ML20141E763
| ML20141E763 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/26/1997 |
| From: | Curry D, Hilbish J External (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20141E632 | List: |
| References | |
| PP-07, PP-7, NUDOCS 9707010156 | |
| Download: ML20141E763 (11) | |
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i MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES i
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Discrepancy Reports 1
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REVISION HISTORY REVISION DATE REVISION DESCRIPTION O
04/03/97 Procedure initiation 1
06/09/97 incorporation of initial NRC Comments 2
06/26/97 incorporate NRC Comments i O 2
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MILLSTONE UNIT 2 ICAVP PP-07 PROJECT PROCEDURES
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TITLE:
DISCREPANCY REPORTS REVISION: 2 DATE: 06/26/97 PAGE 2 OF 11 LIST OF EFFECTIVE PAGES Page &
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TABLE OF CONTENTS 1.0 PURPOSE...............................................................................................................2
- 2. 0 RE FE RE N C E S....................................................................................................... 3 3.0 D E FIN ITI O N S....................................................................................................... 3
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4.0 RES P O N S in It1T1E S............................................................................................. 4 5.0 PROCEDURE........................................................................................................5 5.1 ID ENTI F1 CATI ON O F DIS CREPANCIES........................'.................................... 5 5.2 EVALUATION...........................................................................................................,6 5.3 REVI EW, AP PROVAL AN D FO RWARDING........................................................ 6 5.4 REVIEW OF PROPOSED CORRECTIVE ACTION............................................. 7 5.5 FI N A L RE S O L U TI O N.............................................................................................. 8 ATTACIIMENT I DISCREPANCY REPORT.......................................................... 8 EXHIBIT 1 EVALUATION OF DISCREPANCIES................................................. I 1 0
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MILLSTONE UNIT 2 ICAVP PP-07 M
PROJECT PP.OOEDURES i
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DISCREPANCY REPORTS l
V REVISION: 2 DATE: 06/26/97 PAGE 3 OF 11 1.0 PURPOSE Re purpose of this Project Procedure is to provide guidance and instructions for the initiation, evaluation, submittal and closure of Discrepancy Reports (DR) initiated for apparent discrepancies identified during the conduct of the Millstone Unit 2 Independent l
Corrective Action Verification Program (ICAVP).
2.0 REFERENCES
2.1 NRC Confirmatory Order dated August 14,1996 establishing an Independent Corrective Action Verification Program (ICAVP) 2.2 Audit Plan, Millstone Unit 2 Independent Corrective Action Verification Program O) 2.3 Communication Plan, PLN-02, Millstone Unit 2 Independent Corrective Action Verification Program 3.0 DEFINITIONS 3.1 ICAVP - Independent Corrective Action Verification Program established by Reference 2.1 to verify the adequacy of Northeast Utilities' (NU) efforts to establish adequate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications since issuance of the initid facility operating license.
3.2 Discrepancy Report (DR) - The mechanism for documenting an apparent discrepancy identified during the Millstone Unit 2 ICAVP.
3.2 Discrepancy - A condition, such as an error, omission, or oversight which prevents consistence among the physicsl configuration, infonnation sources (e.g. documentation and databases), design basis and/or regulatory requirements.
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3.3 Design Bases - Information that identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) l restraints derived from generally accepted state-of-the-art practices for achieving functional goals or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals.'
l 3.4 Originator - An ICAVP Team Member who identiSes an apparent Discrepancy.
4.0 RESPONSIBILITIES 4.1 Project Director - Responsible for approval of DRs prior to concurrent reporting to NNECo, NEAC, and the NRC in accordance with the Communications Plan (PLN-02).
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4.2 Deputy Project Director - Responsible for:
review of DRs to ensure completeness and clarity and to identify possible a
duplications of existing DRs; forwarding DRs to the Project Director for approval; ensuring tracking and e
monitoring of DRs; approval ofICAVP Team comments concerning proposed corrective actions by e
Northeast Nuclear Energy Company (NNECo).
4.3 ICAVP Group Leader - Responsible for:
evaluating DRs originated within his group; e
validating their bases; closing those for which the bases are found to be invalid; i
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' 10 CFR Part 50, Paragraph 50.2 l
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M MILLSTONE UNIT 2 ICAVP PP-07 E
1 PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS i
REVISION: 1 DATE: 06/09/97 PAGE 5 OF 11 commenting on the proposed resolution by NNECo.
e 4.4 Originator - Responsible for documenting in accordance with this procedure any apparent Discrepancy identified during the conduct of the Millstone Unit 2 ICAVP. The Originator additionally may be asked by the ICAVP Group Leader to provide comments on the proposed resolution by NNECo.
5.0 PROCEDURE 5.1 IDENTIFICATION OF DISCREPANCIES 5.1.1 During the course of the Millstone Unit 2 ICAVP, anyTeam member may identify an apparent Discrepancy and originate a Discrepancy Report (DR) (Attachment 2). Further evaluation by the ICAVP Team may be required to cen6rm the basis for the Discrepancy, p) as documented on the DR form. The DR process is depicted in Exhibit 1.
g 5.1.2 The Originator will obtain a DR Log number from the Project Admmistrator. The following information, as a minimum, will be recorded for all DRs for tracking purposes:
DR number Date e
Title NNECo response date Response / resolution review date e
5.1.3 The Originator will ensure that the Initiation portion of the DR form is filled out as completely as possible, including, as applicable, a description of the discrepancy, system or process name, procedure name and number, drawing name and number, affected i
j engineering discipline, and source authority or reference used to identify the discrepancy.
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l 5.1.4 The Originator should additionally provide a brief one to two sentence description of the safety significance of the identified discrepancy on Form PP-07-1. Evaluation of discrepancies to the formal NRC reporting requirements is the responsibility of NNECo.
5.1.5 The Originatar will sign the fonn, and forward it to the Group Lead for evaluation.
S.2 EVALUATION 5.2.1 The DR will be evaluated by the responsible Group Lead, based on discussion with the Originator r.nd 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.
5.2.2 If the basis for the DR is determined not to be valid, the responsible Group Lead may close j
the DR.
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5.2.3 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 following such evaluation.
5.2.4 The respcnsible Group Lead will record the results of the evaluation on the DR form, check the appropriate box (es), sign the form and fonvard it to the Deputy Project Director.
5.3 REVIEW, APPROVAL AND FORWARDING 5.3.1 After a DR has been evaluated by the responsible Group Lead, it will be fonvarded to the Deputy Project Director for review. Following that, the DR will be forwarded to the Project Director for approval. After approval, the DR will be reported concurrently to the NRC, NEAC, and NNECo in accordance with the Reference 2.3. The approval and forwarding of a Discrepancy Report is documented on the DR form (Attachment 1).
5.3.2 DRs will be posted on the World Wide Web in accordance with Reference 2.3. DRs will be reported 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 n
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i REVISION: 1 DATE: 06/09/97 PAGE 7 OF 11 reporting the DRs to NNECo, NEAC, and the NRC. His includes DRs that were closed following a deternunation that the basis was not valid and for DRs that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management Plan.
5.3.3 Questions that arise during the review or approval of DRs will be resolved by the Deputy Project Director following discussions with the Group Lead and Originator, as necessary.
5.4 REVIEW OF PROPOSED CORRECTIVE ACTION 5.4.1 Proposed corrective action by NNECo in response to a DR will be forwarded to the ICAVP Group Leader responsible for evaluating the DR.
5.4.2 The ICAVP Group Leader will prepare conunents on the proposed corrective action, p}
consulting with the originator, as necessary, to ensure the proposed resolution correlates to the original concern. Comments should focus on the perceived adequacy of the proposed action to resolve the discrepancy and prevent recurrence, consistent with the purpose of the ICAVP (refer to Definition 3.1 and Reference 2.2). Comments on the NNECo response will be documented on the DR form.
5.4.3 A copy of the proposed corrective action will be sent to the Originator after approval.
5.4.4 The ICAVP Group Leader will forward the DR to the Deputy Project Director for resiew.
prior to releasing the comments per Reference 2.3.
5.4.5 The ICAVP Project Director will approve comments and forward comments to the NNECo, NEAC, and the NRC per the Communications Plan (PLN-02).
5.4.6 A summary of the NNECo response and approved comments will be posted on the WWW per the Communications Plan (PLN-02).
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REVISION: 1 DATE: 06/09/97 PAGE 8 OF 11 5.5 FINAL RESOLUTION j
5.4.1 If the proposed corrective action by NNECo will resolve the Discrepancy, the Deputy i
l Project Director will close the DR by signing the Final Resolution section.
l 5.4.2 If, in the opinion of the ICAVP Team, the proposed corrective action by NNECo is not i
hkely to resolve the Discrepancy, the Deputy Project Director will identify the DR as an open item.
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TITLE:
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REVISION: 2 DATE: 06/26/97 PAGE 9 OF 11 ATTACHMENT 1 DISCREPANCY REPORT DISCREPANCY TITLE DR Log Number DISCREPANCY Include System / Process Name, Procedure / Drawing Name/ Number, (Attach additional documentation as necessary)
Description of Safety Significance Provide a briefDescription ofthe safety sigmjicance ofthe identified DR O'v Originator Group Date EVALUATION Validation ofbasisfor Discrepancy or Closure ifnot valid (Attach documentation as necessary)
Osasis valia Osasis Invalid - Closed OPreviously Identified by NNECo - Closed Group Lead Date REVIEW AND APPROVAL 1
. Reviewed:
Dep. Proj, Director Date i
Approved:
Project Director Date l
Fwd'd to NNECo, NEAC, and NRC:
Posted to WWW Date Date
S MILLSTOi4E UNIT 2 ICAVP PP-07 l
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TITLE:
DISCREPANCY REPORTS REVISION: 2 DATE: 06/26/97 PAGE to OF 11 ATTACHMENT 1 DISCREPANCY REPORT PAGE 2 DR Log Number SUMstARY OF NNECO PROPOSED CORRECTIVE ACTION:
COMMENT ON NNECO RESPONSE:
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Group Lead Date Reviewed:
Dep. Proj. Director Date Approved:
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Fwd'd to NNECo, NEAC, and NRC:
Posted to WWW Date Date FINAL RESOLUTION Dep. Proj. Dir.
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1 REVISION: 2 DATE: 06/27/97 PAGE 11 OF 11 J
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m Review Basis Invalid DR E Approve ICAVP Basis Invalid DR E Discrepancy issued Comment E
ICAVP Aorreved Co nment cC Activities Closed DR E
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Discrepancy Review Tracking Data Base N
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