ML20137N964

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Evaluation of Findings
ML20137N964
Person / Time
Site: Millstone Dominion icon.png
Issue date: 04/03/1997
From:
External (Affiliation Not Assigned)
To:
Shared Package
ML20137N877 List:
References
PP-07, PP-7, NUDOCS 9704090100
Download: ML20137N964 (10)
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" PARSONS PP-07 MILLSTONE UNIT 2 lCAVP PROJECT PROCEDURES

Title:

Evaluation of Findings REVISION 0 Prepared by: 2/ , Date: 9//8!97-

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Approved by: N Date: M!3!fk Project Director 8 REVISION HISTORY REVISION DATE REVISION DESCRIPTION 0 04/03/97 Procedure initiation O

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FP) MILLSTONE UNIT 2 ICAVP PP-07 8 PROJECT PROCEDURES  !

TITLE: EVALUATION OF FINDINGS 4

REVISION: 0 DATE: 04/03/97 PAGE 2 OF 10 TABLE OF CONTENTS 1.0 PURPOSE............................................................................................................3 2

2.0 DEFINITIONS.............................................................................................................3 3.0 R ES P O N S I B I L I TI ES ........................ .......... .......... .. .. . ......... ............. ... ....... ........ ....... 4 4.0 PROCEDURE..............................................................................................................4 4.1 IDENTIFICATION OF POTENTIAL FINDINGS. . . . .. 4 4.2 IDENTIFICATION OF FINDINGS.. . .. .. . . ..4 4.3 REPORTING OF FINDINGS . . . . . . .6

\ 4.4 REVIEW OF PROPOSED CORRECTIVE ACTION.. .. . . .. .6 .

l ATTACHMENT I - POTENTIAL FINDING LOG . . . . . . . .7 1 l

l ATTACHMENT 2 - RESOLUTION OF FINDINGS . . . .8 l

. EXHIBIT I - EVALUATION OF FINDINGS. . .. . . .. . .10 1 i

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MILLSTONE UNIT 2 ICAVP PP-07

> PROJECT PROCEDURES t7 ,i V TITLE: EVALUATION OF FINDINGS REV!SION: 0 DATE: 04/03/97 PAGE 3 OF 10 a

1.0 PURPOSE

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The purpose 4.,f this Project Procedure is to provide the guidance necessary to evaluate project findings developed during the conduct of the Millstone Unit 2 Independent Corrective Action Verification Program (ICAVP). Findings developed by the Millstone Unit 2 ICAVP will be reported in parallel to both the NRC and the licensee in accordance

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with the Communications Plan (PLN-02). Potential Findings are evaluated as shown in Exhibit 1.

10 DEFINITIONS 2.1 Findings - A finding is a defect, deficiency or an unresolved item identified during the Millstone Unit 2 Independent Corrective Action Verification Program. Licensee corrective action and response is required for Findings, i

2.2 Defect - A defect is any condition that resuits in the plant being outside its current licensing bases. This would include a condition that would be considered an unreviewed

safety question in accordance with 10 CFR 50.59. It would also include a condition that would prevent a structure, system, or component (SSC) from meeting a specific docketed regulatory requirement applicable to Millstone Unit 2, 2.3 Deficiency - A deficicacy is an error or omission in the Millstone Unit 2 licensing or design basis which is not identified as a defect.

2.4 Unresolved Item - An unresolved item requires more information to reach a conclusion.

Licensee response and further evaluation are rec,uired for resolution.

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l E3 MILLSTONE UNIT 2 ICAVP PP-07 E . PROJECT PROCEDURES

-() TITLE: EVALUATION OF FINDINGS REVISION: 0 DATE: 04/03/97 PAGE 4 OF 10 ac _

3.0 RESPONSIBILITIES l l

1 3.1 Project Director - The Project Director is responsible for approval of Findings prior to concurrent reporting to NNECo and the NRC in accordance with the Communications Plan (PLN-02).

3.2 Deputy Project Director - The Deputy Project Director is responsible for revinv of Findings prior to concurrent reporting to NNECo and the NRC in accordance with the Communications Plan (PLN-02) and for tracking and monitoring of Potential Findings.

The Deputy Project Dir:ctor is responsible for approval of comments concerning proposed corrective action on Findings by the Licensee.

3.3 Originator - The Originator is responsible to identify potential findings during the conduct of the Millstone Unit 2 ICAVP. The Originator additionally has input on the comment resolution phase based upon resolution proposed by the Licensee.

4.0 PROCEDURE 4.1 IDENTIFICATION OF POTENTIAL FINDINGS 4.1.1 During the course of the Millstone Unit 2 ICAVP, any Project Team member may identify and originate Potential Findings. Further Parsons evaluation is required to determine the bases of the Potential Finding.

4.1.2 Once a Potential Finding has been identified, it is logged in on Form PP-07-1 (Attachment 1) for tracking and monitcring purposes.

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! E3 MILLSTONE UNIT 2 ICAVP PP-07 E PROJECT PROCEDURES TITLE: EVALUATION OF FlNDINGS REVISION: 0 DATE: 04/03/97 PAGE 5 OF 10 4.2 IDENTIFICATION OF FINDINGS 4.2.1 Once the identified Potential Finding has been evaluated and the basis validated by the responsible Group Lead, it will be determmed to be either a Finding or the Potential Finding may be closed if the basis is determined not to be valid. The initiation and evalm. tion of a potential finding is documented on the Resolution of Findings form (Attachment 2).

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! 4.2.2 A Potential Finding is determined to be a Finding ifit is determined to be a defect, deficiency or an unresolved item, as described below.

4.2.3 A Potential Finding is determined to be a defect if during the evaluation, it is determined that the potemial finding mecs any of the following criteria:

l O 4.2.3.1 The probability of occurrence or the consequences of an accident or malfunction of l

equipment important to safety previously evaluated in the safety analysis report has l

l increased; or i

4.2.3.2 The probability of an accident or malfunction of a different type than any evaluated previously in the safety analysis report has been created; or l

4.2.3.3 The margi / safety as defued in the basis for any Technical Specification is reduced, or l 4.2.3.4 The regulatory bases of the system, structure or component are not met.  ;

l 4.2.4 A Potential Finding is determined to be a deficiency ifit meets an error or omission is i found in the licensing and design basis of Miilstone Unit 2 and the criteria for a defect are not met. This includes identification of Potential Findings that have been fcund to already l have been identified and documented by NNECo.

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EG MILLSTONE UNIT 2 ICAVP PP-07 M . PROJECT PROCEDURES

\ TITLE: EVALUATION OF FINDINGS REVISION: 0 DATE: 04/03/97 PAGE 6 OF 10 4.2.5 A Potential Finding is determined to be an unresolved item if additional information required from the licensee to complete the evaluation. Action is required by the licensee and follow-up action is required to complete evaluation of the unresolved item.

4.2.6 A Potential Finding is determined to be a closed item if through further evaluation, it is determined that the issue is not a fmding.

4.3 REPORTING OF FINDINGS 4.3.1 Once a potential Finding has been determined to be a finding, it will be reviewed by the Deputy Project Director and approved by the Project Director and reported concurrently to the NRC and NNECo in accordance with the Comumnications Plan (PLN-02) 4.4 REVIEW OF PROPOSED CORRECTIVE ACTION G 1 1

4.4.1 PPGl is responsible to commem on the proposed corrective action prepared by NNECo in i response to Findings.

4.4.2 The ICAVP Group Leader responsible for generatmg the Finding is responsible for commenting on the resolution. A copy of the proposed corrective action will be sent to the originator. Comments should cover the adequacy of the response to bring the issue back within the licensing and design basis. He Resolution of Findings Form (Attachment 2) is used to document the Parsons responses and close out of the NNECo response.

4.4.3 The Deputy Director is responsible for approving resolution comments prior to releasing the comments per the Communications Plan (PLN-02).

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P) MILLSTONE UNIT 2 ICAVP PP-07 E PROJECT PROCEDURES TITLE: EVALUATION OF FINDINGS REVISION: 0 DATE: 04/03/97 PAGE 7 OF 10 1

Attachment 1 l Potential Findings Log Millstone Unit 2 ICAVP PF Niunber Originator Date Resolution Date

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E) MILLSTONE UNIT 2 ICAVP PP-07 E > PROJECT PROCEDURES TITLE: EVALUATION OF FINDINGS REVISION: 0 DATE: 04/03/97 PAGE 8 OF 10 Attachment 2 i Resolution of Findings I Potential Finding Tracking Number Initiation of Potential Findine

Description:

(Attach additional documentation as necessary)

(Initiator) (Date)

Evaluation of Potential Finding O Resolution (Finding or Closed): (Attach additionaldocumentation as necessary) i i

(Group Lead) (Date) 1 Evaluation of Finding i Resolution (Defect Deficiency, UnresolvedItem): (Attach additional l documentation providing basis, as necessary) l Reviewed: (Dep. Proj. Dir.) (Date)

Approved: (Proj. Dir.) (Date) ]

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I E) MILLSTONE UNIT 2 ICAVP PP-07 E PROJECT PROCEDURES TITLE: EVALUATION OF FINDINGS REVISION: 0 DATE: 04/03/97 PAGE 9 OF 10 Attachment 2 Resolution of Findings (Continued)

NNECo Response:

Summary:

i Comment on NNECo Response:

, I Reviewed: (Dep. Proj. Dir.) (Date)

Approved: (Group Lead) (Date)

Closed (Dep. Proj. Dir.) (Date)

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LE "d MILLSTONE UNIT 2 ICAVP PP-07 l PROJECT PROCEDURES i O

V TITLE: EVALUATION OF FINDINGS REVISION: 0 DATE: 04/03/97 PAGE 10 OF 10 Exhibit 1 EVALUATION OF FINDINGS Initiate Potential Finding

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Log / Track Potential Finding

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Review /

Evaluate k

Is Close and , No Potential Document , Finding Basis Vfd Yes Classify Finding V + V i

Evaluate as Evaluate as Evaluate as  :

l Defect Deficiency Unresolved Item

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) Review /

Appmval l

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Concurrent Reporting of Finding to NNECO NRC per PLN-02

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NNECO

Response

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Review / Comment Ox on NNECO Response

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Document Comments l per PLN-02 )

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