ML20141E706
| ML20141E706 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/27/1997 |
| From: | Blocher E, Curry D External (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20141E632 | List: |
| References | |
| PROC-970627, NUDOCS 9707010144 | |
| Download: ML20141E706 (18) | |
Text
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O pansoms powen l INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM MILLSTONE UNIT 2 AUDIT PLAN Revision 2 O
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Prepared By: ON
- Date: June 27,1997 Deputy Project Director Approved By: be /./[5Me Date: June 27,1997 anagir, Company Quality Program J
Approved By:
Project Director A GM Date: June 27,1997 i l
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- PARSONS POWER -
Audit Plan Revision 2 9707010144 970627 June 27,1997 PDR ADOCK 05000336 P PDR
MILISf0NE UNIT 2 AUDIT PLAN REVISION LOG Section Revision No. Descrintion D. gig All 0 Initial Issue April 3,1997 All 1 Incorporation of NRC Comments June 9,1997 3,4,5 2 Incorporation of NRC Comments June 27,1997 0
This list delineates sections of this manual that are currently in er A ct. The latest changes are indicated by a vertical line in the right hand margin of the affm d pages.
O - PAR 8086 POWIE -
Audit Plan Revision 2 i June 27,1997
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- MILLSTONE UNIT 2 AUDIT PLAN LIST OF EFFECTIVE PAGES Pane No. Revision No. Pane No. Revision No.
I 2 0-1 1 il 2 6-2 1 ill 1 6-3 1 iv 1 7-1 1 1-1 1 7-2 1 2-1 1 3-1 1 3-2 1 3-3 1 34 1 3-5 2 l 34 1
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4-4 2 l l 4-5 1 l (m 4-6 2 l l 4-7 1
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&9 2 4-10 1 4-11 1 4-12 2 -
4-13 2 4-14 1
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- 4-17 2 l l 4-18 1 4-19 1 4-20 1 4-21 2 l l 4-22 1
! 4-23 1 l &24 2 l 4-25 1 4-26 2 l 4-27 1
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- PM8H8 PHH -
Audit Plan Revision 2 ii June 27,1997 l
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3.3.1 Manaear of Company Ouality
- (' The Manager of Company Quality (MCQ) has been assigned the responsibility for l
monitoring effective implementation of the Parsons Power Nuclear Quality Program.
The MCQ reports directly to the President of Parsons Power and has the independence, freedom and authority to assess the effectiveness of qually activities and to provide mechanisms to initiate corrective measures when necessary.
The MCQ is assigned to this project and directs all QA Program activities for this Project. The MCQ serves as the primary quality interface between the project and other Parsons Power units which contribute to the QA Program.
The MCQ will routinely review all aspects of the Quality Program accomplishments and status. Evidence of deficiencies in procedures, processes, or systems shall prompt appropriate corrective action.
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3.3.2 Internal Audits and Surveillances l The project will be audited through the Corporate Internal QA Audit Program.
Audits will be planned, scheduled, coordinated, and performed in accordance with
,A Parsons internal procedures. Audits will be performed by properly trained, experienced, and certified personnel not engaged in the activity being audited.
Surveillances may be performed at any time during the course of the project activities.
These surveillances shall follow the guidelines of the ASQC Surveillance Handbook and Guidelines. Surveillances will be performed using applica'ble elements of internal audit procedures, with the intent to evaluate and improve both performance and process. ' Surveillances should be in-process evolutions. Personnel trained in auditing techniques will be utilized to perform these surveillances. Copies of internal audit and surveillance reports will be sent to the NRC.
3.4 ASSIGNMENT OF STAFF All personnel assigned to the project, either Parsons employees or consultants, will be evaluated for their independence from Millstone Unit 2 design and design review activities and their financial independence from Northeast Utilities. All personnel initially assigned to the project may be interviewed by the NRC and other interested parties [i.e., Connecticut Nuclear Energy Advisory Committee (NAEC)]. All personnel additions or substitutions will be processed in accordance with Project 4
- PAR $0BE P9WER -
Audit Report Revision 2 3-5 June 27.1997 l
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" Safety System Functional Inspection". '
O Following system selection by the NRC, the SVSR will be performed as shown in .
. Exhibit 4-2. Project Procedure PP-01 " System Vertical Slice Review" and Project Instruction PI-01 " Conduct of SVSR will be used to perform the inspection. The SVSR is based on the activities noted below and discussed in the following paragraphs:
- Select System for SVSR L e Determine System Boundary
. Identify Licensing and Design Basis Requirements e Prepare System Specific Checklist e Evaluate System Configuration Management
- Prepare SVSR Final Report
! 4.1.1 Select Systems for SVSR l-Parsons Power Group has developed criteria for NRC use in selecting systems for the vertical slice review. The initial systems to be reviewed will be' selected from those systems categorized as Group 1 using criteria developed as part of maintenance rule !
Implementation (10CFR50.65). Systems are categorized as Group 1 based safety j related and risk significance.
The Parsons Tier 1 system selection criteria will supplement the Maintenance Rule criteria (risk and safety significance) based system fanction, operational and configuration history, regulatory history, and professional opinion. A major factor that will be considered will be previous opportunities for introducing inappropriate changes to the system or design bases (a high number of modifications or significant system reconfigurations), and previous problems with the system (at both the plant level and industry wide).
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- PAR 8estPOWER -
Audit Plan Revision 2 4-4 June 27,1997
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- i Parsons will consider a system as a likely candidate for an SVSR if the system: '
O = Has experienced a high number of modifications.
Has had a major modification or a number of major modifications involving a I
design change with internal interfaces between major discipline areas and/or i external interfaces with the NSSS vendor, component vendors, and engineering l service organizations.
l Has a high level of risk significance based on PRA insights as determined by a i panel of individuals familiar with the Plant PRA.
Has an identified history of deficiencies or operating problems based on plant or industry operating experience.
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The NRC should make the final determination of the relative ranking of the systems i i
based on the results of the system selection survey, system boundaries, industry I experience, and their own knowledge of the systems and the requirements of the ICAVP. The NRC should bias their weighting for the selection of systems using consideration of issues identified as part of the August 14,1996 confirmatory order.
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l Additional detail on system selection criteria is provided in PP-01, System Vertical 1
l Slice Review Procedure. i i
4.1.2 Determine System Boundarv -
i The System Boundary will define the scope of the SVSR in regards to the selected system. Interfaces with, and portions of other systems may be included v ithin the boundary of the selected system to the extent they are necessary to support the I functional requirements of the selected system. In additions, system boundaries may ,
be defined at appropriate components that provide physical isolation, as long as the selected boundary does not split the component between systems. The NRC and l NNECo will review the system boundary for agreement in interpretation of SVSR l
scope.
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! -rasseusrowin-Audit Plan Revision 2
( 4-6 June 27.1997
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a Emphasis will be on verifying that the subject systems processes, practices and procedures used to perform engineering design, design change control document control and records updating of the design bases have been successful in maintaining the system configuration in accordance with regulatory requirements. Operations,
- Maintenance, and Test Procedures will be reviewed to verify that correct licensing and ,
. design bases information have been incorporated into the procedures.
The SYSR Team will provide ongoing reports which will detail the status, on a system specific basis, of the progress of the SVSR for each of the selected systems. As discrepancies are identified during the review, they will be immediately communicated to management for evaluation. Each discrepancy will be provided with a complete description, including all pertinent information per the requirements of Project Procedure PP-07 "" Discrepancy Reports."
A size of at least 4 systems for the SVSR is predicated on the assumption that the assessment will not find significant discrepancies. Additional systems may,be added to the SVSR as directed by NRC.
L Evaluation of configuration management considerations will be focused on licensing
- and design bases requirements. Evaluations and will utilize appropriate level documentation (drawings, calculations, design documents, etc.) to the inspection detail necessary to verify and validate conformation to requirements. The vertical slice reviews will emphasize design control and will verify that
. The current configuration accurately reflects the licensive-bases, including the updated FSAR.
- Calculations and analyses were performed using recognized and acceptable j_ analytical methods and that assumptions made in calculations or analysis supporting changes are technically sound.
. The results of calculations or analysis supporting the unmodified portions of the original configuration and design changes are reasonable (based on engineering i judgment) for the scope of the change.
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Audit Plan Revision 2 4-8 June 27,1997 l
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Millstone Unit 2 considered the effect of a change on design margins and that the design changes received the appropriate level of engineering and management review during the design phase and prior to implementation.
Millstone Unit 2 considered the effect of a change on pre-operational, startup or system baseline acceptance test results.
Design changes are accurately reflected in operating, maintenance, and test procedures, as well as in training materials.
Proposed design changes, subsequently canceled, were not replaced by procedural changes that imposed excessive burdens on plant operators.
Adequate control of operational procedures, maintenance procedures, test and surveillance procedures, operator training and control of the plant simulator configtia aion.
The current configuration is consistent with the licensing bases at the level of detail contained in piping and instrumentation diagrams (P& ids) or system flow diagrams, piping isometric drawings, electrical single-line diagrams, and emergency, abnormal and nonnal operating procedures, e
The analyzed configuration is consistent with the current plant configuration.
Identification numbers are as indicated on the P&ID or. process flow diagram, and equipment name plate data is consistent with design specifications and analyses.
The location of pipe supports, snubbers, and other pipe restraints is consistent with design specifications and piping stress analyses.
- Divisional separation of safety-related systems, structures and components, j seismic II/I, and other topics addressed by the licensee's hazards analyses are reflected in the current plant configuration.
r O - PARS 8BS POWER -
Audit Plan Revision 2 4-9 June 27,1997
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Exhibit 4-3 AMSR Review Process FSAR Chapter 14 Tech _ Spec k identify Define Each Develop I
' { Develop System Emera Op PrC h
v Critical 4 Safety
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7 l Boundary D:agrams-____ .
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h Function Functions Diagram g NNECo Data w
lE g Reg. Review Lic. Requirements g;j AnaWs Priority DBEvCDC g }f l to i4RC for Review 4 To Mr1
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g o > Database + Design Y Critical characteristics by system '
p Basis r g Structure Characteristics g Events l .
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A generic critical function diagram will be developed presenting the active functions that must be executed for the spectrum of DBEv along with the identified component configuration. An example of a critical function diagram is shown in Exhibit 4-4. This set of conditions will ensure the development of a complete set of Critical Design Characteristics.
- The Emergency Operating Procedure (EOP) will be reviewed to determine consistency with the funcational and system level critical characteristics.
I 4.2.2 Prepare Characteristics Database A critical design characteristic is defimed as that aspect of a component or system that must be included in the design to ensure that the component or system will perform i its critical safety function. The critical design characteristics are an accumulation of the system design characteristics, and the system's components critical characteristics, coupled with the plant and component configuration at the time of the DBEv. These l G characteristics will be determined based on the existing information contained in the V licensing basis for Millstone Unit 2. The data will be used to perform the systems verification. ;
The following list represents a core group of documents that contain a significant amount of information about the critical parameters for the plant:
e Updated FSAR for Millstone Unit 2 l
. Technical Specifications for Millstone Unit 2
. System Design Bases Documents e Probabilistic Risk Assessment for Millstone Unit 2
- e Combustion Engineering Owners Group Documents l !
- System Design Calculations i
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i O - PMSM8 POWEA -
Audit Plan Revision 2 4-13 June 27,1997
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l characteristics that have been incorporated. Differences between the two sets of data will be evaluated and compared against the results from the NNECo corrective action programs. As discrepancies are identified during the review they will be reported per l the requirements of Project Procedure PP--07 " Discrepancy Reports". i I
A listing of the critical design characteristics will be prepared. This listing of critical design characteristics will be the source data base to be used by the Review Team for 1 the systems that will be covered in the SVSR and AMSR process.
1 4.2.3 Validation of Critical Desian Characteristics The AMSR will include a comparison of critical design characteristics versus the j as-documented design for 100% of the functinoal/ system level characteristics derived from FSAR chapters 14,6,7, 8, and 9. This comparison will use plant l configuration documents such as drawings, DBDs, calculations, etc. that reflect
! the current documented plant configuration. All discrepancies will be documented.
The AMSR will include a validation of 100% of the functional / system level critical characteristics derived from FSAR chapters 14,6,7, 8, and 9. This i validation will be based on review of plant test data, Technical Specifications, calculations, or other alternate methods, as appropriate. All discrepancies will be documented.
This validation process is independent from the one performed by the SVSR Team.
Those characteristics associated with the systems being reviewed by the SVSR Team will be given to the SVSR team to verify.. The results of SVSR Team validation will be incorporated into the AMSR report for completeness.
4.2.4 Preparation of AMSR Rgp_q1 A final report will be prepared identifying the critical design characteristics by system and by DBEv. Included in the report will be the listing of the characteristic and how it was verified . The AMSR Report will be included as part of the ICAVP Final Report, and will contain the following:
- Summary l
- Critical Safety Function by system by DBEv
- Critical Design Characteristics by System
- Discrepancy Reports summary l
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- PAR 8ONSP8W M -
Audit Plan Revision 2 4-15 June 27,1997
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"' Tier 3 Process Smnmmy .
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l l . Master equipment list maintenance. and revision tQ = Information systems design and change control U
l e Setpoint changes
- Specification preparation and revision
. . Vendor manual updates
. ISI/IST ASME Section XI repair and replacement
- Procurement of replacement parts !
e Equipmecuparts Equiv2!ency Substitution including Commercial grade dedication
- Jumper, Lifted Lead, and Bypass Control l
e Temporary or Emergency Changes NCR & EWR (use as is) e Design and Lic. Basis Document change not associated with a Mod. '
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- Drawing Revision not associated with a Mod ,
e Document Control l l
The sample will be over and above what may be reviewed by the System Vertical Slice :
Review. The sample of work products or outputs will be chosen to provide, as l appropriate, a cross section of attributes such as discipline, (mechanical, electrical, i I&C, etc.), time frame in which the product was produced, and other characteristics which have been found by experience to be potential weakness,(e.g. numerous l l organizational interfaces, or past industry problems). Sample size and its rational will be proposed and submitted to the NRC for review and oversight. Sampling and l
reviews will be conducted in twc phases to ensure all CMP systems have been l
l considered. l The methodology, documentation requirements, depth of review, walkdown inspections, etc. for this program verification review is similar to what is described in the System Vertical Slice Review procedures except this review is focused on change -
1 processes instead of systems.
l 4.3.2.1 Preoare Review Checklist Review checklists will be developed specifically for the change control processes identified above. The checklists will serve to maintain inspection focus and to ensure a complete and thorough review. ,
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The checklists, incorporating the input of each inspector and the team leader, will be developed in a team environment to ensure maximizing the expertise of the entire 1
. group. The checklists will identify programmatic evaluation criteria, (i.e. quality assurance, regulatory, etc.) for each of the inspection areas and will utilize the SVSR source book for specific technical review criteria..
- PARSONS POWER -
Audit Plan Revision 2 4-21 June 27,1997 i
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l All documents in each of these categories will be screened for applicability Documents relating to certain programmatic areas such as security, fire protection, j environmental qualification, emergency response and planning and quality assurance will not be reviewed as part of the Regulatory Review. Specialists will be employed to review pertinent aspects of these programmatic areas to support detailed Tier reviews.. Additional details of the screening process are provided in Project Procedure PP-04, " Regulatory Review."
Each applicable document will be summarized. The summary will key on required licensee action. In addition, the licensee's docketed response or application as applicable will be reviewed and summarized. This summary of the response will focus on the licensee's commitments.
For each applicable document, a review of the current Updated Final Safety Analysis Report will be performed to determine if an FSAR change was required, and if required, whether the FSAR was updated as required by 10 CFR 50.71.
4.4.2 Commitment /Reauirement Verification Specific commitments identified during the Regulatory Review will be verified during the Millstone Unit 2 ICAVP. The verification will be performed within the System Vertical Slice Reviews (Tier 1), Accident Mitigation Systems Review (Tier 2), or Process Review (Tier 3), as appropriate. Summary and conclusions of the verification efforts will be provided in the Regulatory Review Report. -
4.4.3 Prepare Summary Report of Regulatory Review A report will be prepared summarizing the results of the Regulatory Review performed as part of the Millstone Unit 2 ICAVP. A summary will be provided for each set of documents listed in Section 4.4.1 included in the Regulatory Review. In addition, each of the completed Regulatory Review Summary Forms within the scope of the Tier reviews will be provided.
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O - PAR 80N8 POWER -
Audit Plan Revision 2 4-24 June 27,1997
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i l 4.5 ICAVP ACCEPTANCE CRITERIA
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Due to the complexity of the reviews conducted by the ICAVP and the wide breadth in -
l scope and potential severity of deficiencies th'an may be identified by the ICAVP; !
criteria can not be established that would fairly and adequately address all possible outcomes. The Parsons ICAVP Team will report all identified discrepancies to the NRC for evaluation. The discrepancy reporting process will also provide a brief description of the safety significance of each discrepancy. The NRC will evaluate l ICAVP discrepancies both individually and collectively and take appropriate action.
l The Pasons ICAVP Team will prepare a final report as well as individual reports for j each inspection tier when completed. Each of these reports will include a collective
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evaluation of discrepancies. The evaluation will assess consistency of design / licensing ,
p basis, adequacy of configuration control, and acceptability of NNECo corrective actions. ,
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L 4.6 PROJECT PROCEDURES & INSTRUCTIONS
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Project Procedures noted in Exhibit 4-7 and Parsons Power's Quality Program will be used to support implementation of this Audit Plan. Project procedures are required for major project audit activities (i.e., SVSR, Accident Mitigation System Review, Process Review, and Regulatory Review) and implementation of Audit Plan Requirements. Project Instructions are developed as required to supplement or provide clarifications for Project Procedures associated with major project inspection activities.
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[ Audit Plan Revision 2 i i
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- j 5.0 DISCREPANCY REPORTS i During the course of the Millstone Unit 2 ICAVP, any Team member may identify an apparent discrepancy and originate a Discrepancy Report (DR) in accordance with Project Procedure PP-07. A discrepancy is a condition, such as an error, omission, or oversight l which prevents consistence among the physical configuration, information sources (e.g.
documentation and data bases, design basis and/or regulatory requirements. The process for evaluation of Discrepancy Reports is presented in Exhibit 5-1.
5.1 IDENTIFICATION, EVALUATION AND REPORTING OF DISCREPANCIES l
All DRs will be evaluated by the responsible Group Lead, based on discussion with the Originator and other Team Members, as appropriate, to determine ifits basis is valid and to ensure that all known aspects of the Discrepancy are adequately described on the DR.
If the basis for the DR is determined not to be valid, the responsible Group Lead may close I
the DR. DRs for issues that are evaluated and found to have been identified previously by )
NNECo as part of their Configuration Management Plan shall be noted as such and closed l 1
following such evaluation. I p '
G After a DR has been evaluated by the responsible Group Lead, and reviewed by the Deputy Project Director, it will be forwarded to the Project Director for approval.. After l approval, the DR will be reported concurrently to the NRC, NEAC and NNECo in I accordance with the Communications Plan (PLN-02). DRs kill be posted on the Parsons World Wide Web page 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (2 working days) after reporting to NNECo, NEAC and the NRC. This includes DRs that were closed following a determination that the basis was not valid and for issues that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management Plan.
l 5.2 REVIEW OF PROPOSED RESPONSE TO DISCREPANCIES i
Proposed corrective action by NNECo in response to a DR will be forwarded to the ICAVP Group Leader responsible for validating the DR. The ICAVP Group Leader will l prepare comments on the proposed corrective action. Once comments on the proposed I resolution have been approved they are forwarded to the NRC, NNECo and NEAC. A s
,O - PARSONS POWER -
\, Audit Plan Revision 2 5-1 f June 27,1997 I
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Exhibit 5-1 -DiscrepancyReports Communication Plan U
Approved DR m issue issued DR m Reviewed DR m m
E Review Basis Invalid DR E Approve ICAVP Basis invalid DR E Discrepancy Issued Comment E ICAVP Approved Comment oC Activities Closed DR C Report Closed DR C l h Activities NNECo Response Proj. Suppo Dep. Proj. Dib Proj. dim World Wide Web DR Basis Invalid DR Comment on NNECo Resnonse t^ E
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" Perform Proposed NNEco DR Corrective Action Tiu 1 '
Activities 3 NNEco CMP + Validate /
" ^ l > Evaluate Perfonn Discrepancy Report, (DR) m Discrepancy Tier 2
- w/ Description & Safety Significance ^ Report, (DR)
Activities Group Lead (s)g TeamMembers Perfonn y Tier 3 S Activities
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$I Lh Perform Regulatory workinz Ouestion w/ Basis m
Assign Tracking #
Working Ouestion w/ Basis + a Tracking #"
m Discrepancy s
$0 Review & Tracking Data Base Proj. Support Closed DR
. _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _