (SDTM) as the lead for answering the PVRT question or comment.
- c. ESTIMATE the number of man-hours to resolve the question ;
and CHECK the appropriate "LOE" box in ACCESS database. l SDTM 1.4.3 DEVELOP response to each assigned record.
(
1.4.4 WHEN response is complete, CHECK " Complete" box in ACCESS database.
1.4.5 IE record needs Operations verification, CHECK " Returned" radio button under DBVT Status and CHECK the "Open" radio button under DBRT Status.
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1.S System Record Disposition Using ACCESS Database ,
l 1.5.1 WHEN PVRT and Design Team work is complete for all records ;
l /VRT Lead . l" !
associated with a given system, PERFORM the following: .
- a. PERFORM a cursory review of system records for completeness and detail. j
- b. VERIFY system is ready for discussion by PVRT
- c. SCHEDULE a system acceptance presentation meeting with the l -
l PVRT, DEL, and SE.
l 1.5.2 REVIEW each record in ACCESS database for system under l PVRT l" ,
review.
1.5.3 DEVELOP the final team disposition for each record and l
DOCUMENT in the " Disposition" field.
l l NOTE ,
System disposition requires closure of all Log Number Items associated with a System / Program Number. l 3
1.5.4 WHEN system is dispositioned AND the disposition is acceptable r to the PVRT, NOTIFY the Unit Project Manager.
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1.6' Team Reviews Using Hardcopy _
~
NOTE .
, A system design entry consisting of a single sentence which does not identify the system component (design review item) being discussed is not acceptable.
" 1.6.1 PROVIDE system LB or DB requirements as follows:
Design Engineering
" . VERIFY each entry (paragraph or sentence) contains sufficient detail to ensure the following:
. Design review item is readily identifiable.
- Any assumptions (such as valve or switch lineup, operating bounds, etc.) are clearly noted.
. Reference can be made to the location of the LB or DB requirement in the document (such as page number, section number, step number, etc.)
- VERIFY LB or DB requirements that require operational controls are clearly identified. Examples:
IDENTIFY differences in component applications, such i
as an alarm that provides component protection vs. one that is relied on to meet LB or DB requirements.
i
- SPECIFY that a piece of equipment is expected to be operated in a certain way.
- ASSIGN a unique ID number to each record and MAINTAIN log. ;
_ l 1.6.2 WHEN design information is ready for review, COORDINATE I [ chairperson l" - the responsible Design Engineering Lead (DEL) and System Engineer (SE) for a presentation to the PVRT.
& A NUC PI 8 i A Level of Use gyr yg.g7 vgy,NE7" Rev.0 lnformation jpg j;9 [f$ f( 11 of 17
NOTE
~
~
Examples of other operations-focused experts to be involved in team reviews include Chemistry, Health Physics, Emergency Planning, etc., as
. deemed necessary by the Chairperson.
6 1.6.3 Prior to convening a team review session, IDENTIFY any other operations-focused experts needed to aid in interpreting and investigating adequacy of existing operational controls, and REQUEST each group send a representative to the meeting.
1.6.4 )VHEN team review session is convened, VERIFY at least the minimum team is present.
1.6.5 PROVIDE sufficient hardcopies of each record to PVRT
( DEL or SE l" members for review and discussion.
1.6.6 Throughout the review process, RECORD key discussions and l
[PVRT l" decisions relative to the item. l l
1.6.7 Refer To Attachment 1," Plant Verification and Readiness Team Review Process Flow Chart," and REVIEW record.
1.6.8 PERFORM applicable action:
l chairperson f
. E the record is determined to be a design statement of fact, STATE "No operational controls exist or are required." No further review is required.
E the record contains sufficient information such that a member of the PVRT can conduct research and determine the adequacy of operational practices, ASSIGN resolution to PVRT member and DOCUMENT name of PVRT member.
E the record does not contain sufficient information such that a PVRT member can conduct research and determine the adequacy of operational practices, PERFORM the following:
- ROUTE record to Design Engineering for additional detail.
. IDENTIFY problem or concern.
- E the record does not reflect current operational practice or plant configuration, DOCUMENT concern or question, to be answered by Design Engineering.
A A A dm- NUC PI 8 Level of Use 0' m'THINK'
'STOP L 4* _" REVIEW
% ACT Rev.0 gnformat. ion jpg p.4 j;q gaQ 12 of 17
1.7 Review of Existing Operational Controls Using Hardcopy 1.7.1 WHEN assigned a record for review, PERFORM the following:
.ivaT f
- b. IE procedure reference exists, IDENTIFY and RECORD the following for each reference: l
~
. Procedure Number
- Title 3
- Revision number reviewed a Change number reviewed
- c. RECORD whether existing procedures adequately address the LB or DB requirement. I IE operational reference does not exist E existing procedures do l 1.7.2 l not adequately address the LB or DB requirement, PERFORM the following:
- a. IDENTIFY the need for procedure development or RECOMMEND procedure or plant modification using the Project discrepancy database addressed in NUC PI 14,
" Project Process Administration."
NOTE Procedure change, new procedure, or plant design change must be either complete or dispositioned prior to a complete system resiew by the PVRT.
IE procedure change or new procedure is required, VERIFY
- b. l change or new procedure is completed.
- c. IE plant modification is required, VERIFY Engineering and !
- RAC review and disposition are completed.
i WHEN assigned record review is complete, INITIAL document 1.7.3 and ROUTE to the PVRT Lead. .
A ht A NUC PI 8 Level of Use ,cg@4
. Information pp;g f xpq dSP pygN d5 pq7 Y13EX of17 &T Rev.0
1.8 Design Engineering Activities Using Hardcopy I 1.8.1 On a daily basis, CONTACT PVRT Lead and OBTAIN any new
. DEL l" records for review.
1.8.2 For each new record, PERFORM the following:
- a. READ the specific question or comment identified by the i
PVRT. !
- b. ASSIGN a System Design Team member (SDTM) as the lead for answering the PVRT question or comment. l l
1.8.3 DEVELOP response to each assigned record and DOCUMENT. l
[soTM f 1.8.4 WHEN response is complete, INITIAL document and ROUTE l j
to the DEL !
1.8.5 REVIEW response and PERFORM applicable action:
[ DEL l '
. IE response is acceptable, SIGN record.
- IE response is not acceptable, INITIAL record and RETURN to originating SDTM.
l I
I
- NUC PI 8 K A Level of Use .yfgpr w7g7,y;rvnhF f Rev.0 l lnformation ,gsg png jpg( jpqz 14 og 17
1.9 - System Record Disposition Using Hardcopy 1.9.1 WHEN PVRT and Design Team work is complete for all records t
' PVRT Lead l> associated with a given system, PERFORM the following: ,
t
. a. PERFORM a cursory review of system records for l
completeness and detail.
- b. VERIFY system is ready for discussion by PVRT.
- c. SCHEDULE a system acceptance presentation meeting with the PVRT, DEL, and SE.
- d. VERIFY unique ID numbers for records match log index l maintained by Design Engineering. ,
1.9.2 REVIEW each record for system under review.
lPVRT l" i
1.9.3 DEVELOP the final team disposition for each record and DOCUMENT. l 1.9.4 RECORD minutes of meeting for system disposition.
I 1.9.5 WHEN system is dispositioned AND the disposition is acceptable j
to the PVRT, NOTIFY the Unit Project Manager.
Level of Use ' STOPLp 'THINK ye li wACT# ' REVIEW b CPI 8 Rev.0 gnformat. ion j;Wg );q jyg pgk 15 of17
l l
i
- 2. REFERENCES 2.1 Configuration Management Plan (CMP) 2.2 RP-4," Adverse Condition Resolution Program" (for Millstone) 1 2.3 ACP 1.2-16.5," Adverse Condition Report Process Implementation" (for Connecticut Yankee)
' 2.4 NUC PI 14," Project Process Administration"
- 3. COMMITMENTS None
- 4. S'UMMARY OF CHANGES 4.1 OriginalIssue i
I O
! A / '$. NUC PI 8 Level of Use .9h$F' 'inr '%dF'rniv5! Rev. 0 Information P4 fi Pa j? w 16 0r 17
I Attachment 1 Islant Verification and Readiness Team Review Process Flow Chart (Sheet l of1)
Engineering PVRT g, , Potential Needs UFSAR Ye NOTEitem tem correct Verincation ANNOTATE change "
status ENTER DB itern &
FORW5RD to PVRT for --
per current OPS y discrepancy, concern, or question or OPS "Open" initial review. 46 in" Discussion." impact? for PVRT.
pracucc7 A
No 9P Yes yes
-e w PROVIDE F input (proposed UFSAR rewrite, PVRT procedure concern change, etc.).
9P' I associated with RT issue? NOTEitem status y 9P " Closed" g
for PVRT.
NOTE item status y "Open" for PVRT.
NOTE dispositionin ASSIGN item to
" Disposition" section ResolutionTeam l and RECORD vote. (RT).
I A
No or Needs Verificatio, Surveillance J or testing
' adequate?
Yes No RESEARCH to determine appropriate surveillance or Resolution OBTAIN applicable procedures. complete testing to assure 'l NOTE action in
- Discussion" (unanimous component teadiness to F see: ion.IDENnFY procedure in fulfill safety function. PVRT vote)
" Procedure" section.
NOTE action in
- Discussion" section. j IDENUFY procedure in y,3
" Procedure" section. 9p-
- INTHATE revision or change to procedures as needed. Ready NOTE disposition in
- for l
- Disposition" section, and CLOSE item 7^ MOC review DETERMDE Snaldisposition.-J> -
v b RERJRNitem for PVRT review. . ,J 1
4 -
4 A e- d NUC PI 8 v
Level of Use A '- y'THINK'A NACTB#
- STOP REVIEW Rev. O nformat. ton jpg jp#e3 [k 17 Of 17 I
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.~ This ProjectManagement Configuration Instruction (PI) Plan (CMP).is part ofimplementation of the i
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- ( Mtg. No. ^{r val ve Millstone SORC Q-/ p g g.gf g,jg,pf CYPORC MPI PORC MP2 PORC MP3 PORC _
l l Responsible Individual: Level of Use B. Cox Subject Matter Expert: Information B. Cox ,
Documentation of Training Requirements Icomm 3.2) r (Sheet 1 of 1) iSeetion u amamm - liDoEuiiripint: Inf6ririit!' - o fi$$39$3@!Q- Q-@ip@M_ggggLyms wu Document Number: M o e 7"T m Revision No. O Change No. Document
Title:
bIkhdEIMhgyM $5tijd5%gy$[595$$$$$$Mg((fgg@$$ k Requirements of TQ-1, ""&ainmg and Quali5 cation"
/ Knowledge level of personnel performing procedure vTrevious training of personnel performing procedure
/
Quali5 cation of personnel performing procedure
" Procedure Level of Use Dif5culty of procedure or task VCensequence ofincorrect procedure performance VAdvice of Nuclear Training Department ,
Name of person contacted at Training Department: q QQ C, g(, Required for new documents and revmons only , y , KL . . . , . ,
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i Section 3 i m%._Tra,inm_g or Familiarization R.equirements' y.; ejn-
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" Raining to be done by Nuclear Training before effective date.
8 Training to be done by Department or Nuclear Training Department
. within 60 days of Effective Date and prior to perfoITnance of procedure.
Familiarization required Methods to Provide Familiarization: prior to Effective Date. . Department meeting O Familiarization required, no
- Pre-shift briefing impact on Effective Date. - Pre-work briefing No familiarization or . Document Acknowledgement Sheet training required.
Target Group Requiring Training or Familiarization: Enter information pertaining to who requires training or famniarization, which parts of the procedure are applicable, special instructions, etc. I Approved By: b&- > M Yd Depa-tment Head or Responsible Individual date
.nm.
, d en mm ja- _,w k .
DC 1 Attachment 5
,*STOP'
% INK' NACT" ~ REVIEW Rev. 4 S% ARA 8E% F% 64 of 69
MP1, MP2, MP3, CY NU Common Procedure . Configuration Management TABLE OF CObrTENTS
\
- 1. INSTRU CTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Quality Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 ;
1.2 Training Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.3 Instructions for Phase 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
~
1.4 Instructions for Program Continuation (Phase 2) . . . . . . . . . . . . . . 5 1.5 Re vie ws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.6 Discrep an cies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.7 Recomm endations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 1.8 Monitoring and Reporting Short-Term Performance . . . . . . . . . . 13
- 2. REFEREN CES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
- 3. COMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
- 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 ATTACHMENTS AND FORMS Attachment 1, " Con 5guration _ Management Mode 1" . . . . . . . . . . . . . . . . . 15 Attachment 2, " Configuration Management Review Report" . . . . . . . . . . 16 Attachm ent 3, "D efinitions" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 1 l i Level of Use d 6
*STOP"e-- +'THINK ',- "%ACT"n- TEVIEW A
e4 NUC PI10 Rev. 0 jpg l lnformatIon jpg ppq jpg 3 of 37
1 e 1. INSTRUCTIONS I This Project Instruction provides a consistent approach for review and evaluation of programs, processes, and procedures that ensure configuration control. : l This PIis used to: ;
- Develop a list of programs, processes, and procedures to be evaluated t
- Evaluate the adequacy of programs, processes, and procedures.
- Report evaluation results and recommendations for improvement.
* . Provide a means of tracking those recommendations.
l I f i s
. t l
f f th NUC PI10 Level of Use ,_lt,..s'._5L,.TIEAdT[7'hiEST Rev. 0
STOP' THINK" lnformation f?% pF4g p4}g jpek 2 of17 ,
1.1 Quality Requirements l CM Manager l 1.1.1 ENSURE the following:
. The Designated Reviewer (DR) is familiar with the specific program, process, or procedure being evaluated.
. Program, process, or procedure improvements recommended as a result of PI implementation are accomplished using an approved change control process.
1.2 '&aining Requirements l CM Manager l 1.2.1 ENSURE all personnel involved in implementing this PI are:
. Trained in Configuration Management Goals in NGP 3.2,
" Configuration Management."
. Trained in use of the five-box Configuration Management Model presented in Attachment 1.
. Familiar with NUREG 1397,"An Assessment of Design Control Practices and Design Reconstitution Programs in the j Nuclear Power Industry."
. Familiar with NUMARC 90-12, " Design Basis Program Guidelines" l 1
1 l i
. 1 l
i i A A
- NUCPIl0 Level of Use . mfg, gl'ggr f sqgg,TfhWT Rev. 0 Information jq pq jpg jpsg 3of37
1.3 Instructions for Phase 1 . configuration 1.3.1 SELECT those programs, processes, and procedures that support Management the safe operation of the plant for review during completion of Team (CMD Phase 1 of the CMP. 1.3.2 EVALUATE and LIST those NRC inspection items and results from NUC PI 2, " Unit-Specific Assessments," which involve CM issues. 1.3.3 IE an NRC inspection item or root cause analysis item is not readily identifiable to an existing program, process, or procedure, LIST the item under " Unidentified Programs, Processes, or Procedures." 1.3.4 EVALUATE list and DETERMINE the following:
- Which existing programs, processes, or pro edures require review for potential CM control weaknesses.
. What new programs, processes, or procedures are required to address items identified under " Unidentified Pr ograms, Processes, or Procedures."
( 1.3.5 Go To Section 1.5 for Phase 1 continuation. 1 l l 4
, $AP ' ' Od r " M P ' n/;ssr Rev. 0 NUC PI 30 Level of Use Information p4 p;g j3g ,pg 4 og 17 :
1.4 Instructions for Program Continuation (Phase 2) - lCMT f 1.4.1 OBTAIN a comprehensive list of all programs, processes, and procedures for each department from Nuclear Document Services. 1.4.2 SELECT those additional programs, processes, and procedures for review during completion of Phase 2 of the CMP. 1.4.3 DETERMINE whether all programs, processes, and procedures needed to meet the requirements of 10 CFR 50 Appendix B are listed as follows:
- a. IDENTIFY the processes needed to meet the requirements of10 CFR 50 Appendix B.
- b. IDENTIFY and LIST corresponding Nuclear Group procedures that produce outputs using Appendix C of 2.e NU Quality Assurance Program.
1.4.4 EVALUATE the list and DETERMINE the following:
. Which existing programs, processes, or procedures require
.- review for potential weaknesses.
t What new programs, pr ocesses, or procedures are required to address items identified under " Unidentified Programs, Processes, or Procedures." 1.4.5 Go To Section 1.5 for Phase 2 continuation. i 7 A A A NUC PI10 Level of Use yg- vg 3g 5-g;/ Rev.0 Information jpg pg jeg jys% 5 of17
1 l i i
' I 1.5 Reviews NOTE :
- 1. Attachment 2 presents the required format for the log used to track ,
the review process.
- 2. Both internal and external reviews are performed by individuals knowledgeable in the assigned programs, processes, and procedures.
lDR l 1.5.1 PERFORM Internal Review as follows: ;
- a. LOG the title and DESCRIBE the purpose of the program processes or procedure in one or two sentences.
- b. REVIEW the program, process, or procedure to determine whether any of the following intemal configuration control process discrepancies exist, and MARK each communication link:
- Communication links are missing.
- Internal product transitions (band-offs between individuals, groups, databases, etc.) are unclear or not
( defined.
. Service support (centralized data entry, drafting, reproduction, etc.) is unclear.
. Requirements to finalize products (independent reviews, approvals, etc.) or to transmit products (for use or to storage locations such as trend database or Nuclear ,
Records) are' unclear. l
. The reviewer believes a process activity may jeopardize l configuration control requirements.
- c. IDENTIFY all external inputs to and outputs from the program or procedure for evaluation in step 1.5.2.
4 e2 A A NUC PI 10 Level of Use A- mn. . A-
,rSTO ,P *THINK NACT' ' REVIEW Rev.O gnformat. ion y pq pag p;p;&. 6 of 17
i l i t i
- d. DOCUMENT the following information on Attachment 2 for any internal discrepancies (from step 1.5.1.b.) and external -
- inputs or outputs (from step 141.c.)
. Type (internal or external)
! . Input or output (I/O) e } . Configuration Management Communication Links
- description J
. Communication format (drawing change, data base, etc.)
- . Transmittal mechanisa (E-mail, AITTS, phone, etc.) !
. Input or output timing requirements (1 week,72 hours,
- etc.)
. Input or output source or destination (including j document identification number, step number, etc.)
l l Should it exist (is it needed?)
. Does it exist?
. Is the communication link effective as evaluated by the review criteria on the form?
i
- Recommended corrective action i
i i e. PRINT name and DATE Attachment 2. I i e-A k NUC PI10 Level of Use ,gfpreg[.~RT %g7d EVT Rev. 0 Information geqq jsqq jpqq peeg 7 of 17
l NOTE - External reviews are performed using a table-top process by a team of at least three individuals knowledgeable of the Configuration Management , Model presented in Attachment 1. One individual shall be a Designated i Reviewer in the program, process, or procedure being evaluated. Additionally, the team shall have the expertise required to evaluate the : communications links against each attribute of the Configuration Management Model. 1.5.2 PERFORM External Review as follows: lDR l: a. PROVIDE the program, process, or procedure overview, including information contained in Attachment 2 and the reviewed copy of the program, process, or procedure. I cM1 l
- b. Refer To Attachment 1, " Configuration Management Model,"
and IDENTIFY communications links that should exist.
- c. REVIEW the program, process, or procedure and PERFORM the following: ;
(
- 1) IDENTIFY existing communications links. (
l
- 2) COMPARE to communications links that should exist ;
(from step 1.5.2.b.). i
- 3) LIST any discrepancies (both needed communications !
links and existing communications links not identified as ! neededj on Attachment 2. l 1 1 I A A Aa 4 NUC PI10 Level of Use m- -.,_ A _
"LSTOP"e - s'TtilNK,'. w%ACT" 'REVIEv/ Rev. O lnformat. ion jpg jgsq jygk /F*% 8 of 17 l l
- d. IE communications 11nks exist AND are identified as needed (from step 1.5.2.b.), CONSIDER the following and -
EVALUATE 1 ink effectiveness;
. For Outputs:
Is the destination clearly identified by the program, process, or procedure?
- Does the destination accept and provide receipt information (feedback) to the program, process, or procedure?
Does the destination provide receipt instructions?
. Is the transfer mechanism acceptable?
. Are there tuning requirements? Should there be?
Are stated timing requirements appropriate?
. For Inputs:
. Does the program, process, or procedure provide
. information receipt instructions?
- Is the source clearly identified by the program, process, or procedure?
- Does the program, process, or procedure accept and provide receipt information to the source?
- Is the transfer mechanism acceptable?
. Are there timing requirements? Should there be?
Are stated timing requirements appropriate?
- e. IE communications links are not effective, IDENTIFY (for each discrepancy) actions required to support the short-tenn
_fix or actions that are long-term recommendations.
! A i NUC PI10 Level of Use ggp xgg mgy.NsW Rev.0 Information j
g JN4 j;q jpg 9of37
l
- f. IE a communications link should exist AND does not exist, PERFORM the following for each discrepancy: .
- 1) IDENTIFY required action and whether the action should ;
be a short-term fix or long-term recommendation. '
- 2) Refer To the applicable procedure and,if required, INITIATE an ACR for each identified discrepancy:
- RP-4, " Adverse Condition Resolution Program" 1
(for Millstone)
. ACP 1.2-16.5, " Adverse Condition Report Process Implementation" (for Connecticut Yankee)
- g. IE a communications link exists AND is not identified as needed (from step 1.5.2.b.), PERFORM the following for each discrepancy:
- 1) EVALUATE the value added and RECOMMEND whether the link should be continued or deleted.
- 2) IDENTIFY whether the action should be a short-term fix or long-term recommendation.
1.5.3 PRINT names of team members and ENTER date review was completed on Attachment 2. I CM Manager f 1.5.4 VERIFY all discrepancies are documented for resolution and are properly identified as either a short-term fix or a long-term recommendation. l I i < l .- I l 1 4 l l A k 8 NUC PIl0 Level of Use yg eggg7 yg71~$ fit Rev.0 Information jpg jpg jgg jg( 10 of17
1.6 Discrepancies NOTE - Peporting, tracking, and resolution of discrepancies are addressed in ND PI14," Project Process Administration." l cut l 1.6.1 TRANSFER Phase 1 (short-term fix) and Phase 2 (long-term recommendation) items to the ACCESS database. 1.6.2 For Phase 1 (short-term fixes), PERFORM the following:
- a. DEVELOP a Procedure Action Request (PAR) or Change Request (CR) to implement each short-term fix.
- b. DOCUMENT PAR or CR initiation in the ACCESS database.
1.6.3 For Phase 2 (long-term recommendations), PERFORM the following: ,- a. INITIATE a CM AITIS assignment for each long-term '- recommendation and DOCUMENT corresponding Action Request number in the ACCESS database " Disposition" field.
- b. DEVELOP CM recommendations to ensure CM requirements are adequately maintained, based on the following:
- Performance monitoring criteria developed and presented in CMP-95-085," Configuration Management Program Performance Indicator Report Transmittal"
- Additional information presented in NUREG 1397, "An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Power Industry" s li ^ i NUC PI10 Level of Use -477 mg7 ,qg-~enN Rev. O Information jpg pq jpg jpq3 13or17
1.7 Recommendations 1.7.1 COLLECT alllong term configuration recommendations and REVIEW for the continuation of Configuration Management activities. 1.7.2 DEVELOP long-term configuration management l recommendations, such as: l
- To ensure configuration management requirements are adequately maintained, the Configuration Management Team recommends adopting the perfortnance monitoring criteria 1 developed and presented in CMP-95-085, " Configuration Management Program Performance Indicator Report j Transmittal".
i
. In summary, these criteria utilize existing processes (ACR and ATITS) and the assignment of key words in the trending area of ATITS to monitor ACRs written against any l of the five boxes (Attachment 1) associated with configura+ ion management.
l l t i l i ( . ( NUC PI 10 l Level of Use y dy y 1T!SNK-SW ,y_ACT'k._.,_A_ W EEVIEW Rev.O l Informat. ion peg jpg pygj
. - - - - . _ = . - . - . _ _ .
- 1.S Monitoring and Reporting Short-Term Performance l CM Manager l 1.8.1 Refer To NUC PI 14," Project Process Administration," and +
PERFORM Quality Control inspections or audits as required. 1.8.2 Periodically REPORT on the following: l CMT Leader l l
. Short-term corrective actions identi5ed versus resoh ed
. Input / outputs identified versus time I
I ( I i 4 4 NUC PI10 8 Level of Use ggpr x-fgr q;3hy: rI61&T Rev.0 n Information
#4 ft#% [s% f?44 13 cf17
l l 1 l 1
- 2. REFERENCES I
2.1 10 CFR 50, Appendix B ,, 2.2 NUREG 1397,"An Assessment of Design Control Practices and Design i Reconstitution Programs in the Nuclear Power Industry" l 1 l l l 2.3 NGP 3.2," Configuration Management" 2.4 ACR 7007," Event Response Team Report" : i l l l 2.5 NUQAP Topical Report 2.6. Configuration Management Plan (CMP) . 2.7 RP-4," Adverse Condition Resolution Program" (for Millstone) 2.8 ACP 1.2-16.5," Adverse Condition Report Process Implementation" ; ) (for Connecticut Yankee) 2.9 NUC PI 2," Unit-Specific Assessments" l
- 2.10 NUC PI 14," Project Process Administration"
\
l , 2.11 CMP-95-085," Configuration Management Program Performance i ! Indicator Report Transmittal" 2.12 NUMARC 90-12," Design Basis Program Guidelines" l
- 3. COMMTTMENTS l
t None
- 4.
SUMMARY
OF ChNGES 4.1 OriginalIssue I 1 l l . A 8 NUCPIl0 Level of Use vfgg.r g7 sgy. dis Rev.0 Information l f% P% P% pd( 14 cf17
t Attachment 1 Configuration Management Model i (Sheet l of1) 96 As Designed As Licensed Configuration Configuration V # Designc: wings UFSAR Calculations Techr.icalSpeci5 cations Speci5 cations TechnicalRequirements Manual Co:nponent Lists g State andlocalPermits Commitments Design Basis Documents f i l I l Communications % Y
\
A
# l Physical Plant y A As Built Configuration As Operated Configuration (Hardwne) Configuration (Software)
Plant MOV Program Design Drawings Lifted Leads and Erosion / Corrosion Program Calculations , Jumper Bypasses Operations Procedures Sped 5 cations Setpoints Maintenance Procedures Component Lists ; Valve Lineups Surveillance hocedures t Fuse control , Example of Communications within a Function
. Regulatory . ~ '
UFSAR' , Commitments l As Licensed . Configuration
' - Tech Specs & l
. TRM< 4 Requirements l r! - ,a A A # NUC PI10 Level of Use . a .
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*STOP' ~THINK v'WACT* BEVIEW Rev. O !
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Attachment 3 Definitions i (Sheet 1 of1)
~
Communications link - 1) A complete configuration management interface between individuals, departments, or databases including outpul, input, transmittal instructions, receipt acknowledgement instructions, and timing requirements; or 2) an exchange of . information or data. l Configuration Management - An integrated management process to ensure a nuclear ! unit's physical and functional characteristics are maintained in conformance with the ! unit's Licensing Basis (LB) and Design Bases (DB); that operating, training, l modification, and maintenance processes are consistent with the LB and DB; and that the plant is operated and maintained within the LB and DB. External Review - A review of configuration management communications links that : cross single program or single procedure boundaries. ; Input - The portion of a configuration management communications link that I receives actions or information (engineering calculation, drawing, licensing : commitment, etc.) from another individual, department, or database. , l. Internal Review - A review of configuration management communications links that , do not cross single program or single procedure boundaries. f Phase 2 (Long-term Recommendation) - Activity or recommendation that enhances j configuration management effectiveness or correct deficiencies not needed to support the 10 CFR 50.54(f) response effort. Not required prior to unit restart. l t NGP - Nuclear Group Procedure l Output - The portion of a configuration management communications link that passes actions or information (engineering calculation, drawing, licensing commitment, etc.) to another individual, department, or database. j Procedure - A set of formalinstructions used to implement a process or activity. t i Process - A set of formal instructions. Program - Engineered program that addresses generic solutions for nuclear units and i evolving industry issues as specified in NGP 232, " Engineering Programs." Phase 2 (Short-term Fix) - Activity or recommendation required to support the 10 CFR 50.54(f) response effort. Must be completed prior to unit restart. 50.54(f) effort - Efforts required to respond to NRC letters addressed in the CMP. 4 Level of Use . y ,- r vx F 0 Information j;;g jwg jpg jps% 17 of17
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9W p.- 4..: ..s NUC PI11 % l Rev.O is part ofim This ProjectManagement Configuration Instruction (PI) Planfor(CMP)plementation the Design Bases Component of the of the Nuclear Excel' ence Plan for Northeast Utilities (NU). i $ l t it T ~ %: ;" A royal Effective
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i MP1PORC l l t MP2 PORC l l MP3 PORC 1 e Responsible Individual: i Level of Use W. Merritt l' Information Subject Matter Expert: W. Merritt
Applicable Units Project Instruction ( Independent Assessment
'"ABLE OF CONTEMS
- 1. INSTRUCTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Assignment of Independent Assessment Tasks . . . . . . . . . . . . . . . . . 3 1.2 Independent Assessment Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 13 Discrepan cies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.4 D eliverables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
- 2. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
- n. . - __ . . . , . . . . . - . - . - - . . . .
- - - -3. .. COMMITMENTS . . . . . . . . . . . . . . . . . . . . n .. . . . . . . . . . . . . . . . 7 --- -
i 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 l l 1 ATTACHMENTS AND FORMS l Attachment 1, " Independent Assessment Team Organization" . . . . . . . . . 8 Attachment 2, " Independent Assessment Form" . . . . . . . . . . . . . . . . . . . . . 9 Attachment 3, " Review Elements to be Considered" . . . . . . . . . . . . . . . . . 10 (( Attachment 4, " Definitions" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 f
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1, INSTRUCTIONS This Project Instruction provides a method to perform an independent technical , assessment (peer evaluation) of the activities performed as specified in the CMP. An Independent Assessment Team (IAT) shall assess the quality and completeness of NU activities to assure that discrepancies and vulnerabilities are identified for disposition. The IAT may review specific work products and resolution activities as assigned, and assess progress of activities against the schedule. NU requested the formation of the IAT to assure the highest quality of deliverables for the CMP in accordance with NU requirements. The IAT reports to the Director of Nuclear Design Engineering and Program Services. Organization of the IATis presented in Attachment 1. The IAT shall be comprised of staff with appropriate experience and training, as documented in Qualification Records.
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- 1.1 Assignment ofIndependent Assessment Thsks NOTE -
Activities that are identified in step 1.1.1 as Hold Points must be completed prior to proceeding to the next activity. l IAT Leader l: 1.1.1 OBTAIN a list of activities to be included in the Independent Assessment process from the Director of Nuclear Design Engineering and Program Services, and the Unit Project Managers. 1.1.2 Upon receipt of the NU work product and review schedule, SELECT and ASSIGN a Lead Engineer for each work product, based on the following criteria: i
, _ __ < _ . , . _ _ - - - - - . ~ . . ~.- - - - -
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---Engineer has experience and required qualifications in the -
design or licensing requirements for the assigned work product. A Qualification Record is. complete for the Engineer. 1.1.3 Refer To step 1.1.1 list and DEFINE the Hold Points in the schedule requiring assessment. ,
. [
(i s 1.1.4 DOCUMENT the following information for the assignment on
- l LeadEngineer the Attachment 2 Assessment Form:
- Description of the assigned task j Estimate of time required for the assessment [
NU interface person to be contacted
=
Schedule for completion ' Results of subtasks and assessments A 8 8 6 NUC PI11 Level of Use y g 7 v g g e g 7. g uT Rev.0 Information pwg pq pg( ps 3of33
,1.2' Independent Assessment Process 2
Lead 1.2.1 COORDINATE the independent assessment process as required. l Engineer - NOTE l l The Attachment 3 list is not all-inclusive. Technicaljudgement is needed ! to assure adequate depth of assessment. [ IAT Member l 1.2.2 Refer To Attachment 3 as required and PERFORM an assessment of the assigned work product as follows:
- a. REVIEW the assigned work activity. j
-....._I .. . . . . . S. -INTERVIE_W-NU-firs.t.._l_in_eteviewers.
i
- c. EVALUATE work product and process for technical :
adequacy and completeness. i Lead 1.2.3 DOCUhENT the following assessment information and results on i Engineer the Assessment Form and ROUTE the form to the IAT Leader: j .c . Documentation reviewed l Ei.
- Personnelinterviewed !
- Comparison results
- Progress against the schedule
= i Recommendation on whether to proceed beyond the Hold Point I
1.2.4 PREPARE a report (including a recommendation on whether to proceed beyond the Hold Point) and INFORM the NU interface of ; assessment results at an exit meeting. l Level of Use - L r "THINK'd, edL_.._AL- . @C PI11
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l, l 1 1 2.- REFERENCES (' ' 2.1 Configuration Management Plan (CMP) 2.2 RP-4," Adverse Condition Resolution Program"(for Millstone) 2.3 ACP 1.2-16.5," Adverse Condition Report Process Implementation" l (for Connecticut Yankee) I 2.4 NUC PI 14, " Project Process Administration"
- 3. COMMTTMENTS None 4,
SUMMARY
OF CHANGES _ , _ _- _ m. _ - . . __ . _ . 4.1 OriginalIssue t i ( r
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Attachment 1 - Independent Assessment Team Organization
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(Sheet 1 of1) NOTE . Yankee staff from specialty departments (Nuclear Engineering, Environmental Engmeering, Radiological Engineering, Engineering Services, Plant Support, etc.) are available for support on an as-needed basis. Team 12ader
- - . . - - - - -. A -- -- :-- .:....-_ _ ., - : ;. . _ _ _ , , z, QA Representative h
MP1 MP2 MP3 CY Review Review Review Review Team Members: Team Members: Team Members: Team Members:
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Attachment 2
. Independent Assessment Form
, (Sheet 1 of1) f Independent Assessment Fonn Unit: Assigned Lead Engineer:
Task: Estimated Effort (days): NU Intedace: Schedule: Work Order. Results
- Reviewed:
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Evaluated: I i Comments: } l 1 r- - --.._.:- _ ._ ____~.__~ . _ . Recommend proceeding beyond the Hold Point?' Yes O No O Schedule Status: . Exit Meeting
Contact:
Signoffs .- Lead Engineer Signature and Date Team Leader Review Signature and Date
- A~ITACH additional sheets as necessafy. . Page of
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Attachment 3 ) Review Elements to be Considered )
. (Sheet 1 of1)
This list is not all-inclusive. Technicaljudgement is needed to assure adequate ~ depth of review during either independent assessment. l Definition of the review process (program, procedure, instructions)
. Review of past NRC or NU commitments, including disposition
. Resolution of previous outstanding issues
. Independence of first-line resiewer
. Depth and results of first-line resiew
_l . Reports _gy,inpu.tsgns.idgred oyverifipd __
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. Basis for the design t
- Impact of Technical Specification limits
. Revision level or issue date for each Code used and for each calculation or specification used
. . Procedural or design changes identified and implemented ,
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. Schedule adherence .
. . .. 1 . _ . _
1 1 (.: Level of Use ji $ NUC PI11 Information
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Attachment 4 Definitions
. (Sheet 1 of1)
Independent Assessment - An evaluation of specific activities relating to review of , activities to assess work practices, depth of review, and management controls; and to - identify any areas needing corrective actions. This is an in-process function that may be initiated at any point in the overall CMP completion process and may include Hold Points. Independent Assessment Team (IAT) - That group of individuals that provides the independent technical assessment or peer evaluation of activities performed as specified in the CMP. i Work Product - Any process related to activities performed as specified in the CMP that requires independent assessment as specified in this PI. l
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NUC PI14 Rev.0 This Project Instruction (PI) is part of implementation of the ( Configuration Management Plan (CMP). 1 1 1 1 1 1 '~ A royal Effective Mtg. No. ate Date l
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Millstone SORC g/o _c,7 j g g.jg, pgo g fg pj; l 1 CY PORC . MP1 PORC MP2 PORC MP3 PORC Responsible Individual: Bob Cox Level of Use Subject Matter Expert: Pete Austin Information
Documentation of Training Requirements [comm 3.2) (Sheet 1 of 1) TSection 1 <
- Document Information4 , sa . . r ~a.,- ,< O.. ,y ,
Document Number: NUC Pl 14 Revision No. O Change No. Document
Title:
Configuration Management Plan Project Process Administration Instruction iSection 2: 2 TrainirigLCon'siderations? . - , .. . _
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..4.< n t /< u..w ? ..u... ' 4.s aw >.-s. .w s.w;.. v. ::. Au ate. ^ .g.gg Requirements of TQ-1, " Training and Quali5 cation" Knowledge level of personnel perfonning procedure Previous training of personnel performing procedure Qualification of personnel performing procedure Procedure Level of Use Difficulty of procedure or task Consequence of incorrect procedure performance Advice of Nuclear Training Department Name of person contacted at Training Department: h [g,y,3 g Required for new documents and revutons crJy Section 35 Training or Familia,rization Re..qu_irements . ,
. . . _ . , .. ~ . _ m. .m _ , m.s I
. Training to be done by Nuclear Training before effective date.
3
- Training to be done by Department or Nuclear Training Department within 60 days of Effective Date and prior to performance of procedure.
1 Familiarization required Methods to Provide Familiarization: l prior to Effective Date. . Department meeting l Familiarization required, no
- Pre-shift briefing impact on Effective Date.
- Pre-work briefing O No familiarization or . Document Acknowledgement Sheet training required.
Target Group Requiring Training or Familiarization: Enter information pertaining to who requires training or familiarization, which pans of the procedure are applicable, special instructions, etc. MS Aa- m b lm_ o Nwm ( p CA2 GD.W_____________'_____-----. _ _k_ _ _W_ Approved By: I~ ' 6 3 Depart 6ent Head or Responsible Individual Date
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l 1 r MP1, MP2, MP3, CY Project Instruction . Configuration Management Plan Project Process Administration Instruction i l TABLE OF CONTENTS ! l 1
- 1. INSTRUCTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 !
1.1 Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 I 1.2 Personnel Qualification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.3 Discrepancies, Reporting and Tracking . . . . . . . . . . . . . . . . . . . . . . . 5 1.4 Project Progress Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ' 1.5 Project Self- Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.6 CMP Performance Measurements . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1.7 Approval and Responsibility of CMP Documents . . . . . . . . . . . . . . 9 1.8 Control of CMP Documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
- 2. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 3. COMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
( , 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 i l l 1 i 1 A Level of Use _ew va~rA xya A A e-NUC PI 14 Rev. O
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i j
- 1. INSTRUCTIONS
~
This Project Instruction provides a consistent review and approach for administrative control of the Configuration Man'agement Plan (CMP). This Project Instruction defines the requirements and provides the instructions for the administrative control of the CMP. The scope of this Project Instruction includes the following:
- Communications
= Personnel Qualifications
= ' Discrepancies, Reporting and Tracking
= Project Progress Reports
= Project Self-Assessment
- Project Performance Measurements
-- = Approval and Responsibility of CMP Documents
' = Control of Project Documents and Data Bases l
l l Level Of Use y d . ,_I y STOP-L THINK' y d_._ wACT' ,_ REVIEW d._ NUC PI 14 Rev. 0 gOrmal.lOn p gg ykg j:p; 2 of10
1.1 Communications
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i 1.1.1 Project Communications , l I l: a. Refer To Nuclear Group Policy NGP 5.2," Communications," i lUPM and DC 2, " Developing and Revising Millstone Procedures," l and APPLY communications guidance. , i I l b. Refer To Section 1.4 and COMMUNICATE project status. l WP&OM l: c. DEVELOP Level 1 Schedule using the following criteria: j ! . INCLUDE major milestones , l - SPECIFY milestones as status points for each of the units l involved to complete the CMP effort 1.1.2 Internal Communications This effort is intended to provide ongoing information so unit , personnel can see progress being made. Units should use the l available communications tools (e.g., daily unit status, Power of i
.~- Five, etc.).
l
. upu j' a. PROVIDE status updates as project milestones are complete. l l 1.1.3 Documentation !
Each Unit Project Manager is responsible for retention of documentation for those activities specific to that unit. In order I l to provide retrievability, CMP documentation should be clearly identified as part of the CMP effort and should include subject information. l Project a. IDENTIFY documentation as part of CMP effort. Parsonnel
- b. ENSURE subject information is included in documentation. ,
l lUPM l
- c. RETAIN documentation in project file and SUBMIT to l Nuclear Document Services at conclusion of project.
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,- 1.1.4 Project Information Book A Project Information Book (PIB) should be developed at project commencement, and should be similar to a standard outage handbook.
I lUPM [ a. At project commencement, DIRECT Project Personnel to develop Project Information Book. Project b. DEVELOP PIB and INCLUDE the following minimum Personnel mformation: 1
- Organizational charts Scope of unit CMP efforts Listing and locations of unit project groups including phone numbers Direction for external and internal concerned parties point of contact for project information input
- Level 1 Schedule with major milestones highlighted f
- Personnel qualification documents 1.1.5 Information Release Unit Project Managers, or their designees, are responsible for the release of information from The Project Group to other groups under the Northeast Utilities operational control.
Northeast Utilities Nuclear Information Services Group is responsible for the release of any information from Northeast Utilities Group to external groups which may include, but is not limited to, members of the general public, the media, and shareholders and investors. L UPM or a. .R. ELEASE information to groups under Northeast Utilities l Respcnsible operational control. l Individual Nuclear b. RELEASE information from any Northeast Utilities Group Information to any external group which may include, but is not limited to, j','vj'es members of the general public, the media, and shareholders and investors. k A h h NUC PI14 Level of Use g7 yg_ ,Qr-ggr Rev. 0 Information gg pq j;% p%&, 4 of10 l
[ 1.2 Personnel Qualification The Unit Project Manager is responsible for the overall review and approval of project personnel based on a technical background as required to implement individual Project Instructions. lUPM f 1.2.1 Refer To NGP 2.26, " Departmental Training" and ENSURE project personnel, including contractor personnel, are trained and qualified to specified requirements, which include maintaining records. 1.3 Discrepancies, Reporting and 'Iracking lUPM f , 1.3.1 DETERMINE and ASSIGN priority to discrepancies as follows: Priority 1 - Those discrepancies required to be resolved before completion of the CMP Phase 1 effort. Those corrective actions considered necessary to suppo'rt the safe operation of the plant, to demonstrate sufficient progress in weak performance areas, or to correct significant discrepancies.
- Priority 2 - Those discrepancies which will be resolved in I.
. Phase 2 of the CMP effort. Corrective actions identify additional improvements to areas which are functionally satisfactory now or which when completed achieve the desired cultural environment, or corrective actions involving longer-term enhancements to progiams/ processes which are considered currently satisfactory.
NOTE All discrepancies must be evaluated in accordance with RP 4 or ACP 1.2-16.5. RIsponsible 1.3.2 SCREEN and TRACK discrepancies for safety significance, and Individual resolution using the following process:
- a. IDENTIFI discrepancies as specified in CMP Project Instructions.
- b. ENTER record for discrepancy into a database and ASSIGN a unique " Log" number.
A & 5 NUC PI14 Level of Use fpr f{ig' V2ETFi$sRT Rev.0 lnformation jp4 pig jpw4 jperg 5 of10
t J NOTE Database controls prevent deletion of records. ,
- c. Once entered, ENSURE discrepancy record and unique log number is not deleted.
- d. ENTER the following discrepancy status information into i database as a rninimum: I
- Current Status - open/ closed / fixed disposition
. Potential Operability Issue - Yes/No
- Follow-up Action Required (e.g. procedure change, calculation revision, or plant modification required)
- Priority 1 or 2
- c. ENTER information and logie discussion used to resolve discrepancy into database. i l
( 1.4 Project Progress Reports l Project Lead l 1.4.1 Weekly, PERFORM the following for inclusion in Weekly Project Progress Report:
- a. MAINTAIN listing of deficiencies (ACRs, NCRs, LERs) generated and identified as a result of the CMP.
- b. MAINTAIN listing of activities worked during the week period including, but not limited to, the following:
. Calculations completed
. Procedures revised or written
. DCNs written
~
i A
- NUC PI14 f
Level of Use ,rgy fygg xgr dT Rev.0 Information jpg jyq. jpg pa$ 6 cf10 1 1
- c. MAINTAIN listing of deliverables completed including the i
following: Description of deliverabl6
- Deliverable completion date
. Responsible manager
- d. REVIEW Action Item Tracking & Trending System (AITTS) foritems which may have been completed as part of the CMP item. AITTS shall be updated to reflect the item completed.
- e. PROVIDE input to UPMs for schedule variances occurring, and variances which may be coming in the future.
- f. PROVIDE input to UPMs for planned activities for the next reporting period.
- g. On a weekly basis, PERFORM the following to the project schedule:
. UPDATE pertinent items
. ADD peninent items l
. DELETE pertinent items.
1.4.2 On a weekly basis, SUBMIT required information to UPM in support of Friday issuance of Project Progress Report. lUPM l 1.43 On each Friday, ISSUE Project Progress Report. 1.5 Project Self-Assessment Foundation of the self-assessment process is a candid and objective assessment of the project performance with the belief that performance can be improved lUPM l 1.5.1 DEVELOP a unit self assessment plan and schedule to determine adequacy of projects activities as follows:
- a. SELECT unit assessment personnel.
- b. ENSURE assessment personnel obtain, review, and complete qualifications in the Millstone Self-Assessment Manual.
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. c. REVIEW and APPROVE project activities self-assessment I
plan. UPM or d. IMPLEMENT project activiti.es self-assessment plan. Responsible individual 1.6 CMP Performance Measurements PI for the project a'ctivities must develop performance standards. Performance standards must be translated into tangible, measurable and observable requirements that apply directly to the long-term quality of products related to the LB and DB activities and to identifying both positive and negative trends. Such measurements can be personnel surveys, ACR trends, operability determination tools, etc. Project Managers will be responsible for periodic reports. ( l l i l A d i NUC PI14 Level of Use gy wjg wgg7.T$iFT Rev.0 InfOrmation jag j;pl4 g;pg jp% 8 of10
1 1.7 Approval and Responsibility of CMP Documents i i Doc. Type Approval Responsibility CMP VPORS/WPTS/ MP1UPM l l VPOS/PORC/SORC Attachment 1 MP1PORC MP1UPM ! Attachment 2 MP2 PORC MP2 UPM Attachment 3 MP3 PORC MP3 UPM Attachment 4 CYPORC CY UPM PIl SORC/PORC(CY) MP1UPM PI 2 SORC/PORC(CY) MP2 UPM 7 PI3 . SORC/PORC(CY) MP2 UPM PI 4 PORC (MP3) MP3 UPM l PI 5 PORC(MP3) MP3 UPM PI 6 SORC/PORC(CY) MP1UPM ! l PI 7 SORC/PORC (CY) MP2 UPM i PI 8 SORC/PORC(CY) MP1UPM l PI 9 SORC/PORC(CY) MP1UPM l I.. PI10 SORC/PORC(CY) CM MGR f PI11 SORC/PORC(CY) MP1UPM ! l PI 12 SORC/PORC(CY) MP1UPM ; PI13 SORC/PORC(CY) MP1UPM PI 14 SORC/PORC(CY) CM MGR PI15 PORC (MP3) MP3 UPM ; PI16 SORC/PORC MP1UPM l l 1.8 Control of CMP Documents , t Responsible units above have the responsibility of ensuring that the CMP documents are distributed and maintained current. An index of project ; documents shall be made available to the end user so it can be verified _ that the latest revisions are in use. i l r l I A A NUC PI 14 ! Level of Use / $ 477 ,agy, MF~ TENT Rev. 0 l Information jpgl( pug jpq( f? 9 of 10
]
- 2. REFERENCES 4
2.1 Communications - 2.1.1 Northeast Utilities Nuclear Group Policy 5.2, " Communications," Rev.1, dated 4/14/94. 2.1.2 Millstone Nuclear Power Station, Station procedure DC 2,
" Developing and Revising Millstone Procedures and Forrns."
2.1.3 Station Procedure (CY) ACP 1.2-6.5. 2.1.4 RP 4," Adverse Condition Resolution Program." 2.1.5 ACP 1.2-16.5, " Adverse Condition Report Process Implementation"(for CY). 2.1.6 Configuration Management Plan (CMP). 2.2 Self-Assessment 2.2.1 NU Millstone Self- Assessment Manual, Revision 1, dated January 1,1995. (
- 3. COMMITMENTS 3.1 None .
l i
- 4.
SUMMARY
OF CHANGES 4.1 Originalissue. i l l I I 1 l l
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39kl33 Date: ls-2h h 1
. Effective Datb: b-2cr9(.o Level of Use Subject Matter Expert:
General MPR
; t Revision 1 t PROJECTINSTRUCTION NUCPI15 l l SELECTED MILLSTONE UNIT 3 SYSTEM REVIEWS ..~ j 1.0 Introduction .
bI ;
- 1.1 Purpose Provide a consistent review and evaluation approach for selected Millstone Unit 3 (MP3) systems in order to develop a basis for assessing the effectiveness of design ;
controls and configuration controls. This activity is a vertical slice review. - 1.2 Objectives J 1.2.1 Provide guidance to the review team participants when evaluating systems for effective implementation of design and configuration controls. 1.2.2 Provide guidance for documenting the system evaluations and the results of , these evaluations. ! 1.3 Scope 1.3.1 This PI will be used to evaluate the following systems:
- Service Water
- Quench Spray and Containment Recirculation
-Reactor Trip Breakers
- Auxiliary Feedwater Including ESFAS and AMSAC Initiation
- Emergency AC Power System
- Class 1E 125V DC Power
- Station Blackout Diesel Generawr d1
- 120V Vital AC l
- Control Building Filtration and Ventilation
-ResidualHeat Removal (S1 mode)
- Pressurizer Safety and Relief Valves i Reference 6.1 provides the rationale for selecting the systems listed above.
1.3.2 This PI provides guidance for evaluating system configuration controls as they apply to plant documents. This PI also describes associated walkdown activities. l g[ 1
1.4 Applicability ,
*Ris PI will be used to review the effectiveness with which design controls and ,
configuration management controls have been applied to selected MP3 Systems. 2.0 Prerequisites and Administrative Requirements . 2.1 Quality Requirements This review will be performed in accordance with the NU Appendix B Quality Assurance Program. , Project Instruction users will be trained in accordance with NGP 2.26 in the goals and objectives of this review. System reviewers must have broad experience and a sound t'echnical background in systems similar to those which they review. O Any discrepancies or adverse conditions identified by these system reviews will be brought to NU's attention for resolution in accordance with NUC Pl.5 Millstone Unit 3 g System Readiness Review. 2.2 Definitions 2.2.1 Configuration Management ,
- An in'egrated management process to ensure that a nuclear unit's physical and functional characteristics are maintained in conformance with the unit's design and licensing bases.
- That operating, training, modification and maintenance processes are l consistent with the design and licensing basis.
- That the plant is operated and maintadned within these bases. g 2.2.2 Licensing Basis (')
1
- The set of applicable NRC requirements
- Written commitments that are docketed and in effect
- The design bases .
(1) Defiel6en from CMP l gg 2
l 2.2.3 Discrepancy - i
)
A finding generated as the result of an activity performed in accordance with .- ; j this PI which indicates a potential need for process improvement or remedial action and for which an Unresolved Item Report (UIR) has been prepared but which has ; not yet been reviewed by the Plant Verification and Readiness Team (PVRI) in gg accordance with PI 5 to determine the significance of the UIR and its priority for i resolution. 2.2.4 Design Bases (DB)")
-Information which identifies the specific functions to be performed by a ,
structure, system or component
- The specific values or range ofvalues chosen for controlling parameters as reference bounds for design l 2.2.5 Design Control f i
A process defined in 10CFR50, Appendix B, which satisfies the following l requirements: l
- The design shall be defined, controlled and verified.
- Applicable design inputs shall be appropriately specified on a timely basis and correctly translated into design documents.
- Design interfaces shall be identified and controlled.
- Design adequacy shall be verified by persons other than those who designed the item.
2.2.6 Engineering Design BasesU) [ RI
- Information which describes a system, structure, or component i
- Operating values or parameters which are not reference bounds for design
-Information which identifies functions important for economic, maintenance, installation, or other nonsafety function of design basis i systems, structures, or components 3
l 1
-Information and operating values describing the functions of nonsafety systems -
~
- Calculations, descriptions, and other " outputs" -
i 2.2.7 Configuration Management Plan (CMP) , ne overall plan developed by NU to define the overall process and each Key Project Activity necessary to meet the following Mission Statement: The project must be able to provide reasonable assurance that the future operation of each unit will be conducted in accordance with the terms and conditions of the unit's operating license, NRC regulations, and the unit's UFSAR. ; 2.2.8 Procedure ! A set of formal instructions used to implement a process or activity. 2.2.9 Program Programs that address generic solutions for nuclear units and evolving industry issues in accordance with NGP 2.32, Engineering Programs. 2.2.10 Vertical Slice Review Team (VSRT) The team assigned to perform the vertical slice review described in this Pl. 2.3 Team Responsibilities 2.3.1 The VSRT Project Manager reports to the NU Director of Nuclear Design Engineering and Program Services and has overall responsibility for the quality, schedule, and administrative aspects of this review. The team leaders report to the Project Manager and have responsibility for the systems reviews assigned to their teams by the Project Manager. i 3.0 Instructions 3.1 System Reviews 3.1.1 For each system listed in Section 1.3.1, the assigned systems review team shall complete a matrix of system attributes to be reviewed against plant documents and programs for the , following three (3) areas: Design Bases Consistency, Licensing Basis Consistency, and Plant Documentation. Attachment 5.1 is an example of the form used for these matrices and illustrates the plant documents and program areas included in each vertical slice system review. When completed, these matrices provide the summary basis for a vertical 4
i o slice system review. l gi The review team will select key system attributes appropriate to the specific system being reviewed on the basis ofimportance to the safety-related system design bases. Attributes will be selected from the following parts of the Design Control Manual NUC DCM:
-DesignInputs, Attachment 4-1 l - Interdiscipline Review Engineering Evaluations, FORMS 4-1C through 41F
! - Interdiscipline Review Evaluations for Engineering Programs, FORMS 4 1G through 4-1M
- The Managenant Quality Committee (MQC) must approve the attributes selected by the VSRT prior to commencing the system reviews. dl l
The following activities are associated with completing these matrices. 3.1.2 Document retrieval: For each system attribute to be evaluated, request the retrieval of the necessary documents by completing the "1996 MPR Assessment-MP3" form, Attachment 5.2. Attachment 5.3 is an example of a completed document request form. l These forms are input to an NU computerized database for future retrieval, if necessary. g; ; A completed, computer generated form will be retumed to the requester when the , documentation is retrieved. 3.1.3 System attribute evaluation: For each system attribute the systems resiew team member assigned will document positive and negative comments and/or observations of the evaluation on an Attachment 5.2 form. An example of a completed system attribute evaluation is shown in Attachment 5.4. Potential discrepancies which require safety significance screening shall be indicated on this form as shown and processed in accordance with Section 3.3 of this Project Instruction. 3.1.4 The NU team coordinator shall prepare and update a database of all MPR Assessment
- Request Forms prepared in accordance with subsections 3.1.2 and 3.1.3 above.
3.1.5 Each system review team shall update the appropriate system review matrix as the evaluation process continues. 3.2 Information Sources Information sources and data bases should be queried to obtain information on past and present status of the system attributes being reviewed. This information will be part of (l l what is used to make a judgment on design basis validity, configuration management and l 5
o l l l ultimately for readiness-for-stanup. Information can be obtained on Adverse Condition . Repons (ACRs), Non-Conformance Reports (NCRs), outstanding maintenance and engineering work items on two Network. based data bases. Examples ofinformation
~~
sources are below, but additional sources may be used. 3.2.1 Action Item Tracking and Trending System (AITTS) - An overview and description of this data base can be accessed via the Network Navigator. i I CAUTION: nis database is mostly complete and in-use, but in some cases (sub-categories) may be in the process of startup. The AITTS contains historical and up-to-date information on : ACRs, Bypass & Jumper Logs, LERS, DCNs, Engineering Work Requests (EWRs), Set Point Change Requests, and QA records, and may be sorted by system, date, etc. l [} 3.2.2 Plant Maintenance Management System (PMMS) This data base is a separate data base contaming maintenance issues and is accessed via the Network. 3.2.3 Non-Conformance Repons (NCRs) This historical and real-time database is accessed via the Network, but is on the mainframe database system; it contains historical NCRs, dispositions and current outstanding requests. 3.2.4 Plant Design Change Records (PDCRs) This is a hard-copy system maintained by MP-3 staff. 3.2.5 Plant Operational Records his data is contained in both the AITTS and on hard copy records contained in the U3 control room. 3.2.6 Generation Records Information Tracking System (GRITS) His system includes information on drawings, DCNs, etc. 3.3 Screening of Discrepancies 3.3.1 All discrepancies identified during the review process shall be tagged during the data j collection and evaluation process by indicating in the checkoff box on the data l collection form that there is a " DISCREPANCY IDEN Iw1ED" . This will trigger the (I j 6
i i I process to ensure this item gets funher review by the Team I.mader for that system. . 33.2 For each assessment item that indicates " DISCREPANCY IDENTIFIED", the' cognizant i Team Leader shall complete a Discrepancy Screening Form (see Attachment 5.5). The purpose of the screening is to identify those items that have potential safety g, significance for expedited tumover as described in 333 below. . . : NOTE: The term " potential safety significance" is intended only to expedite review by l NU, and is not intended to imply a level of safety significance. 333 Upon completion, the Discrepancy Screening Form shall be forwwded to the ANSI Lead Auditor for a review of document consistency and completeness and, agreement with the Team Leader's determination. *Re Lead Auditor shall initial on the form to indicate concurrence and the form shall be provided to the NU Unit Project Manager for preparation of an Unresolved Item Report in accordance with PI 5. gI l t 3.4 Scope Expansion l If NU determines that the venical slice review has identified safety / operability significant . discrepancies, or if other problems symptomatic of new process weaknesses not $l l previously identified are found, the reviews will be expanded to include additional j vertical and/or horizontal reviews, as appropriate, to further test the process weakness ; identified by the discrepancy. For example, these areas could include FSAR updating, , drawing control,50.59 process, etc. The specific criteria for the expansion are dependent : on the nature of the finding and will be determined by the review team leaders and approved by the Project Manager and the MQC. If no additional significant discrepancies are found in the expanded reviews, the initial discrepancy will be considered an isolated l error. , 3.5 Characteristics of Review Results. In order to facilitate evaluation of review results, general guidance for sorting these g[ results is provided in Attachment 5.6. 3.6 Walkdowns 3.6.1 General For the systems lined in subsection 13.1, the System Reviewer shall perform a system general area walkdown and/or one or more directed system walkdowns A system general area walkdown is performed by VSRT members assisted as n'ecessary b by a team of qualified designers. These walkdowns do not require advance preparationof j l attribute check lists but are based on the VSRT reviewers' general system knowledge (see l 7 4
- - - - ,- ,w ------
s :. i j 4 section 2.1) and on MP3 specific knowledge derived from the VSRT resiew of design, . licensing, and operations and maintenance documents. Directed system walkdowns are performed by a team of qualified designers in , accordance with written direction from VSRT members to verify specific phys.ical plant characteristics, data and attributes. The objective of this walkdown is to verify the design , hacia and licentino basin linknee to the as-built ennfieuration= The System Reviewer will
- select key system attributes appropriate to the specific system and appropriate for field verification on the basis ofimportance to the safety-related system design bases. For
- example, component nameplate data and serial number would be appropriate for field
, verification, but system flow rate could not be verified by field walkdown. Attributes will be selected from the following parts of the Design Control Manual NUC DCM: k)esignInputs, Attachment 4-1
- Interdiscipline Review Engineering Evaluations, FORMS 4-1C through 4-1F
- Interdiscipline Review Evaluations for Engineering Programs, FORMS 4-1G through 4-1M The required characteristics and data will be summarized on a "1996 MPR Assessment -
MP3" form (Attachment 5.2). The form will be provided to the team of qualified gl designers for performance of the directed walkdown(s). If safety / operability significant discrepancies are found by the walkdowns, the number of key attributes for field verification will be expanded for the systems listed in subsection 1.3.1. If additional scope expansion is considered necessary by the resiew team leaders, the guidelines of Section 3.4 will apply. 3.6.2 A review will be performed to confirm the as-dentened-to-as-built linknoe. Under the ; supervision of the Project Manager of the VSRT, a team of qualified designers will walkdown PDCRs selected as part of the system readiness review performed in 1 accordance with PI-5 down to the component level (such as solenoids, limit switches, g( l instrument hook-ups, wiring configuration, etc.) to confirm the as-designed-to-as-built linkage. *Ihe MQC must approve the list of selected PDCRs prior to the walkdowns. (It , I is noted that the SRT will be confirming the as-denianed ennficuration and the FS AR linkagsin accordance with PI 4.) 3.6.3 The "1996 MPR Assessment - MP3" (Attachment 5.2) form shall be used to record the results of the walkdowns. Walkdown results will also be summarized in the VSRT Report (see 3.8) and presented to the MQC for approval to ensure that the completed C( i walkdown scopes are sufficient to satisfy the objectives of the vertical slice review. l 8
l
~~
3.7 Communications l 3.7.1 Intemal communications are dermed as team to team communications and . - communications between the teams and the assigned NU coordinator. Intemal communications will be facilitated by brief meetings at the end of each work day to l highlight in-process review results and overall review progress. l 3.7.2 Extemal communications are defined as communications between team members and NU pro fide daily briefings to NU management and oversight representatives on review team progress. 3.8 Deliverables . 3.8.1 The deliverable for this system review will be a technical reports. Attachment 5.7 1 provides a typical outline for this report. This report will be transmitted to the Project Manager for incorporation into the final Project report. ; 4.0 Reviews , 4.4 Internal Reviews Intemal reviews will be conducted by a qualified ANSI Lead Auditor. These reviews will provide additional assurance that team activities are conducted in accordance with this Pl. 4.5 External Reviews i Extemal reviews will be conducted by NU oversight organization representatives as assigned by NU management. 5.0 Attachments 5.1 Example System Review Matrix 5.2 Example 1996 MPR Assessment - MP3 (Vertical Slice) Form 5.3 Example of Completed 1996 MPR Assessment - MP3 (Vertical Slice) Form (Document Request) 5.4 Example of Completed 1996 MPR Assessment - MP3 (Vertical Slice) Form l (Review Results) j i 9
s 5.5 Example Discrepancy Screening Form 5.6 Categorization of Review Results .- 5.7 Typical System Specific Report Outline ,. l 41 6.0 References 6.1 Memo NE-96-SAB-115 from S.D. Weerakkody to J.M. Vargas dated May 1, 1996. *
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Attachment 5.1 Example System Review Matrix .
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O Attachment 5.2 - Example 1996 MPR Assessment MP3 . (Vertical Slice) Form . r 4 i l l l 1 i f B
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- 1996 MPR ASSESSMENT-MP3 (Vertical Slice) i .
J ITEM UNIT: ] 3 ] 2 3 ] Site NUMBER i mE - R:
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I (Please Print) NUMBER I", I TOPICS: ' *
- TTPES
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j % Service Water ResidualHeat Rernoval ( Infor nstion QSS/RSS PZR
- SafetyRelicfValve i
Meeting ReactorTrip Breakers Other: j DD@d Auxiliary Feedwater including ESFAS & AMSAC for /JW On. Site AC Power 3 l C WM0" DC Power .- DW App.B Control Blds FiltrationNentilation l ATTRIBUTE NO. I I j issor: I t I ! NARRATION: i 1 DISCREPANCY 3DENnF1ED: O DOCUMENTATION ATTAQfED: YEs NOl l mECErvED svi .4TE nwE, y ABEIGNED TO: l
Attachment 5.3 - Example of Completed 1996 MPR - Assessment - MP3 (Vertical Slice) Form (Document Request) 1 l i
1 i 1996MPR ASSESSMENT-MP3 (VerticalSlice) UNIT: ]I ]2 3 ] Site NUMBER EXAMfLEl .
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, TOPICE: ~
@ Service Water ResidualHeat Removal Information QSS/RSS PZR SafetyRelicfValve g4 , ReactorTripBreakm Other.
DD@ 3 Auxiliary Feedwater including ESFAS & AMSAC for AFW
]On Site ACPower U WMO*D DC Power DWApp.B j.].J Contrp1 Bids Filtration' Ventilation .-
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Attachment 5.4 - Example of Completed 1996 MPR " Assessment -MP3 (Vertical Slice) Forms (Review Results) 4 I e I J l f B
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REVIE%TR (Please Print) NUMBER IUOII TOP 3CS: ' ~~ w Service Water Residiaal, Neat Removal lnfansion QSS/RSS PZR *
! Meeting ReactorTrip Breaken SafetyReliefValve
] Other: Auxiliary Feedwater including ESFAS & AMSAC for AFW i 3 OWM On. Site AC Power DCPower ) DWApp.B contrp1 Bldg FiltrationNentilation I, . i ATTRIBUTE NO. lSMF D81 1 assUs:
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Attachment 5.5 - Example Discrepancy - Screening Form - D 3 B
l l l 1996 MPR ASSESSMENT - MP3 (VERTICAL SLICE) i Screening Form l
~
1 REVIEWER ND.: TEAM LEADER: -
. = rs= i Safety Significance Review .'
, Codd the lasue involve an actual or potential:
Dyes DNo Personnel, environmental, or equipment safety hazard? Dyes D No Operability or reportablitty concem? ' i
; Dyes D No Adverseimpact on the un!!?
NOTES: 1 l l hsed on the above information, this information D should D should not he forwarded to the plant for further review and consideration. Hisissueis determined to be: D Potenbatty Significant D Not Significant GA REY!EW: DOCUMENTATION ATTACHED: OYES O NO u u voew I RECEfVED BY: DATE TIME 8% AsslGNEDTO: RESOLVED:
RESPONSE
i l This item is considered closed.
i I b Attachment 5.6 . I
@O Categorization of '
Review Results .. i I i e
i I i o - 4 ) CATEGORIZATION OF REVIEW RESULTS The results of all system reviews will be sorted in the manner described in this attachr'nent.
- 1. The process described in this attachment applies to all system review results. Specifically, a j miew result is defined as either a determination that a specific review action did not j identify any potential deficiencies (i.e. a " positive result) or a determination that the review j action identi5ed one or more potential deficiencies.
- 2. The results of all system miews performed in accordance with the matrices in Attachment 5.1 as well as reviews of previous inspection / audit results and of presiously recorded open item repotts such as ACRs, LERs, DCNs will be sorted into 3 major categories:
-A. Current Configuration
-B. Administrative Programs ,
-C. Training "Ihese categories were selected to conform to similar categories in the ACR 7007 Event Response Team Report.
- 3. After sorting all review results into the 3 major categories described in paragraph 2, above, the results are further subdivided into subcategories. These subcategories have been selected based on the results of earlier reviews and are intended to assist in analyzing the. i miew results. The following listing relates the appropriate subcategories for each major category.
Category A. Current Configuration A.I . Design basis 1 A.2. Key document (FSAR, DBDPs, Technical Specifications, Ops critical drawings) ; A3. Design details / Design implementation A.4. Regulatory program compliance A.S. Physical configuration A.6 ' Operations (ops, LCOs, Surveillance tests and inspections) Category B. Adminientive Programs B.1 Design Control and Configuration Management Processes (PDCRs, DCNs) B.2. Maintenancerresting (Open Work authorizations / backlog, Calibration program, Surveillance Testing) BJ. Conective Action (ACRs,LERs) B.4. Licensing commitment tracking system B.5 Operations / Procedures ,.
l l .- .- l 1 Category C. Training l C.1. Industry andIntemalIssues - C.2. General Training ,. ;
- 4. After sorting the review results into the categories and subcategories describN in paragraphs 2. and 3. above, review results will be divided into those which did not identify ;
any problems (positive results) and those which indicate a potential deficiency. Potential deficiencies within each category and subcategory will then be sorted to indicate the probable contributing factors. These contributing factors will be selected from the followinglist:
- a. inadequate training
- b. attention to detail '
c.nonretrievableinformation
- d. inadequate supervision
- e. material defect
- f. insufficient resources (management) !
- g. human error h.procedureinadequacy
- i. procedure noncompliance
- j. incomplete engineering
- k. acceptance of nonconforming condition
- 5. The sorted review results will be maintained in a database for use in preparing the final report.
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Licensing B, skis, Tan'^'d Design:Bsses y a Walkdowns [:.'::' , . I %2.: .. ' '., p- se s
,n'u)d' NUC PI16 '4n.
Rev.O This ProjectManagement Configuration Instruction (PI) Plan (CMP).is part ofimplementation of the e ~w < , . . A royal Effective
, o Mtg. No. ate Date Millstone SORC b c2 & S-D3-9(o CY PORC MP1 PORC MP2 PORC MP3 PORC Responsible Individual:
Level of Use J. Haseltine Information - Subject Matter Expert: J. Haseltine m-
MP1, MP2, CY NU Common Procedure - Licensing Basis and Design Bases Walkdowns , , TABLE OF CONTENTS 1.. ., INSTRU CTI ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Establishing Walkdown Teams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 l 1.2 Walkdown Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l 5 l 1.3 Inspection Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.4 Discrep an cies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 l
- 2. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
- 3. COM MITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ;
- 4.
SUMMARY
OF CHANGES . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ATTACHMENTS AND FORMS ' Attachment 1, "LB and DB Walkdown Checklist" . . . . . . . . . . . . . . . . . . . . 8 Attachment 2, " Additional Walkdown Checklist" . . . . . . . . . . . . . . . . . . . . . 12 , ML y.dk ..d_ WCPI16 Level of Use y* STOP'-v Rev.O THINK' MAGT" ' REVIEW gnformat. ion ppgg. ppig jpg pyrk 1of12
- 1. INSTRUCTIONS .
~
The intent of this Project Instruction is to perform Licensing Basis (LB) and Design Bases (DB) walkdowns for systems identified in the unit-specific CMP ' Implementation Plans. Attachment 11 of the CMP outlines the . interrelationships and interfaces among this PI and the following PIs:
- NUC PI 6,"I.icensing Reviews"
- NUC PI 7," Graded System Reviews"
- NUC PI 8," Plant Verification and Readiness Team"
- NUC PI 14," Project Process Administration" NUC PI 6 and this PI function as key inputs to NUC PI 7. NUC PI 14 outlines the tracking and resolution of discrepancies noted during any of the PI-related activities. NUC PI 8 interfaces with NUC PI 7 on an iterative basis to provide a system package that documents the system LB and DB.
l This PI provides guidance on the attributes to be investigated during the l walkdown process and the documents necessary to record the walkdown results. Applicable systcm attributes provided by NUC PI 7," Graded System Reviews," shall be utilized in the walkdowns.
.Certain conditions may restrict accessibility for inspection. Also,it is not-l expected that component disassembly would normally be required to perform
! the walkdowns required by this PI. Consideration should be given to ALARA issues, safety, and plant conditions. Any such restrictions on inspection performance are documented. l l
\
l l l l l - l i l l 1 i A A L NUC PI 16 ' Level of Use ,A-, m.A,K ' ,A ~ ., L_
'STOP' ~~ THIN NACT' ' REVIEW Rev. 0 l
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Establishing Walkdown Teams ) 1.1
- l 1.1.1 ASSEMBLE walkdown team that typically includes the followmg.
.RT Leader l
~ l
. System Engineer (SRT Leader) ,
- Design Engineer
- Designer (as needed)
. Maintenance and Operations personnel (as needed) j NOTE i
The SRT Leader and Design Engineer have completed initial engineering c ualifications. Based upon their current job descri 3 tion and assigned i dutie's and responsibilities, they are generally qualiied to perform walkdowns. Specific training in the CMP Walkdown Process will ensure their ability to meet PI objectives. Other team members, as assigned, j require only those skill sets related to their specific job descriptions. 1.1.2 VERIFY walkdown team is trained and qualified in those skill sets lUPM l related to their specific job descriptions for this PI. ) ! i i l 1 1 1 I Level of Use d vgigpv Sg k g vqfj;rmgg[gr J E PI16 Rev. 0 lnformation p#gg jpg pg j;q 3 of12
~
1.2 Walkdown Process This section outlines the general approach to the walkdown process. Inspection items to be addressed throughout walkdowns are contained in - Attachment I and Attachment 2. 1.2.1 DETERMINE approach to be used to perform walkdown, either: l SRT Leader l
- Focus on where to start walkdown, considering major system components and (if applicable)1ong-standing issues.
- Entire Walkdown Team performs preliminary walkdown to identify discrepancies.
- Smaller groups within the Walkdown Team perform a series of walkdowns, with each walkdown having a particular focus.
1.2.2 DOCUMENT results of each walkdown (including any access Walkdown Team restrictions or other issues impacting the inspection, or any deficiencies noted) on applicable form as specified in step 1.3.2: JE LB or DB walkdown: Attachment 1
- IE additional attributes from NUC PI 7 require walkdown:
Attachment 2
' SRT Leader 1.2.3 REVIEW walkdown findings.
l 4 IE any discrepancies are identified, PERFORM the following for 1.2.4 each discrepancy:
- a. DEVELOP recommended resolution.
- b. Refer To Section 1.4.
1.2.5 RETURN copy of completed Attachment 1 and Atta'chment 2 (with any discrepancy resolutions) to the NUC PI 7 System Team. 1.2.6 FILE original walkdown attachments in System Walkdown file. l l i
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k i 4 i i 4 NUC PI16 Level of Use ,-.a_ a-
,"THINK'_/Lc NACT*v.7 EVIEW AL_ Rev. 0
'STOP" R gnformation ppg p;cik /F9 4 of 12
I 1.3 Inspection Items I NOTE .
- 1. The NUC PI 7 System Team normally determines which Attachment 1
- or Attachment 2 items are to be checked by the SRT (and the the UPM or SRT Leader may appropriate acceptance criteria), but,tems.
a,so designate additionalinspection i
- 2. There is no "R" (inspection required) column on Attachment 2, since
-< inspection is required for any inspection attribute noted.
1.3.1 Refer To Attachment I and PLACE check mark in the "R" - { SRT Leader l" column for each item required to be inspected.
- a. 1E any required inspection attribute is not shown, Refer To Attachment 2 and RECORD attribute information. 4 NOTE ,
- 1. For the purposes of this PI, any inspection item marked "Unsat" or "N/I" is treated as a discrepancy. .
- 2. Inspections may be performed in any order.
! 3. Reasons recorded in the " Notes" section for discrepancies are " keyed" to the inspection item by noting the insaection category designator, followed by the specific item number. Example: On Attachment 1, a :
pum,p seal or packing discrepancy is coded "C3," and a specific reason l for Unsat" or "N/I" status is recorded. t 1.3.2 INSPECT each required item and DOCUMENT inspection results Walkdown on Attachment 1 or Attachment 2 (as applicable) as follows: Team i
- IE no discrepancy is noted, CHECK " Sat."
1 IE a discrepancy is noted, CHECK "Unsat."
- IE inspection item does not apply to the inspection in progress, CHECK "N/A."
l I
- IE inspection item is not accessible or inspected, CHECK "N/I."
1.3.3 IE any inspection item is checked "Unsat" or "N/I," RECORD reason for discrepancy in the " Notes" section of the applicable form. 1.3.4 ROUTE completed checklists to SRT Leader for resiew as l ~ i specified in step 1.23. p, 8. & $ NUC PI16 l' Level of Use m3gy QF NQp*~5sGiETT Rev.0 Information pa:( p% jk% /?% 5 of12
r I 1.4 Discrepancies NOTE Deficiencies are tracked and remain as open items until resolved. Resolution of discrepancies is addressed m NUC PI 14," Project Process Administration." '
~
1.4.1 IE required, Refer To applicable procedure and INITIATE an lUPM . f ACR for each applicable discrepancy:
- RP-4," Adverse Condition Resolution Program" (for Millstone)
. ACP 1.2-16.5," Adverse Condition Report Process Implementation" (for Connecticut Yankee)
\
l 1 l l 4 b A A & A NUC PI16 Level of Use yg;r yg7 vg/N7'"NT Rev.0 Information jA jgt jeg p%g 6 of 12
! 2. REFERENCES
' , 2.1 Configuration Management Plan (CMP) 2.2 System Engineer Handbook Section 6.4,"Walkdown Guidelines" i
2.3 RP-4," Adverse Condition Resolution Program" (for Millstone) ! 2.4 ACP 1.2-16.5," Adverse Condition Report Process Implementation"
, ,, (for Connecticut Yankee) 2.5 NUC PI 6," Licensing Reviews" l 2.6 NUC PI 7," Graded System Reviews" i
2.7 NUC PI 8," Plant Verification and Readiness Team" t 2.8 NUC PI 14," Project Process Administration" e
- 3. COMMITMENTS !
i-None t t
- 4.
SUMMARY
OF CHANGES j i 4.1 OriginalIssue l i r i 1 i* l i i I A A A A. NUC PI16 ; ! Level of Use ~9fF 'VM*F '%$$F7'WiirT Rev.0 Information /M( P4 74 JP% 7 of12 l
l Attacnmem i l LB and DB Walkdown Checklist ) l (Sheet 1 of 4) Item Inspection Results R Sat Unsat N/A N/I A All Equipment: ,
- 1. Labeling and component identification installed and correct.
- 2. Equipment covers and safety guards installed.
- 3. As appropriate, equipment operation access platforms installed.
- 4. Manufacturer's equipment tags and name plates installed and legible.
5: -Bolting tight with proper hardware installed.
- 6. General component installation per design drawings.
- 7. Components installed in a manner that provides access for operation and maintenance, and does not present a personnel safety hazard.
- 8. Existing components, systems, or structures undamaged.
- 9. Construction debris removed and proper cleanliness level established.
B Valves:
- 1. Valve glands and packing installed.
- 2. Live load packing adjusted per manufacturer's recom nendations.
- 3. Pressure relief / safety valve / rupture disk settings per design (as indicated on attached valve tags).
- 4. Pressure relief / safety valve / rupture disk discharge piping properly secured and discharge flow directed in a safe manner.
- 5. Valve orientation correct (including check valves and non-return valves).
- 6. Valve hand wheels installed.
- 7. Manual valves have sufficient clearance to be operated. _.
- 8. Locking device provided for those valves / breakers / switches required to be locked in a certain position.
- 9. Valves have manufacturer's labels and/or tags installed.
- 10. Solenoid valves installed with correct porting.
- 11. Solenoid vr. es have proper voltage rating.
- Sat: Satisfactory Unsat: Unsatisfactory N/A: Not Applicable N/l: Notinspectable Notes:
! A ' ^
NUC PI 16 Level of USe a.- Ja - ~ ~
'THINK'
~.2 REVIEW Rev. 0 STOP' i.ACT lnformal.lOn y, ,~ y 8 0f L,.
, 3
i l Attachment 1 i LB and DB Walkdown Checklist l (Sheet 2 of 4)
.R Item Inspection Results C Pumps, Fans, Compressors: Sat Unsat N/A N/I
- 1. Pumps, fans, compressors aligned and coupled; coupling guards installed.
j I 2. ' Pumps and fans oriented correctly.
- 3. Pump seals and packing installed.
- 4. Pump seal or bearing cooling lines installed.
- 5. -Pump sealleakofflines or baseplate drain lines installed.
D Mounting and Supports:
- 1. Equipment mounting bolts installed and tight.
- 2. As required, equipment base plate grouted.
l
- 3. Bolts and concrete anchors have thread engagement per design i requirements.
l 4. Pipe hangers, conduit supports, cable tray supports, and instrument line supports installed per design requirements. l 5. Support and hanger accessories (clips, U-bolts, etc.) installed per design requirements. l 6. Snubbers installed per design requirements and setpoints verified.
- 7. Hanger spring cans installed and adjusted per design requirements.
l i 8. Adjustable struts installed and adjusted per design requirements.
- 9. Seismic anchors and restraints installed per design requirements.
- 10. Temporary supports removed.
E Instrument: ,
- 1. Instrument sensing lines connected per design requirements and are tight.
- 2. Equipment mounted instrumentation installed per design requirements. 1
- 3. Physical protection for instrumentation installed per design requirements.
- 4. Instrument tubing and fittings installed per design requirements.
- 5. Surge suppressors for instrumentation installed per design requirements.
l
- Sat: Satisfactory Unsat: Unsatisfactory N/A: Not App 0 cable N/l: Not inspectable l
Notes: l l 1 l l l A ? NUC PI 16 Level of Use m.1 .ma... ./~ .- -. _ Rev. O gnformat. ion STOP 'TyiNK ~ iACT' ' REVIEW 9 of 12
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Attachment 1 LB and DB Walkdown Checidist (Sheet 3 of 4) Item Inspection Results R Sat Unsat N/A N/I . F Electrical Equipment:
- 1. Electrical Environmental Qualification (EEQ) related equipment installed per design requirements.
- 2. Electrical equipment, raceway, and cable insta!!ed to electrical design requirements.
- 3. Electrical connections made up and tight.
- 4. Panel wiring neat and orderly.
- 5. Conductor identi5 cation tags installed.
- 6. Train separation per design requirements.
- 7. Cable tray wiring neat and orderly.
- 8. Permanently lifted or abandoned lead marked and documented.
- 9. Mechanical protective devices for electrical conductors instal!ed per design requirements.
G IIcat Tra cing, Insulation, Painting:
- 1. Heat tracing insta!Ied per design requirements.
- 2. Painting and other protective surface coatings satisfactorily installed.
l
- 3. Insulation installed per design requirements. 1 H HVAC Equipment: l i
- 1. Ventilation system filters and absorber units installed and properly '
oriented.
- 2. Fire dampers properly oriented and installed.
- 3. Fusible links of the proper temperature range installed.
- 4. Ductwork access doors installed.
- 5. Equipment condensation drains installed.
Unsat: Unsatisfactory N/A: Not Applicable N/l: Not inspectable
- Sat: Sat:sfactory Notes:
^
E E NUC PI 16 Level of USe _- _.. L._
^STOP . THINK' ;ACT' ' REVIEW Rev. O Information f % . . r N 10 of 12 f
Attachment 1 LB and DB Walkdown Checklist l (Sheet 4 of 4) Item Inspection Results *
}R
- Sat Unsat N/A N/I I Piping:
1
- 1. Restricting orifices and flow elements installed.
- 2. . Flow elements oriented correctly.
- 3. Fluid system permanent filters installed.
- 4. Startup filters or strainers installed and identified.
5: . Permanent piping spool pieces (to replace startup filters or strainers) are i available for installation.
- 6. Original materia!Aveld identification numbers are legible.
- 7. Welding da
- ns or purge paper used during piping installation removed or identified (so they can be removed after turnover).
- 8. Teniporary vent paths used for welding (i.e., valve bonnet or check valve intervals removed) have been restored.
- 9. Fire barders, cable tray separators and covers, and other fire protection 7 features / equipment installed per Design requirements.
- 10. Security barriers and other physical security measures properly insta!!ed.
These attributes to be verified during walkdown by a representative of the Station Security Department. J Lubrication
- 1. Lubrication reservoirs installed and at proper operating level.
- 2. Equipment properly lubricated and lubrication records available.
K Cathodie Protection
- 1. Cathodic protection installed per design requirements.
- 2. Insulating flanges installed per design requirements. , ,_
- Sat: Satisfactory Unsat: Unsatisfactory N/A: Not Applicab!e N/l: Not Inspectable Notes: '
r f i i Walkdown Participants-
)
)
)
l Date: Supervisor: Date: SE: A A 6 A NUC PI16 Level of USe a- %, m2 % ., 4 e_ Rev. 0
'STOP~ 'THINK' UACT# ' REVIEW gnformat. ion jpqg g pgg y gg
Attachment 2 Additional Walkdown Checklist
- (Sheet 1 of1) . ~
Date: Time: System:
- Inspection Results
- R f Sat Unsat N/A N/I '
L Inspection Attribute l l I. 2. b 1 1 l 4. 5.
- 6. .
1
- 7. l l
8. 9 10. 11. 12.. 13. 14 15. 16. Unsat: Unsatisfactory N/A: Not Applicable N/l: NotInspectable
- Sat: Satisfactory Notes:
Walkdown
Participants:
l l Supervisor: Date: SE: Date: A 4 A A* NUC PI 16 Level of USe -'* di-r STOP " y ATHINK' r ~VACT" -
~R Ew Rev.0 l
InfOrmat. ion ;awg4n,
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! NORTHEAST UTILITIES NUCLEAR CY - ! NU COMMON PROCEDURE MA T g?% l I i l I Procedure Basis Document l l - l Licensing Basis and Design Bases Walkdmyns NUC PI 16 Rev.O This Project Instruction (PI) is part of implementation of the ; Configuration Management Plan (CMP). ] \ l 1 l i Responsible Individual: Basis J. Haseltine
. Document ,
subject Matter Expert:
'1 J. Haseltine
i j l MP1, MP2, MP3, CY NU Common Procedure i f Licensing Basis and Design Bases Walkdowns w-
+
. TABLE OF CONTENTS j '
i . < l l
,L INSTRUCTI ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 l I . 1.1 Establishing Walkdown Teams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 )
i 1.2 Walkdown~ Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l 1.3 Insp,ection Ite ms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.4 - Discrep an cie s ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 i i. ! 2. REFEREN CES ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ,
- 3. C O M hiITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
- 4.
SUMMARY
OF CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ATTACHMENTS AND FORMS ! Attachment 1, "LB and DB Walkdown Checklist" . . . . . . . . . . . . . . . . . . . . 8 Attachment 2, " Additional Walkdown Checklist" . . . . . . . . . . . . . . . . . . . . . 12 !
.. ~ .
o
- m. -
I i i i l NUC PI16 Basis Rev. 0 Document
- 1 of12 l 1 l
l
1
- 1. INSTRUCTIONS The intent of this Project Instruction is to perform Licensing Basis (LB) and Design Bases (DB) walkdowns for systems identified in the unit-specific CMP Implementation Plans. -
m ,
. This PI provides guidance on the attributes to be investigated during the walkdown process and thel documents necessanj to record the walkdown results. Applicable system attributes provided by NUC PI 7, " Graded System Reviews," shall be utilized in the walkdowns.
~ l Certain conditio~ns may restrict accessibility for inspection. Consideration should be given to"ALARA iss'ues, safety, and plant conditions. Any such restrictions on inspection performance are documented.
'. # w G
l I l
)
l l NUC PI16 l Basis Rev. 0 Document . 2of12 l
I l l 1.1. Establishing Walkdown Teams l SRT Leader l 1.1.1 ASSEMBLE walkdown team that typically includes the following:
- System Engineer (SRT Leader)
- - Design Engineer a Designer (as needed) v . Maintenance and Operations personnel (as needed)
. NOTE l The SRT Leader and Design Engineer have completed initial engineering l c ualifications. Based upon their current job descriation and assigned c uties and responsibilities, they are generally qualified to perform walkdowns. Specific training in the CMP Walkdown Process will ensure l their ability to meet PI objectives. Other team members, as assigned, j require only those skill sets related to their specific job descriptions. lUPM l 1.1.2 VERIFY walkdown team is trained and qualified in those skill sets l related to their specificjob descriptions for this PI. i WC PI16 Basis . Rev. 0 Document S of 12 l
i i 1.2 Walkdown Process . This section outlines the general approach to the walkdown process. r ,e- Inspection items to be addressed throughout walkdowns are contained in Attachment I and Attachment 2. . j l l SRT Leader l: 1.2.1 DETERMINE approach to be used to perform walkdown, either: l
- Focus on where to start walkdown, considering major system components and (if applicable)long-standing issues.
., . Entire Walkdown Team perfonns preliminary walkdown to identify discrepancies. ,
- Smaller groups within the Walkdown Team perform a series of walkdowns, with each walkdown having a particular focus. <
Walkdown 1.2.2 DOCUMENT results of each walkdown (including any access Team restrictions or other issues impacting the inspection, or any deficiencies noted) on applicable form as specified in step 1.3.2: 1E LB or DB walkdown: Attachment 1
- LE additional attributes from NUC PI 7 require walkdown: [
Attachment 2
! SRT Leader l 1.2.3 REVIEW walkdown findings.
1.2.4 IE any discrepancies are identified, PERFORM the following for each discrepancy: l l
- a. DEVELOP recommended resolution.
- b. Refer To Section 1.4.
1.2.5 RETURN copy of completed Attachment I and Attachment 2 (with any discrepancy resolutions) to the NUC PI 7 System Team. 1.2.6 FILE original walkdown attachments in System Walkdown file. ' l l i l I NUC PI16 4 Bas!s Rev. 0 ! Document , J 4of12
5 l 1.3 Inspection Items l i NOTE
- 1. The NUC PI 7 System Team normally determines which Attachment 1 or Attachment 2 items are to be checked by the SRT, but the SRT
. Leader may also designate additional inspection items.
' 2. There is no "R" column on Attachment 2, since
- ' inspection is regm(inspection red for anyinspect required) ion attribute noted.
u f l SRT Leader l 1.3.1 Refer To Attachment 1 and PLACE check mark in the "R" ! column for each item required to be inspected. 1 '
- a. IE any required inspection attribute is not shown, Refer To
! Attachment 2 and RECORD attribute information. i NOTE
- 1. For the purposes of this PI, any inspection item marked "Unsat" or "N/I" is treated as a discrepancy. .
l
- 2. Inspections may be performed in any order.
- 3. Reasons recorded in the " Notes" section for discrepancies are " keyed" to the insoection item by noting the inspection category designator, followed by the specific item number." Example: On Attachment 1, a J pump seal or packing" discrepancy is' coded "C3," and a specific reason l for "Unsat" or "N/I" status'is recor'ded.
Walkdown 1.3.2 INSPECT each required item and DOCUMENT inspection results Team on Attachment 1 or Attachment 2 (as applicable) as follows: JE no discrepancy is noted, CHECK " Sat." IE a discrepancy is noted, CHECK "Unsat." JE inspection item does not apply to the inspection in progress, CHECK "N/A." IE inspection item is not accessible or inspected, CHECK "N/I." 1.3.3 IE any inspection item is checked "Unsat" or "N/I," RECORD reason for discrepancy in the " Notes" section of the applicable form. 1.3.4 ROUTE completed checklists to SRT Leader for review. Basis Document . Rev. 0
; S of 12
1.4 Discrepancies
- i lUPM l" 1.4.1 IE required, Refer To applicable procedure and INITIATE an l ACR for each applicable discrepancy: ,
i
- = RP-4," Adverse Condition Resolution Program" i (for Millstone)
= ACP 1.2-16.5," Adverse Condition Report Process
- Implementation" (for Connecticut Yankee) l i
- 1
! i j i i ) i i 4 k a l 1 ?
, "s ,
i 1 f i i t i NUC PI16 ; Basis
- i
- Rev. 0 Document 6of12
- 2. REFERENCES 2.1 Configuration Management Plan (CMP) j 2.2 c ysiem S Engineer Handbook Section 6.4,"Walkdown Guidelines" -
~
,, I
~. ,
. - 2.3 ' RPy4, " Adverse Condition Resolution Program" (for Millstone) ;
' 2.4"" ACP 1.2 2 1'6.5," Adverse Condition Report Process Implementation"
; (for Connecticut Yankee) ;
*=/
2.5 NUC PI 7," Graded System Reviews" ,
- 3. COMMITMENTS l None ,
i
- 4.
SUMMARY
OF CHANGES l 4.1 OriginalIssue
)
s . NUC PI16 Basis Rev. 0 Document - j 7 of12
Attachment 1 LB and DB Walkdown Checklist (Sheet 1 of 4) i R Item Inspection Results A All Equipment: Sat Unsat N/A N/I '
- 1. , Labeling and component identification installed and correct.
- 2. Equipment covers and safety guards installed.
- 3. As appropriate, equipment operation access platforms installed.
- 4. Manufacturer's equipment tags and name plates installed and legible.
- 5. Bolting tight with proper hardware installed.
- 6. General component installation per design drawings.
- 7. Components insta!!ed in a manner that provides access for operation and maintenance, and does not present a personnel safety hazard.
- 8. Existing components, systen.s, or structures undamaged.
- 9. Construction debris removed and proper cleanliness level established.
B Valves:
- 1. Valve glands and packing instal! d.
- 2. Live load packing adjusted per manufacturer's recommendations.
- 3. Pressure relief / safety valve / rupture disk settings per design (as indicated on attached valve tags).
- 4. Pressure relief / safety valve / rupture disk discharge piping properly secured
; and discharge flow directed in a safe manner.
- 5. Valve orientation correct (including check valves and non-return valves).
- 6. Valve hand wheels installed.
- 7. Manualvalves have sufficient clearance to be operated.
- 8. Locking device provided for those valves / breakers / switches required to be locked in a certain position, j
- 9. Valves have manufacturer's labels and/or tags installed. l 1
- 10. Solenoid valves installed with correct porting.
l
- 11. Solenoid valves have proper voltage rating.
l
- Sat: Satisfactory Unsat: Unsatisfactory N/A: Not Applicable N/l: Not inspectable Notes:
l Basis . NUC PI 16 Document Rev. 0 8 of12
Attachment 1 LB and DB Walkdown Checklist ! (Sheet 2 of 4) l R Item Inspection Results C Pumps, Fans, Compressors: Set Unsat N/A N/I,
- 1. Pumps, fans, compressors aligned and coupled; coupling guards installed.
- 2. Pumps and fans oriented correctly. l
- 3. Pump seals and packing installed.
- 4. Pump seal or bearing cooling lines installed.
- 5. ' Pump seal leakoff lines or baseplate drain lines installed.
D Mounting and Supports:
- 1. Equipment mounting bolts installed and tight.
- 2. As required, equipment base plate grouted. I
- 3. Bolts and concrete anchors have thread engagement per design requirements.
l
- 4. Pipe hangers, conduit supports, cable tray supports, and instrument line supports installed per design requirements.
- 5. Support and hanger accessories (clips, U-bolts, etc.) installed per design requirements.
- 6. Snubbers installed per design requirements and setpoints verified.
- 7. Hanger spring cans installed and adjusted per design requirements.
- 8. Adjustable struts installed and adjusted per design requirements.
- 9. Seismic anchors and restraints installed per design requirements.
- 10. Temporary supports removed.
E Instrument:
- 1. Instrument sensing lines connected per design requirements and are tight.
- 2. Equipment mounted instrumentation installed per design requirements.
- 3. Physical protection for instrumentation installed per design requirements.
- 4. Instrument tubing and fittings installed per design requirements.
- 5. Surge suppressors for instrumentation installed per design requirements.
- Sat: Sat.sfactory Unsat: Unsat:stactory N/A: Not Applicable N/l: Not inspectable Notes:
NUC PI16 Basis Document - Rev.0 9 of 12
Attachment 1 LB and DB Walkdown Checklist (Sheet 3 of 4) R Item Inspection Results F Electrical Equipment: Sat Unsat N/A N/I ,
- 1. Electrical Environmental Qualification (EEQ) related equipment installed
,per design requirements.
- 2. Electrical equipment, raceway, and cable installed to electrical design requirements.
- 3. Electrical connections made up and tight.
- 4. ' Panel wiring neat and orderly.
- 5. Conductor identi5 cation tags installed.
- 6. Train separation per design requirements.
- 7. Cable tray wiring neat and orderly.
- 8. Permanently lifted or abandoned lead marked and documented.
- 9. Mechanical protective devices for electncal conductors installed per design requirements.
G H eat Tracing, Insulation, Painting:
- 1. Heat tracing installed per design requirements.
- 2. Painting and other protective surface coatings satisfactorily installed.
- 3. Insulation installed per design requirements.
H HVAC Equipment:
- 1. Ventilation system filters and absorber units installed and properly oriented.
- 2. Fire dampers properly oriented and installed.
- 3. Fusible linh or the proper temperature range installed.
- 4. Duct:.ork access doors installed.
- 5. Equipment condensation drains installed.
- Sat: Satisfactory Unsat: Unsatisfactory N/A: Not Applicable N/l: Not inspectable Notes:
NUC PI16 Basis - Rev.0 Document 10 of 12
Attachment 1 i LB and DB Walkdown Checklist (Sheet 4 of 4) , R Item Inspection Results * . I Piping: Sat Unsat N/A N/I i
- 1. Restricting ori5ces and flow elements installed.
- 2. . Flow elements oriented correctly.
- 3. Fluid system permanent filters installed.
- 4. Startup filters or strainers installed and identified.
- 5. . Permanent piping spool pieces (to replace startup Slters or strainers) are l
available for installation.
- 6. Original materia!Aveld identification numbers are legible.
- 7. Welding dams or purge paper used during piping installation removed or identified (so they can be removed after turnover).
- 8. Temporary vent paths used for welding (i.e., valve bonnet or check valve intervals removed) have been restored.
i
- 9. Fire barriers, cable tray separators and covers, and other fire protection features / equipment installed per Design requirements.
- 10. Security barriers and other physical security measures properly installed.
These attributes to be veri 5ed during walkdown by a representative of the ; Station Security Department. l J Lubrication
- 1. Lubrication reservoirs installed and at proper operating level.
- 2. Equipment properly lubricated and lubrication records available.
K Cathodic Protection
- 1. Cathodic protection installed per design requirements.
- 2. Insulating flanges installed per design requirements.
- Sat: Satisfactory Unsat: Unsatisfactory N/A: Not Applicable N/l: Not inspectable Notes:
Walkdown
Participants:
SE: Date: Supervisor: Date: NUC PI16 basis
- Rev. 0 Document 11 of 12
I 1 i ! Attachment 2 l Additional Walkdown Checklist (Sheet 1 of1) Date: Time: System: l R Inspection Results
- L Inspection Attribute Sat Unsat N/A N/I 1
1. l 2. l 3. J 4. 5. 6. l 7. 8. 9. l 10. 11.
. 12.
13. 14. 15. 16.
- Sat: Satisfactory Unsat: Unsatisfactory N/A: Not Applicable N/l: Not inspectable Notes:
Walkdown
Participants:
SE: Date: Supervisor: Date: b'UC PI 16 ! Basis - Rev. 0 l Document 12 of 12 1 i
n . l Validation Commbnt and Resolution Form C oMM E4TS [R.om gEWEw (Sheet I of 2) {'
, od rlQT(, (accet, Mtwz, LY.ns, GrAQ f Procedure Number: bb T Revision: O
/
T7 Procedure
Title:
M ff5-I d A/LLfTbAIE UA/ tT 3 5WTE/If #6VIEk/S Select $ Field Simu!sted Table Top & Comparison?"i Validation
- Validation Validation Performance Walk-Through LJ Not Required i Me} hod
- lf a validation is not required. provide an explanation and justMication on sheet 2.
l ) i p E a Field Validation ** Is being performed (validation of procedure using actual l plant or spare equipment), VERIFY all of the following criteria are satisfied:
- Independent reviewi: complete. ;
- If required, an AWO has been prepared and includes the fo!!owing in " JOB DESCRIPDON":
"PORC or SORC APPROVE PROCEDURE PRIOR TO RETEST" Post-validation testing.that demonstrates the work was completed satisfactorily and the equipment is capable of perfor=ing its intended function when returned to service,has been specified.
mcce m A o c.u
- Department Head has designated the individua1 who is authorized to maketsewys to the ) p implemented and the ac(tion pe formed, a c)hange must be documentedj, procedure in the field enter natae below . (Before tag rnedficadons to theprocedure are and cuihorized by indMdu:1on thisform.) :
Name of AuthorizedIndividuah The Department Head has approved the procedure for validation on actual plant or spare equipment. Department Head Approvalfor Field %1idation- Date: *
- The equipment is removed from senice.
The equipment isolated and tagged in accordance with ACP-QA-206A or a Safety Evaluation has
, been prepared indicating that operation of the e validated and will not cause anyinteraction with,quipmentis or impact in accordance on, any component important to with the safety. procedure being One of the following methods has been selec:ed to be used to declare the equipment operable and return the equipment to senice following the validation:
- 1. Final PORC or SORC approval of the procedure before unisolating and retesting and satisfactory completion of the retestbefore declaring the equipment operable and returntng n to semce.
- 2. Using a current PORC or SORC approved procedure to restore the equipment, circuit, or system to its original condition.
** Upon completion of the field validation of a procedure, any changes must be incorporated into the procedure and concurrence obtained from the Independent Reviewer. The revised ,
procedure is presented to PORC or SORC for final approval. -
, y _g-On., eda M f y M A (Ih 4 hr Ea Simula d Perforrhance i be g performed, VERIFY the equipment is no! '
considere @! ant PJ:ocedurc, Se eAr, quipmen{Kas-specified 1.3.2 J OBTAIN Department in U eapproval. Head Jufin!!!on prov!ded in I th; V&V Department Head
. Appron!for Simulated Performance: Date: I
. jh d d A- DC3, Attachment 3 Page / of [ N5TOF fiq 7$dTK7 XX6p7jgjg Rev0
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Validation Commer[ nd Resolution Form (Sheet 20f 2)
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Procedure Number: NoC PI If Revision: $D . item SI P I Comments
- Resolution and Authorization (if required) l Section No.
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..., Validation Conuncur " 3d Resohition Form *
(Shett 2 of 2) . Procedurc Number: 80C b II Revision:10 :. .
'P Comments
- Resolution and Authorization (If required) l item Sect On o.
I' - 2. 4 0Ad Tn - Il- OLId J fr- ps bkJ' p_4tua .
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,., Validation Comment ' id Resolution Form '
l :, (Sheet 20f 2) . Procedure Number: #d C- II 'I' Revision: EO ' Item 'P Comments
- Sect on o. Flesolution and Authorizatican (if required) l
- 19. 7 f- Uy h4 eah A fyfA (
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l ' Validation Comment-(Sheet 2 of 2) 11 Resolittion Form l* Procedure Number: ML'C N T Revision: kO 4 item P f S ton o. Comments
- Resolution and Authorfzation (if required) l
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