ML20147H704

Independent Corrective Action Verification Program for Millstone Unit 3, Project Manual

ML20147H704
Person / Time
Site:	Millstone
Issue date:	03/06/1997
From:	Neri A, Querio R, Raheja R SARGENT & LUNDY, INC.
To:
Shared Package
ML20147H030	List: ML20147H025 ML20147H035 ML20147H704
References
PROC-970306, NUDOCS 9704080009
Download: ML20147H704 (150)

Text

.. . -. _ _. . _ . - . - _ _.

f

/+

. e .,g m:m

' .,j.y o%, ~

, Sar gens g.- u L u n d y c

' kix. f,w Rif^

,1

! INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM e

i FOR 4

. s MILLSTONE Ux1T 3 c

(

. Project Mantial; ..

v Y

$8 p' ,

y u f ' T * * *<

f

^

/>

'~

l -

5w .

7 e yl 4 + '

n.y. .. . hh ro n nn , . >

+>

< s' s-~ h;?% >

W . .. N$

qan

+ '

• r- , ., 4 ', rwy y a c/ >

' " ^ $ijisd.u d;

', l2?

4 4 s >

I ', ' * ^ .

y, >,

[< f2 1 f

hl',$., % h,':J.@l 'h'!b by ghU

+

" * ". .* 4 -% ; h %o l ln :'< >

y w a :',

i A& -

g. p ;;ly,g q ) % mimy%

>>, $'v .;-

') ~

, >s r ')

5 a >

• r .

9 9 S

o ^- ' / 5 4 {f44 y

N5 n .,1 k }Yi% t!> , <:l s fe' 0.> <s,

-m >

, .,. ,< , o

/ 5 w \ 4 i

p bh

???E8sE88"gh5 p __

w, . J@ -

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

La us v"'

U 1

i AUDIT PLAN FOR INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM (ICAVP)

NORTHEAST UTILITIES MILLSTONE UNrr 3 PROJECT NO. 9583-100 Prepared by: v M/ bf t3 d 7 R. D.laheja l/ ' Dafe Accident Mitigation Review Group Lead

.l #A' R. Querio Date Operations & Maintenance & Testing Review Group Lead M

ex G/6/97 ~~

A. A. Neri u Date System Review Group Lead 3 f77 T.#ftya[ D'atl Programmatic Review Group Lead Approved by: W A. K.' Singh Wb[97 Date IRC Chairman O  %.T __

m , -

3 -6~9 7 D. K. Sclippfer i Date Verification Team Manager ]

(1) l

, Nortbest Utilities "~

ICAVP Audit Plan Millstone Unit 3 1

1.0 OBJECTIVE The objective of this project is to implement an Independent Corrective Action Verification Program (ICAVP) at Northeast Utilities Millstone - Unit 3 in accordance with the Nuclear Regulatory Commission's (NRC) August 14,1996 1

) con 6rmatory order. The ICAVP will be an independent verification of the adequacy of results of the Configuration Management Plan (CMP) currently being

' implemented by Northeast Utilities which is directed at resolving existing design

' and configuration management deficiencies. The ICAVP will provide independent verification that, for selected systems, Northeast Utilities' CMP has identified and resolved existing problems, documented and utilized licensing and design bases, and established programs, processes and procedures for effective configuration management in the future. The ICAVP will be comprehensive, incorporating all of the appropriate engineering disciplines, such that the NRC can be con 6 dent that Northeast Utilities has been thorough in identification and resolution of problems.

The ICAVP review will be conducted independently of Northeast Utilities and its design contractors.

2.0 SCOPE OF WORK The scope ofwork for the ICAVP as described in the NRC's August 14,1996 confirmatory order to Northeast Utilities includes:

1 i

a. A review of engineering and design control processes, i

b. verification of current as modified plant conditions against design bases and licensing bases documentation. l

c. veriScation that design and licensing bases requirements are translated into l operating procedures and maintenance and testing procedures,

d. verification of system performance through review of specific test records and/or observation of selected testing ofparticular systems, and l

e. review ofproposed and implemented corrective actions for design deficiencies identified by Northeast Utilities.

The NRC's December 19,1996 oversight inspection plan provides further direction on the scope of the ICAVP. In addition to the above items, the oversight p inspection further requires a review of accident mitigation systems that assesses the V

(2)

l Nortbest Utilities A"~

f ICAVP Audit Plan TO Millstone Unit 3 U

l critical design characteristics to ensure that these systems and components can perform their speci6ed safety functions.

S&L will implement the above scope of work as follows:

a. The review of engineering and design control processes will consist of an assesstrant ofNortheast Utilities change process procedures as well as a review of all plant modifications to the systems selected for a vertical slice review by the ICAVP that were prepared after issuance of the operating license. The review of the modifications will include:

• A technical review of the changes contained in the modification packages to system specific analysis and output documents and to topical engineering programs.

Verification that current design output documents have incorporated 77 the changes identified in the modification packages.

U e Verification that current system operating, maintenance, testing and training procedures adequately reflect the modifications.

• Verification that the physical installation conforms with the modification package.

1

• Verification that the post modification test procedure and test results demonstrate the system is capable of performing its function.

• Verification that no unreviewed safety question exists for the l modification as documented inthe 50.59 safety evaluation.

1 i

b. The verification ofcurrent as modified plant conditions against the design bases and licensing bases will include:

e Review ofcalculations, analysis, specifications aid design output I documents for consistency and for conformance with the design and l l licensing bases. I gm . A p'1ysical walkdown </ the system to verify conformance with the

() design output documents.

1 (3) 1 l

1 Nortbest Utilities " " '

ICAVP Audit Plan Millstone Unit 3 ,

i i

6 i

c. The veri 6 cation that the design and licensing bases are translated into 1

)

{ operating, maintenance and testing procedures will include a cross-check of

!' i functional and performance requirements identified in the licensing and

! {

design bases versus those identified in the operating, maintenance, testing  ;

l' f

and training procedures.

i

1 j d. The veri 6 cation of system performance will be accomplished through a j review of specific test records for recently completed surveillance and post  ;

j modification functional tests. '

! e. The review ofproposed and implemented corrective actions for

'I deficiencies identified by Northeast Utilities during the CMP will include a review of all corrective actions for systems selected for a vertical slice ,

[ review by the ICAVP and a review of randomly selected corrective actions for systems outside the scope of the vertical slice review.

)

{ >

4 i

f. The review of the accident mitigation systems will include an assessment of l the critical design characteristics to ensure that the systems and components can perform their specified safety functions.

I l

3.0 PROJECTORGANIZATION The organizational structure wil? facilitate both the internal and external interfaces 1-of the Project Team. Exhibit I shows the project organization. This section describes how the organization will function and the expected interfaces. The

', roles and responsibilities of the different parts of the organization are provided.

3.1 Management Team i

The Sargent & Lundy management team for this project is comprised of 2

the Project Director, Bryan Erler, the Verification Team (VT) Manager, Don Schopfer; and the Chainnan of the Internal Review Committee, A. K.

Singh. They are collectively responsible for ensuring that the project is

{ properly planne! ed unplemented, that it meets the requirements of the MC Confirmatory Order, and that the process and the results are open and credible to the 6RC and the public.

O The Project Director will have the overall responsibility for Sargent &

Lundy's performance for the work. He will be responsible for facilitatmg

~

(4)

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

I .

I Nortbest Utilities " #"

ICAVP Audit Plan Millstone Unit 3 ,

}

l n

a 4

the resolution of any differences between the VT Manager and the Internal Review Committee. The Project Director will be the primary external

{ spokesman fbr the ICAVP Team and will meet with and report to the ICAVP Oversight Team (IOT), NRC, and Northeast Utilities as required i

! and as allowed by the approved protocol. He will be available to the press, 1

the media, and the public when requested by the NRC and NU. The j Project Director will also be signatory to the final report produced by the j ICAVP Team. 1 T

i The VT Manager will be responsible for directing the development of and

approving the plans and procedures for implementing the review, including reconmended system selection criteria and the protocol covering comrnnications between Sargent & Lundy project personnel and the other j orgamzations. He will manage the work through the technical leads on the VT. He will be responsible for reviewing the findings produced by the VT,

and, upon acceptance, submitting them to the Internal Review Committee.

He may also retum them to the VT Leads for additional information or further review. The VT Manager will be responsible for distributing the O findmgs, including posting them on the electronic bulletin board as established in the approved protocol after acceptance of the findings by l IRC. Similarly, the VT Manager will review, accept and distribute / post the

VT's evaluation of the NU responses to the findings. He will be j responsible for preparing the final report documenting the work of the VT, i l The VT Manager will also serve as the backup for the Project Director l

vf respect to communication with the IOT, NRC, and NU when 3 necessary. l The Chairman of the Intemal Review Committee will be responsible for i coordinating the activities ofthat group. The roles and responsibilities of ]

the Internal Review Committee is provided later in this section of the audit  !

[ plan. The IRC Chairman will also make himself available to the IOT, NRC,  !

i and NU when reqbeste.  !

3.2 Verification Team The VT is the core of the organization and is the group that does the actual review of the design and licensing bases and the effectiveness of the NU j corrective actions. The VT is organized into fou; functional subgroups.

Each subgroup will be headed by a Lead engineer and will be responwbie

for a portion of the overall verification program. There will be a System i Review Group (SRG), a Programmatic Review Group (PRG), an l

4

, (5) 1

Nodhest Utilities ICAVP Audit Plan Millstone Unit 3

{

l i

Operations and Maintenance and Testing Review Group (ORG), and an l Accident Mitigation Systems Group (ARG).

The SRG will perform the in-depth review of the selected systems. This i group will review the current system output documents and analysis to i vedfy conformance with the design and licensing bases. The SRG will also j review design modifications to the seixted systems made since receipt of ,

the OL, focusing on the validity of the design process, identification of system interface requirements, potential synergistic effects of the

)

l modifications, and appropriate design document controls.  :

The SRG will also be responsible for vedfying iist the current, as-built condition of the plant matches the current design output documents. This task includes physical and functional walkdowns of the selected systems i and will be performed by the Physical Configurttion Review subgroup (CRG) of the SRG. .J l

The ORG will be responsible for reviewing system operating procedures, l surveillance procedures, maintenance procedures, and training documents to confirm that the design bases and any changes made to the design bases l

have been translated correctly into these documents. This group will also confirm that current testing requirements and post modification testing requirements are adequate to verify system performance.

l The ARG group will be responsible for reviewing the accident analysis  !

contained in the FSAR to determine the accident mitigation systems and their critical design characteristics. The ARG will then review the accident L mitigation systems and their critical characteristics to ensure the systems can perform their safety functions specified to .~.4; ate the FSAR accident scenarios.

The PRG group will be responsible for the review of select NU processes for changing the facility design and for changing characteristics, i procedures, or practices for maintaining, operating, testing, and training to I ensure the adequacy of the change process. The PRG will also be I

responsible for the review ofNU's corrective actions resulting from their '

i configuration management plan review. This review will determine the adequscy of the corrective actions.

iO (6)

}~

/ ,

Nortbest Utilities W "'

ICAVP Audit Plan

Millstone Unit 3 1

3.3

[ Role of the Internal Review Committee The Internal Review Committee will provide a Sargent & Lundy j

management technical oversight role. It will also help to provide i

! consistency in the review results. It will be comprised of four very senior j {

personnel within the organization that have specialized expertise in the j

areas being reviewed. The IRC Chairman will be responsible for obtaining

)

t the IRC's review of the planning documents and procedures for performing j the verification program. This includes the audit plan, the protocol, and the j individual procedures required for the work. The IRC will review the 6ndings of the VT for extent and for significance. They will also review the responses by NU after they have been accepted by the VT. The IRC may also make specific recommendations regarding the scope or methodology of the verification process as the work progresses. The IRC will also review the final report of the ICAVP.

3.4 ICAVP Oversight Team O The establishment of an executive oversight team for the ICAVP will add i

to the NRC's and the public's confidence that the process and the results of the verification program were in accordance with NRC's Confirmatory Order. The ICAVP Oversight Team (IOT) will oversee and monitor the project team's activities. The IOT will be provided with the key process l documents such as the confirmatory order, oversight inspection plan, audit i plan, the protocol, the key procedures, and the recommended system selection criteria. The members of the IOT will include a person from the l

local public sector with a strong technical background, a person with  ;

former experience in nuclear power reactor regulation, a current or former executive (s) from a utility with an acknowledged excellent nuclear program, and one or more executives from Sargent & Lundy who are not directlyinvolved with theICAVP.

1 The ICAVP Management Team will provide periodic technical briefings to the IOT on a monthly or more frequent bases, depending on the activities of the ICAVP project team. The purpose of these briefings will be to allow the IOT observe the process and examine the types of technical decision making by ICAVP project team. Input and guidance from the IOT will be  ;

accepted, considered, and factored into the program, as applicable. The O IOT members will be permitted to attend all meetings between the ICAVP Project Team, NU, and the NRC.

(7)  ;

Nortbest Utilities ""

ICAVP Auclit Plan Millstone Unit 3 ,

i The IOT will document their evaluation of the ICAV4 v>ons and results by preparing a briefreport which summarizes ineir c. ; >asions. This report will be included in the final overall ICAVP report. If requested, the IOT willin efthe NRC on its efforts.

4.0 METHODOLOGY This section of the audit plan describes the methodology S&L will use to implement the ICAVP. Exhibit 2 depicts the review uocess. In general, the ICAVP will consist of the following tasks:

l e Document Gathering e System Review e Physical Walkdowns e Operation, Maintenance and Testing Procedure Review ,

e Accident Mitigation System Review I

/ e Programmatic Reviews e Processing VT Findings e  !

Review ofNU Resolutions 1

. Issuing Final Report 4.1. Document Gathering The first step in the ICAVP review process will be to gather the licensing and design bases documents, procedures, design process documents and design output documents needed to perform the review. The following top level controlled documents have been obtained and are stored in both the l S&L Chicago office and the local offsite office:

1 i

e Configuration Management Program e Design Control Process Procedures e Current FSAR e FSAR at O/L e SER and allrevisions e 10 CFR 50.59 Safety Evaluation Procedure e Procedures for and System Specific Assessments e Corrective Action Procedures O

e List or database officensing commitments e Description ofdocument system and hiert.rchy system  ;

l (8)

Nortbest Utilities ICAVP Audit Plan Millstone Unit 3 /

O e List of all modifications designed since receipt of O/L for Maintenance Rule Category 1 and 2 system, sorted by primaiy affected system, including the organization responsible for the design e Complete index of the Unit 3 controlled documents, including calculations and drawings e Complete index of the procedure system for Unit 3, including corporate / administrative procedures, engineering procedures, maintenance procedures, and operating procedures including emergency opereting procedures

• Complete listing of Adverse Condition Reports, sorted by system Documents describing specific engineering programs that may not be included in the above listing, such as MOV program, ISI/IST program etc.

• NRC inspection reports, QA audit reports and the NU responses to them The following system specific documents for the systems chosen for review O will be requested in accordance with the protocol outlined in PI-MP3-01.

• Engineering Calculations (Mech, Elect, Struct, I&C and Piping Analysis) e Equipment Procurement Specifications e Modification Packages e System Descriptions e Equipment List e Environmental and Seismic Qualification Reports e P& ids e Logic Drawings e Electrical Schematics e Piping Drawings

• Electrical Single Line Drawings e PanelWiring Drawings e Cable Routing Drawings and Databases e Pipe Support Drawings e Structural Equipment Mounting Details e General Arrangement / Equipment Location Drawings e Instrument Location Drawings O e Zone Maps (Environment / Fire Protection, etc).

Operating Procedures including Emergency Operating Procedures (9)

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

I i

Nortbest Utilities '"" ICAVP Audit Plan I A Millstone Unit 3 ,

l iV ,

! l I e Maintenance Procedures  !

• Surveillance Test Procedures i e Vendor Manuals

• System Training Procedures  !

I i 4.2 System Reviews .

l The vertical slice system reviews will be performed by the SRG in a

accordance with PI-MP3-02 and 03. System reviews will focus on two

{

objectives,1) to verify the system design elements being reviewed are ,

3 technically adequate and consistent with the licensing and design bases (PI-  ;

{ MP3-02) and 2) to verify the modifications implemented after receipt of the -l

! operating license are technically adequate and that configuration control of  !

l design documents was maintained (PI-MP3-03). 1 i-The first step of the process is to review the licensing and design bases l documentation to identify the functional, design, performance, operational l and testing requirements of the system. These requirements will be  ;

O- individually tabulated on a system requirements checklist. This checklist will be used by the SRG and ORG as the bau for verifying design conformance to the design and licensing bases Following the development of the system requirements checklists, the SRG will perform the three reviews described below. The purpose of these reviews is to determine how the design meets the functional and performance requirunents of the system and to ensure consistency between the various design output documents and design process documents.

These three reviewsinclude:

a. A review of design process documents to verify the technical adequacy of each document and its confornance to the design and licensing bases. This review will include mechanical, electrical, I&C, and stmetural calculations, piping analysis and equipment EQ/SQ repons.

b. An upper tier drawing review including P& ids, electrical schenatics and logic diagrams to verify the system design is capable of performing the functional requirements described in the design and licensing bases and to verify the drawings are consistent with the 64;n process documents.

(10)

L jO Nortbest Utilities - " D "" ICAVP Audit Plan Millstone Unit 3 /

!O 4

i

c. A component review to verify consistency between the licensing and design bases documents and the design output documents such as, component specifications, system calculations, and vendor component drawings.

Once the reviews are completed, the SRG will enter on the systems requirements checklist how each of the design, functional and performance requirements is satisfied. The ORG will complete the portion of the checklist relative to operating and testing requirements.

The next step will be to review the plant modifications issued aAer receipt of the operating license Each modification will first be screened to identify the lead discipline (mechanical, electrical or IAC). A lead verifier from the affected design discipline will then perform a modification screening process to identify which design elements are affected by the modification.

The lead verifier will complete a checklist consisting of general questions to facilitate the determination of which design elements are affected by the modification. The design elements that will be screened include:

%)

a. MechanicalDesign

b. ElectricalDesign

c. I&C Design

d. Structural Design

e. ALARA Design .

f. . Security

g. Appendix R Compliance

h. Electrical Equipment Qualification

i. Seismic Qualification

j. Radiological Environment

k. Non-Radiological Environment

1. Station Blackout

m. Control Panel Design

n. Piping Design

o. Setpoint Database

p. Hazards /HELB Program

q. Fire Protection

r. Licensing Review

s. PRA

t. Training Procedures O u.

v.

Plant Procedures (OPS, Maintenance, Surveillance)

Configuration Change Review (11)

O Nortbest Utilities Millstone Unit 3

- "~f W "" ICAVP Audit Plan .

V

w. Quality Software Design Review For each design element that is affected, a VT member with the appropriate technical background will perform a detailed review to verify that the design element was adequately addressed in the modification. This review will verify the technical adequacy of calculations, specifications and design documents impacted by the modifications. All reviews will be performed by the SRG with the exception ofItems t and u which will be performed by the ORG.

The SRG will then perform a detailed review of the changes to licensing documents that were generated for each modification to ensure the changes are adequately incorporated into the FSAR, Teck cal Specifications, etc. The SRG will also review the 10 CFR 50.59 safety evaluation prepared for each modi 6 cation to ensure the unreviewed safety question determination was thorough and well documented.

Finally, the SRG will review the installation and testing requirements including acceptance test criteria to determine that appropriate installation and testing requirements were specified. The ORG will be responsible for verifying that satisfactory post- moddication testing was implemented.

4.3 . Physical Conbration Review The physical configuration review will be performed by the CRG in accordance with PI-MP3-05. This review will focus on verifying the current as built condition of the plant matches the current design documents. This group will perform a physical and functional walkdown of the systems in the scope vertical slice review. This group will also review plant modifications implemented after issuance of the OL to verify the as built condition conforms to the modification documents and to verify the modification documents have been accurately incorporated into the affected design drawings or are posted against the affected design drawings. The walkdown ofsystem modifications will be a more in-depth walkdown than the system functional walkdown described above. Key critical dimensions such as analysis / calculation bases and/or dimensional restrictions identified on drawings will be verified during the modification walkdowns.

O After retrieving the system design drawings and outstanding changes, the CRG will create a set of walkdown documents by redlining the open (12)

' Nortbest Utilities ""

ICAVP Audit Plan Millstone Unit 3 I

amendments onto the physical drawings. The CRG will then perform a }

review of the lower tier drawings such as piping drawings, wiring diagrams, etc., to verify conformance to the upper tier P& ids and schematics. This review is required to ensure the lower tier h=aats being used for con 6guration walkdowns are functionally in agreement with the upper tier documents that are checked for technical accuracy by the SRG. The SRG as part of their calculation reviews will also verify calculations such as stress reports and lower tier drawings such a piping isometrics are in conformance. Discrepancies identified by the SRG in this area will be communicated to the CRG. This review is not intended to be a line by line review of the lower tier documents, but only a functional check.

Prior to performing the walkdowns, the CRG will identify system boundaries on the walkdown drawings.' These boundaries will be reviewed with the SRG for consistency in the scope for the two groups.

The next step will be to perform physical plant walkdowns of the systems.

The walkdown will check the following attributes:

O. a. System component location and id ,2-Mi;on are as indicated on the P& ids and other schematic type documents.

b. Component nameplate data is consistent with compo.smt specifications and drawings. I

c. System components are not physically damaged.

l;

d. System configuration is functionally consistent with design output documents byverifying:  !

e Line size e Configuration ofpiping including number and location of l bends, location ofvalves, supports and other in-line components  !

Valve orientation and flow direction

• Pipe support type and configuration

• Equipment and instnnnentation mounting details

• Configuration of conduit and tray routing

• Cable"To and From" routings

• Conduit and cable size 1

(13)

i Nortbest Utilities ""

ICAVP Audit Plan a

pY Millstone Unit 3 /

i e Conduit and tray support type and con 6guration

, . Tubing / electrical con 6guration to instruments

! e HVAC ductwork size and routing i

e. Divisional trains of the system are physically separated by barriers

and or distance. Electrical separation will be checked by verifying

! cable is routed through applicable divisional raceway, i

t

f. Portions of the system which are not safety related have been designed to H/I seismic requirements.

1 l As stated previously, this walkdown is not intended to check all dimensions, but is merely intended to be a functional verification.

The CRG will also perform a review of the modifications identi6ed by the SRG as impacting system configuration drawings. The SRG will provide / identify drawing changes resulting from system modifications.

Upon receipt of this data, the CRG shall first review the drawing changes

{ to ensure they are either incorporated into the current drawings or are

! identi6ed as open amendments against the drawings. The CRG will then j perfonn a detailed walkdown of the modified area. This walkdown will include a check of critical dimensions in addition to the other walkdown 1-attributes described above for the functional walkdown.

j 4.4 Operation & Maintenance and Testina Review I-The operating & maintenance and testing review will be performed by the

[ ORG in accordance with PI-MP3-06. This review will focus on verifying i that the system operating procedures, maintenance procedures, surveillance i procedures and training documents conform to the systems design and licensing bases. This group will also review the post modification tests  !

performed following the installation of plant modi 6 cations to the system to i verify the testing was adequate to maintain the design and hcensmg bases.

i i.

Upon receipt of the system requirements checklists from the SRG, the 4

ORG will perform a review to verify the following:

i- ,

e a. The operating procedures are in conformance with the systems i j functional requirements described in the Licensing and Design  ;

Bases. This review will include all modes of system operation c l

! (14)  !

4

,e - -- -nm- -

Northest Utilities "~

ICAVP Audit Plan ,

Millstone Unit 3 l including normal, abnormal and emergency system operations. This review willinclude:

a.1 Review of the operating procedures against the system P& ids.

I t

a.2 Verification that instrumentation and controls described m l the procedure are consistent with the installed condition.

a3 Verification that procedures for support systems are adequate to support the operation of the system.

a.4 Verification that manual operator actions can be performed under accident conditions.

b. The maintenance procedures are in confornumce with the maintenance requirements described in the Licensing and Design Bases. The review will:

O . b.1 Verify that maintenance procedures and vendor manuals exist for key system components.

b.2 Check the maintenance procedures for technical adequacy.

b3 Review a sampling of vendor manuals, generic communications (i.e., Bulletin, Information Notices, Generic Letters, NSSS Techincal Bulletins) and verify applicable items have been implemented into the maintenance program. j i

b.4 Review component history files to identify recumng l equipment problems and determine if any trends exist. l I

b.5 Review past maintenance activities and verify technical adequacy, performance of the appropriate post maintenance l testing, and satisfactory demonstration ofequipment  ;

operability. l

c. The review will verify that test procedures and surveillance

(~ procedures are in conformance with the Design and Licensing )

\

Bases. The review will focus on the following: l 1

(15) l

Nortbest Utilities ""

ICAVP Audit Plan Millstone Unit 3 c.1 Review the technical adequacy of Technical Specification

. Surveillance Test Procedures and verification of the adequacy of a sampling of test results completed within the last two years.

c.2 Verify the system tests adequately ensure the system will operate as intended under postulated conditions.

c.3 Determine ifsurveillance test procedures comprehensively  ;

address system responses addressed in the licens*mg bases.

I Upon completion of the above reviews, the ORG will complete the system  ;

requirements checklist to document how the Licensing and Design Bases

}

requirements related to Operation & Maintenance and Testing are satisfied.

l The ORG will also review plant modifications implemented after issuance of the Operating Licensing. As stated in Section 4.2 of this audit plan, the j SRG screening pt ocess will determine if plant modifications affect the operation, maintenance or inspection requirements of a system. When affected, the ORG will evaluate the modification to identify the requirerl changes. The ORG will then review the operating, maintenance and tening i procedures to verify the changes due to the modification have been reflected in the procedures. Additionally, the ORG will review the post modification test results for each modification to verify the adequacy of the test results.

4.5 Accident Mitiaation Systems Review The process discussed in this section will be used by the ARG to develop the critical parameters for the accident mitigation systems. This process shall be implemented in accordance with PI-MP3-07.

The ARG Lead and Verifiers will review the initiating events in the FSAR, as they apply to Millstone Unit 3 and identify the accident mitigating systems and components within the system. The reload analysis and the FSAR shall be used to identify the specific critical parameters which are required to mitigate the event. As a result of this review, the ARG Lead will create a database consisting of the following items: a) Analyzed Accidents, b) Mitigating Systems, c) Components, d) Critical Parameters O and c) References to the accidents and associated documents contained in the SAR.

(16)

i I

Nortbest Utilities ""

ICAVP Audit Plan

.(~N- Millstone Unit 3 x) .,

The poeion of the database consisting of the accident mitigation systems in the the scope of the vertical slice system reviews (Subsection 4.2) will be given to the ORG and SRG for their review of the Critical Parameters.

The ARG Verifiers will verify the Critical Parameters using a documented System / Component test, and or Surveillance test from the Millstone Unit 3 Technical Specification or Post Maintenance Tests.

l In addition, the Critical Parameters will be verified using the design calculations, specifications, and vendor documents for acceptability .

4.6 Pronrammatic Reviews The programmatic reviews wi!! be conducted by the PRG on a horizontal bases (across systems) for the purpose of determining if the actions taken by Northeast Utilities (NU) to correct previously identified problems have been effective and if the NU change processes are effective. The programmatic reviews will be performed in accordance with PI-MP3-04.

Licensee Initiated Corrective Actions  ;

As part ofits Configuration Management Program (CMP), NU has performed a vertical slice review of safety-significant systems and has l

identified degraded or non-conforming conditions. For each of these degraded or non-conforming conditions NU is initiating corrective actions.

The programmatic review will assess the adequacy of these corrective actions. This review will be conducted for all corrective actions associated with the systems included in the scope of the ICAVP venical slice system reviews, and for a representative sample of corrective actions associated with the other NU completed CMP vedical slice systems.

The NU CMP findings / corrective action documents will be obtained both for the systems in the scope of the ICAVP vertical slice system review and for systems outside the ICAVP vertical slice system review.

A checklist will be prepared for the review of corrective actions. Using the checklist, the PRG Verifier will assess the corrective actions for adequacy '

of the following:

(17)

4 l Northest Utilities - "

[ "" ICAVP Audit Plan  !

Millstone Unit 3 ,

i <

d

a. Root cause determination - the extent to which plant processes  ;

and procedures are affected. '

b. Extent of condition determination - the extent to which other j systems, structures or components are affected.

.l

c. Plant restart -is the corrective action required prior to restart?

{

j d. Content - is the corrective action adequate in resolving the issue?

4 Channe Processes NU's current plant change processes will be reviewed for both their adequacy with respect to industry standards and for the effectiveness by l which they are being implemented. Both design change processes and I a

procedure change processes will be included in this review.

i As part of the ICAVP system reviews, the SRG and the ORG will assess the plant modifications made on the sample systems. This review will

! evaluate the effectiveness of the change processes involved in these

! modifications (i.e. if the resulting modification is found to be acceptable, it i

can be inferred that the process used in performing the modification is acceptable). In addition to this system review, specific process related

'. reviews will also be performed by the PRG. The various change processes

! reviewed will include the following: i I

faggu Corresponding MP3 Procedure I drawings NUC DCM Chapter 7 specifications NUC DCM Chapter 6 l calculations NUC DCM Chapter 5 i

procedures DC1, DC2, DC3, DC4 temporary alterations (ifapplicable) minor modifications NUC DCM Chapter 3 modifications NUC DCM Chapter 3 (18)

i Northest Utgities " "*

1 Minstone Unit 3 ICAVP Audit Plan i

I i

licensing documents NGP-4.03 i vendor manuals 1

NUC DCM Chapter 8 1

like forlike replacements NUC DCM Chapter 1 i

The current MP3 procedure for the processes listed above will be evaluated for its content and completeness. This evaluation will determine if the

i. procedure exercises adequate controls on the change process and invokes i appropriate interface reviews to assure the plant design bases and i con 6guration is maintained consistent with the licensing bases. The j evaluation will be based on guidance provided in the following:

} Reg Guide 1.33, Quality Assurance Program Requirements (Operation) i NRCInspection Manual 1- INPO guidelines f INPO 87-006, Report on Configuration Management in the Nuclear i Industry NEIguidelines i

The adequacy ofNU's implementation of the change process procedure

' will also be evaluated. Since the system review will assess the technical adequacy of the change, the progri--.raic review is intended to evaluate i

only the procedural adequacy of the change. The evaluation will determine j if the procedure is being followed, that the required checklists are being l

accurately and completely filled in, and that all other documentation is j complete and accurate. This evaluation shall be performed for the changes  !

captured in the ICAVP system reviews. If any of the processes noted i j

above are not included in the system reviews, an example outside the ICAVP will be selected for review, i

4.7 Processina Verinceton Team Findian When a member of the VT identifies a discrepant condition which does not I I

appear to meet the requirements, he shall initiate a discrepancy report (DR) per PI-MP3-11. Exhibit 3 ofthis Audit Plan depicts the DR process.

Examples of discrepant conditions are a disagreement between the system design bases and the FSAR, the as-built configuration of a piping system and the piping analysis, or a change to maintenance procedures, which should have been made due to a plant modification, but was not. The DR O will document the discrepant condition and the documents or walkdown (19)

Nortbest Utilities ""

lCAVP Audit Plan Millstone Unit 3 ,

reports that were reviewed to arrive at that conclusion. Other technical and administrative items will be included on the DR form to help track, trend and analyze the results of the verification program. The DR will be signed by the VT member and forwarded to the VT Group Lead.

The VT Group Lead will review each DR with the VT member for technical adequacy, completeness, and whether that specific issue has already been addressed by another DR or by an existing NU corrective action document. The DR could be returned to the VT member for additional information or investigation; or it could be accepted and signed by the VT Group Lead; or it could be determined to be not valid. For any DRs determined to be not valid, thejustification for this decision will be documented on the DR and the DR will be signed by the VT member and the VT Group Lead. If valid the VT Group Lead will assign a DR number and forward the DR to the VT Manager.

The VT Manager will review each DR with the Group Leads for technical adequacy, completeness, and whether that specific issue has already been addressed by another DR or by an existing NU corrective action document.

The DR could be returned to the VT member for additional information or investigation; or it could be accepted and signed by the VT Manager; or it  ;

could be detennined to be not valid. For any DRs determined to be not i valid, thejustification for this decision will be documented on the DR and the DR will be signed by the VT member, VT Group Lead and VT Marager, i

The VT Manager will submit accepted DRs to the IRC for their review.

They will review the DRs for extent of the condition to confirm that the VT looked deep enough into the issue to ensure that the problem is fully scoped; they may make recommendations to the VT to look for similar conditions in other areas or systems. The IRC may request that the VT member obtain additional information; they could accept the DR as written, whereupon the IRC Chairman would sign the DR and return it to the VT Manager, or the IRC may conclude the DR is not valid. If the VT member, VT Group Lead, and the VT Manager agree with the conclusion that the DR is not valid based on additional infonnation, those justifications shall be documented on the DR and signed by the VT member, VT Group Lead, and the VT Manager.

(- All valid and accepted DRs will be transmitted to both NRC and NU when

( the above process is completd. The DRs will be transmitted in accordance (20)

j)""

Nortbest Utilities ICAVP Audit Plan Millstone Unit 3 .

with the approved protocol. Since an important part of this project is to keep the public informed cf the status acd results, in addition to expected monthly meetings with the public, all DRs which are sent to NU and the NRC will be posted on the Internet World Wide Web.

4.8 Review NU Resolution to Verification Team Findings As shown in Exhibit 3 the handling ofNU's proposed resolution of the VT findings will follow a similar process as the generation of the findings. The resolution will be submitted to the VT member who initiated the DR the VT Group Lead and the VT Manager. If the proposed resolution is determined acceptable, it is forwarded to the IRC for their review. If both the VT Team and the IRC find the NU resolution of the DR to be adequate, NU and the NRC will be notified by the method established in the protocol. At this point we will post the accepted resolutions to the

, findings on the Internet bulletin board established for public access. If NU's resolation to the finding is not considered adequate by the VT member, VT management, or the IRC, it will be returned to NU and sent in O parallel to the NRC with a written explanation and bases for why the team did not consider it to be adequate. It is expected that NU would reconsider the information and resubmit it to the VT. Meetings between NU and the VT may be required to reach an understanding and resolution of particular issues. These meetings would be requested and held in accordance with the established protocol.

i 5.0 SYSTEM SELECTION CRITERI4 I At the public meetings on September 24,1996, the NRC indicated that they would select the systems for review rather than S&L. They also stated at those meetings that the NRC would decide on the number of systems to be selected for review. l As input to the NRC staff, S&L recommendations on the number and selection of the systems for review are provided below.

Sargent & Lundy's system selection criteria are based on NRC Inspection Manual Chapter 2535, Design Verification Program, modified to be appropriate to this situation of an operating unit. These criteria would be applied to the list of approximately 20 systems for which the NU line organization and the NU oversight organization will have completed their review also.

O l (21)

Nortbest Utilities

- - 4umav -

ICAVP Audit Plan iO \_/

Millstone Unit 3 i

1) The systems should be in the top quartile of risk significant or safety related systems.

I 2) The systems should involve a full cross section of engineering disciplines with internal and external organizational interfaces, such as NSSS supplier, component vendor, and engineering service organization.

3) The concept and implementation of the design should not be limited to the .

NSSS supplier or another single component supplier,

4) The systems should be generally representative of the safety related features ofother systems. i

5) The systems should be reasonably complex, requidng multiple operating modes.

6) The systems should have multiple, non-trivial modifications performed on it since initial licensing, preferable by different design organizations.

O With the likely selection of four systems, it is not necessary that every system meet all of the above criteria. However, each system should meet as many of the criteria as possible and each of the criteria should be met by at least two of the selected systems. The system selection may ofcourse also be weighed more heavily to i concentrate on specific known problem issues at Millstone Unit 3.

6.0 PROJECT DELWERABLES Deliverables for this project willinclude a final report which describes the scope of the ICAVP, the methodology used, the results of the review and the conclusions regarding the adequacy of the configuration management program and the corrective action program at Millstone Unit 3. Exhibit 4 of this audit plan presents an outline of the final report.

7.0 PROJECT TEAM The project team members are identified on the project roster included herein as Exhibit 5. The project organization chart is included herein as Exhibit 1.

The selection of personnel for the ICAVP was based on their qualifications to 1 O perform the assigned reviews, their financial and technical independence from the Unit being reviewed, and NRC acceptance of the personnel. Substitution of l

(22)

l Nortbest Utilities ""

ICAVP Audit Plan 1 O Millstone Unit 3 ,

' L) existing personnel on the team may be required to add expertise or manpower to fully investigate issues which are identified during the course of the program. A specific procedure (PI-MP3-08) has been written to govern the substitution and t addition ofpersonnel to the project team. NRC notification and approvalis l required. i

8.0 GOVERNING PROCEDURES i

The work for this project is classified as Nuclear Safety Related and shall be performed in accordance wan uds audit plan, S&L's Quality Assurance Program

and the following project instructions

2 Project Instruction No. Title PI-MP3-01 ICAVP Communications Protocol PI-MP3-02 Review of System Design for Compliance with Design and Licensing Bases  !

PI-MP3-03 Review ofPlant Modifications Prepared i After Receipt of Operating License for Technical Adequacy and for Configuration l Control PI-MP3-04 Programmatic Reviews PI-MP3-05 Physical Plant Configuration Walkdowns

} PI-MP3-06 Operations and Maintenance and Testing

) Procedures and Training Documentation Reviews

PI-MP3-07 Review of Accident Mitigation Systems PI MP3-08 ICAVP Team Personnel Substitution and/or Addition  !

PI-MP3-09 Preparation and Approval ofChecklists PI-MP3-10 Differing Professional Opinions PI-MP3-11 Discrepancy Report Submittal and Closure PI-MP3-12 Project FileIndex The project team members will be trained to the applicable project instructions.

l Training records will be maintained in accordance with S&L QA procedures. The Manager of the S&L Quality Assurance Division will select an audit team to monitor the activities of the project as it progrenes. Their review will be to ensure that the process used by the project team is in accordance with the NRC Confmnatory Order and the procedures developed to implement those

' O)

(_ requirements. The QA auditors will review selected DRs identified by the VT and i

(23)

l Nortbest Utilities lCAVP Audit Plan Millstone Unit 3 ,

1 will pay particular attention to any DRs that are determined to be not valid. A l summary of the QA activities related to the ICAVP and their conclusions will be

included as part of the ICAVP final report.

i 9.0 PROJECTINTERFACES j The purpose of this project is to obtain an unbiased assessment of the Millstone -

Unit 3 configuration management and corrective action programs. Therefore, every reasonable effort must be made to assure that the observations and

!. conclusions made are the result of our Project Team's own indapaadaat assessment and not influenced or biased by outside organizations. To maintain this assurance ofindependence, communications with outside organizations will be in

accordance with PI-MP3-01, "ICAVP Communication Protocol".

10.0 LOCATION OF WORK j 1

The S&L VT with the exception of the CRG subgroup of the SRG will be stationed in S&L's Chicago offices. The CRG will be stationed at an offsite office located near the Millstone station.

The project team members stationed in the Chicago offices may make periodic trips to the S&L offsite office and to the station as needed to gather documentation, interview NU personnel, or to attend meetings to discuss NU proposed resolutions to S&L discrepancy reports.

11.0 PROJECT SCHEDULE The project schedule is illustrated in the bar chart included herein as Exhibit 6.

12.0 BUDGET DATA Applicable project number and task codes for this project are listed in Exhibit 7.

O (24)

l l

1 i

Exhibit!

l0 ICAVP Project

{ Organization Chart 1

- Northeast utilities NRC

System AL Ak A EA k l

1 lCAVP < B. A. Erler Oversight > Project Director l Team

! Quality Assurance

{ A. K. Singh D. K. Schopfer i IR Committee Verification Chairman Team Manager i

I IR CommiMee O&M and Accident Programmatic System Review Lead Testing Mitigation Review Lead K. J. Green Review Lead Review Lead W. G. Schwartz R. E. Querlo R. D. Raheja A. A. Neri T.J.Ryan i D. P. Galle 4

Physical

Configuration Review Lead g

des lO R. E. Kropp My~"

i

u_.- ._h ,. m . ~ - - --h u 64.- J nn I

O .l; i -jal i 1.i v , 1 i.

-jjl i 4  !

u .lI i ~ 1 l':

~4

~

is 11 n -

I ll.f]mp lj I-I j , ,

Ili ,;;j; ie li iln 4 l tI i I i- 1 fg !j

! 1" ,

l i,iL 1 l i

g . 8*ijl  !. I

+.lr l p I" / j '-il';

Y .

y i h  !

p i}  ! 5- gj! 'l f I,3 l

.o lg 111lyi qjihlljliji;jjiy Jjli ,

!"!.1ji -  !

. j ig . N' I I .

'", I ll' lI<sjij 1

'l t-

l !l @, j i

-il --d s-

=

a s a ll 5

!L  ;

11 1 4

-- 1 ,

'g  :

i +

i+ i- s @ ,

]

[ i tl i,i i -..

Il i..

[1 1 i j .

ll i +

i  ;

I~

Exhibit 3 Initiate Discrepancy

(~

\

PROCESSING FINDINGS  :

AND RESOLUTIONS vr l v Rh DR

m. m.

VT Mgmt u

Document Basis for

' is DR Valid & DR nd Not Discrepant n Aq a.? veu P VT

! Y ,es g, % Review DR Wo Raghed IRC 4

u is DR Valid & DRnd Adequate? VeW -

O Submit DR to NRC/NU i

& Post on Electronic I BB I

, VT Mgmt 4

Provide DR Response j to VT Management NU h

- Review NU Response forAdequacy VTNT Mgmt Document Reasons for Rejection / Submit to h NU/NRC Review NU Response VT Mgmt & VT Acceptance /

a Rejection  ;

IRC i y

Document Acceptance O, Ne NU Response toDR Yes--*

& Submit to NRC/NU &

Post on Electronic BB Adequate?

VT Mgmt

I Exhibit 4 OutlineICAVP Final Report k/

Executive Summary l ICAVP Ovenight Team Report Sargent & Lundy Quality Assurance Division Report t

I. Introduction i A. Background B. Objective C. Scope D. Methodology E. Project Organization II. Conclusions A. Overall Conclusion B. Design Control Process C. Design Basis / Licensing Basis Consistency q D. Design Adequacy l V E.

F.

As-built Plant Configuration Translation of design into plant maintenance and operation '

G. Adequacy ofTesting Programs i H. Applicability of selected sample to all Millstone 3 systems I. Corrective Action Program III. Review Results A. System 1 B. System 2 C. System 3 D. System 4 E. Accident Migitation Systems F. Corrective Action Program O. Change Processes Appendices i

1. Project Team j

2. Objectivity Questionnaires I 3. Review Records j( '

4. Discrepancy Reports

k 5. NU Resolutions

6. Project Manual

7. List ofChecklists

Millstona ICAVP Pcrs nn:l Roster EdiNt 5 Page 1 of 2 7~

k' l ICAVP Project Team Unit 3 Project Director / Project Manaper B. A. Erler X PSD '

D. K. Schopfer X PSD Internal Review Committee A. K. Singh X F&A D. P. Galle X 279/OMSS K. J. Green X MDM W. G. Schvertz X PSD Verification Team SRGIA. A. Neri X PSM J. L Tenvinkel X PSM K. R. Novatny MPED J. DeMarco X l&CPE

l. Wamer X EPED

T. L. Sarver X ERIN R. Hindia X l&CPE C. M. Launi X NT&R J. M. Ricn X NT&R lN. Klab X NPD

, !J. W. Johnson X CMED lP. R. Olson X NPD

'N 'M. D. Stout X HVAC CMED EQ Specialist X ERR # 351 NPD Piping specialist X ERR # 352 NPD CIS Engineer X ERR # 353

" )

PSED ME 3 X ERR # 354 '

i "

PSED ME 3 X ERR # 355 EPED Sr. Engr X ERR # 356 EPED Sr. Engr X ERR # 357 CfiG R. E. Kropp X 279/MPED l lCMED Sr. Engr X ERR # 358

'G. E. Bitar X ERIN Mechanical Designer A X ERR # 387 Mechanical Designer B X ERR # 388 Electrical Designer A X ERR # 389 Electrical Designer B X ERR # 390 l

ARG R. D. Raheja X ;PSM T.J.Kane X !PSED L A. Bemett X ERIN W. R. PeeNes X PSED

" l W. J. Johnson X NTRD j l&C Engr-Offer to TU X ERR #325 l EPED Project Engr X ERR #326 l Nitin Patel X 279/l&C/El.

1

'I m/

Mill:t:no ICAVP Pcrsanr.i" Roster Em5 Page 2 of 2 3

1 l

ICAVP Project Team Unit 3 l

PRGlT. J. Ryan X SCD ID. A. Schroeder X EPED R. P. Sheppard X QAD i "

S.P.Wrona X ERIN l&CPED Sr. Proj. Engr X ERR # 359 ORG R. E. Querio X 279/OMSS

8. A. Childers X 279/OMSS J. A. Kleam X 279/OMSS R. L. Marsh X 279/OMSS J. P. O'Brien X 279/OMSS R.Bax 289 T. Tamlyn l 279/OMSS i R. Spear 279/OMSS J. E. Rushwick ERIN l

O

f m

\ \

'\ J J Northeast Utilities - Millstone Units 1 & 3 sar9.w a Lundy ICAVP Implementation Schedule Novernber December { January l Febr ID Task Name Start Finish 11/10 l 11M 7 [ 11/24 12M l 12/8 l12/15l12/22l12/29l 15 l 1M211/19 l 1/26 l 2/2 l 29 1 NU meet with NEAC sG-. .. 11M 496 11/1496 2 NU submt responses to NEAC subcomm 11MS96 11/:D96 3 Subcomm. evaluate resp. & report to NEAC @ public meeting 11/21 S 6 12/1296 .

4 NU hold pubhc meeting w/ NRC re: Restart Plans 12M 7/96 12M7M6 5 NU docket letter to NRC for Cortrador sew 1aon 12/18/96 12M8SS 12f18 6 NU issue letter of irtert to S&L for Unt 3 12/19/96 12/19/96 7 NRC eve!uate selecbon of S&L Team 12/19W96 2/497 8 NRC schedule public meeting on ICAVP Cortractor 1/2S7 1/2S7 h 9

9 NEAC premde input to NRC on ICAVP Contractor 12/1396 12/3006 g

to NRC hold putWie meebng to drscuss selection 25G7 2KV97 '

i Ii 11 NU respond to issues raised at NRC pubuc meeting 2/7S7 2/21/97 12 NRC finanze approval of NU selecbon 2/2497 3/11 S 7 13 NU issue contrad / purchase order for Unt 3 3/12S7 3/14/97 14 S&L develop draft Protocol & submt to NU 12/27/96 1/3G7 ' '

~

15 Ottain Current Non-system NU Documerts for Unt 3 12/2096 in497 16 Develop Unt 3 Proj. Manual / Pts & AP 1/10G7 2/27S 7 ,

17 Develop Unt 3 review checidists 2/28/97 3/24/97 18 Hold KO. meeting w/ NRC & Submt Audt Plan for approval 3/12/97 3/1297  !

i 19 NRC review Unt 3 Audt Plan & Pts 3/1397 4/2S7 20 Mobilize and Train Projed Team 4GG7 4G97 21 i *ty tT1 NU notifies NRC that Unt 3 wm be ready for ICAVP on 5/8/97 4/l497 4/1497 22 NRC Select UnR 3 systems 4/15/97 4/28 S 7

' -h o

23 Ottain Unt 3 system specific documerts 4/29/97 5/7B7 "a

4 24 Perform Reviews for Unt 3 5/8/97 7/2/97 25 Process and Report Unt 3 Findings 5/29/97 7/1G97  !

Page 1 l

p !3 (~)

'd V V Northeast Utilities - Millstone Units 1 & 3 s.r9ent a %

3J08/97 ICAVP Implementation Schedule November December l January l Fehr ID Task Name Start Finleh 11/10 l 11n 7 l 11/24 12r1 l 122 l12r15 l12/22l12/29l 15 l in2 l 1/19 l 1/26 l 2/2 { 2/9 26 NU Provide Proposed Resolution 6f12S7 7/30S7 27 Re*w NU Proposed Resolution 6/26/97 7/3067 28 Propere Unt 3 Final Report 7/2497 8/13 s7 29 NU request S&L proposal for Unt 1 12/20 s8 12/2006 i 30 S&L submt proposal supplemert for Unt 1 1/3G7 itt3G7 ,

31 NU issue Letter of friert fbr Unt i 1/167 1117B7 i i

32 Obtain Currett Non-system NU Documerts for Unt 1 if27S7 2f167 33 Develop Unt 1 Pts I AP & Submt to NRC 2/2BS7 3/17B7 34 Dewtop Unt i review checidists 3/18s7 3/24 s7 35 NRC review Unt 1 Audt Plan & Pis 3/18/97 4/7s 7 36 NU notifies NRC that Unt 1 is ready for ICAVP 3/17/97 an 7/97 1

37 NRC Select Unt i systems 3/25/97 4/7/97 38 Ottain Unt 1 system specific documents 48/97 4714G7 39 Perform Re*ws for Unt 1 4/15B7 6/QG7 40 Process and Report Unt 1 Findings SG97 Gl23G7 i 41 NU Provide Proposed Resolution 5/2007 7#B7 42 Review NU Proposed Resolution 6G97 7/7/97 43 Prepare Unt 1 Final Report 7/1/97 7/21/97

• I 55 "w

40 g*

k*

i Page 2

____a__.___ _ _ _ __--_____._____--- _ _ _ -_ _ - __ _ . _ _ _ _ . _ _ . - _ _ _ . _ _ _ _ _ _ _ _ . - _ _ _ _ _ ____A _ - _ _ _ - _ _ _ - _

O 4 O Northeast Utilities - h,' stone Units 1 & 3 sarg.ra a %

ICAVP Implementafon Schedule ary l March l Aprli l May , June l July l Aug ID 2/16 l 2/Z3 l 3/2 l 39 l 3n613/23 l 300 l 44 14n3 l 4/20 l W27 i S/4 l 5/11 l E18 l S/25 6n l 63 .i t5/15 l 6/22 { 6/29 j 72 l 7M3 l 7/20 l 7/27 l 80 l BnO 1

t 2 I i 3

4 ,

i 5

6 7 .

8 9

to 11 g_

22 gg '

13 i s '

I E 14 .

15 16  ;

7 l I lW 18

• c tTj ,

u; mE 23 I 24  ;

25 '

l i i

Page 3

___.__.__..m_ _ _ _ . - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ - _ _ - _ _ . _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ - - - _ _

. _ _ ____ _ _ .____ _. . ~_.... -...._.___ _ __.. _ _ _ .._. _ --_ _ . _._ _..._...-.__. _ _ _._ - _.._... _ _ ..._.._. _ _ .

(

l i

Northeast Utilities - Millstone Units 1 & 3 sarse,* a Lumsy 3N8N7 ICAVP Implementation Schedule ,.

ary l March l AprH l May June so l July i Aug 2ne i 2rzs I ar21 as I ane I ar23 I aco 14e 14ns 14co I 4r271 s/4 I snt I sns I sr2s en I ee I ens l er22 I er291 7m 17na l Tr20 l 7/27 I 8o I atto 30 .

! I2 i

i I

! 31 t I

32 sa lg i i

n ,

[

t

&"U -

37 i as '

1. t -

41 '

k$ .

43  ;  ;  ;

h. '

o 1

M. h

&y%"  ;

k*

=

i 1

l Page 4 r

1 Exhibit 7 ICAVP Budget Data I j

Project No.: 9583-100 Task Codes: As follows:

l Task Code Description i A00311 Development ofProject Manual l

A30020 Project Administration I A30022  !

IRC Review ofDRs and Disposition '

A30027 Development of Communications i'

A30028 Development ofWeb Site A30055 Training & Mobilization A30056ARG ARG - Perform Reviews / Report Findings A30056CRG CRG - Perform Reviews / Report Findings A3005f0RG ORG - Perform Reviews / Report Findings A30056PRG PRG - Perform Reviews / Report Findings A30056SRG I SRG - Perform Reviews / Report Findings A30057 Evaluate Resolution ofFindings A30058 Final Report A30090 Independent Oversight Team O

i lC PROJECT INSTRUCTION *f .-

INSTRUCTION PI-MP3-01 REV.0

)

Client: Northeast Utilities i

I Station: Millstone Unit 3

Title:

INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM COMMUNICATIONS PROTOCOL 3 Safety-Related Non-Safety-Related Reviewed By: Approved By:

System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman

, m _ } , Date:3'f=~$7 0/94 WL: Ydkad N4bdt% &Yldp U kQ %#LW

~ '

Description initialli(sue 1

O' Page 1 of 8 l l

i 4

I

l i

O PROJECT iNSTauCTiON "["-

INSTRUCTION PI-MP3-01 Rev. 0 i

I 1

1.0 PURPOSE i

The purpose of employing an independent reviewer for the independent  ;

Corrective Action Program (ICAVP) is to obtain an unbiased assessment of the Millstone Unit 3 configuration management and corrective action .

programs. Therefore, every reasonable effort will be made to assure that the  !

observations and conclusions made are the result of the Project Team's own l independent assessment and not influenced or biased by representations of other parties such as the NU line organization or their contractors responsible for subjects under review. To maintain this assurance of independence, this formal protocol has been established and will be implemented to control the communications between S&L, NU, and the NRC. This protocol has been written so that the Project Team reviewers remain objective and unbiased, yet '

will permit the legitimate need for the Project Team to communicate with the NU organization to obtain information including any necessary verbal l clarification to maintain an efficient process. It is, however, the responsibility of the independent reviewers to assure that these guidelines are implemented in a manner which assures the objectivity and independence of the review. I Sargent & Lundy Project Team internal communications are unaffected by the requirements of this protocol, including those between or among the Verification Team, the Intemal Review Committee and the Independent Oversight Team (IOT).

2.0 ORGANIZATIONAL-POINTS OF CONTACT Each of the organizations involved in the ICAVP (NRC, NU, and S&L) has provided a primary and backup point of contact. These points of contact are the personnel through which inter-organizational communications will occur or be arranged. This includes both verbal and written communications, including electronic mail.

6 Page 2 of 8

t 1

i i

PROJECT

. O iNsTauCTiON .- f INSTRUCTION PI-MP3-01 REv. 0 I i 4

2.1 Northeast Utilities l

l Primary

Contact:

Bob Grazio, ICAVP Project Manager i

Phone - 860 440-0459 Fax - 860-444-5520 j

e-mail- grazire@gwsmtp.nu.com

! Ovemight mail- Northeast Utilities l Millstone Nuclear Power Station i

Rope Ferry Road Waterford, CT 06385 Backup

Contact:

Richard Laudenat Phone - 860-440-5248 1 Fax - 860-440-2091  ;

Ovemight mail- Northeast Utilities l

Millstone Nuclear Power Station l

Rope Ferry Road i

Waterford, CT 06385 2.2 Nuclear Regulatory Commission Primary

Contact:

Gene Imbro, ICAVP Manager Phone - 301-415-1490 Fax - 301-415-2260 e-mail- evi@nrc. gov Ovemight mail - Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Backup

Contact:

Loren Plisko, ICAVP Team Leader Phone - 301-415-123' Fax - 301-415-2260 e-mail - Irp@nrc. gov Ovemight mail - Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 h Pace 3 of 8

I "

PROJECT INSTRUCTION PI-MP3-01 O INSTRUCTION -[f REv. 0 l 2.3 Sargent & Lundy i

Primary

Contact:

Don Schopfer, Verification Team Manager Phone - 312-269-6078 Fax - 312-26's-2049 e-mail - don.k.schopfer@sichicago.infonet.com Ovemight mail- Sargent & Lundy 55 E. Monroe Street j Chicago,IL 60603

. Backup

Contact:

Bryan Erler, ICAVP Project Director 4 Phone - 312-269-7132 j Fax - 312-269-2049 e-mail - bryan.a.erler@sichicago.infonet.com i

Ovemight mail- Sargent & Lundy 55 E. Monroe Street l Chicago,IL 60603 3.0 RULES FOR VARIOUS TYPES OF COMMUNICATIONS

There are a variety of types of communications necessary to effectively implement the ICAVP. The following identifies the various types of inter-

} organizational communications required and defines the rules goveming those types of communications. These rules address aspects such as who initiates l the communication, whether notification of other parties is given, who may l

! participate in the communication, whether public access is to be given, and i

! the documentation requirements for the communication and to whom it is provided. Other communication between personnel in these project organizations or their contractors should be avoided during the performance of the ICAVP.

3.1 Request for information - S&L will need significant amounts of documents and drawings from NU to commence and proceed with the review. The information request process from S&L to the NU organization will be a frequent occurrence during the ICAVP.

, The S&L Verification Team Manager, or one of the Review Leads, will submit all requests for information to the NU primary contact in writing.

j This may be via fax, e-mail or ovemight mail. Each request shall be

O Page 4 of 8

l PROJECT INSTRUCTION

f" INSTRUCTION PI-MP3-01 REV.O I

t i

on a standard form developed for this purpose and shall be provided with a sequential number for tracking (See Attachment 5.1). A copy of each request for information shall be provided to the NRC's primary contact. NU's response to the requests shall be submitted in duplicate to the S&L primary contact, one copy to Chicago and one copy the .

office space provided by NU to S&L near the Millstone station. NU '

shall provide an index of all documents submitted, includirig a revision  !

number oridentifying date.

In order to ascertain the availability of information or to identify the appropriate documents containing required information, the S&L Verification Team Manager or one of the Review Leads may contact the NU primary contact or a designated Document Control personnel via phone. This type of informal contact shall only be made in the process of preparing and submitting a request for information.

1 3.2 Request for informal conference - S&L may on occasion request a conference with NU line organization personnel to obtain clarification or l O further understanding of particular issues. Altemately, NU may request a conference to discuss or clarify findings issued by S&L. This conference can be by telephone, by videoconference, or in person.

The primary contact for the organization initiating the informal conference shall contact the primary contact of the other organization (via phone, fax, or e-mail) and identify the reason for the conference and the participants needed. The NRC primary contact will be notified of the conference and given the opportunity to participate. A minimum of a half day advanced notice shall be provided to the participating organization and to the NRC. Notes of the conference shall be written by the initiating organization and distributed to the primary contacts of the participating organizations and the NRC.

3.3 lasuance of Findings - The findings identified by S&L will be distributed to NU and the NRC, including their posting on an Intemet Web Site.

The S&L primary contact, or designee, will distribute the findings (discrepancy reports) from the ICAVP to the NU and the NRC primary contacts by fax and ovemlght mail. In addition, S&L will post the findings on a uniquely identified Intemet page. This will allow public h Pace 5ofR

i j

PROJECT #

7 INSTRUCTION PI-MP3-01

. INSTRUCTION .

REV.0

{ access to this information. More information about accessing the 1

' ICAVP information on the Internet is included in Section 4.0 of this protocol. The S&L instructions for the processing of the discrepancy reports and their proposed resolutions is provided in project instruction PI-MP3-11.

' 3.4 Submittal of proposed resolutions - NU will evaluate the findings submitted by the S&L Project Team and develop proposed resolutions and submit these proposed resolutions to S&L for review.

The NU primary contact will submit the proposed resolutions to the ICAVP findings to both the S&L and the NRC primary contacts.

Following acceptance of the resolution in accordance with PI-MP3-11 S&L will post the NU resolution on the ICAVP Web Site.

3.5 Formal Meetings or Briefings - It is expected that there will be formal meetings with the various participants and the public to discuss the results of the program.

Formal meetings to discuss the results of the ICAVP and periodic briefings for the public will normally be scheduled in advance or initiated by the NRC. The NRC will notify the NU and S&L primary contacts at least one week in advance of the meetings. For meetings open to the public, the NRC normally provides a two week notification.

S&L will also post meeting notification on the Web Site for meetings open to the public after the NRC has issued notification. S&L participation at this type of meeting will normally be the Project Director, the Verification Team Manager, and others as may be determined by S&L. Participation other than G&L will be determined by the NRC. If the NRC has the meeting transcribed, no other notes of meeting are required. Otherwise, S&L will publish notes from the '

meeting and distribute them to the participants. Copies of all presentation material will be available at the public meetings and will l be posted to the Web Site.

3.6 Meetings between S&L and LOT - The S&L Project Team will have periodic meetings to brief the independent Oversight Team on the progress of the ICAVP. The IOT is considered part of the S&L review process.

6 Page 6 of 8

I PROJECT INSTRUCTION PI-MP3-01 INSTRUCTION REV.0 1

i l Periodic meetings between S&L and the IOT will normally be scheduied well in advance. A minimum two week advanced notice will i be provided for non-routine meetings. S&L will contact each member '

of the IOT by fax, e-mail, or ovemight mail, as appropriate, with the meeting logistics and an agenda for the meeting. This meeting will not

be open to the public, but the NRC will be given an opportunity to

, attend. Notes of the meeting will be prepared by S&L and distributed i to all IOT members and the NRC primary contact.

3.7 Press and/or Media Communications - Based on the current level of i public interest in the ICAVP and Millstone in general, there is expected to l be press and media interest in the work of the ICAVP Contractor.  !

Communications with the press and media and notification of the NRC and NU of such interest are included in this protocol.

Requests for interviews with the press or media shall be referred to the Project Director or the Verification Team Manager. One of them O shall notify the NU and the NRC primary contact of the request. The Director or Manager shall respond appropriately to the press or media

{

l requests.

3.8 Communications related to NRC oversight of S&L - S&L's activities in the ICAVP are considered an extension of the NRC. As such,  !

communication between S&L and the NRC will be required, both related to the execution of the review and to the NRC's oversight of S&L's performance.

From time to time S&L may have specific questions or need direction from the NRC. When necessary the S&L primary contact may call or meet with the NRC primary contact, or his designee, to discuss these issues. Notes of conference shall be prepared by S&L to reflect specific decisions, actions or direction provided, and these notes shall be distributed to the NRC primary contact. No other participants are required for a conference of this type between S&L and the NRC nor will the notes be distributed to any other party.

6 Page 7 of 8

1 6 "

PROJECT O INSTRUCTION - f INSTRUCTION PI-MP3-01 REV.O {

l i

3.9 Financial / Contractual lasues between S&L and NU - As with any contractual relationship between two organizations, periodic discussions and / or written communications will be required between S&L and NU.

These discussions will be outside the scope of this protocol. This type of l communication will be primarily between the S&L Verification Team l Manager and the NU Director - Contracts & Purchasing and/or the NU l ICAVP Project Manager, and will be limited to purchasing and contract

! related issues.

4.0 PUBLIC ACCESS TO ICVAP INFORMATION ON THE INTERNET As discussed in earlier sections of this protocol, discrepancy reports identified during the course of the ICAVP and their accepted resolution will be posted on the Internet Web Site to allow public access. In addition, certain other documents will be posted on the Web Site, including portions of the Project Manual, periodic status report information, and the final report. The address for the Web Site is http://www.mp_lcavp.com.

Sargent & Lundy will add a hyperlink on its Intemet home page entitled Millstone ICAVP that will send the viewer to that page w;th a menu showing the available documents posted. The S&L home page may be accessed on the Internet World Wide Web at http://www.s/ chicago.com.

5.0 ATTACHMENTS 5.1 ICAVP Request for Information (1 page) 4 I

l Paos 8 of 8

l

(

PI-MP-01 Anehment 5.1 Northeast Utilities RFI No.

Millstone Unit 3 REQUEST FORINFORMATION l INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM '

To: Mr. Bob Grazio, ICAVP Project Manager From: .

Date ofRequest: / Date Needed by:

Document Title or Description Document Title or Description i

i l

1 O g i

cc: Mr. D. K. Schopfer

a f[*"

j PROJECT INSTRUCTION PI-MP3-02 INSTRUCTION .- REV.0

)

1 Client: Northeast Utilities

! Station: Millstone Unit 3

Title:

REVIEW OF SYSTEM DESIGN FOR COMPLIANCE WITH THE DESIGN AND LICENSING BASIS S Safety-Related Non Safety-Related Reviewed By: Approved By: i System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman

, g / j Date: .?-le-D MM~

Description Inigafis(ue

[ .hd ad kb% V' db 3k A l

O l l

Page 1 of 15

PROJECT INSTRUCTION PI-MP3-02 l

INSTRUCTION .- REV.0 l l 1.0 PURPOSE i

1

This instruction establishes the requirements for the design review of systems

included in the scope of the Independent Corrective Action Verification j Program (ICAVP). The purpose of the design review is to verify the system

design as reflected on design output documents and design process

! documents is consistent with the plant's Design and Licensing Basis.

Additionally, the design review will verify technical adequacy of design

} process documents.

l 2.0 REFERENCE 2.1 NRC Inspection Manual Procedure 93801, Safety System Functional Inspection 2.2 NRC InspectionWanual, Chapter 2535, Design Verification Programs 2.3 10CFR50.2, Definitions 2.4 NRC Confirmatory Order Establishing Independent Correction Action Verification Program - Millstone Nuclear Power Station, Units 1, 2, and 3 2.5 NUMARC 90-12, Design Basis Program Guidelines l 2.6 PI-MP3-06, Operations and Maintenance and Testing Procedures and Training Documentation Reviews i

2.7 PI-MP3-07, Review of System Design for Compliance with the Design and Licensing Basis i

2.8 PI-MP3-09, Preparation and Approval of Checklists 2.9 PI-MP3-11, Discrepancy Report Submittal and Closure 2.10 PI-MP3-12, Project File Index 6 Page 2 of 15

1

" l

! PROJECT INSTRUCTION Pl-MP3-02 4

INSTRUCTION .-

f REV.O i

I 2.11 CK-MP3-02 Series Checklists as follows:

i CK-MP3-02-01 System Reference List j CK-MP3-02-02 System Requirements List l CK-MP3-02-03 Design Process Document Review Checklist CK-MP3-02-04.1 P&lD Review Checklist i CK-MP3-02-04.2 Logic Diagram Review Checklist j CK-MP3-02-04.3 Electrical Schematic Review Checklist CK-MP3-02-05.1 Mechanical Component Review CK-MP3-02-05.2 Electrical Component Review CK-MP3-02-05.3 I&C Component Review Note: Checklists used in the performance of this Pl are not included as  ;

attachments to the Pl. Checklists are prepared and controlled as separtate documents per PI-MP3-09.

3.0 DEFINITIONS 3.1 Accident Mitigation Systems Review Group (ARG)-The subgroup of the ICAVP Verification Team responsible for review of critical characteristics of accident mitigation systems to ensure those systems can perform their required safety functions.

3.2 Operations & Maintenance and Testing Review Group (ORG)-The subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training materials for l the systems within the scope of the ICAVP.

3.3 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

3.4 Configuration Review Group (CRG)-The subgroup of the SRG Verification Team respont,1bie for walkdowns to verify the current as-built conditions are in conformance with the design output documents. .

h Page 3 of 15

i PROJECT INSTRUCTION PI-MP3-02 j INSTRUCTION REV.O

l l 3.5 Design Bases - The information which identifies the specific functions to l be performed by a structure, system or component of a facility, and the l specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived

. from generally accepted " state of the art" practices for achieving i functional goals or (2) requirements derived from analysis of the effects of

, a postulated accident for which a structure, system or component must meet its functional goals (Reference 2.3).

l 3.6 Design Output Documents - Controlled plant documents such as l specifications, drawings, vendor drawings, datasheets, lists and i databases (Reference 2.5).

l 3.7 Design Process Documents - Documents such as calcul ations, analysis, l evaluations or other documented engineering activities that subctantiate the final design (Reference 2.5).

]

4 j 3.8 Current Licensing Basis (CLB)-The set of NRC requirements

! applicable to a specific plant, and a licensee's written commitments for j assuring compliance with and operation within applicable NRC i l

, requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19, 20, 21, 30, 40, 50, 51, 55, 72, 73,100 and appendices thereto; orders; license conditions; exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented in the most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 and the licensee'c commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports. (Reference 2.7) 3.9 Verifier - The individual assigned to review engineering attributes within his area of responsibility.

Page 4 of 15

~

PROJECT INSTRUCTION PI-MP3-02 j INSTRUCTION REV.0 l

1 l 4.0 RESPONSIBILITIES 1

] 4.1 The Verification Team Manager shall be responsible for overall 1 management of the Verification Team.

} 4.2 The SRG Lead shall be responsible for assigning the Lead Verifier for

each system in the ICAVP scope and for overall coordination of the SRG l effort.

i j '

4.3 The Lead Verifier shall be responsible for performing system reviews for the attributes within his area of expertise and for assigning verifiers with

! appropriate background for review of remaining attributes.

i j

4.4 The Verifiers shall be responsible for performing reviews of engineering attributes within their area of expertise in accordance with this instruction.

5.0 PROCEDURE j 5.1 General

} m

! The Nuclear Regulatory Commission (NRC) Confirmatory Order l

referenced in Section 2.0 of this PI requires Northeast Utilities (NU) to j implement the ICAVP. The confirmatory order also defines the scope of

the ICAVP. Item 2 of the scope of the ICAVP described on page 13 of the

confirmatory order requires the Licensee to verify the current as-modified plant conditions against design basis and licensing basis documentation.

This procedure describes one aspect of the process needed to perform the verification described above. Specifically, this procedure will determine if the current system design as reflected on design output

documents and design process documents is consistent with the system

! design basis and licensing basis documentation. This review is not

! intended to verify the design basis as stated in the Licensing Basis Documentation is consistent with the Licensing Basis. For example, a l design basis consideration that may be described in the FSAR is that the

, system is designated a Quality Class 1 system in accordance with i RG1.26. This review will verify the design of the system was performed to

, Quality Class 1 standards. This review will not verify that the Quality Class 1 designation was applied correctly per the guidelines of RG1.26.

In other words, this procedure verifies the design basis requirement is

!m 1

Page 5 cf 15

1

~

PROJECT INSTRUCTION PI-MP3-02 INSTRUCTION REV.0 l

1 properly incorporated in the design and does not verify the design basis is I j in conformance with the licensing basis. Verification of conformance I j between licensing basis and design basis was performed by NRC prior to j issuance of the operating license. Changes subsequently issued will be

! reviewed in detail as part of the modification review process (PI-MP3-03). l

{ The systems to be included in the scope of the ICAVP program will be j

defined by the Nuclear Regulatory Commission. Once the systems have l been identified, the following tasks shall be performed in order to l determine if the system's design is consistent with the plant's design and licensing basis

! a. Document Retrieval & Review i

b. Identification of System Requirements

c. Technical Review of Design Process Documents I

d. Upper Tier Drawing Review

e. Component Review

f. Reconciliation of Design vs. Design & Licensing Basis

g. Discrepancy Raport Preparation and Closure

h. Final Report Preparation The detailed instructions for performing these tasks are provided in the subsections 5.2 through 5.9 below. References 2.1,2.2 and 2.4 were used to develop these instructions. Attachment 6.1 is a flow chart illustrating the system review process.

5.2 Document Retrieval & Review 5.2.1 Since there may be duplication between documents required by the various review groups, the following division of responsibility has been established:

5.2.1.1 The SRG shall gather, as a minimum, the following licensing and design bases documents and system specific documents:

a. Design & Licensing Basis Documents (Applicable Sections Only) a.1 NRC Regulations a.2 Technical Specifications a.3 Updated Safety Analysis Report umumminumer Page 6 of 15

i i

PROJECT INSTRUCTION PI-MP3-02

O 1

INS 1 AUCTION - Rev. 0 4

j a.4 NRC Safety Evaluation Report a.5 MP3 Commitments to NKC a.6 Design Basis Documentation Package (DBDP) j b. System Specific Documents b.1 Engineering Calculations (Mech, Elect, Struct, l&C and Piping i Analysis) l

b.2 Equipment Procurement Specifications  !

l b.3 Modification Packages j b.4 System Descriptions  !

b.5 Equipment List  !

j b.6 Environmental and Seismic Qualification Reports \ l i b.7 Findings and corrective actions identified by NU during the

implementation of their Configuration Management Plan

! (CMP) i l 5.2.1.2 The ORG Shall gather, as a minimum, the documents listed below-  !

I a. Operating Procedures including Emergency Operating Procedures

b. Maintenance Procedures

c. Surveillance Test Procedures  !

d. Vendor Manuals

e. System Training Procedures

f. Necessary Support and/or Related Procedures l 5.2.1.3 The CRG shall gather, as a minimum, the following system specific drawings:

a. P&lDs

b. Logic Drawings

c. Electrical Schematics

d. Piping Drawings

e. Electrical Single Line Drawings

f. Panel Wiring Drawings

g. Cable Routing Drawings and Databases

h. Pipe Support Drawings

1. Structural Equipment Mounting Details J. General Arrangement / Equipment Location Drawings O

Page 7 of 15

1 PROJECT INSTRUCTION PI-MP3-02 INSTRUCTION , REV.O

k. Instrument Location Drawings

l. Zone Maps (Environment / Fire Protection, etc).

5.2.2 Design and Licensing Basis documents are available in the S&L

ICAVP Library. System specific documents shall be obtained from l NU. Requests for documentation from NU shall be submitted in j accordance with subsection 3.1 of PI-MP3-01.

2 5.2.3 Once the documents have been gathered, each group shall complete the applicable section of the System Reference List (SRL) and forward i the completed SRL to the SRG Lead. Checklist CK-MP3-02-01 shall be used for the SRL. ,

l

5.2.4 The SRG Lead shall combine the SRL input from each review group,

{ and issue the combined list for use to the ORG, SRG and CRG.

i 4

5.2.5 Each member of the ORG, SRG and CRG assigned to review the system shall study the documentation to become as familiar as possible u,d achieve an in-depth understanding of the system as it

! relates to their area of expertise. Each member shall also review the l j findings and corrective actions that resulted from NU's CMP. S&L i sha!! not duplicate findings identified by the NU CMP. 1

! 5.2.6 If the need for additional documents is identified during the review

process, these documents shall be requested in accordance with

subsection 5.2.2 of this Pl.

1 i 5.2.7 Requests for updates to the SRL shall be forwarded to the SRG Lead.

The SRG Lead shall issue formal revisions to the SRL as needed.

j 5.2.8 The SRG Lead shall file the SRL in accordance with PI-MP3-12.

5.3 Identification of System Recuirements

! 5.3.1 The SRG shall review the licensing and design basis documents to identify the functional, performance, and other design requirements for the system being reviewed. Identification of operating, testing and maintenance requirements shall be performed by the ORG in accordance with PI-MP3-06.

m Page 8 of 15

PROJECT INSTRUCTION "f -

INSTRUCTION PI-MP3-02 REV.0 i

5.3.2 The SRG Lead shall assign a Lead Verifier for each of the systems being reviewed. The Lead Verifier shall be from the related discipline (Mechanical for Mechanical System, Electrical for Electrical System, ,

etc). The SRG Lead shall also assign verifiers from other disciplines l as needed to support the system review process.

5.3.3 The Verifier (s) shall review the Licensing and Design Basis Documents for the system being reviewed to identify design, performance and functional requirements. Each requirement shall be tabulated along with a reference on the Systems Requirements Checklist (Checklist CK-MP3-02-02).

5.3.4 The system requirements review for functional, performance and design requirements shall be limited to the following design aspects:

a. Mechanical Design

b. Electrical Design

c. l&C Design

d. Structural Design O e.

f.

einioo Desion Equipment Qualification (environmental and seismic) 5.3.5 The Lead Verifier shall incorporate input received from the ORG (per PI-MP3-06)into the System Requirements Checklist. The Lead Verifier shall also incorporate the characteristics identified by the ARG (per PI-MP3-07) for the system if the ARG determines the system is an i accident mitigation system. Upon completion, the Lead Verifier shall l obtain signatures from the verifiers providing input and shall sign the l

" Input Approval" block of the checklist.

5.3.6 The SRG Lead will review the Systems Requirements Checklist for completeness and shall indicate his concurrence by signature and date in the appropriate block on Checklist CK-MP3-02-02.  ;

5.3.7 The SRG Lead shall distribute the checklist to the ORG Lead and to applicablo SRG verifiers for use and to the project file in accordance with PI-MP3-12.

o

- Page 9 of 15

I PROJECT *? #~ '

INSTRUCTION PI-MP3-02 INSTRUCTION . REV.O I 5.4 Technical Review of Desian Process Documents j 5.4.1 The SRG shall perform a detailed review of applicable design process

documents to verify technical adequacy.

i 5.4.2 Appilcable design process documents shall include:

)

! a. Mechanical calculations (hydraulic calculations, component

, sizing calculations, design pressure and temperature l calculations, NPSH calculations, etc.

! b. Electrical calculations (load calculations, voltage drop, etc.)

l c. I&C calculations (setpoint calculations) i

d. Structural calculations (equipment mounting, pipe supports, cable tray supports, conduit supports, etc.)

i e. Piping Analysis j f. EQ/SQ Reports i Note: The review process is not intended to include the entire population of repetitive component calculations such as pipe support j calculations. The SRG shall review an adequate sample of repetitive

, type calculations.

i i 5.4.3 Checklist CK-MP3-02-03 shall be used to document the design process document review. The applicable subject specific checklists from PI-MP3-03 shall also be used.

5.4.4 The Verifier (s) shall review the adequacy of the following attributes:

a. Numerical Accuracy - The numerical aspects and mathematical  ;

operations shall be error free. The number of significant figures i shall be consistent with the input data, assumptions and design methodology. Transposed or transferred numbers are correct,

b. Modeling Accuracy - Analytical models shall be consistent with the degree of accuracy of the input data, assumptions and design methodology,

c. Assumptions and Engineering Judgment - Assumptions and engineering judgment shall be consistent with the design approach and methodology.

m Page 10 of 15

i PROJECT a "*

INSTRUCTION PI-MP3-02 INSTRUCTION ./sy REV.O

d. Design inputs - Design inputs shall be based on the latest controlled design documents.

I e. Methodology -The rnethod shall be appropriate for the purpose l and scope of the calculation.

i l 5.4.5 The Verifier (s) shall note any comments identified during the review on l the Design Process Document Review Checklist (CK-MP3-02-03).

l 5.4.6 The Verifier (s) shall evaluate the enmments to determine if they affect the conclusion of the Design Process Document. The evaluation shall l be documented on the Design Process Document Review Checklist (CK-MP3-02-03).

l 5.4.7 The Verifier (s) shall indicate on the checklist coversheet (CK-MP3 l 03) whether the conclusions are acceptable with comments or unacceptable, and shall sign and date the coversheet.

l O 5.4.8 Por acceptehie with comments er enacceptera disnoeitioes. ihe Verifier shall generate a Discrepancy Report per subsection 5.8 of this l

Pl. The Verifier (s) shall also evaluate the unacceptable disposition for l

impact on other documents that may use the conclusion as input. The  !

l Verifier (s) shall consult other SRG members while evaluating the l impact.

l Note: Calculation results are typically used as input in other  !

documents. If a Discrepancy is identified which affects the result of i l the calculation, it is important to define where those results were used I

and evaluate those documents for impact. The review should be done prior to generating a Discrepancy Report so that the Discrepancy Report describes the full extent of the condition.

5.4.9 The Lead Verifier shall verify the checklists have been properly completed, indicate his concurrence with signature and date, and shall l compile and file the design process document review checklists prepared by the Verifier (s) to the project file in accordance with PI-MP3-12.

i Page 11 of 15

7 PROJECT # "'

INSTRUCTION PI-MP342

] INSTRUCTION .- REV.0 5.5 Upper Tier Document Review 5.5.1 The SRG shall perform a functional review of the upper tier drawings to verify the system is capable of performing its functions as described in the design and licensing basis. The SRG shall also perform a technical review of the drawings to verify conformance to design calculations and classification criteria.

5.5.2 The Verifier (s) shall utilize drawing review checklists CK-MP3-02-4.1, -

4.2, -4.3 for the review of the P&lDs, logic diagrams and electrical schematics, respectively. These checklists define the attributes to be reviewed. In general, review attributes will include flow paths, interlocks, automatic actuations, permissives, redundancy and separation, safety classification, component sizes, pressure class, overpressure protection, etc. The review is not intended to identify drafting or style errors.

5.5.3 The Verifier (s) shall note any comments on the applicable checklists

. (CK-MP3-02-4.1, -4.2, -4.3).

O 5.5.4 upon completion of the review, the verifier (s) shaii sign and eate tne coversheet of the applicable checklists.

5.5.5 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.8 of this P1 for any discrepancies not previously identified by the NU CMP.

5.5.6 The Lead Verifier shall verify the checklists have been properly completed, indicate his concurrence with signature and date, and shall compile and file all drawing review checklists prepared by the ,

Verifier (s) in the project file per PI-MP3-12.

5.6 Component Review 5.6.1 The SRG shall perform a detailcJ review of system components. This review shall verify the design data included in the design and licensing basis, the vendor drawings, the procurement specifications, equipment list and calculations are consistent.

m Page 12 of 15

PROJECT

- " ' " ~ "'

r INSTRUCTION PI-MP3-02 INSTRUCTION REV.0 5.6.2 The scope of this review shall include all major mechanical, electrical j and l&C components.

l 5.6.3 Detailed component checklists are included in the CK-MP3-02-05

series checklists. These checklists verify attributes such as l classification, design conditions, operating conditions, functional l requirements, applicable codes and standards, performance i

requirements, and qualification requirements, etc.

j

. 5.6.4 The Verifier (s) shall cornplete individual Component Review j Checklists (CK-MP3-02-05 series) for each component within the i scope of review. Discrepancies noted shall be indicated in the appropriate blocks on the checklists.

! 5.6.5 Upon completion of the review, the Verifier (s) shall sign and date the l checklists.

4 i 5.6.6 The Verifier (s) shall generate a Discrepancy Report in accordance with Subsection 5.8 of this PI for any discrepancies not previously

identified by the NU CMP.

! 5.6.7 The Lead Verifier shall verify the checklists have been properly

completed, indicate his concurrence with signature and date, and shall l file all completed checklists in the project file per PI-MP3-12.

j 5.7 Reconciliation of Desian vs. Desian and Licensina Basis 1

f 5.7.1 The SRG will complete the verification of the system design versus the i design and licensing basis documentation. The verification shall be completed by dispositioning each requirement on the System l Requirements Checklist (Checklist CK-MP3-02-02).

5.7.2 Where applicable, the Verifier (s) shall identify on the System Requirements Checklist, the design process documents which verify the restraints imposed by the system requirement are not exceeded.

The Verifier (s) shall either indicate the design process document is technically adequate or describe any deficiencies. The Verifier shall also identify missing design process documents, if applicable.

m Page 13 of 15

l PROJECT INSTRUCTION PI-MP3-02 I INSTRUCTION REV.0 5.7.3 The Verifier (s) shall identify on the System Requirements Checklist, the design output documents related to the system requirement. The Verifier shall indicate whether the technical requirements contained in the design output documents are consistent with the system requirements or shall identify the discrepancy.

5.7.4 The Verifier (s) shall initial and date all entries in the System Requirements Checklist, and shall sign the System Requirements Checklist when completed.

5.7.5 The Verifier (s) shall generate a Discrepancy Report in accordance with Subsection 5.8 of this PI for any discrepancies not previously  !

identified in Subsection 5.4,5.5, and 5.6 of this procedure.

5.7.6 The SRG Lead shall review the disposition in the system requirements Checklist (CK-MP3-02-02) for completeness and technical accuracy.

The SRG Lead shall indicate his concurrence with signature and date in the appropriate column. The SRG Lead shall notify the ARG Lead I that either all critical characteristics for accident mitigation systems l O " eve eeem etieried er he "e'i ieeoi>fx which " eve met "eeo-1 5.7.7 The Lead Verifier shall file the completed checklixs in the project file per PI-MP3-12.

5.8 Discrepancy Report Preparation and Closure 5.8.1 Discrepancy Reports for discrepant conditions identified during the system review process shall be prepared and processed in accordance with PI-MP3-11. Discrepancy reports shall not be initiated for findings already identified by NU during implementation of the CMP.

5.8.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in accordance with PI-MP3-11.

5.9 Final Report 5.9.1 The Lead Verifier shall draft a final report summarizing the results of the system review.

m Page 14 of 15

! PROJECT INSTRUCTION PI-MP3-02 INSTRUCTION ,

REV.O  ;

l

}

j 5.9.2 The report format shall be determined by the Verification Team

! Manager.

i f 5.9.3 The report shall be reviewed and approved by the VT Lead, VT l

, Manager and IRC prior to external distribution. '

l l 6.0 ATTACHMENTS 1

1 1 6.1 ICAVP Process Flowchart, ' System Review". ( 1 page) i i I

l 4

i i O I

l i

i i

Pm l

f Page 15 of 15 I . . . _ _ - . . . _ . _

l Identify Systemsin RW. 0 ICAVP PROCESS FLOWCHART - lCAVP Scope ATTACHMENT 6.1

! SYSTEM REVIEW l C NRC 1 L.)y Gather besign &

Ucensing Basis Documents & Design Output Documents SRG, CRG, ORG 4

Prepare System Reference Ust SRG, CRG, ORG i  !

• l Distribute APP Define System Design System Reference & Ucensing Basis /

Ust for Use Prepare System  : f Q cm SRG Requirement Ust \ PM5H7 SRG v l

+ + + v '

Perform Detailed Perform Component Submit Des /Lic. Perform Fun::tional Calc Review P.eview for I ) Basis Ust to Review (M/E/1/ Piping Analysis Consistency (Uc & Des (V CRG for Use PalD/ Logics /Schm. & EQ/SQ Rept.) Basis /Dwg/Cales/

Specs ,

SRG SRG SRG SRG l e + +  ;

y Disposition System Requirements LL-t cupo. mon or N

. crmo i N .'

$Y SRG Were discrepancies Not identified?

Yes l Process Discrepancy l Reports (Pi-MP3-11)

SRG C)

U , u v Prepare Review Report SRG

PROJECT INSTRUCTION *[*"' .-

INSTRUCTION PI-MP3-03 REV.0 l

1 l

Client: tertheast Utilities (

Station: Millstone Unit 3 i

Title:

REVIEW OF PLANT MODIFICATIONS PREPARED AFTER RECEIPT OF OPERATING LICENSE FO '

TECHNICAL ADEQUACY AND FOR CONFIGURATION CONTROL l h Safety-Related _

Non Safety-Related Reviewed By: Approved By:

System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team Lead Mitigation Committee Manager O Shhd ,

$ Wh ~ Yd!/ne's !$h/11k $e?l

/ ,

kWW&N Date:3-4-97 Description Initisfirde U' '

k Page 1 of 14

i b,

PROJECT INSTRUCTION M[*" INSTRUCTION PI-MP3-03 REV.O

] 1.0 PURPOSE l This instruction establishes the requirements for the review of modifications to i systems included in the scope of the independent Corrective Action

Verification Program (ICAVP). The purpose of the modification review is to i verify the adequacy of the engineering design and configuration control processes.

{

j

2.0 REFERENCES

i

! l t 1

2.1 NRC Inspection Manual Procedure 93801, Safety System Functional j inspection i

) 2.2 10CFR50.2, Definitions l i

i 2.3 NRC Confirmatory Order Establishing independent Correction Action i Verification Program - Millstone Nuclear Power Station, Units 1,2, and 3  :

O 2.4 NUMARC 90-12, Design Basis Program Guidelines 1 2.5 PI-MP3-02, Review of System Design for Compliance with Design &

} Licensing Basis l

2.6 PI-MP3-04, Programmatic Reviews j 2.7 PI-MP3-05, Physical Plant Configuration Walkdowns j 2.8 PI-MP3-06, Operations and Maintenance and Testing Procedures and l Training Documentation Reviews i

2.9 PI-MP3-09, Preparation and Approval of Checklists j 2.10 PI-MP3-11, Discrepancy Report Submittal and Closure j

j 2.11 PI-MP3-12, Project File Index m

]

1, i

i 4

Page 2 of 14 4

I 1 ,

A PROJECT INSTRUCTION -

p "

INSTRUCTION PI-MP3-03 REV.0

, 2.12 CK-MP3-03, Series Checklists as follows:

CK-MP3-03-01 Modification Review Administrative Checklist

! CK-MP3-03-02 Modification Screening Checklist CK-MP3-03-03 Mechanical Systems Design Review CK-MP3-03-04 Electrical Design Review

!l CK-MP3-03-05 l&C Design Review

! CK-MP3-03-06 Structural Design Review CK-MP3-03-07 ALARA Design Review j CK-MP3-03-08 Security Review CK-MP3-03-09 Appendix R Compliance Review

CK-MP3-03-10 Electrical Equipment Qualification Review CK-MP3-03-11 Seismic Qualification Review CK-MP3-03-12 Radiological Environmental Review l CK-MP3-03-13 Non-Radiological Environmental Review j CK-MP3-03-14 Station Blackout Review i CK-MP3-03-15 Control Panel Design Review i CK-MP3-03-16 Piping Design Review

O CK-MP3-03-17 Setpoint Database Design Review cx-ues-oa-'8 "ezeres'"e's eroorem aevie-CK-MP3-03-19 Fire Protection Review j CK-MP3-03-20 Licensing Review i CK-MP3-03-21 PRA Review l CK-MP3-03-22 Quality Software Design Review CK-MP3-03-23 Installation Plan Review l,

CK-MP3-03-24 Test Plan Review j CK-MP3-03-25 Project Closecut Review Note: Checklists used in the performance of this Pl are not included as

! attachments to the Pl. Checklists are prepared and controlled as j separate documents per PI-MP3-09, 3.0 DEFINITIONS i

3.1 Operations & Maintenance and Testing Review Group (ORG) - The subgroup of the ICAVP Verification Team responsible for the review of the  ;

operating, maintenance and testing procedures, and training materials for l the systems within the scope of the ICAVP. '

m Page 3 of 14

PROJECT

~ ' ' " " "

INSTRUCTION PI-MP3-03 INSTRUCTION - REV.0 3.2 System Review Group (SRG)-The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

3.3 Configuration Review Group (CRG)-The subgroup of the SRG responsible for walkdowns to verify the current as built conditions are in conformance with the design output documents.

{

3.4 Design Bases - The information which 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) restraints derived l from generally accepted " state of the art" practices for achieving functional goals or (2) requirements derived from analysis of the effects of a postulated accident for which a stri? ., system or component must l meet its functional goals (Reference 2.2).

3.5 Design Output Documents - Controlled plant documents such as specifications, drawings, vendor drawings, datasheets, lists and O databases (Reference 2.4).

3.6 Design Process Documents - Documents such as calculations, analysis, evaluations or other documented engineering activities that substantiate the final design (Reference 2.4).

3.7 Current Licensing Barls (CLB)-The set of NRC requirements i applicable to a specific plant, and a licensee's written commitments for i assuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the l license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19, 20, 21, 30, 40, 50, 51, 55, 72, 73,100 and appendices thereto; orders; license conditions; exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented in the most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as i

i Page 4 of 14

! f l PROJECT INSTRUCTION .

p#~ INSTRUCTION PI-MP3-03 REV.0 licensee commitments documented in NRC safety evaluations or licensee 4

event reports. (Reference 2.7) 3.8 Verifier - The individual assigned to review engineering attributes within his area of responsibility.

1 4.0 RESPONSIBILITIES 4

, 4.1 The Verification Team Manager shall be responsible for defining final report format and for overall management of the Verification Team.

) 4.2 The SRG Lead shall be responsible for assigning the Lead Verifier for

each system in the ICAVP scope and for overall coordination of the SRG

effort.

4.3 The Lead Verifier shall be responsible for reviewing modification elements

! within his area of expertise and for assigning verifiers with appropriate j background for review of remaining elements.

'O 4.4 Tae veririer "eiisereenemei8iererge<<ermioorevie or moeiricetioa elements within their area of expertise in accordance with this instruction.

/ 5.0 PROCEDURE 1

j 5.1 General f

+

The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in Section 2.0 of this PI requires Northeast Utilities (NU) to l j implement the ICAVP. The confirmatory order also defines the scope of J

the ICAVP. Item 1 of the scope of the ICAVP described on page 13 of the confirmatory order requires the Licensee to perform a review of the  ;

engineering design and configuration control processes. The scope of l the review encompasses the modifications to the selected systems since initiallicensing.

This procedure provides the instructions for performing an orderly review of the modifications to the selected systems in order to comply with the confirmatory order and applies to both major modifications and minor modifications. Like for like replacements are not included in the scope of ,

6 Page 5 of 14

i PROJECT INSTRUCTION PI-MP3-03 INSTRUCTION REV.0 this review. Adequacy of the engineering design process will be determined by performing detailed technical reviews of the modification 4

i design elements including changes to design process documents and design output documents. Adequacy of the configuration control process will be determined by verifying that changes resulting from the

modification have been reflected in design output documents, licensing i

documents such as the Technical Specifications and FSAR, plant procedures such as operating procedures, maintenance procedures and surveillance procedures, physical configuration and engineering programs. This project instruction only verifies the adequacy of the configuration control process as it relates to design output documents, engineering programs and licensing documents. Configuration control as ,

it relates to plant physical configuration and plant procedures U covered '

by PI-MP3-05 and -06, respectively. Review of NU's design change

process procedures is covered by PI-MP3-04.

The review of the system modifications shall be performed in ,

j chronological order because of the impact subsequent modifications 1 can have on previous modifications. The SRG shall also be O resPonsibie for cieariv identifvino prior to the CRG end ORG revie of the system modification, which portions of modification packages were

, subsequently revised by later modification. The SRG shall also clearly identify which modifications have not yet been installed. These measures are needed to prevent generation of erroneous discrepancy reports during the CRG system walkdowns and the ORG review of i plant procedures.

i The systems included in the scope of this review and the applicable modification packages were identified and retrieved as pad of the system review process described in Pl-MP3-02. The specific tasks associated i

with the review of modifications include:

a. Screening of affected modification elements.

b. Review of affected modification design elements.

c. Review of Installation and Test Plans.

d. Review of Changes to Licensing Documents.

e. Review of Modification Close-out.

f. Discrepancy Report Preparation and Closure.

g. Final Report Preparation.

o m . --.

Page 6 of 14

1

PROJECT

[y

~

INSTRUCTION PI-MP3-03 lNSTRUCTION ,

REV.0

The detailed instructions for performing these tasks are described in Subsection 5.2 through 5.8 below. Attachment 6.1 is a flow chart illustrating the modification review process.

l t

5.2 Screenino for Affected Modification Elenients

5.2.1 The SRG Lead shall screen the system modifications to identify

whether the modification is a Mechanical, Electrical, I&C or Structural modification. The SRG Lead shall then assign a Lead Verifier from j the applicable discipline to perform the modification review. The SRG 1

Lead shall document this assignment on the Modification Review I

Administrative Checklist (Checklist CK-MP3-03-01).  ;

1 1 5.2.2 The Lead Verifier sba!! screen the modifications for impact on I modification elements by completing the Modification Screening l Checklists (CK-MP3-03-02 Checklists). This task involves resocnding to a series of questions intended to minimize unn?cascory l

) discipline / program personnel review. The Lead Verifier may seek i assistance as needed from other members within the SRG to respond to questions outside his area of expertise.

i 5.2.3 The Lead Verifier and Verifier (s) shall respond 'yes' or "no" to each l question on the checklists and shall initial each response. The topics j addressed in the screening checklist include:

MODIFICATION SCREENING

SUMMARY

MECHANICAL SYSTEMS DESIGN REVIEW l . ELECTRICAL DESIGN REVIEW

. l&C DESIGN REVIEW l . STRUCTURAL DESIGN REVIEW l . ALARA DESIGN REVIEW

. SECURITY REVIEW APPENDIX R COMPLIANCE REVIEW l .

ELECTRICAL EQUIPMENT QUALIFICATION REVIEW e SEISMIC QUALIFICATION REVIEW

) .

RADIOLOGICAL ENVIRONMENTAL REVIEW

e NON-RADIOLOGICAL ENVIRONMENTAL REVIEW i . STATION BLACKOUT REVIEW J

. CONTROL PANEL DESIGN REVIEW l N Page 7 of 14

I

{ PROJECT ""

INSTRUCTION PI-MP3-03 INSTRUCTION .

REV.O i

• PIPING DESIGN REVIEW

I e

SETPOINT DATABASE DESIGN REVIEW e

HAZARDSIHELB PROGRAM REVIEW i e FIRE PROTECTION REVIEW l . LICENSING REVIEW j e PRA REVIEW e

TRAINING PROCEDURES REVIEW EMERGENCY PREPAREDNESS PROGRAM REVIEW l PLANT PROCEDURES REVIEW l (OPS, MAINTENANCE, SURVEILLANCE, TESTING) j e  !

CONFIGURATION CHANGE REVIEW l

e QUAllTY SOFTWARE DESIGN REVIEW

5.2.4 When the screening process has been completed, the Lead Verifier i shall indicate on the Modification Screening Checklist Summary Sheet j

(CK-MP3-03-02) which modification elements are affected. I

! 5.2.5 The Lead Verifier shall then assign Verifiers from the applicable I

{ discipline to perform a detailed review of the affected modification l j

elements in accordance with Subsection 5.3 of the project instruction.

If the screening process identifies that physical plant configuration or j plant procedures may be affected by the modification, the Lead l

] Verifier shall forward the completed Modification Screening Checidist (CK-MP3-03-02) and a copy of the modification package to the CRG j

and ORG for their review. This step shall not be performed until after all modifications to the system have been screened, the impact of

] subsequent modifications to previous modifications has been assessed, and the identification of modifications not yet installed has been completed. Note: CRG and ORG modification reviews are covered by PI-MP3-05 and 06, respectively.

I 4

5.2.6 The Lead Verifier shall document on the Modification Review l' Administrative Checklist (CK-MP3-0341) that the affected modification element screening process has been completed and shall file the i,

Modification Screening Checklist in the project file per PI-MP3-12.

I 1

i m Page 8 of 14

. -. . . . = . . - .-__ _ .- - - . - - - - - - - . .-

PROJECT d " "' INSTRUCTION PI-MP3-03 INSTRUCTION .

REV.0 5.3 Review of Affected Modification Elements 5.3.1 The Verifier (s) assigned by the Lead Verifier shall perform a detailed review of the affected modification design elements within his area of responsibility. The detailed review shall include a verification of the technical adequacy of changes to, or new, design process documents <

and design output documents prepared for the modification.

]

5.3.2 The Verifier (s) shall review the modifications utilizing the applicable 1 element review checklist. The element review checklists include: )

Checklist No. Description i l

CK-MP3-03-03 MECHANICAL SYSTEMS DESIGN REVIEW

! CK-MP3-03-04 ELECTRICAL DESIGN REVIEW CK-MP3-03-05 l&C DESIGN REVIEW l CK-MP3-03-06 STRUCTURAL DESIGN REVIEW l CK-MP3-03-07 ALARA DESIGN REVIEW t

CK-MP3-03-08 SECURITY REVIEW CK-MP3-03-09

,O ck-ues-os-,o APPENDIX R COMPLIANCE REVIEW e'ecraic^' eoUiPMeNT OuAlisiCATiON I

REVIEW l

CK-MP3-03-11 SEISMIC QUALIFICATION REVIEW CK-MP3-03-12 RADIOLOGICAL ENVIRONMENTAL REVIEW CK-MP3-03-13 NON-RADIOLOGICAL ENVIRONMENTAL REVIEW CK-MP3-03-14 STATION BLACKOUT REVIEW CK-MP3-03-15 CONTROL PANEL DESIGN REVIEW CK-MP3-03-16 PIPING DESIGN REVIEW CK-MP3-03-17 SETPOINT DATABASE DESIGN REVIEW i CK-MP3-03-18 HAZARDS /HELB PROGRAM REVIEW l CK-MP3-03-19 FIRE PROTECTION REVIEW CK-MP3-03-21 PRA REVIEW CK-MP3-03-22 QUALITY SOFTWARE DESIGN REVIEW l These checklists are intended to identify topics which should be reviewed for each element. The Verifier shall indicate on the checklist whether the topic has been addressed satisfactorily, was not addressed satisfactorily or is not applicable to the modification.

i l

Page G of 14

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

4 PROJECT INSTRUCTION PI-MP3-03 INSTRUCTION -

REV.0 l

i comments needed to substantiate the Verifier (s) response shall be

entered on the comment sheets included with each checklist.

i 5.3.3 The Verifier (s) shall perform a technical review of the new or revised design process docurnents in accordance with Section 5.4 of PI-MP3-02.

) 5.3.4 The Verifiers shall perform a technical review of new or revised design i output documents including drawings, specifications and or lists. The i review is a line by line review to verify the changes made to the design j output documents are technically correct and consistent with the level

of detail previously shown on the drawings.

5.3.5 When the review is completed, the Verifier shall sign and date the applicable element review checklist and forward the completed I checklist to the Lead Verifier.

L 5.3.6 The Verifier shall generate a discrepancy report for any discrepancies I

! identified during the review in accordance with Subsection 5.7 of this iO i

Preject imet<"ci>em- j i 5.3.7 The Lead Verifier shall indicate on the Modification Screening i Summary Checklist (CK-MP3-03-02) that the affected element has been reviewed and shall indicate whether any discrepancies were l l Identified. When all affected elements have been reviewed, the Lead j Verifier shat,' sign and date the Modification Screening Summary '

Checklist (CK-MP3-03-02), assemble and file the C.K-MP3-03-03 series detailed element review checklists in the project file per PI-

! MP3-12.

] 5.3.8 The Lead Verifier shall indicate on the Modification Review

{ Administration Checklist (CK-MP3-03-01) that the affected t

modification element detailed review process has been completed.

5.4 Review of installation & Test Plans 5.4.1 The Lead Verifier shall review the modification scope and confer with other modification verifiers to determine installation and test (s) requirements. The Installation Plan Checklist (CK-MP3-03-23) and Page 10 of 14

. l PROJECT INSTRUCTION PI-MP3-03 IQ INSTRUCTION REV.0 the Test Plan Checklist (CK-MP3-03-24) shall be used as the basis for identifying these requirements.

5.4.2 Once installation and testing requirements have been identified, the Lead Verifier shall assign verifiers to review the installation plan and l test plans contained in the modification package.

5.4.3 The Verifier (s) shall review the installation plans utilizing Checklist

, CK-MP3-03-23. This review is intended to verify that appropriate

installation requirements includhg welding procedures, ASME Section i

XI, NDE requirements, etc., are specified. Upon completion of their reviews, the Verifiers shall sign and date the checklists. Justification for responses entered on the checklists may be entered on the checklists comment sheet.

4 5.4.4 The Verifier (s) shall review the test plans utilizing Checklist CK-MP3- '

03-24. The review is intended to verify that adequate test j requirements including code required preservice tests and  !

inspections, component level tests, system level tests and integrated

,h tests are specified. Upon completion of the reviews, the Verifier (s)

shall sign and date the checklists. Justification for responses entered on the checklists may be entered on the checklist summary sheet. If l post modification tests are required, the SRG Lead Verifier shall i submit the test requirements and acceptance criteria and Checklist i

CK-MP3-03-24 to the ORG for review.

5.4.5 Discrepancies identified during the installation and test plan review i

shall be processed in accordance with Subsection 5.7 of this project instruction. DRs regarding post-modification tests shall be reviewed with the ORG to determine whether the test that ws performed was inadequate.

5.4.6 The Verifier (s) shall forward the completed checklists to the Lead Verifier.

5.4.7 The Lead Verifier shall indicate on the Modification Review Administrative Checklist (CK-MP3-03-01) that the installation and test plan review process has been completed and shall file the applicable checklists in the project file in accordance with PI-MP3-12.

4 Page 11 of 14

. _ _ _ _ __. . _ _ _ _ _ . . _ _ _ -~ .___ _____

t l

PROJECT INSTRUCTION PI-MP3-03 j INSTRUCTION . REV.0 l

5.5 Review of Chances to Licensino Documents 5.5.1 The Lead Verifier shall perform a review of changes to licensing documentation including FSAR changes and Technical Specification

, changes to ensure accuracy and completeness. The Lead Verifier shall perform a review of the 10CFR50.59 safety eva!uation or safety j evaluation screening to verify completeness and accuracy.

l 5.5.2 The Lead Verifier shall review the Licensing Document changes using Checklists CK-MP3-03-20. The intent of this review is to verify that i changes due to modifications have been reviewed for impact on the j FSAR and Technical Specifications. If it is determined that a change is required, the Lead Verifier shall verify changes were processed and i shall review these changes for consistency with the modification.

] Upon completion of the review, the Lead Verifier shall complete Checklist CK-MP3-03-20, enter any comments on the checklist

]1 comment sheet and sign and date the completed checklist.

l 5.5.3 The Lead Verifier shall review the safety evaluation prepared for the j modification using Checklist CK-MP3-03-20. The intent of this review

{ is to verify the modification is safe and satisfies the requirements of j

^

10CFR50.59. Upon the completion of the review, the Lead Verifier shall complete Checklist CK-MP3-03-20, enter any comments on the

, checklist comment sheet and sign and date the completed checklist.

5.5.4 The Lead Verifier shall generate a Discrepancy Report in accordance with Subsection 5.7 of this PI for any discrepancy identified while performing Subsection 5.5.2 and 5.5.3.

5.5.5 The Lead Verifier shall indicate on the Modification Review Administrative Checklist (CK-MP3-03-01) that review of licensing document changes and the safety evaluation has been completed and shall file the applicable checklists in the project file per PI-MP3-12.

l 5.6 Review of Modification Close-out Activities .

I 5.6.1 The Lead Verifier shall perform a review to verify adequate modification close-out. The intent of this review is to verify that changes identified in the modification package have been processed f

4

- Page 12 of 14

t

• PROJECT INSTRUCTION PI-MP3-03 INSTRUCTION s REV.O to incorporation ar are identified as open changes. The scope of this review includes t use design output documents, design process

, documents and licensing documents within the SRG scope. These I documents as a minimum include:

a. Calculations

b. Specifications

c. Drawings

! d. Lists and Databases

e. Engineering Program Documents i f. FSAR

g. Technical Specifications 5.6.2 The Lead Verifier shall review modification close-out activities using Checklist CK-MP3-03-25.

5.6.3 The Lead Verifier shall complete Checklist CK-MP3-03-25, note any comments on the checklist comment form, and sign and date the checklist.

5.6.4 The Lead Verifier shall generate a Discrepancy Report in accordance with Subsection 5.7 of this project instruction for any discrepancies identified during the review.

5.6.5 The Lead Verifier shall indicate on the Modification Review Administrative Checklist (CK-MP3-03-01) that the review of modification close-out activities has been completed and shall file the applicable checklists in the project file per PI-MP3-12.

5.7 Discrepancy Report Preparation and Closure 5.7.1 Discrepancy Reports for discrepancies identified during the system modification review process shall be prepared and processed in accordance with PI-MP3-11.

5.7.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in accordance with PI-MP3-11.

! N Page 13 of 14

PROJECT INSTRUCTION PI-MP3-03 INSTRUCTION REV.0 5.8 Final Report l 5.8.1 The Lead Verifier shall draft a final report summarizing the results of

) the system modification review. The results of the review tasks

'. described above shall be used to determine that adequacy of both

! design and configuration control processes for the development of j modifications after receipt of the operating license, l

j 5.8.2 The report format shall be determined by the Verification Team j Manager.

i

! 5.8.3 The report shall be reviewed and approved by the VT Leads, VT j Manager and IRC prior to external distribution.

l 6.0 ATTACHMENTS 6.1 lO f

ICAVP Process Flowchart,

• Review of Modifications". ( 1 page) 6 Page 14 of 14

Pi-MP3 03, REV. O ICAVP PROCESS FLOWCHART- ATTACHMENT 6.1

7. REVIEW OF MODIFICATIONS Screen Mod Pkos. to identify Lead Discipline l

SRG v ,

Screen Mod Packages l

to identify Affected  ;

Elements

)

Submit to CRG for SRG Submit to ORG for Does Mod  %%

Review +Yes ' Review change Physical effect OPS /Maint/ Yes +

per Pl-MP3-05 Y per PI-MP3-06 Con 5g? swves. Teett SRG Review Affected Engr. SRG Elements No No SRG

+ 4 CRG 4 ORG i Review Review Review l Not Licensing Changes Not l Required & Safety Eval. Required l l

Q SRC

+

Perform instal. & Test Requirement &

4 Acceptance Criteria SRG Submit Test Inst. &

Were All Criteria to ORG

-Yes Discrepancies 4 "? IS Post Mod Test Yes-* for Review identified? Required? per PI MP3-06 u SRG Process Discrepancy No No Reports + +

(PI-MP3-11)

ALL h

]

IP 1P Prepare O Report SRG

l PROJECT

• I " "'

INSTRUCTION PI MP3-04 INSTRUCTION -

REV.O

Client

Northeast Utilities l Station: Millsione Unit 3 i

i

Title:

PROGRAMMATIC REVIEWS I

i l

i 8 Safety-Related _

Non Safety-Related Reviewed By: Approved By:

i j System Lead Programmatic O&M Lead Accident QA Engineer intemal Review Verification Team 1 Lead Mitigation Committee Manager 1

Lead Chairman l , , Date: 3*S '$l

/

h$$ $$ $lhlxt& Y bYtthy fkmbadN b?? m/ Wb Description u Irhtlat fd'e V' i

l l

i i

i

)

}

1 i

i j

i

)O a

Page 1 of 7 l

I

l PROJECT k "

INSTRUCTION PI-MP3-04 l INSTRUCTION REV.0 l

2 1.0 Purpose This project instruction (PI) establishes the Sargent & Lundy procedure for performing programmatic reviews as a part of the ICAVP. These programmatic reviews are performed in addition to the ICAVP system design and licensing basis, O&M and '

testing, accident mitigation system reviews, and physical configuration reviews. The i programmatic reviews are conducted on a horizontal basis (across systems) for the purpose of determining if the actions taken by Northeast Utilities (NU) to correct

' previously identified problems have been effective and if the NU change processes are effective.

' The scope of the programmatic reviews willinclude:

2 i

Licensee initiated Corrective Actions 4

As part of its Configuration Management Program (CMP), NU has performed a vertical slice review of safety-significant and risk significant systems and has identified I degraded or non-conforming conditions. For the degraded or non-conforming

conditions NU is initiating corrective actions. The programmatic review will assess the adequacy of these corrective actions. This review will be conducted for all corrective actions associated with the ICAVP sample systems, and for a representative sample of

corrective actions associated with the other NU completed CMP vertical slice systems.

! Chance Processes i

NU's current plant change processes will be reviewed for both their adequacy with i i respect to industry standards and for the effectiveness by which they are being t

implemented. Both design change processes and procedure change processes will be included in this review.

4 2.0 References 2.1 NRC Confirmatory Order Establishing Independent Corrective Action '

Verification Program - Mi!! stone Nuclear Power Station, Units 1,2 and 3 2.2 Millstone ICAVP Oversight inspection Plan, approved 12/19/96 2.3 PI-MP3-09, Preparation and Approval of Checklists 2.4 PI-MP3-11, Discrepancy Report Submittal and Closure 2.5 NUMARC 90-12, Design Basis Program Guidelines o

h Page 2 of 7

PROJECT INSTRUCTION PI-MP3-04 INSTRUCTION REV.0 2.6 PI-MP3-12, Project File Index i 2.7 CK-MP3-04, Series checklists as follows:

j

! CK-MP3-04-01 Corrective Actions CK-MP3-04-02 Change Process Review j CK-MP3-04-03 Change Procedure implementation I

j Note: Checklists used in the performance of this P1 are not included as attachmens to the Pl. Checklists are prepared and controlled as separate l

} documents per PI-MP3-09. l 3.0 Definitions

! 3.1 Programmatic Review Group (PRG)- The subgroup of the ICAVP Verification l l

Team responsible for performing the reviews of corrective actions and change

processes.

i 1 3.2 Current Licensing Basis (CLB)- The set of NRC requirements applicable to a specific plant, and a licensee's written commitments for assuring compliance  !

~ with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,30,40, 50, 51, 55, 72, 73,100 and appendices thereto; orders; license conditbns; exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented hi the most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports.

3.3 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

3.4 Operat!ons & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training manuals for the systems within the scope of the ICAVP.

6 Page 3 of 7

J

PROJECT INSTRUCTION PI-MP3-04 INSTRUCTION , REV.0 3.5 Design Bases - The information which 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) restraints derived from generally accepted " state of the art" practices for achieving functional goals or (2) requirements derived from analysis of the effects of a postulated accident for which a structure, system or component must meet its functional goals.

3.8 Verifier - The individual assigned to review engineering attributes within his area of

responsibility.

3.7 Discrepancy Report (DR)- The mechanism for documenting the discrepant conditions identified by the ICAVP and reporting an apparent error, inconsistency,

or procedural violation with regard to licensing commitments, specifications, i procedures, codes or regulations.

4.0 Responsibilities 4.1 The Programmatic Review Group Lead shall be responsible for assigning the i verifier for each programmatic review and for overall coordination of the O Programmatic Review effort. He shall also approve checklists that are prepared for each program review, and he shall provide concurrence after the review is performed that the checklist is complete.

4.2 The Verifier shall be responsible for performing the programmatic review and 4

completing the appropriate checklist. The Verifier or any other appropriate l PRG Member shall prepare checklists prior to a program review, t

5.0 Procedure 5.1 Corrective Actions 5.1.1 General i

All NU identified corrective actions for the ICAVP sample systems shall be

included in the programmatic review. For the remaining systems in the CMP i vertical slice which have been completed by NU, a statistically significant (95/95 i

confidence / reliability) random sample of NU corrective actions shall be reviewed. It is not the intant of the ICAVP to verify completion of the corrective l action, but only to assess the acceptability of the proposed corrective action.

3 Therefore, it is only necessary that the corrective action determination be

completed by NU to be included in this sample.

i Page 4 of 7

i i

PROJECT * "'

INSTRUCTION PI-MP3-04 INSTRUCTION s REV.0 3 5.1.2 Review Process i

The NU CMP findings / corrective action documents sha!! be obtained from the i

j SRG for the ICAVP sampled systems. The other CMP completed findings / corrective action documents (for systems outside the ICAVP) shall be

obtained from NU.

Checklist CK-MP3-04-01, " Corrective Actions" shall be prepared by an i

appropriate team member for the review of corrective actions. Using the checklist, the PRG Verifier shall assess the corrective actions for adequacy of the following:

i a. Root cause determination - what is the fundamental cause, which, if

corrected, wi!! prevent recurrence of the condition? Are plant processes or procedures affected?

b.

Extent of condition determination - the extent to which other systems, structures, components, or activities are affected.

c. Plant restart - is the corrective action required prior to restart?

d. Content - is the corrective action adequate in resolving the issue?

l j

After reviewing the checklist for completeness, the PRG Lead shall file the

{ checklist in accordance with PI-MP3-12.

i j 5.1.3 Discrepancies i

The Verifier shall prepare a Discrepancy Report in accordance with PI-MP3-11 l for any discrepancies identified during the corrective action review.

j 5.2 Chance Processes i

j 5.2.1 General i

As part of the ICAVP system reviews, the SRG and the ORG will assess the plant modifications made on the systems sampled inthe ICAVP. This review will i evaluate the effectiveness of the change processes involved in these i

i modifications (i.e. if the resulting modification is found to be acceptable, it can j

be inferred that the process used in performing the modification is acceptable).

in addition to this system review, specific process related reviews will also be 3

performed as controlled by this Pl. The various change processes reviewed l shallinclude the following:

i N Page 5 of 7

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

i i

PROJECT *"

INSTRUCTION PI-MP3-04 INSTRUCTION REV.0 I Process Correspondina MP3 Procedure 1

drawings NUC DCM Chapter 7 specifications NUC DCM Chapter 6 f calculations NUC DCM Chapter 5 i

j procedures DC1, DC2, DC3, DC4 i

k temporary afterations (if applicable) minor modifications NUC DCM Chapter 3 1

modifications NUC DCM Chapter 3

licensing documents NGP-4.03 i

! vendormanuals NUC DCM Chapter 8 like forlike replacements NUC DCM Chapter 1 l f.2.2 Review Process A. Assess Adequacy of Process The current MP3 procedure for the process listed in Section 5.2.1 will be evaluated for its content and completeness. This evaluation will determine if the procedure exercises adequate controls on the change process and invokes appropriate interface reviews to assure the plant design basis and configuration is maintained consistent with the licensing basis. The evaluation will be based on guidance provided in the following:

Reg. Guide 1.33 Quality Assurance Program Requirements (Operation)

NRC Inspection Manual INPO guidelines INPO 87-006 Report on Configuration Management in the Nuclear industry NEl guidelines i

i Page 6 of 7  !

)

4 e

i PROJECT $ ""' INSTRUCTION PI-MP3-04 INSTRUCTION -

REV.O i -

i i

j Checklist CK-MP3-02, " Change Process Review" shall be prepared by an appropriate team member for the evaluation of the current MP3 i

j procedures according to the above. Using the checklist, the PRG Verifier i shall assess the adequacy of each procedure. After reviewing the i checklist for completeness, the PRG Lead shall file the checklist in accordance with PI-MP3-12.

} B. Assess implementation of Procedures

! The adequacy of NU's implementation of the change process procedure j will be evaluated by reviewing actual plant change documentation. The

evaluation will determine if the procedure is being followed, that the i required checklists are being accurately and completely filled in, and that all other documentation is complete and procedurally adequate. This i

evaluation shall be performed for the plant changes captured in the 4 ICAVP system reviews. If any of the processes noted in Section 5.2.1 1

are not included in the system reviews, an example outside the ICAVP will be selected for review. Since the system review will assess the

{

technical adequacy of the change, the programmatic review will evaluate only the procedural adequacy of the change.

O Checklist CK MP3-04-03, " Change Procedure implementation" shall be prepared by a qualified team member for the evaluation of the implementation of MP3 procedures on current changes according to the above. Using the checklist, the PRG Verifier shall assess the adequacy of each change. After reviewing the checklist for completeness, the PRG 1.ead shall file the checklist in accordance with PI-MP3-12, 5.2.3 Discrepancies The Verifier shall prepare a Discrepancy Report in accordance with PI-MP3-11 for any discrepancies identified during the change process reviews 6.0 Attachments 6.1 1CAVP Process Flowchart, " Programmatic Reviews"(1 page) am Page 7 of 7

PI MP3-04 Attachment 6.1 j

C Gather Programmatic Documents-1 AITTS Listing PRG '

2 i

, l l

Prepare Checklists

]

l PRG

_3r

_ ir ir i

' Obtain ChanQe Perform Change Documentation from i Select Corrective Process Procedure SRG,NU Action Samples Review PRG PRG PRG i i ( \

• lb ,,

Perform Process implementation

~

Review Perform Corrective PRG Action Review 4

, PRG l Were i Discrepancies No i Identified?

Yes i

? 1r Process Discrepancy File Checklist per Report per PI-MP3-11 PI-MP3-12 PRG PRG

{ '

ICAVP PROCESS FLOWCHART Programmatic Reviews

l

! PROJECT INSTRUCTION PI-MP3-05 l

g INSTRUCTION -

REV.O Client: Northeast Utilities SidJon: Millstone Unit 3

Title:

PHYSICAL PLANT CONFIGURATION WALKDOWNS l h Safety-Related Non-Safety-Related i I

! Reviewed By: Approved By:

I l System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team j Lead Mitigation Committee i

Manager

' Lead / Chairman

_. y _

Date: 3Yi7 l

'LY hh1Lhy ,pkjeih h '

hK,b

• Description '

l u1 initIdfIs/de i

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

PROJECT P*" INSTRUCTION PI-MP3-05 INSTRUCTION REV.O

! 1.0 PURPOSE I

This instruction establishes the requirements for conducting physical i walkdowns of the systems included in the scope of the Independent Corrective l Action Verification Program. The scope includes Phase 1 - Syatem Functional l Walkdowns and Phase 2 - Detailed Walkdowns of Modification implemented l After Receipt of Operating License.

l 1

! 2.0 REFERENCE i

I 2.1 NRC Inspection Manual Procedure 93801, Safety System Functional j inspection

) 2.2 NRC Oversight inspection Plan for the Millstone Independent Corrective Action Verification Program dated 12/19/96. 1

2.3 NRC Confi

matory Order Establishing independent Correction Action i Verification Program - Millstone Nuclear Power Station, Units 1,2, jO end a l 2.4 PI-MP3-01, ICAVP Communications Protocol

]

l 2.5 PI-MP3-02, Review of System Design for Compliance with the Design j and Licensing Basis t

l

!' 2.6 PI-MP3-03, Review of Plant Modifications Prepared After Receipt of l I

l Operating License for Technical Adequacy and for Configuration i Control i 2.7 PI-MP3-09, Preparation and Approval of Checklists l

2.8 PI-MP3-11, Discrepancy Report Submittal and Closure 2.9 PI-MP3-12, Project File Index l

N Page 2 of 12

PROJECT INSTRUCTION PI-MP3-05 i INSTRUCTION REV.O i

l 2.10 CK-MP3-05, Series Checklists as follows:

CK-MP3-05-01 Walkdown Control Checklist l CK-MP3-05-02 Physical Drawing Review Attributes Checklist

CK-MP3-05-03 Functional Walkdown Checklist

CK-MP3-05-04 Modification Walkdown Checklist l Note

Checklists used in the performance of this Pi are not

included as attachments to the Pl. Checklists are j prepared and controlled as separate documents per PI-i MP3-09.

l l 3.0 DEFINITIONS l

l 3.1 System Review Group (SRG)- The subgroup of the ICAVP Verification i Team responsible for performing an in-depth review of the design of the j systems in the scope of the ICAVP.

3.2 Configuration Review Group (CRG)-The subgroup of the SRG lO j

ve<irio tien Teem reePenei8ie rerweixeewne io ve<ir conditions are in conformance with the design output documents.

v the cerrent e-eeiii

! 3.3 Design Output Documents - Controlled plant documents such as

specifications, drawings, vendor drawings, datasheets lists and j databases (Reference 2.4).

i 3.4 Walkdown Team - The team from within the CRG responsible for performing walkdowns in accordance with the instructions. The team shall consist of, as a minimum, an engineer (Lead Verifier) and one mechanical and one electrical designer (Verifier).

4.0 RESPONSIBILITIES 4.1 The SRG Lead shall have overall responsibility for the implementation of the physical configuration walkdowns.

4.2. The CRG Lead shall be responsible for providing overall direction to the CRG at S&L's offsite office and shall be responsible for interfacing with the SRG Lead.

m Page 3 of 12 I

)

\

PROJECT INSTRUCTION PI-MP3-05 INSTRUCTION .- REV.0 4.3 The Lead Verifier shall be responsible for: l j .

1 i

e Coordination of system walkdowns I

' . Reviewing checklists, system boundary drawings and redline i drawings prepared by the walkdown team verifiers f 4.4 The Verifier (s) shall be responsible for: I j e Performing system and modification walkdowns & completing j applicable checklists

! e Preparing redline drawings l

• Preparing system boundary drawings l e Verifying that modification packages agree with current design i drawings l

5.0 PROCEDURE l

i 5.1 General The Nuclear Regulatory Commission (NRC) Confirmatory Order

(Reference 2.3) requires Northeast Utilities (NU) to implement the l lCAVP. The confirmatory order also defines the scope of the i ICAVP. Item 2 of the scope of the ICAVP described on page 13 of the confirmatory order requires the Licensee to verify the current as-modified plant conditions against design basis and licensing basis documentation for the specific systems selected by the NRC.

This procedure describes one aspect of the process needed to i perform the verification described above. Specifically, this procedure shall determine if the current system design as reflected  !

on design output documents is consistent with the physical installed condition of the plant. This determination shall be made by performing physical walkdowns of the plant systems. The walkdowns shall be performed in two phases. Phase 1 shall i perform functional walkdowns of the entire system to verify the current configuration is consistent with the current design output documents. Phase 2 shall perform a detailed walkdown of the portions of the system modified after receipt of operating license to verify the modified installation is consistent with the modification package. The Phase 2 walkdown shall include more extensive Page 4 of 12

PROJECT INSTRUCTION PI-MP3-05 INSTRUCTION REV.0 l dimensional checks, such as spool end to end dimensions, hanger

locations, etc., which are not required for the Phase 1 walkdown.

~

The decision to exclude dimensional checks for the Phase 1 ,

l l walkdown was based on the guidance provided in References 2.1 i and 2.2 and the fact that various inspection programs were j typically implemented during initial plant construction and startup j prior to receipt of an operating license.

i l The systems to be included in the scope of the ICAVP will be 3

defined by the Nuclear Regulatory Commission. Once the systems l have been identified, the first step is to gather the applicable j system documents. This activity shall be performed in conjunction 4 with the SRG as outlined in PI-MP3-02. Once the documents have j been gathered, the following tasks shall be implemented per this procedure:

I a. General Walkdown Preparation i b. Phase 1 Walkdown and Planning iO c.

d.

Phese 2 Weikeewn ene Pienning Walkdown Documentation Package Assembly i e. Discrepancy Report Preparation and Closure j f. Final Report Preparation 4

1 Attachment 6.1 is a process flowchart illustrating the Physical l Configuration Walkdown process.

I j 5.2 General Walkdown Preparation Reauirements l 5.2.1 The CRG Lead shall be responsible for assigning a walkdown tearn for l each system in the scope of the ICAVP. The CRG Lead shall i document the walkdown team assignment in the appropriate blocks of 1 l the Walkdown Control Checklist (CK-MP3-05-01). The Walkdown l

! Team shall consist as a minimum of an engineer (Lead Verifier), and

. one electrical and one mechanical designer (Verifier (s)). l i Note: The assigned walkdown team is responsible for implementing j both phases of the walkdown for that system.

1 1 I j Page 5 of 12

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

PROJECT *"

INSTRUCTION PI-MP3-05 INSTRUCTION ,

REV.O I i

l

! 5.2.2 The Lead Verifier shall obtain a copy of all applicable design output j

documents for the system and all plant modification packages for that system (Refer to Section 5.2 of PI-MP3-02).

1

) 5.2.3 The Lead Verifier shall identify the plant areas which contain the j system from general arrangement drawings. The Lead Verifier shall schedule the walkdown, notify the appropriate plant personnel and

{ obtain all necessary clearances. Discussions and/or contacts with NU

personnel shall be in accordance with the protocol outlined in PI-MP3-

! 01. '

s 5.3 Phase 1 Watkdown & Plannina 5.3.1 The Walkdown Team shall highlight the system boundaries on the j following drawir.gs, as applicable:

a. P&lDs l b. Piping Isometrics l

lO i

}

c.

e.

e.

Electrical Schematics and Single Line Drawings siectriceie"veiceiComeeitene Trev aoetioo ore ioos Vendor Skid Drawings i

l 5.3.2 The Walkdown Team shall identify all support drawings (pipe and electrical), equipment mounting details, component vendor drawings and instrument details for components to be verified in the walkdown.

5.3.3 The Lead Verifier shall review the boundary drawings and commodity drawings with the applicable Lead Verifier from the SRG. The respective Lead Verifiers shall resolve any comments and denote their concurrence by signing and dating the applicable blocks on the Walkdown Control Checklists. The CRG Lead Verifier shall list all applicable documents including revision number or date on the Walkdown Control Checklist (CK-MP3-05-01).

5.3.4 The Walkdown Team shall incorporate all open change documents (redline) into the parent document. Redlining shall be limited to incorporation of only those details which will be verified during the walkdown (i.e., since Phase 1 walkdowns do not verify dimensions, m Page 6 of 12

O PROJECT

'NSTRUCTioN "f"' -

INSTRUCTION PI-MP3-05 Rev. 0 dimensional data need not be shown). The Lead Verifier shall list all the incorporated change documents on the redlined documents.

Note: Only those change documents which have been completely installed shall be included in the redline scope. These will ,

be identified by the SRG. '

5.3.5 The Lead Verifier shall note completion of the redline step on the I

Walkdown Control Checklist (CK-MP3-05-01) and shall initial and date the ently.

5.3.6 The Walkdown Team shall perform a review of the lower tier drawings versus the upper tier drawings as follows:

l Note: Upper tier drawings will be reviewed against calculations, specifications and design and licensing bases by the SRG per PI-MP3-02. The intent of this review is to verify the l consistency of the piping isometrics and electrical physical

! drawings and electrical single lines to the upper tier documents.

l 5.3.6.1 The Walkdown Team shall review the following drawings:

a. P&lDs versus Piping Isometrics

b. Electrical schematics versus electrical single lines and electrical physical drawings.

The review attributes shall be in accordance with the Physical Drawing Review Attributes Checklist (CK-MP3-05-02).

5.3.6.2 The Walkdown Team shall prepare an individual CK-MP3-05-02 Checklist for each type of drawing reviewed and shall sign and i date each checklist.

l 5.3.6.3 Discrepant conditions identified during this review shall be processed in accordance with Subsection 5.6 of this project instruction.

l

\

Page 7 of 12

._. _ _ .._ _ _ _ _ _ ~. _ _. __ _ _ _ _ . . ____ _ ._ _._ _ _ _ ._ _ __

4 ,

}

PROJECT INSTRUCTION .

f"" INSTRUCTION PI-MP3-05 REV.0 l 5.3.6.4 The Lead Verifier shall indicate completion of the physical drawing

review step on the Walkdown Control Checklist (CK-MP3-05-01) l and shallinitial and date the entry.

l 5.3.7 The Walkdown Team shall perform the Phase 1 system functional l walkdowns as follows:

i i 5.3.7.1 Phase 1 system functional walkdowns shall be performed using the

! Functional Walkdown Checklist (CK-MP3-05-03). Each attribute j verified during the walkdown shall be verified by two walkdown i team members.

l l 5.3.7.2 The Phase 1 functional walkdown shall in general verify the nameplate data of the system components, check for physical damage and functionally check system installation by checking the i following items for proper configuration (not dimensions):

i a. Equipment Nos. and Equipment Location i b. Piping Line Size (Diameter) l \, c. Pipe configuration functional location of bends, valves, l supports, and other in line components j d. Valve orientation and flow direction

e. Insulation and/or heat tracing

! f. Support type

g. Equipment and support mounting type and anchorage details (No. of bolts, weld pattern, etc.)

h. Cables are functionally routed to appropriate "To" and "From" equipment.

] i. Conduit size, cable size where practical i J. Conduit support and cable tray support type j k. Configuration of tubing and electrical for instrumentation l Note: If pipelines are insulated, verification shall be accomplished i by adding insulation thickness to line size and measuring outside j diameter ofinsulation.

h Refer to checklists CK-MP3-05-03 for further details and attributes.

i 1

l N Page 8 of 12 i

I i

)

PROJECT INSTRUCTION M[# /

INSTRUCTION PI-MP3-05 REV.0 l l

l The walkdown shall also review divisional separation and seismic i ll/l attributes. Specifics are provided on the functional walkdown  ;

l checklist (CK-MP3-05-03) l 5.3.7.3 The Walkdown Team shall enter the nameplate data found on the

components in the applicable section of the Functional Walkdown

Checklist (CK-MP3-05-03).

i

}

~ 5.3.7.4 The Walkdown Team shall note visible physical damage, such as separated supports, in the applicable section of the Functional Walkdown Checklists (CK-MP3-05-03).

J

) 5.3.7.5 The Was,down Team shall mark any configuration discrepancies j identified during the walkdown directly on the redline drawings

! developed in step 5.3.4.

j 5.3.7.6 The Walkdown Tevn shallinitial and date any entries made on the Functional Walkdown Checklists (CK-MP3-05-03) or Redline

'O i

drawings.

5.3.7.7 Following completion of the walkdown, the Walkdown Team will verify nameplate date recorded in the field with the vendor i drawings and indicate any discrepancies on the Functional l Walkdown Checklist (CK-MP3-05-03).

i

! 5.3.7.8 The Lead Verifier shall review the completed Functional Walkdown l Checklist (CK-MP3-05-03) to ensure it has been properly i completed and shall note his concurrence by signature and date.

' 5.3.7.9 Discrepant conditions identified during this review shall be processed in accordance with Subsection 5.6 of the project instruction.

5.3.7.10The Lead Verifier shall indicate completion of the functional walkdown step on the Walkdown Control Checklist (CK-MP3 01) and shall initial and date the entry.

i i

o

- Page 9 of 12

-t PROJECT INSTRUCTION PI-MP3-05

'O 'sSTRuCriOs 7 REv. 0 i

j 5.4 Phase 2 Walkdown & Plannino l 5.4.1 During the system modification review, the SRG shall per PI-MP3-l 03, identify any modifications to the system being reviewed which l resulted in plant configuration changes. The SRG will also identify j which portions of a previous modification were revised by a j subsequent modification.

j 5.4.2 Upon receipt of the modification data from the SRG, the Lead i Verifier shallinitiate a physical walkdown of the modified portion of

! the system by initiating a Modification Walkdown Checklist (CK-

! MP3-05-04). A separate modification walkdown checklist shall be l prepared for each system modification being reviewed. The Lead l Verifier will enter the modification number and description on the l checklist (CK-MP3-05-04).

! 5.4.3 The Walkdown Team shall review the document changes

contained in the mcdification package versus the redline drawings i

prepared as part of the system walkdown (Subsection 5.3 of this project instruction). Discrepancies shall be noted on the Modification Walkdown Checklist (CK-MP3-05-04).

5.4.4 The Lead Verifier shall identify key critical dimensions that will be checked by the Walkdown Team. The Lead Verifier shall note these key critical dimensions on the Modification Walkdown Checklist (CK-MP3-05-04). Key critical dimensions may include analytical / calculation bases, specific dimensional limits and requirements stated on the drawings which deviate from the standard installation tolerances, etc.

5.4.5 The Walkdown Team shall perform a walkdown of the modified area to verify installation is in accordance with the modification package. This step includes checking critical dimensional data included in the mo jification package. Any discrepancies shall be noted on the Modilication Walkdown Checklist (CK-MP3-05-04).

m Page 10 of 12

i PROJECT iO INSTRUCTION -

INSTRUCTION PI-MP3-05 REv. 0 l

! 5.4.6 Upon completion of the walkdown, the Walkdown Team shall sign

! and date the completed Modification Walkdown Checklists (CK-l MP3-05-04) and shall generate a Discrepancy Report per l Subsection 5.6 for any discrepant conditions identified during the

walkdown.

4 5.4.7 The Lead Verifier shall review the completed Modification Walkdown Checklists (CK-MP3-05-04) for completeness and shall l signify his concurrence by signing and dating the checklist.

j 5.4.8 The Lead Verifier shallindicate completion of the modification j

walkdown on the Walkdown Control Checklist (CK-MP3-05-01) and l shallinitial and date the entry.

5.5 Walkdown Documentation Packaae Assembly

5.5.1 The Lead Verifier shall assemble a documentation package l consisting of the following

• Reference Drawings

. Redline Drawings

! . CK-MP3-05 Series Checklists i

5.5.2 The Lead Verifier shall distribute the package to the project file in j accordance with PI-MP3-12.

j 5.5.3 The Lead Verifier shall indicate completion of this step by signing i and dating the Walkdown Control Checklist (CK-MP3-05-01).

d j 5.6 Discrepancy Report Preparation and Closure j

5.6.1 Discrepancy Reports for discrepant items identified during the system and modification walkdowns shall be prepared and processed in accordance with PI-MP3-11. Discrepancy reports shall not be initiated for findings already identified by NU during implementation of the CMP.

5.6.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in acco"Jance with PI-MP3-11.

m Page 11 of 12

i PROJECT ""

INSTRUCTION PI-MP3-05 INSTRUCTION REV.O l

i i

)l 5.7 Final Reoort

}

} 5.7.1 The Lead Verifier shall draft a final report summarizing the results i

of the system and modification walkdowns.

l, j 5.7.2 The report format shall be determined by the Verification Team j

4 Manager.

1

! 6.0 ATTACHMENTS 6.1 ICAVP Process Flowchart, " Physical Plant Configuration

! Walkdowns". (1 page)

'I i

I i

!O i

i i

i i

i l

.i j

m i

Page 12 of 12

PI-MP345, REV. O ICAVP PROCESS FLOWCHART ATTACHMENT 6.1

, PLANT PHYSICAL A8' ion W8Ikdo*a I'**

CONFIGURATION WALKDOWNS CRG Lead v

Gather Documents per PI-MP3-02 Lead Verifier i

d 1F Obtain Clearance /

Schedule Walkdowns

. Obtain Installed Mod Lead Verifier Packages from SRG Der Pl-MP3-03 Lead Verifier "

Define System

Boundries/ Review with v v SRG Review Mod Package Lead Verifier /SRG 4

vs. Redline Drawings Walkdown Team V Redline Walkdown f]

NJ V Documents

^

Define Key Critical Walkdown Team i Dimensions Lead Verifier "

Review Lower Tier Docs vs. Upper Tier v

Perform Modification Walkdown Team J I

Walkdown Walkdown Team "

Perform Functional Walkdowns Waikdown Team ar Are Discrepancies \ No identified?

Yes

, + v Prepare & Process Prepare input for DRs per PI-MP3-11 Report SRG CRG

4 1

- " ~f""

2 PROJECT INSTRUCTION PI-MP3-06 INSTRUCTION - REV.0

.i I

Client: Northeast Utilities Station: Millstone Unit 3 j

Title:

OPERATIONS AND MAINTENANCE AND TESTING PROCEDURES AND TRAINING j DOCUMENTATION REVIEWS l

l Safety-Related Non-Safety Related i I Reviewed By: Approved By:

I 1

System Lead Programmatic O&M Lead Accident QA Engineer Intemal Review Verification Team Lead Mitigation Committee Manager Lead Chairman O $Y ,, _ ,,

V! N $$s2 $lOd1erv $

/ ,

h E'YY Date: S* d'9?,.

Description J '

Irfat isfde

]/)

O-l Page 1 ofl9

t I

i

/8/"~

PROJECT INSTRUCTION PI-MP3-06 i

INSTRUCTION REV.O 1 PURPOSE

, The purpose of the Operations, Maintenance and Testing (O&M&T) portion of the i

Independent Corrective Action Verification Program (ICAVP) is to determine whether l the design and licensing bases for Millstone, Unit 3, have been adequately translated into operating, maintenance and test procedures for the selected systems. The O&

M&T portion of the ICAVP will also verify that changes made to Unit 3 since issuance of

the operating license were implemented by appropriate procedure changes and

' testing. Training program procedures and other Significant Support / Interacting Systems and Related Activities required for proper implementation of these procedures and testing will also be evaluated. The O&M& Twin also confirm that current testing requirements, maintenance, and post modi'ication testing are adequate to verify l system performance, i

j 2 REFERENCES

! 2.1 NRC Inspection Manual Procedure 93801, Safety System FunctionalInspection.

2.2 10 CFR 50.2, Definitions.

2.3 NRC Confirmatory Order Establishing Independent Corrective Action j Verification Program - Millstone Nuclear Power Station, Units 1,2, and 3.

2.4 NRC ICAVP Oversight and Inspection Plan, dated December 19,1996.

j 2.5 Regulatory Guide 1.33. Revision 2, Quality Assurance Program Requirements

(Operations) 2.6 NUMARC 90-12, Design Basis Program Guidelines, j 2.7 NRC Generic Letter 90-03, Relaxation of Staff Position in Generic Letter 83-28,

} ltem 2.2, Part 2, Vendor Interface for Safety-Related Components.

4 2.8 NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability.

2.9 PI-MP3-01, independent Corrective Action Verification Program Communications Protocol.

2.10 Pl-MP3-02, Review of System Design for Compliance with the Design and Ucensing Basis.

/

Page 2 of 19

i

/

PROJECT INSTRUCTION

• %ers #

INSTRUCTION PI-MP3-06 REV.0 1

2.11 P1-MP3-03, Review of Plant Modifications Prepared After Receipt of Operating

License for Technical Adequacy and for Configuration Control.

)

i 2.12 PI-MP3-04 Programmatic Reviews l

l 2.13 PI-MP3-05, Physical Plant Configuration Walkdowns.

i j 2.14 PI-MP3-07 Review of Accident Mitigation Systems i

l 2.15 PI-MP3-09, Preparation and Approval of Checklists.

I j 2.16 PI-MP3-11, Discrepancy Report Submittal and Closure.

4 I 2.17 PI-MP3-12, Project File Index.

f j  ? 13 CK-MP3-06 Series Checklists as follows:

1 I i

CK-MP3-06-01 Accident Mitigating Systems-Critical Parameters Checklist

) CK-MP3-06-02 Bases / Change Features Checklist i CK-MP3-06-03 System Modes / Phases Checklist i CK-MP3-06-04 P&lD Checklist CK-MP3-06-05 Significant Support / Interacting Systems and Related Activities Checklist.

CK-MP3-06-06 Supplemental Documents Checklist CK-MP3-06-07 Process Indications Checklist CK-MP3-06-08 Vendor Manuals / Files Checklist CK-MP3-06-09 Performance History Files Checklist CK-MP3-06-11 Mod Procedures Checklist CK-MP3-06-12 PRG Change Process Procedures Checklist CK MP3-06-13 Training Materials Checklist CK-MP3-06-14 Testing Requirements Checklist CK-MP3-06-15 Testing Requirements Review Checklist CK-MP3-06-16 Test Procedure Adequacy Checklist CK-MP3-06-17 Testing Records Review Checklist CK-MP3-06-18 Procedures Observed in The Field Checklist Note: Checklists used in the performance of this PI are not included as attachments to the Pl. Checklists are prepared and controlled as separate documents per PI-MP3-09.

o m Page 3 of 19

t

) PROJECT f#"" INSTRUCTION PI-MP3-06 INSTRUCTION -

REV.0 1

3 DEFINITIONS 3.1 Operations & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification Team responsible for review of the operating, maintenance and testing procedures, and training materials for the systems

) within the scope of the ICAVP.

, 3.2 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

i 3.3 Configuration P.eview Group (CRG)- The subgroup of the SRG Verification l Team responsible for walkdowns to verify that the current as-built conditions are j in conformance with the design output documents.

3.4 Accident Mitigation Review Group (ARG)- The subgroup of the ICAVP

[ Verification Team responsible for the review of the critical system attributes of i

the systems used to mitigate the consequences of an accident, 1 3.5 Programmatic Review Group (PRG)- The subgroup of the ICAVP Verification Team responsible for performing a review of the design control and corrective j action processes in the scope of the ICAVP.

i i 3.6 Current Licensing Basis (CLB)- The set of NRC requirements applicable to a i

specific plant, and a licensee's written commitments for assuring compliance

} with and operation within applicable NRC requirements and the plant-specific j design basis (including all modifications and additions to such commitments j

over the life of the license) that are docketed and are in effect. The CLB

' includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,30,40, 50, 51, 55, 72, 73,100 and appendices thereto; orders; license conditions; exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented in the most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 i and the licensee's commitments remaining in effect that were made in docketed j

licensing correspondence such as licensee responses to NRC bulletins, generic j letters, and enforcement actions, as well as licensee commitments documented

in NRC safety evaluations orlicensee event reports. (Reference 2.7) t

3.7 Design Bases - The information which identifies the specific functions to be j performed by a structure, system or component of a facility, and the specific 3

values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally 4

i i

Page 4 of 19

3 g 0,

i PROJECT INSTRUCTION }7" INSTRUCTION PI-MP3-06 O REV.0 4

i l accepted " state of the art" practices for achieving functional goa!s or (2) j requirements cerived from analysis of the effects of a postulated accident for which a structure, system or component must meet its function goals.

(Reference 2.2) 4

3.8 Design Output Documents - Controlled plant documents such as

} specifications, drawings, vendor drawings, datasheets, lists and databases.

(Reference 2.5) i i 3.9 Design Process Documents - Documents such as calculations, analyses,

! evaluations or other documented engineering activities that substantiate the final design. (Reference 2.5) 3.10 Verifier - The individual assigned to review engineering attributes within his 1 area of responsibility.

i

3.11 Significant Support / Interacting Systems and Related Activities - As used in this Pi Significant Support / Interacting Systems and Related Activities refers to j those process systems, activities, or procedures that are considered essential and significant by the ORG Verifiers in accomplishing the Design or License l Basis item that is being evaluated. It is not intended that this consideration of Significant Support / Interacting Systems and Related Activities be viewed as an I all encompassing chain of all possible support and related activities. As an

! example, if an operator or maintenance worker must be trained with specific i skills to perform particular procedures, then the existence of approved training procedures will be verified to accomplish that specific skill training. Neither the

! entire training program nor the skills nor qualifications of the trainers will be evaluated as part of meeting the subject design basis item being evaluated.

i

! 4 RESPONSIBILITIES 3 4.1 The Verification Team Manager shall be responsible for overall management of  ;

the Verification Team.  !

i 4.2 The ORG Lead shall be responsible for assigning a Lead Verifier for each  !

! system in the ICAVP scope, for assigning other verifiers as necessary to '

support the Lead Verifier, and for overall coordination of the ORG effort.

i 4.3 The ORG Lead Verifier shall be responsible for performing a review of j procedures, vendor manuals, training materials and plant simulator j configuration as described in this instruction.

1 Page 5 of 19

i

{ PROJECT

• T) " ~ INSTRUCTION PI-MP3-06 j INSTRUCTION / REV.O i 4.4 The ORG Verifiers shall be responsible for performing reviews within their area l of expertise in accordance with this instruction.

5 INSTRUCTIONS l 5.1 General i

l The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in j Section 2.0 of this Pl requires Northeast Utilities (NU) to implement the ICAVP.

The Confirmatory Order also defines the scope of the ICAVP. This scope I

includes verification that design and licensing bases requirements are translated into operating, maintenance and testing procedures. The ORG includes as part of this verification a check that functional and performance requirements, identified by the SRG in the licensing and design bases of the selected systems, j

~

are implemented in the operating, maintenance and testing procedures and training material. The ORG will also review modifications to the system to verify

) that the appropriate procedures correctly reflect the changes made. The ORG j

will also verify system performance through review of test records, maintenance i

history, and observation of selected testing. Walkdowns will be used as i appropriate to verify adequate control of operational, maintenance, test and surveillance procedures, operator training, and control of the plant simulator

configuration.

1

5.1.1 Additional Significant Support / Interacting Systems and Related Activities j

may be identified during reviews in order that procedures governing such activities can be evaluated for adequate implementation of Design Bases l items. Refer to Definition 3.11 of this Pl for clear understanding of this

action.

l 5.2 Document Retrieval and Review i

5.2.1 Refer to Project instruction PI-MP3-02 for a detailed breakdown in the l division of responsibility within the ICAVP Verification Team for gathering j documents. The ORG shall gather, for the selected system, the i following minimum list of documents:

i j a. Operating Procedures including Emergency Operating Procedures

b. Maintenance Procedures

c. Surveillance Test Procedures

d. Vendor Manuals

e. System Training Procedures 4 f. Other Significant Support and/or Related Procedures 1

lo i

N Page 6 of i9

i 2

f PROJECT ** ""

INSTRUCTION PI-MP3-06

INSTRUCTION -

REV.O i

.i i

5.2.2 The ORG shall use the station document index to determine the typ' es of i

documents or records to be gathered and to identify specific procedures i and tests applicable to the system being reviewed.

5.2.3 The ORG shall request relevant documents which are not in the ICAVP Library, from NU in accordance with subsection 3.1 of PI-MP3-01.

5.2.4 The ORG shall complete the applicable section of the System Reference

! List (SRL) with the documents identified in 5.2.2 and forward the i

completed checklist to the SRG Lead. Checklist CK-MP3-02-01 shall be

{ used for the SRL.

5.2.5 Once the ORG Lead has received the combined SRL from the SRG Lead, the ORG Lead Verifier and the other ORG Verifiers assigned to j

review the system shall review the appropriate documentation in order to 4

achieve an in-depth understanding of the system as it relates to their

! area of expertise.

t

.' 5.2.6 Prior to the ORG review of system modifications which have occurred i since the issuance of the operating license, the SRG shall provide the I

O ORG a clear description of portions of modification packages which were subsequently revised by later modifications. The SRG shall also clearly t;cribe for the ORG the modifications which are complete and

! implemented, and those that have not yet been installed. These i measures are required, in part, to prevent generation of erroneous discrepancy reports during the ORG review of procedures and other supporting material.

l 5.2.7 The SRG screens the modifications using a Modification Screening Checklist (CK-MP3-03-02 ). Among the topics addressed by the

' checklist is a screening of the modification forimpact on training procedures and plant procedures (operations, maintenance and i surveillance). If the screening process determines that plant procedures may be affected by the modification, the SRG Lead Verifier shall forward

! a copy of the checklist and the modification package to the ORG for review. This step shall not be performed until all modifications to the system have been screened.

5.2.8 If the system being reviewed is an Accident Mitigating System, critica!

l pararmters will be provided by the ARG to the ORG. The ORG Verifier j shall f.st the critical parameters on Checklist CK-MP3-06-01. The ORG j

verifier shall verify that the procedures to be reviewed for implementation i

Pm I

Page 7 of 19

l l

1 i PROJECT INSTRUCTION -

[" INSTRUCTION PI-MP3-06 REV.O f

I of these parameters are listed on the checklist. The ORG Verifier shall j

verify that the appropriate surveillance test procedures adequately 1

implement these critical parameters and document the results on Checklist CK-MP3-06-01.

i

5.3 Identification of System Reauirements i

j 5.3.1 As described in PI-MP3-02, the SRG shall use a Systems Requirements Checklist (SRC), Checklist CK-MP3-02-02, to identify the functional, performance and other design requirements for the system being i reviewed.

5.3.2 The ORG shall use the Systems Requirements Checklist (SRC),

Checklist CK-MP3-02-02, to review the licensing and design bases  ;

q documents to identify operating, maintenance, and testing requirements. l 5.3.3 The ORG Lead will assign a Lead Verifier for each of the systems being j reviewed.

i j

5.3.4 The Lead Verifier shall tabulate the requirements along with a reference i

on the System Requirements Checklist (CK-MP3-02-02).

O 5.3.5 The ORG Lead shall approve the ORG input on the SRC and forward it to the SRG Lead for combination with the other ICAVP inputs.

i j 5.3.6 The SRG Lead shall provide the ORG Lead a signed copy of the j combined SRC for use.

i j

5.3.7 The ORG Verifier shall plan and schedule plant walkdowns for the

{ purpose of verifying system performance and to verify adequate control

of procedures through observation of selected activities and testing,as described in Section 5.6.9 of thisPl. The ORG Verifier shall refer to PI-l MP3-05 for guidance in planning walkdowns, and coordinate the walkdown plan with the CRG Lead.

5.4 Bases Reauirements Review 5.4.1 The ORG Verifier shall perform a detailed review of the appropriate procedures listed on the SRL to evaluate them for implementation of the bases requirements as listed on the SRC. During the detailed review, the ORG Verifier should consider the need to identify specific Significant Support / Interacting Systems and Related Activities to be reviewed for implementation of the bases requirement being evaluated based on o

m Page 8 of 19

i j PROJECT "

INSTRUCTION Pl-MP3-06 INSTRUCTION REV.O i

i i initial reviews W results of questions considered as described in Section i

5.4.3.d of this Pl. The Verifier shall refer to Definition 3.11 of this PI for clarification.

5.4.2 The ORG Verifier shalllist each SRC requirement to be evaluated, or j each modification or process change item, on each checklist used below i

or in Section 5.5 of this Pl. The ORG Verifier shall list the procedures to i

be reviewed for each requirement on this same checklist. The ORG Verifier shalllist the specific section of each procedure as a reference for j each requirement being evaluated on this same checklist.

5.4.3 The ORG Verifier shall review relevant procedures to:

{

a. Verify that the design bases features and the current licensing basis

! features are adequately translated into the referenced procedures.

jl The Verifier shalllist the features and document the results of his review on Checklist CK-MP3-06-02.

i j b. Verify by reviewing the procedures that all modes and phases of the selected system are adequately operated. maintained, and tested.

l Where appropriate, the review shall verify that any required manual i operator actions can be performed under accident conditions. The I i

Verifier shall list the appropriate modes and phases and any required l

accident conditions and document the results of his review on j Checklist CK-MP3-06-03.

l c. Verify that the various system configurations described in the

procedures will perform their intended functions by reviewing the i appropriate P&lD's. The ORG Verifier shalllist the appropriate P&lD's and document the results of his review on Checklist CK-MP3-

[ 06-04.

1

d. Verify that any required Significant Support / Interacting Systems and i

l Related Activities (refer to Definition 3.11 of this Pl for clarification) adequately provide for proper performance of the system being

{ reviewed to accomplish its bases requirements.. The ORG Verifier

! shall complete Checklist CK-MP3-06-05 to evaluate the need for j

further items to be reviewed. The Verifier shall add any requirements j

to the SRC in accordance with Section 5.3 of this Pl. The Verifier

shall add any necessary references to the SRL in accordance with 1

Section 5.2.4 of this Pl. The Verifier shall document the results of his l review on Checklist CK-MP3-06-05 i

^ Page 9 of 19 1

d f

PROJECT INSTRUCTION

• N7"" ' INSTRUCTION PI-MP3-06 REV.O Y

NOTE

This step is not intended to verify the adequacy of supporting systems and functions, but is merely intended to verify that a

procedures for supporting systems and functions reflect the ICAVP j systems' requirements.

{ e. Verify that sections of vendor manuals, equipment operating l

instructions, drawings, or other supplemental documents that aro

} referenced, or used directly as operating or maintenance procedures receive the sama level of MP3 review and approval as the initial j

procedures. This is not a review of the technical adequacy of the j documents. The Verifier shalllist any such documents and document the results of his review on Checklist CK-MP3-06-06.

i j f. Verify that the instruments and controls identified in the procedures j

to be used for remote and local operation are consistent with the j

installed configuration. The Verifier shall list any such instruments j

and controls, identify whether they are local or remote. and document the results of his review on Checklist CK-MP3-06-07.

l i

, g. Verify that vendor manuals / files adequately support the bases j requirements for the system being reviewed. The Verifier shalllist j the appropriate vendor manuals and tiles, and document the results

. of his review on Checklist CK-MP3-06-08.

i

h. Verify that performance history files adequately support the bases

{ requirements for the system being reviewed.This verification shall l include reviews to identify recurring equipment problems, and i determination of any trends. Additionally, the verification shall include review of the technical adequacy of maintenance activities, j

performance of appropriate post-maintenance tests, and satisfactory j demonstration of equipment operability. The verifier shalllist the files

{ and specific items reviewed. Specific references shall be indicated on the checklist. The Verifier shall document the results of his review on Checklist CK-MP3-06-09.

i. It may be appropriate to walkdown some samples of procedure j

usage in the field to observe for procedure control, and to witness samples of the reviewitems from the above sections. Refer to

{l Section 5.6.9 of this PI for a description of the walkdown arrangements. The Verifier shall clearly identify any items verified by 1 walkdown on the appropriate Checklist, and document the results of j his review with comments on the appropriate checklist.

I 4

4 d

Page 10 of 19

lA PROJECT INSTRUCTION

• ]y#~-

INSTRUCTION PI-MP3-06 REV.O iV i

i 5.4.4 The verifier shall note any comments identified during the review on the

! comment section of each checklist used in the above reviews. Additional copies of the checklists and comment sections shall be used as required j to thoroughly document the results of the reviews.

l 5.4.5 The ORG Lead Verifier and the other Verifiers shall also review the 1

findings and corrective actions that resulted from NU's Configuration j

Management Plan (CMP). S&L shall not duplicate findings identified by 4

de NU CMP.

j 5.4.6 The ORG Verifier will complete the verification of the procedures versus the i system requirements by dispositioning each requirement on the System j Requirements Checklist (Checklist CK-MP3-02-02).

5.4.7 The Verifier (s) shall identify on the System Requirements Checklist, the

' procedures that verify the system requirements are satisfied. The Verifier (s)

,! shall indicate that the procedure is technically adequate or describe any deficiencies. The Verifier shall also identify missing procedures, if j' applicable.

i

~

5.4.8 The Verifier (s) shall initial and date all entries in the System Requirements j

Checklist, and shall sign the System Requirements Checklist when

{ completed.

i 5.4.9 The ORG Lead shall review the disposition in the system requirements Checklist (CK-MP3-02-02) for completeness and technical accuracy. The ORG Lead shallindicate his concurrence with signature and date in the l appropriate column. The ORG Lead shall notify the ARG Lead that either all critical characteristics for accident mitigation systems have been satisfied or he shall identify which have not been.

f 5.4.10 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.7 j

of this P1 for any discrepancies not previously identified by the NU CMP.

5.4.11 The ORG Lead shall verify the checklists have been properly completed j

and shalliindicate concurrence by signing and dating the checklists. The ORG Lead will file the checklists in the project file in accordance with PI-MP3-12.

i 5.5 Review of Chanaes j

5.5.1 The ORG Verifier shall independently review the Modification Packages

{ and appropriate Modification Screening Checklists (CK-MP3-03-02) that Page 11 of 19

1, i l PROJECT INSTRUCTION d[""

INSTRUCTION PI-MP3-06 REV.O I

1 have been forwarded from the SRG. The intent of this review is to '

identify the specific procedures to be reviewed by the SRG for those modifications that were determined to either have procedure impact, or may have procedure impact, by the SRG .

4 1

5.5.2 The ORG Verifier shalllist the Modification Package identification and j

the appropriate Modification Screening Checklist identification on any checklists used in the steps of this section of the Pl. The ORG Verifier i

' shall also list the appropriate procedures for the modification being evaluated on each checklist used in this PI, 1

l 5.5.3 Based on a technical review of the modification packages forwarded to l the ORG from the SRG, the ORG Verifier shall confirm that the j appropriate procedures for the modification being evaluated are listed on the SRL obtained from the SRG lead as described in Pl Section i 5.2.5. Any additional procedures that are identified during the modification review that are not on the SRL should be listed on a copy of 1 the SRL, and forwarded to the SRG Lead for updating the SRL. The

! ORG Verifier shall use Checklist CK-MP3-06-11 to list all procedures for

] the modification being evaluated.

l '

5.5.4 The ORG Verifier shall list the change processes that the PRG is i

reviewing according to PI-MP3-04 on Checklist CK-MP3-06-12. The ORG Verifier shall select 1 or 2 procedure change items for each of the

) change processes that the PRG is reviewing and list these procedures also on Checklist CK-MP3-06-12, and provide a detailed review of those l; changes to verify the technical adequacy of the changed procedures to i

reflect the initiating change. These procedures shall be reviewed as described belowin Section 5.5.8 of this Pl. The results of the review of these PRG Change Process procedures shall be evaluated for j discrepancies and reported as described in Section 5.5.15 of this Pl.

5.5.5 Any newly identified procedures that are not in the ICAVP Library should

! be requested from MP3 in accordance with section 3.1 of PI-MP3-01.

4 1

4

! 5.5.6 The ORG Verifier shall perform a detailed review of the appropriate l l procedures for each modification or change process to evaluate them for l j

implementation of the changes identified. During the detailed review, the  !

ORG Verifier should consider the need to identify specific Significtot l Support / Interacting Systems and Related Activities to also be reviewed i j for implementation of the above identified ca.3nges, based on initial i reviews or results of questions considered as described in Section l

l s

4 j Page 12 of 19

I l PROJECT INSTRUCTION -[" INSTRUCTION PI-MP3-06 REV.0 1

l l 5.5.9.d of this Pl. The Verifier shall refer to Definition 3.11 of this PI for l clarification

5.5.7 The ORG Verifier shall verify that the design and operation changes identified by the SRG in Section 5.2.7 above, or identified by the reviews j

of this section of the PI, or the changes identified by the PRG as I

described in Section 5.5.4 above, are adequately reflected in operating, I maintenance, and testing procedures, in training materials, and in the simulator configuration as appropriate. The ORG Verifier shall list each

modification or change process to be evaluated on each checklist used j in Section 5.5.9 below. The Verifier shall list each procedure that is being evaluated forimplementation of the changes also on each

) checklist used in Section 5.5.9. The ORG Verifier shall also list the specific procedure section as a reference for each item thatis being

! evaluated.

4 5.5.8 The ORG Verifier will review the relevant procedures to:

a. Verify that operation and maintenance of the system is consistent with any modifications to the design bases and current licensing basis features for the system being reviewed. The Verifier shall list O the features and document the results of his review on Checklist CK-MP3-06-02.

b. Verify by reviewing the procedures that all modes and phases of the selected system are adequately operated, maintained, and tested to reflect the changes. The Verifier shall list the appropriate modes and phases and document the results of his review on Checklist CK-MP3-06-03.

c. Verify that the various system configurations described in the procedures will perform their intended functions to reflect the "'

changes by reviewing the appropriate P&lD's. The ORG Verifier shall list the appropriate P&lD's and document the results of his review on Checklist CK-MP3-06-04.

I

d. Verify that any required Significant Support / Interacting Systems and  ;

l Related Activities (refer to Definition 3.11 of this PI for clarification) adequately provide for proper performance of the system being reviewed to accomplish the changes. The ORG Verifier shall complete Checklist CK-MP3-06-05 to evaluate the need for further items to be reviewed. The Verifier shall add any requirements to the  !

SRC in accordance with Section 5.3 of this Pl. The Verifier shall add l l

6 Page 13 of 19

...,4___. . _ ,. m . . . _ ._m.. . _ _ __,_...am ._.._.__.2

_ . . _ _ _, _~..s-m ..m._ m_-_m, m

-... _ _ _ _ .- _. .._. ; m. ._

i a

l PROJECT INSTRUCTION "Mf -

INSTRUCTION PI-MP3-06 REV.O i

i j any necessary references to the SRL in accordance with Section j

5.2.4 of this Pl. The Verifier shall document the results of his review {

i on Checklist CK-MP3-06-05 i

NOTE: This step is not intended to verify the adequacy of supporting j

systems and functions, but is merely intended to verify that j

procedures for supporting systems and functions reflect the ICAVP j l systems' requirements. 1 1 1 4

1

e. Verify that sections of vendor manuals, equipment operating instructions, drawings, or other supplemental documents that are 4

referenced, or used directly as operating or maintenance procedures receive the same level of MP3 review and approval as the initial procedures. This is not a review of the technical adequacy of the documents. The Verifier shalllist any such documents and 3

document the results of his review on Checklist CK-MP3-06-06.

f. Verify that the instruments and controls identified in the procedures l to be used for remote and local operation are consistent with the 4

installed configuration. The Verifier shall list any such instruments and controls, identify whether they are local or remote. and document the results of his review on Checklist CK-MP3-06-07.

1

' g. Verify that vendor manuals / files adequately support the requirements for the change. The Verifier shalllist the manuals / files reviewed, and j

document the results of his review on Checklist CK-MP3-06-08.

t

h. Verify that performance history files adequately support the change j requirements for the system being reviewed.This verification shall include reviews to identify recurring equipment problems, and l i determination of any trends. Additionally, the verification shall l

] include review of the technical adequacy of maintenance activities, i l performance of appropriate post-maintenance tests, and satisfactory l demonstration of equipment operability. The verifier shall list the files '

3 and specific items reviewed. Specific references shall be indicated l

) on the checklist. The Verifier shall document the results of his review l on Checklist CK-MP3-06-09. l I

1. Verify that training materials, especially operator training materials, have been appropriately updated to reflect the change. The Verifier shall also identify any required simulator configuration changes to j evaluate.The Verifier shall list the training materials reviewed, and i

Page 14 of 19 J

l l

1 t

j PROJECT 4

INSTRUCTION PI-MP3-06 INSTRUCTION -

REV.O

! any simulator changes evaluated, and document the results of his review on Checklist CK-MP3-06-13.

i

J. It may be appropriate to walkdown some of the changes in the field

{

' to observe for procedure control, and to witness samples of the reviewitems from the above sections. Referto Section 5.6.9 of this

{ P1 for a description of the walkdown arrangements. The Verifier shall j

clearly identify any items verified by walkdown on the appropriate j

Checklist, and document the results of his review with comments on i

the appropriate checklist.

l 1

5.5.9 The verifier shall note any comments identified during the review on the i

comment section of each checklist used in the above reviews. Additional

) copies of the checklists and comment sections shall be used as required j to thoroughly document the results of the reviews j

5.5.10 The ORG Lead Verifier and the other Verifiers shall also review the  ;

findings and corrective actions that resulted from NU's Configuration l

} Management Plan (CMP). S&L shall not duplicate findings identified by

! the NU CMP. l

! 5.5.11 The ORG Verifier will complete the verification of the procedures versus the change requirements by dispositioning each requirement on the System Requirements Checklist (Checklist CK-MP3-02-02).

1 5.5.12 The Verifier (s) shallidentify on the System Requirements Checklist, the l

l procedures that verify the change requirements are satisfied. The Verifier (s)

}

shallindicate that the procedure is technically adequate or describe any j

deficiencies. The Verifier shall also identify missing procedures, if l applicable.

1

{ 5.5.13 The Verifier (s) shall initial and date all entries in the System Requirements Checklist, and shall sign the System Requirements Checklist when j completed.

t 5.5.14 The ORG Lead shall review the disposition in the system requirements Checklist (CK-MP3-02-02) for completeness and technical accuracy The l ORG Lead shallindicate his concurrence with signature and date in the i

appropriate column. The ORG Lead shall notify the ARG Lead that either all critical characteristics for accident mitigation systems have been satisfied or he shall identify which have not been.

k

Page 15 of 19 i.

f i

1

! PROJECT INSTRUCTION (["#

INSTRUCTION PI-MP3-06 REV.O i

5.5.15 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.7 of this P1 for any discrepancies not previously identified by the NU CMP.

}

) 5.5.16 The ORG Lead will verify the checklists have been properly completed i and willindicate concurrence by signing and dating the checklists. The i

ORG Lead will file the checklists to the project file in accordance with PI-MP3-12.

! 5.6 Review of Testina j 5.6.1 The ORG Verifier shalllist the test requirements from the SRC, the i modification tests forwarded by the SRG, and the Surveillance tests

} required to verify the critical parameters for the Accident Mitigation Systems forwarded by the ARG on Testing Requirements Review j Checklist CK-MP3-06-15. The ORG Verifier shall also identify other j

testing requirements for the system being reviewed by using Testing j Requirements Checklist Ck MP3-06-14. The Verifier shall review the i

resource material for each category on the CK-MP3-06-14 to identify required testing for the system being reviewed. Modification functional

}j test requirements and acceptance criteria are contained in the j modification packages and are being reviewed by the SRG per PI-MP3-03. The ORG shall use input from the SRG to assist in the identification of required testing for the system. The ORG Verifier shall

, list the specific test requirements for each category on Checklist CK-1 MP3-06-14 and the specific procedures that implement each required j test as a reference on CK-MP3-06-14.

} 5.6.2 The ORG verifier shall use the station document index to identify the

{ specific testing procedures and the data / calculation / review sheets for j each category on the list.

4 j 5.6.3 The ORG Verifier shall request relevant documents, which are not in the ICAVP Library, from NU in accordance with subsection 3.1 of PI-MP3-01.

4 5.6.4 The ORG Verifier shall provide a list of required procedures that were not on the SRL to the SRG Lead so that an update to the SRL can be prepared and issued. Additionally, any requirements that were identified in Section 5.6.1, above, that were not on the System Requirements Checklist, CK-MP1-02-02, shall be listed on a copy of CK-MP1-02-02, and forwarded to the SRG Lead for updating the System Requirements Checklist.

o m Page 16 of 19

, i j

d

~

f PROJECT INSTRUCTION PI-MP3-06 yfp INSTRUCTION -

REV.0 '

{ 5.6.5 The ORG Verifier shalllist each test requirement item from Section 5.6.1 l l' above on a copy of Checklist CK-MP3-06-15, along with the specific procedure or procedure sections as references. The Verifier shall use CK-MP3-06-15 to complete the reviews described in Section 5.6.7 of this i Pl.

i 5.6.6 The ORG Verifier shall select a sample of the on-going periodic tests to i

review based on the required frequency of the specific test item. For test l

l items with a frequency of regular intervals within each refuel cycle, the  !

sample shall include the most current three performances of the specific j

test. For test frequencies that are once per refuel cycle, the sample shall .

l be the last time the test was performed. The verifier shall identify the

} test frequency on the appropriate checklist for each item. For tests that i are one-time performance, such as post maintenance tests or special l j tests, the Verifier shall select a sample of three items to review for each I test category as described in Section 5.6.1 above of this Pl. l

\

5.6.7 The ORG Verifier will review each test item to-l \

a. Verify that test data and results have been appropriately reviewed I

) and approved. Specific data and results identifications shall be listed

.' for each item on CK-MP3-06-15. The Verifier shall document the i

results of his review on the Checklist. It may be appropriate to conduct field walkdowns to verify the results for some of the tests to j be reviewed. The process for the walkdowns is described in Section j 5.6.9 of this Pl below.

4

b. Verify that acceptance criteria have been met. The Verifier shalllist 4

i j the specific acceptance criteria, and document the results of his  !

l review on Checklist CK-MP3-06-15.

/

4 l c. Verify that each test appropriately tests for the requirements

} identified in Section 5.6.1 and listed on CK-MP3-06-15 The Verifier i shall list the bases requirements, and document the results of his review on Checklist CK-MP3-06-15

d. Assess the adequacy of the test procedure and of the actions taken as a result of the tests, ( e.g., test " trend"information and root cause analyses for test failures; where appropriate, retesting; compliance with Limiting Conditions for Operations; condition reports). The Verifier shall list the items to be reviewed on Checklist CK-MP3 16, and document the results on the Checklist.

o m Page 17 of 19

l PROJECT INSTRUCTION h#~ INSTRUCTION PI-MP3-06 REV.0

) e. Verify that testing records are appropriately maintained, and are i retrievable. The verifier shallidentify the specific records j reviewed,and document the results on Checklist CK-MP3-06-17.

5.6.8 The verifier shall note any comments identified during the review on the i comment section of each checklist used in the above reviews. Additional j copies of the checklists and comment sections shall be used as required j to thoroughly document the results of the reviews 1

5.6.9 The ORG Verifier may identify a sample of activities to walkdown and observe for actual performance in the field. The walkdown may be used

] to aid in verifing system performance, and to aid in verifing adequate

control of the appropriate procedures,and to observe for proper conduct l of the activity according to the approved procedures. This walkdown can 3 be used for witnessing conduct of any of the procedures subject to j review by this Pl. This includes; operating procedures, maintenance l procedures, surveillance procedures, and simulator training 3 performance. The verifier shallidentify any activities to be observed on

! Checklist CK-MP3-06-18. The ORG Verifier shall refer to PI-MP3-05 for i guidance in walkdown planning, or discuss the walkdown plan with the CRG lead.

O i 5.6.10 The ORG Verifiers shall also review the findings and corrective actions that resulted from NU's Configuration Management Plan (CMP). S&L shall not duplicate findings identified by the NU CMP.

i 5

5.6.11 The ORG Verifier will complete the verification of the testing procedures

versus the system testing requirements by dispositioning each requirement on the System Requirements Checklist (Checklist CK-MP3-02-02).

5.6.12 The Verifier (s) shall identify on the System Requirements Checklist, the

] testing procedures that verify the system testing requirements are satisfied.

The Verifier (s) shall indicate that the procedure is technically adequate or j describe any deficiencies. The Verifier shall also identify missing procedures,if applicable.

5.6.13 The Verifier (s) shall initial and date all entries in the System IIequirements

Checklist, and shall sign the System Requirements Checklist when j completed.

j 5.6.14 The ORG Lead shall review the disposition in the system requirements

Checklist (CK-MP3-02-02) for completeness and technical accuracy. The i

ORG Lead shallindicate his concurrence with signature and date in tiie m

1 lo 4

l l Page 18 of i9

i

! d, l PROJECT INSTRUCTION -[i"~ INSTRUCTION PI-MP3-06 REV.0 4

4 appropriate column. The ORG Lead shall notify the ARG Lead that either all i

critical characteristics for accident mitigation systems have been satisfied or i he shall identify which have not been.

J j 5.6.15 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.7 j of this PI for any discrepancies not previously identified by the NU CMP.

i

5.6.16 The ORG Lead shall verify the checklists have been properly completed

! and shallindicate concurrence by signing and dating the checklists. The ORG Lead shall file the checklists to the project file in accordar.ce with Pl-MP3-12.

j 5.7 Discrepancy Report Preparation and Closure 1

5.7.1 Discrepancy Reports for discrepancies identified during the review

] process shall be prepared and processed in accordance with PI-MP3-11.

j Discrepancy Reports shall not be initiated for findings already identified 1

by NU during implementation of the CMP.

I

{ 5.7.2 Review of NU dispositions for the Discrepancy Reports generated during j the review cycle shall be in accordance with PI-MP3-11.

iO j 5.8 Final Report

} 5.8.1 The ORG Lead Verifier shall draft the section of the final report summarizing the results of the ORG system reviews.

5.8.2 The report format shall be deterrhined by the Verification Team Manager.

?

6 ATTACHMENTS

} 6.1 O&M&T Process Flow Chart page(1 page)

I l

. 1 4 4 Page 19 of 19

931p/.muR:/,gj 1

-(. ,s-Manas

• - 6.1 ICAVP i FLOWCHART FOR  !

p O&M AND TESTING REVIEW  !

g '"e,"e',.5,,'""'

e PROCESS i NRC#1CAVP e

Docniment RoWval erul Renew SRGORGtCRO '

l Propero System Reference List )

6RGCRGiCRO L Input kom o' SRGilCAVP Review DOC) for Fameenly  !

ORG d

' Syelem Reguremente _

% Byetem input i ORO kom ARG Begin Seses Renew e

mese chanses mense i

Ane Companas assee Begm Tsoung Renew ORG a*we d

M MsomTe m {

idonelly ($ecWc  !

MosChangeinput '

Procedures M erm ORG l 6AGMtG Identify Test g i Raouireme us v i ORG RenowtVenfy

• w Requesmente 8 4 s Pecedures Renew Mod Packageo Select Change ORG Pmcoes Semotes idenilly Spacec Test ORG OR3 Procerksee i i ORG d

Select Test Samole idenlW Based on Perfonnance Saecae Protadures Frequenor ORG Ons e

4 4 i

"'**"p*McP , Revmwe% Test Reno =Nevey Test ORG uns uns I i

= l

,e -

be Corukactory *" .

4

[ Sg*."'a'*

_--n-- ORO no Arrange welkoonne per Pl4dP3-06 ORG m.oon.

%u.w _ ver*,weness ORG ORG

.Oes .

moi.ORG

. ,a ,

e e Propero Report ORG

1 PROJECT INSTRUCTION PI-MP3-07 j INSTRUCTION -

REV.0 l

I Client: Northeast Utilities Station: Millstone Unit 3 l

l

Title:

REVIEW OF ACCIDENT MITIGATION SYSTEMS 1

1 i

I h Safety-Related Non-Safety-Related a

i i

I Reviewed By: Approved By:

l l

System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team Lead Mitigation Committee Manager i Lead Chairman j

/ ,

Date: 3-647, hh$a ' Y$w Ybb/6'N $YT/W> $YN h& k '

C

~

Description inRfaldsue '

1 l

i l

O Page 1 of 5

~

! PROJECT INSTRUCTION .-

[*"' INSTRUCTION PI-MP3-07 REV.0 i

t i

1.0 PURPOSE

{

j This procedure establishes the requirements for the ICAVP Verification Team to j identify and review the critical design characteristics for the accident mitigating i systems to provide reasonable assurance that these system parameters meet their design and licensing requirements as discussed in References 2.1 and 2.2.

i j 2.0 REFERENCE l

2.1 NRC Confirmatory Order establishing independent Corrective Action Verification Program - Millstone Power Station Units 1, 2 and 3.

2.2 Millstone Independent Corrective Action Verification Program - Oversight

Inspection Plan dated 12/10/96.

l 2.3 S&L Project Instruction PI-MP3-01, ICAVP Communications Protocol l 2.4 S&L Project instruction Pi-MP3-02, Review of System Design for Compliance with Design and Licensing Basis

}O 2.5 S&L Project Instruction PI-MP3-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control 2.6 S&L Project instruction PI-MP3-06, Operations and Maintenance and Testing Procedures and Training Documentation Reviews 2.7 S&L Project instruction PI-MP3-09, Preparation and Approval of Checklists 2.8 S&L Project Instruction Pl-MP3-11, Discrepancy Report Submittal and Closure 2.9 S&L Project instruction PI-MP3-12, Project File Index 2.10 CK-MP3-07 Series Checklists as follows:

CK-MP3-07-01 FSAR Ch 15 Accidents, Systems & Components (Notincluded in this PI) m Page 2 of 5

i PROJECT INSTRUCTION PI-MP3-07 INSTRUCTION .- REV.O i

3.0 DEFINITIONS

3.1 Accident Mitigation Systems Review Group (ARG)- The subgroup of the

! ICAVP Verification Team responsible for the identification and review of the

! critical design characteristics for the accident mitigating systems to ensure j that they can perform their required safety functions.

t i 3.2 System Review Group (SRG)- The subgroup of the ICAVP Verification l Team responsible for performing an in-depth review of the design of the l system in the scope of the ICAVP.

I

! 3.3 Operations & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification team responsible for the review of the i operating, maintenance and testing procedures, and training manuals for the systems within the scope of the ICAVP.

i l 3.4 Independent Corrective Action Verification Program (ICAVP) - The

! program required by NRC Confirmatory order, Reference 2.1 to verify the j

' adequacy of the corrective actions taken by NU for their configuration management of design and licensing basis of the unit.

j 3.5 Discrepancy Report (DR)- The mechanism for documenting the discrepant conditions identified by the ICAVP and reporting an apparent error, inconsistency, or procedural violation with regard to licensing commitments, 3 specifications, procedures, codes or regulations. i I 3.6 Verifier -The individual assigned to review engineering attributes within j his area of responsibility.

l 3.7 System Critical Parameters - The variables that are relied upon for j

performing the safety related functions of an accident mitigating system.

1 4.0 RESPONSIBILITIES 4.1 The Verification Team Manager shall be responsible for providing overall guidance and management to the teams.

4.2 The ARG Lead shall be responsible for assigning the discipline verifiers for identifying the accident mitigating systems and a review of their critical design characteristics necessary to perform their safety function (s).

m Page 3 of 5 1

i j PROJECT #

INSTRUCTION PI-MP3-07 INSTRUCTION - REV.O i 4.3 The Discipline Verifiers (Mechanical, Electrical, l&C, Nuclear) shall be i

responsible for identifying the critical system parameters from the FSAR j accident parameters and verifying that these attributes meet the plant i

current design basis in accordance with this instruction.

l

! 5.0 PROCEDURE 4

i The process discussed below shall be used by the ARG to develop the critical parameters for the accident mitigating sys* ems. Sections 5.1, 5.2 and 5.3 i, discussed below shall be the responsibility of the ARG for a!I the accident j mitigation systems. ARG shall be responsible for the remainder of the Sections

5.4 through 5.7 for only those accident mitigation systems which are not 1

included in the detailed Vertical Slice Review (VSR) which shall be done by i

ORG and SRG. These reviews are addressed in the Project Instructions l References 2.4 through 2.6.

5.1 The ARG Lead and Discipline Verifiers shall review the accidents

) analyzed in the FSAR, for Millstone Unit 3 and identify the accident j mitigating systems, components within the system and specific critical

parameters which are required to mitigate the event. As a result of this j review the ARG Lead or his designee shall create a database consisting 3

of the following items: a) Analyzed Accidents, b) Mitigating Systems, c)

Components, d) Critical Parameters and e) References to the accidents I

and associated documents contained in the SAR, where the parameters were used by the NSSS supplier or AE during the original analysis at the time of receipt of the Operating Ucense or a revised analysis due to

changes or modific. dons.

j 5.2 The ARG Lead or his designee shall sort the database in Section 5.1 to  !

facilitate the verification of the critical parameters in the following order.

j a) Mitigating Systems, b) Components, c) Critical Parameters, d) j References and e) Analyzed Accidents.

4, i S.3 The portion of the database consisting of the accident mitigation j

systems in the VSR shall be given to the ORG and SRG for their review i of the Critical Parameters.

l l

O l Page 4 of 5

i i

! PROJECT * * " "

INSTRUCTION PI-MP3-07 INSTRUCTION .

REV.O i 5.4 The ARG Verifiers shall verify the Critical Parameters listed in Section 5.2 using a documented System / Component test, and or Surveillance i test from the Millstone Unit 3 Technical Specification or Post Maintenance Tests. The verification shall be documented on the j

appropriate ORG Checklist (s) from Reference 2.7 which shall be signed i

and dated.

)

l 5.5 In addition to the verification of the Critical Parameters by test reviews

! discussed in Section 5.4, the design calculations, specifications, vendor l  !

documents and drawings shall be obtained and reviewed for '

} conformance with the design requirements of the accident analysis.

Request for documentation shall be processed in accordance with l Reference 2.3.

i

! 5.6 Verification of the Critical Parameters using design calculations, i

specifications, vendor drawings or documents shall be documenteu on i

the appropriate SRG Checklist (s) (Ref. 2.4 and 2.5) which shall be

{ signed and dated. If the Critical Parameters cannot be verified the l review conclusions shall be documented on the appropriate Checklist (s) 3 and a Discrepancy Report shall be processed in accordance with Reference 2.8.

j 5.7 The ARG Lead or his designee shall verify that the checklists have j been properly completed and indicate concurrence with his signature and date. He shall file the documents per Reference 2.9.

j 5.8 The ARG Lead shall draft a final report summarizing the results of the l review. The report format shall be determined by ths Verification Team

Manager.

6.0 ATTACHMENTS 6.1 ICAVP Review of Critical Parameters for Accident Mitigation Systems

-(1 page)

- Page 5 of 5

i Floure 1 ICAVP Review of Critical Parameters  !

for l Accident Mitigating Systems l 4

Review Plant Accident initiating Events l ARG

+

Create a Database Accidents, Systems, I Components, Critical Parameters, -. Provide Critical l Parameters for VSR References Systems to ORG/SRG ARG + for Review per l P!-MP3-02 & 06 '

4 Verify Critical Parameters Using h

'd Tech. Spec.,

Design Cales, Specifications, vendor documents / drawings  !

ARG W ere No Discrepancie[s identified?

MRy v

Yes Process DRs PI-MP3-11

, ARG h

Prepare Report O '

V ARG

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

l l

! d i PROJECT INSTRUCTION *~""*f #"'

INSTRUCTION PI-MP3-08 REV.O

{

i l

Client: Northeast Utilities l Station: Millstone Unit 3 j

Title:

ICAVP TEAM PERSONNEL SUBSTITUTION AND/OR ADDITION I

h Safety-Related _

Non-Safety-Related E

i Reviewed By: Approved By-

! System Lead Programmatic O&M Lead Accident QA Engineer intemal Review Verification Team i Lead Mitigation Committee Manager i I Lead Chairman b Date:E*l*Sl

,, , l b IbNbsd d[chhy 8h/M ' bN AT,M ui --

1' Description lpidalpue l

Page 1 of 4

PROJECT *"'

INSTRUCTION PI-MP3-08 INSTRUCTION - REV.O l 1.0 PURPOSE l i l l This instruction establishes the requirements for the substitution and addition

! of personnel to the ICAVP Project Team. The selection of personnel for the

! ICAVP was based on their qualifications to perform the assigned reviews, l

} their financial and technical independence from the Unit being reviewed, and i

NRC acceptance of the personnel. Substitution of existing personnel on the

} l team may be required as a result of unavoidable circumstances. Addition of l

{ personnel may be required to add expertise or manpower to fully investigate l issues which are identified during the course of the program.

l l

2.0 REFERENCE 2.1 NRC Confirmatory Order Establishing independent Correction Action l Verification Program - Millstone Nuclear Power Station, Units 1,2, and j 3

2.2 PI-MP3-01, ICAVP Communications Protocol 3.0 DEFINITIONS l

3.1 Substitution - Replacing existing personnel on the ICAVP Project Team which were included in the original proposal for that Unit and which the NRC interviewed and accepted.

3.2 Addition - Adding personnel to the ICAVP Project Team.

3.3 System Review Group (SRG) - The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

3.4 Operations & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training manuals for the systems within the scope of the ICAVP.

- Page 2 of 4

l PROJECT M "

INSTRUCTION PI-MP3-08 l INSTRUCTION . REV.0 l

i 3.5 Accident Mitigation Review Group (ARG)-The subgroup of the l lCAVP Verification Team responsible for the review of the critical system attributes of the systems used to mitigate the consequences of j an accident.

i

) 3.6 Programmatic Review Group (PRG)- The subgroup of the ICAVP l Verification Team responsible for performing a review of the design l control and corrective action processes in the scope of the ICAVP.

l l 4.0 RESPONSIBILITIES i

I 4.1 The Verification Team Manager shall be responsible for the selection i

of substitute or additional personnel for the ICAVP Project Team.

l 4.2 The individual personnel shall be responsible for completing the l Objectivity Questionnaire.

l 5.0 PROCEDURE 5.1 Substitution i

i The Nuclear Regulatory Commission (NRC) Confirmatory Order

! referenced in Section 2.0 of this PI requires that the selection of the

! members of the ICAVP Project Team be subject to NRC staff approval.

Prior to the start of the program the original team will have been j approved by the NRC. If for some reason team members cannot fulfill i

their obligation to the Project Team, the Verification Team Manager j shall select replacements for them. The substitute personnel shall j have the technical background, education and experience necessary l to perform the functions that are required of them by their position on

the ICAVP Project Team. They shall also be required to meet the j independence criteria established for the original team members. The substitute personnel shall satisfactorily complete the ICAVP Objectivity

} Questionnaire (Attachment 6.1). The Verification Team Manager shall j notify the NRC and NU in writing in accordance with the i

Communications Protocol (Pl-MP3-01) that substitutions were made.

l The Verification Team Manager shall provide the NRC and NU with a m

t

~

4 Page 3 of 4

4 PROJECT

"~

INSTRUCTION PI-MP3-08 INSTRUCTION REV.0 l

j copy of the substitute personnels' resumes and a copy of their 1 completed Objectivity Questionnaires (Attachment 6.1). If the NRC i notifies S&L that it has unresolvable objections to the qualifications or i the independence of the substitute personnel, they shall be i

suspended from any further work on the ICAVP and all work performed by them shall be reperformed by acceptable individuals.

! 5.2 Addition l Since the specific systems selected for the ICAVP are not known at this time, it is difficult to know exactly the number of engineers in each

! discipline and the number of specialists that will be needed to j implement the ICAVP. In addition, as the program proceeds, specific j issues may be identified which need specialized expertise to fully l investigate. Or, the size and complexity of the systems chosen for review may be greater than estimated. If any of these situations occur, additional staff may be needed for the Verification Team. !n this case the Verification Manager will select additional personnel for j the ICAVP Project Team. Similar to section 5.1 above, the additional j personnel shall have the technical background, education and j experience necessary to perform the fur.ctions that are required of l them by their position on the ICAVP Project Team. They shall also be i required to meet the independence criteria established for the original team members. The additional personnel shall satisfactorily complete the ICAVP Objectivity Questionnaire (Attachment 6.1). The Verification Team Manager shall notify the NRC and NU in writing in accordance with the Communications Protocol (PI-MP3-01) that i additional personnel are being added to the Project Team. The Verification Team Manager shall provide the NRC and NU with a copy l of the additional personnel's' resume and a copy of their completed Objectivity Questionnaires. If the NRC notifies S&L that it has unresolvable objections to the qualifications or the independence of the additional personnel, they shall be suspended from any further work on the ICAVP and all work performed by them shall be reperformed by acceptable individuals.

6.0 ATTACHMENTS '

6.1 ICAVP Objectivity Questionnaire (1 page) m Page 4 of 4

h j  !

Millstone Unit 3 ICAVP Attachsaent 6.1 Objectivity Questionnarie

. I

1. Name:

2. Current Employer:

i

-3. Project Title / Function

l 4. Have you ever been employed by any of the following companies:

l~ Northeast Utilities Yes _

! Stone & Webster No _

Yes No ___

j MPR Yes _ No _

I

5. Have you been involved in any Millstone 3 activity in your previous

or current position?

! Yes _,. No _  !

)

6. Have any of your immediate family (father, mother, spouse, son, i or daughter) been involved in any Millstone 3 activity in their

! previous or current position?

Yes No _

7. Do you own/ control stock in any of the following companies?

Northeast Utilities Yes _ No _

Stone & Webster Yes No MPR Yes No _.

8. Have you been promised any additional compensation, reward of anything of any value, contingent upon the position you take on any issue being considered by you in connection with the Millstone 3 ICAVP?

Yes _._ No _

9. Do you know of any reason, whether or not inquired about in this questionnaire, which would affect your ability to be completely objective in performing any of the tasks assigned to you with the Millstone 3 ICAVP7 Yes No _

10. Are you aware of any reason which might create a perception that you would not act with objectivity in performing any of the tasks assigned to you in connection with the Millstone 3 ICAVP? Yes ._._. No __ _

11. If the answer to any one or more of the questions was "yes", please explain each such reply fully, referenced by the question number, on the reverse side of this questionnaire. Attach additional sheets as needed.

Signature of Appicant Dato

\

Reviewed and Accepted by: Date

] ,

PROJECT INSTRUCTION - f INSTRUCTION PI-MP3-09 REV.O s

Client: Northeast Utilities Station: Millstone Unit 3

Title:

PREPARATION AND APPROVAL OF CHECKLISTS l

1 l

l i

h Safety-Related _

Non-Safety-Related i

Reviewed By: Approved By:

j System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team

Lead Mitigation Committee Manager i

Lead Chairman l _

j Date:3* d" 7 l

$$$d ~$L YhddtO OyYhilvi, W/$na/d! k& KTAL v%L -

Description IMial fssue V' " 'N i

1 1

I I

l O'

Page 1 of 5

i PROJECT * *"'

} INSTRUCTION PI-MP3-09 INSTRUCTION REV.0 i 1.0 PURPOSE i

This project instruction (PI) establishes the Sargent & Lundy procedure for preparing checklists to be used in the Independent Corrective Action Verification Program (ICAVP) reviews. These checklists shall be used by the ICAVP reviewers to document and verify key attributes and areas covered in the ICAVP. These checklists will provide the team with the basis for determining if discrepancies exist in the design, configuration, and operation, maintenance j and testing of the Millstone Unit 3 plant (MP3).

1 l

' All areas of the ICAVP shall utilize checklists to control the review activities.

These areas include:

System Reviews Operation, Maintenance and Testing Reviews Physical Configuration Reviews Programmatic Reviews Accident Mitigation Systems Review As many checklists as is required to adequately cover the particular review area shall be utilized.

2.0 REFERENCES

2.1 MP3 Final Safety Analysis Report 2.2 MP3 Safety Evaluation Report 2.3 MP3 Technical Specifications 2.4 MP3 Design Criteria 2.5 10CFR50 Appendix A General Design Criteria 2.6 NRC Inspection Manual, Chapter 2535, Appendix A 3.0 DEFINITIONS 3.1 System Review - In depth review of the design of the systems in the scope of the ICAVP

- Page 2 of 5

l PROJECT INSTRUCTION "f"" .-

INSTRUCTION PI-MPS-09 REV.0 i

) 3.2 Operation, Maintenance and Testing Review- Review of the i operating, maintenance and testing procedures, and training manuals for l the systems within the scope of the ICAVP

3.3 Physical Configuration Review - Walkdowns to verify that the current as-bui!t conditions are in conformance with the design and licensing l basis for the systems within the scope of the ICAVP i

' 3.4 Programmatic Review - Review of programs and processes addressing

" generic" (non-system specific) issues

3.5 Accident Mitigation System Review - Review of the critical design j

characteristics for the accident mitigating systems to ensure that they

! can perform their required safety functions.

l l 4.0 RESPONSIBILITIES i

! 4.1 A Verification Team (VT) Member shall be responsible for preparation of a checklist and for performing a review associated with a checklist.

} 4.2 The VT Lead or his designee shall be responsible for approving the i checklists in his area and for providing concurrence for the reviews i conducted within his area.

i

! 4.3 The VT Manager shall be responsible for resolving comments which cannot be resolved between a team member (reviewer) and the Team l

Lead. The Verification Team Manager may also approve checklists.

5.0 PROCEDURE l I

5.1 General The checklists are intended to assure that key issues associated with a i

particular area or element are adequately and consistently evaluated i

during the review process. Some checklists may be system specific, but many of the checklists will apply to elements that are common to many

) or all systems.

I l

m Page 3 o75

i s

PROJECT

• 4 #

INSTRUCTION PI-MP3-09 INSTRUCTION .- REV.0 l

5.2 Checklist Preparation l 5.2.1 Checklists shall be prepared prior to performing the affected review j activities.

l 5.2.2 The checklist shall be prepared by an individual knowledgeable in the j

area or element under review. The preparer may be the individual who

will perform the review.

1 l 5.2.3 The first page of the checklist shall use a form similar to that shown in i Attachment 7.2. The checklist shali con %in questions related to key l Issues applicable to the area or element under review. Applicable i

checklists developed for previous project reviews may be utilized as a

! source for checklist preparation. Input for checklist preparation may be i

obtained from the following:

1 MP3 Final Safety Analysis Report j MP3 Safety Evaluation Report

. MP3 Technical Specifications i MP3 Design Criteria j 10CFR50 Appendix A General Design Criteria

( USNRC Regulatory Guides applicable to MP3 Industry Codes and Standards applicable to MP3

$l l

in addition to the above MP3 source documents, S&L design experience and practices, as well as industry experience, shall provide a basis for

checklist preparation. Chapter 2535," Design Verification Programs",

2 Appendix A, of the NRC Inspection Manual also provides guidance for l checklist preparation, (Ref. 2.6).

l l Checklists shall address system design adequacy, component design l adequacy, design process adequacy, and plant procedure adequacy.

j Specific accept / reject criteria shall be provided for configuration reviews.

l 5.2.4 Checklists shall be numbered by each ICAVP group according to the

! following scheme:

}

CK-MP3-EE-EM 1

Project instruction _ Sequential Number Applicable to the Checklist m Page 4 of 5

l PROJECT

- #~ ""

l INSTRUCTION PI-MP3-09 lNSTRUCTION REV.O i

j 5.2.5 The Team Member designated as preparer of the checklist shall sign

! and date the checklist. The checklist shall be approved by the I respective VT Lead or by the VT Manager, l l' 5.2.6 The VT Lead shall file checklists in the project file in accordance with PI-MP3-12.

5.3 Checklist Completion

The ICAVP Verifier assigned to perform the evaluation of a particular i area / element shall complete the appropriate checklist according to the j requirements of the applicable project instruction and sign and date the j checklist. It is recommended that the checklist be used to document the j basis for accepting questionable items which might otherwise be considered discrepant by another reviewer. As a minimum, the

! appropriate VT Lead or his designee will indicate his concurrence with j the review work performed by the ICAVP Verifier by also signing and j dating the checklist. This concurrence will confirm that thn 6ecklist is complete and that there is adequate explanation describit ne results. l

Concurrence shall not be given unless there is documenta ;n of those j records and/or documents used in filling out the checklist.

i i Any unresolved comments between the ICAVP reviewer and the VT l Lead will be resolved by the VT Manager. Any differing professional l opinions shall be handled in accordance with PI-MP3-10.

l Discrepancies identified as a result of the checklist review shall be I j processed in accordance with PI-MP3-11.

6.0 REVISIONS Any revisions to a checklist shall be prepared and approved in the same manner i as the originalissue. The revision level of the checklist shall be indicated on the i checklist. If a checklist revision is made subsequent to the completion of any reviews, the affected review shall also be updated, as applicable, to account for the revisions to the checklist.

! 7.0 ATTACHMENTS J

1 7.1 ICAVP Process Flowchart," Checklist Preparation, Approval and Use"

(1 page) ,

7.2 Sample Checidist Form (1 page) m l

l1 l Page 5 of 5 4

PI-MP3-09 I Attachm:nt 7.1 Gather MP3 Data &

Questions Related '

"f j

to Checklist

(~}

\J ,

pi i

$t c 1 Team Member /'  !

1. enaand&Ew;st v

l f5 Prepare Checklist #$  !

sg Team Member fj ,

liMi@heEsis?I14223 l Y

li Approve Checklist [j u

l')h Review Team Lead (y  ;

Rda;2 Ent@ aged i V

O Perform Review per p V applicable Checklist [E Requirements iff Fs k

Verifier t

EsEandsnaasdis t

3a Review Concurrence si!

b Review Team Lead f!!.

g;gy2s 1.m as % 4%Q v

File Checklist per PI- [

MP3-12 !j a

l Review Team Lead [

MadiGueu%iakuhA O\

U ICAVP PROCESS FLOWCHART Checklist Preparation, Approval and Use

~

PI-MP3-09

, Attachment 7.2 i

Samole Checklist Cover Pane i

l

Northeast Utilities

Millstone- Unit 3 Independent Corrective Action Verification Program j (ICAVP)

i

1 System Review Checklist l 4

CK-MP3-02 -4.3, Rey, 0 l

Electrical Schematic Review Checklijt  !

i 1 4

l i

f L Prepared by:

Name Signature Date I Approved by:

j Name Signature Date 1

i i  !

IMPLEMENTATION System  ;

Document No/Rev. ,

i Verified by: Date:

1 A Concurrence by: Date:

V

-_. - ~ . _ . _ . . - . . - - . - _ . . - . . _ .. -. - - - - - -_-- --- - __ - -_ _ _. , .

l PROJECT INSTRUCTION PI-MP3-10 l

INSTRUCTION REV.O i

l l Client: Northeast Utilities l

l Station: Millstone Unit 3

Title:

DIFFERING PROFESSIONAL OPINIONS l

i i

h Safety-Related _

Non-Safety-Related j Reviewed By: Approved By:

?

System Lead Programmatic O&M Lead Accident QA Engineer Intemal Review Verification Team

}  ! ead Mitigation Committee Manager

Lead Chairman l _

l j Date: I~&#$l k ll$d WN J,$$!<Ya N(hlt$$$nerlxw$ h& hT!W0 Description inftfal%ue 7 ~

l i

i t

(

I I 1

l i

l l

J i

l Page 1 of 4

i PROJECT INSTRUCTION PI-MP3-10 INSTRUCTION - [ #' REV.O j 1.0 PURPOSE l This instruction establishes the requirements for the handling and resolution of I differing professional opinions (DPO) related to technical safety significant concems I raised during the implementation of the Independent Corrective Action Program 1 (ICAVP) for Millstone Unit 3.

2.0 REFERENCE l

i 2.1 NRC Confirmatory Order Establishing independent Correction Action ,

j Verificat'on Program - Millstone Nuclear Power Station, Units 1,2 and 3  !

i \

! 2.2 PI-MP3-01, Communications Protocol '

i

{ 2.3 PI-MP3-12, Project File Index 2.4 10CFR50.7, Employee Protection 3.0 DEFINITIONS 3.1 Differing Professional Opinion - a written statement expressing an individual's professionaljudgment on a technical issue that is different than l a decision made or a position taken by the management of the project.

f

{ 3.2 DPO Resolution - a written statement providing the technical basis for the

} disposition of the DPO.

j 3.3 initiator - The individual Project Team member that initiates a DPO.

i I

4.0 griSP,0NSti'lLITIES l

l 4.1 W,e initiator shall be responsible for preparing the DPO when he believes it j necessary to raise a ter irEcal safety concem.

i l 4.2 The ICAVP Management Team (Project Director, Verification Team Manager, or Intemal Re#;< Committee Chairman, as appropriate) shall be

responsible for providing the technical basis in writing for a decision made or j a position taken on a technica issue for which a DPO has been generated.

m i

l i

j Page 2 of 4

<v .

. r . - --

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

i 1 ,

l PROJECT INSTRUCTION Pl-MP3-10

INSTRUCTION .

REV.0 4

4.3 The Quality Assurance Manager shall be responsible for establishing a j board to provide a disposition for the DPO using the resources of the j firm as required.

i f

4.4 The Verification Team Manager is responsible for maintaining a log of al!

DPOs initiated during the project and for submitting a copy of the DPOs and j their resolution to the NRC.

5.0 PROCEDURE

! i

! 5.1 General Differences of opinion on technicalissues occur from tir-* to time during the conduct of professional activities. These differences at normally resolved by the individuals within the chain of command of a project. In the case of  ;

the ICAVP, it is expected that the Verification Team Manager will facilitate j the resolution of issues within the Verification Team, and that the Project i j

Director will facilitate the resolution of issues between the Verification Team 4

] and the Intemal Review Committee, when roquired. However, if any 1

• O

. U member of the ICAVP Project Team disagrees with a decision or position taken on a technicalissue that he believes has potential safety significance, he may initiate a formal Differing Professional Opinion in accordance with the following procedural steps.

l 5.2 The Initiator shall prepare the DPO on Attachment 6.1.

The DPO shall contain the following information related to the

technical issue, along with any supporting information

i ~

e i a summary of the Management decision or position on the technical j issue, j e a description of the Initiators view and how they differ from the j management position, e the rationale for the Initiators opinion on the issue, including an i

assessment of the potential consequences, based on risk and safety, if l the initiator's position is not adopted, j 5.3 The Initiator shall sign and date the DPO form and forward the original of i the form along with any attachments to the S&L Quality Assurance i Manager. A copy of the DPO form shall be submitted to the Verification j Team Manager and he shall maintain a log of all DPOs on the project.

1 i

i i

m Page 3 of 4 1

i ,

PROJECT * ##

INSTRUCTION PI-MP3-10  ;

INSTRUCTlON - REV.O j

4 5.4 The QA Manager shall, within three working days of receipt of the i DPO, acknowledge its receipt to the Initiator. The QA Manager shall j notify the S&L Power Services Business Group Executive Vice President l

of the receipt of the DPO and shall convene a board consisting of I l himself, the PSBG Lead Nuclear Project Director and a mutually l j acceptable subject matter expert to disposition the DPO. l 1

5.5 The DPO Board shall provide a disposition to the DPO based on the j

technical merits of the issue within 10 working days from receipt of the j DPO. They may request to interview the Initiator and /or the 4

management of the project or others as required to arrive at their

decision. The QA Manager shall submit the DPO Resolution to the i Initiator, the Verification Team Manager, the Project Director, and the

PSBG Executive VP.

} 5.6 The Verification Team Manager shall log the resolution and submit a i

copy of the complete DPO and DPO Resolution along with all supporting documentation to the NRC primary contact listed in the Communications Protocol Pl-MP3-01 (Reference 2.2).

[ 5.7 The Verification Team Manager shall review the disposition and take any j

corrective action required by the disposition, including any "re-work" of j the ICAVP review process, if required.

I 5.8 The Verification Team Manager shall file the DPO and the resolution in accordance with PI-MP3-12.

4

! 5.9 The initiator and any other employee also has the right to contact the j

NRC directly with a safety concern without fear of reprisal in accordance with S&L policy and 10CFR50.7 (Reference 2.4).

6.0 ATTACHMENTS l

,' 6.1 Differing Professional Opinion Form (1 page)

{ 6.2 Flow Chart, DPO Process (1 page) l Page 4 of 4 4

4 PI-MP3-10

) Attachment 6.1

( DPO-MP3-l 3

j Independent Corrective Action Verification Program

Millstone Nuclear Power Station - Unit 3 1

1 Differing Professional Opinion l i

l t

i Description of Technical Issue and S&L Management Position:

! l l i i

i (Add pages as required) 1 Description ofInitiator's View, Rationale, and Assessment of Consequences, if not adopted:

l I

Initiator Date (Add pages as required) i Disposition:

QA Manager Date (Add pages as required)

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

PI-MP3-10 Attachment 6.2 DIFFERING PROFESSIONAL OPINION jQ PROCESS FLOW CHART Normal Resolution of TechnicalIssues VT Mgr/PD 1r initiates DPO on Safety Concem , Notification of Receipt Initiator v

Log DPO Receives DPO -

: Notifies Power Services VT Manager 6 oanager Business Group Exec VP n

o ,,

Convenes Board to Dispostion DPO QA Manager 1

1r Wion DPO and Distribute to:

Mbute  : Initiator i Project Director l DPO Board P88G Exec VP 1r Subrnit DPO and Deposition to NRC VT Manager v

Corrective Action, if Required VT Manager

I i PROJECT " " " ' "

INSTRUCTION PI-MP3-11 INSTRUCTION .

REV.O Client: f.J2 J, east Utilities

! Station: Millstone Unit 3 l

Title:

DISCREPANCY REPORT SUBMITTAL AND CLOSURE i

l l 2 Safety-Related Non-Safety-Related ,

l '

i l

1 l

l Reviewed By: Approved By:

I I System Lead Programmatic O&M Lead Accident QA Engineer intemal Review Verification Team l Lead Mitigation Committee Manager 4

Lead Chairman l Diw3-4-97

/

$$S Y&/k & hlbY% h& $ N ,Yk i Description Inipal pe V'

i.

1 l

l i

}

O.

l Page 1 of 10

i PROJECT INSTRUCTION PI-MP3-11 INSTRUCTION - REV.O l i

i 1.0 PURPOSE This instruction establishes the requirements for the preparation, submittal i

and closure of Discrepancy Reports for descrepant conditions identified by i the Independent Corrective Action Verification Program (ICAVP) Team. This j instruction addresses the preparation of DRs by the ICAVP team, the review l of proposed resolutions developed by Northeast Utilities and the trending of DRs generated by the Verification Team.

J 2.0 REFERENCE l

j 2.1 NRC Confirmatory Order Establishing Independent Correction Action i Verification Program - Millstone Nuclear Power Station, Units 1,2, l and 3 i

j 2.2 PI-MP3-01, ICAVP Commurhation Protocol i

j 2.3 PI-MP3-02, Review of System Design for Compliance with Design &

i Licensing Basis iO j 2.4 PI-MP3-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy end for Configuration j Control.

i i 2.5 P!-MP3-04, Programmatic Reviews l' 2.6 PI-MP3-05, Physical Plant Configuration Walkdowns

{

4 1

2.7 PI-MP3-06, Operations and Maintenance and Testing Procedures  !

i and Training Documentation Reviews l l l 2.8 PI-MP3-07, Review of Accident Mitigation Systems  ;

l j

2.9 PI-MP3-10, Differing Professional Opinions 2.10 PI-MP3-12, Project File Index i

i1 J

l i 6 Page 2 of 10

i PROJECT INSTRUCTION PI-MP3-11 INSTRUCTION - REV.O I l 3.0 DEFINITIONS j j 3.1 Accident Mitigation Review Group (ARG)-The subgroup of the ICAVP j Verification Team responsible for review of critical characteristics of j accident mitigation systems to ensure those systems can perform their j required safety functions.

3.2 Internal Review Committee (IRC)- A committee comprised of senior l S&L management personnel responsible for overall technical oversight of j the ICAVP.

l l 3.3 Operations & Maintenance and Testing Review Group (ORG)-The l subgroup of the ICAVP Verification Team responsible for the review of the

! operating, maintenance and testing procedures, and training materials for i the systems within the scope of the ICAVP.

l 3.4 System Review Group (SRG)- The subgroup of the ICAVP Verificaticr

! Team responsible for performing an in<fepth review of the design of the

- systems in the scope of the ICAVP.

l 3.5 Configuration Review Group (CRG)-The subgroup of the SRG l Verification Team responsible for walkdowns to verify the current as i built conditions are in conformance with the design output documents.

I l 3.6 Programmatic Review Group (PRG)-The subgroup of the ICAVP l Verification Team responsible for review of the processes used to change j the facility design or the operation, maintenance and testing of the facility.

l The PRG is also responsible for verifying the adequacy of NU's corrective l actions.

! 3.7 Discrepancy Report (DR)-The mechanism fer documenting the l discrepant conditions identified by the ICAVP and reporting the condition

to NU for resolution.

i i

m i

i l Page 3 of 10

a PROJECT INSTRUCTION """"*[* "

INSTRUCTION PI-MP3-11 REV.O

! 4.0 RESPONSIBILITIES

! 4.1 Initiator -

Responsible for preparation of DR in accordene with

{ the instructions contained in this project ins,,metion I

i -

Responsible for review of proposed NU resolutions in

accordance with the instructions contained in this project l instruction.

i

! 4.2 Verification Group Lead -

Responsible for first level review of DRs l prepared by initiator.

l Responsible for assigning DR number.

l t

Responsible for review of S&L's l dispositions to proposed NU resolutions.

I j -

Responsible for resolving comments with the Initiator.

iO i

j 4.3 Verification Team Manager -

Responsible for reviewing initial DRs l and S&L dispositions to proposed NU

! resolutions.

l l -

Responsible for resolving comments l with the Verification Group Lead and l the Initiator.

l -

Responsible for overall control of DR process including maintenance of DR log, trending data and extemal distributions.

4.4 IRC Members / Chairman -

Responsible for reviewing DRs and dispositions of proposed NU resolutions prepared by the Verification Team and for resolving any comments with the Verification Team.

m Page 4 of 10

I PROJECT l INSTRUCTION PI-MP3-11 j INSTRUCTION REV.O 5.0 PROCEDURE i The Nuclear Regulatory Commission (NRC) Confirmatory Order (Reference i

2.1) requires Northeast Utilities (NU) to implement the ICAVP. References 2.3

, through 2.8 provide the instructions for implementing the reviews included in

the scope of the ICAVP. Discrepant conditions identified by the Verification i

Team members during the performance of these reviews will require the initiation of a DR. This project instruction provides the requirements for i initiating, processing and closure of DRs. DRs shall not be generated for j findings already identified by NU during implementation of their Configuration Management Plan.

l

) Note: DRs shall be generated as soon as practical after the condition has been ,

i identified. Those DRs which may be potential operability concerns shall be l l expedited through the review and approval process and NU shall be notified per i Subsection 5.5.1 of this instruction.

The DR process involves the following tasks:

l

a. DR initiation

b. DR resolution and closure

c. DR log and trending data

d. DR distribution DRs shall be generated in en electronic format using a DR Access Database.

Attachments 6.2 through 6.5 of this project instructions illustrate sample database input screens. Hardcopies of the DRs, a DR Log, DR status reports and DR trend reports can be generated from the database.

The detailed instructions for each of the above task are described in sub-sections 5.2 through 5.5. Attachment 6.1 is a flow chart illustrating the DR process.

5.2 DR Initiation 5.2.1 Members of the ARG, CRG, ORG, PRG and SRG Verification Teams shall initiate a DR for any discrepant condition identified during their respective reviews. The individual initiating the DR sh'all be referred to as the initiator. ,

Paga 5 of 10

h PROJECT d "#"

INSTRUCTION PI-MP3-11

)

INSTRUCTION REV.O j i

l Note: Before initiating a DR, the Initiator shall ensure the condition

! has been thoroughly investigated and the total scope of the ,

condition has been identified. Any additional information needed l from NU shall be requested per PI-MP3-01.

5.2.2 The Initiator shall prepare the Discrepancy Report by entering the l l following data into the database's ' Discrepancy Screen", Attachment

6.2

! Note: The fields listed below which are indicated with an asterisk l have pulldown menus. Applicable entries in these menus are listed in

! Attachment 6.6. I i

Field instruction

\

Review Group

• Enter Applicable Review Group

, Review Element

• Enter Applicable Review Element Discipline

• Enter Applicable Organization

{

1

{ Discrepancy Type

• Enter Applicable Discrepancy Type i

I Potential Operability

• Enter whether the Discrepancy is a i

Issue Potential Operability issue using the guidance in Attachment 6.7 i

! Systern/ Process Enter by Full Name the system or process l being reviewed.

i i Discrepancy Enter brief title

}

Description Enter detailed description of condition including specific references and basis for

[j potential operability determination, if DR is determined to be potential operability issue.

m Page 6 of 10

I PROJECT d'Y"'

INSTRUCTION PI-MP3-11 INSTRUCTION ,

REV.0 I

initiator Enter your name; Last name first followed l by first and middle initials (i.e. Doe, J. A.)

l l Date Enter preparation date The database will automatically assign DR Nos., revision level and l status.

! 5.2.3 The VT Lead shall review the initial DR draft.

i j 5.2.3.1 If the VT Lead has comments on the DR or determines that additional j information is needed, the VT Lead shall resolve the comments with

} the Initiator.

! l 1 5.2.3.2 If the VT Lead does not concur with the DR, the VT Lead shall i

complete the " Invalid Screen", Attachment 6.3, by entering his name, i date and justification for the invalid disposition. The VT Lead shall i review the invalid disposition with the Initiator.  !

0 i 5.2.3.3 If the initiator agrees with the VT Lead's invalid disposition, the t

! Initiator shall indicate his concurrence on the " Invalid Screen",

j Attachment 6.3. The initiator shall then file the invalid DR with the applicable element review file.

! 5.2.3.4 If the VT Lead and initiator do not reach agreement, the VT Manager j shall resolve the issue. If either of the parties has a safety concern i related to the DR, the provisions of PI-MP3-10 for Differing

Professional Opinions may be invoked.

5.2.3.5 If the VT Lead concurs with the DR, the VT Lead shall enter his name, and date on the Discrepancy Screen, Attachment 6.2.

5.2.4 The VT Manager shall review the DR. The review process shall be consistent with the instructions contained in Subsections 5.2.3.1 through 5.2.3.5 above, except that any comments or invalid dispositions shall be reviewed with both the Initiator and the VT Lead.

- Page 7 of 10

d j * " " '

PROJECT INSTRUCTION PI-MP3-11 j INSTRUCTION . REV.0 j

i Note: The reviews associated with Subsections 5.2.3 and 5.2.4

can be concurrent in a group session.

l 5.2.5 The IRC shall review the DR. The review process shall be consistent l with the instruction contained in Subsections 5.2.3.1 through 5.2.3.5

! above, except that any comments or invalid dispositions shall be i reviewed with the initiator, VT Lead and VT Manager.

5.2.6 The VT Manager shall distribute approved DRs to the NRC, NU and

! the Public in accordance with Subsection 5.5 of this project instruction.

l l 5.3 DR Resolution and Closure I

l 5.3.1 Proposed resolutions submitted by NU shall be reviewed in a manner i similar to the DR initiation process described in Subsection 5.2 of this

project instruction. The DR proposed resolution shall first be reviewed l by the Verification Team and then the IRC. Concurrent review by VT j members, Leads, and Manager are permitted.

O 532 The Initi8 tor $haii summarizes the Nu resoiution on the NU Resolution Screen", Attachment 6.4. Concurrence by the VI' members j shall be indicated on the screen, Attachment 6.4. The DR shall be distributed to the NRC, NU and the Public per Section 5.5 of this project instruction.

I

! 5.3.3 If the initiator, VT Lead, VT Manager or IRC do not concur with the

proposed resolution, the non-concurring party shall document their j justification for rejecting the resolution on the " Rejection Screen",

l Attachment 6.5 and obtain concurrence from all other members on Attachment 6.5. Rejected Dispositions shall be distributed to the NRC i and NU in accordance with Subsection 5.5 of this project instruction.

i 5.3.4 Revised proposed resolutions submitted by NU in response to S&L

! comments shall be reprocessed in accordance with Subsection 5.3.1

through 5.3.3. Only one additional resolution cycle per discrepancy is anticipated.

l i

m 4

l l

4 Page 8 cf 10

. _ _ _ . _ _ ._ _ _ _ . _ _ _ _ _ . ~ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _

i PROJECT INSTRUCTION PI-MP3-11 INSTRUCTION REV.0 4

i i

5.3.5 If all groups, (the VT members and the IRC) cannot reach agreement l on acceptance of the proposed NU resolutions and anyone has a '

j safety concern, then the provisions of PI-MP3-10 for differing professional opinions DPO may be invoked.

i

) 5.4 DR Loo and Trendino Data '

j 5.4.1 DR Log l

5.4.1.1 The DR database shall automatically assign DR Nos, status and

revision. Hardcopy logs can be generated from the database.

l l 5.4.2 TrendinD Data i

5.4.2.1 The DR database can be sorted by the entries on Attachment 6.6 to generate trend reports.

5.5 DR Distribution 5.5.1 InitialIssues 5.5.1.1 The VT Manager shall distribute valid DRs to the NRC, NU and the Public per Subsection 3.3 of PI-MP3-01. Distribution to the NRC and NU shall be in the form of hardcopies. Since generation of DRs will be by electronic media with database security provisions, signatures shall ,

not be required.

5.5.1.2 DRs determined invalid during review shall not be distributed extemally. Hardcopies shall be maintained in the project file in accordance with PI-MP3-12.

5.5.1.3 The VT Manager will fax DRs which may pose potential operability concern to the NU Point Of Contact identified in PI-MP3-01. The date sent shall be entered on the Discrepancy Screen.

m Page 9 of 10

4 i

o PROJECT INSTRUCTION PI-MP3-11 INSTRUCTION .- REV.0 4

i 5.5.2 Proposed Resolutions i l l 5.5.2.1 The VT Manager shall distribute accepted (closed) DRs to the NRC, I l NU and the Public in accordance with Subsection 3.4 of PI-MP3-01.

Hardcopies shall be sent to the NRC and NU.

l l

5.5.2.2 The VT Manager shall distribute S&L comments on proposed i resolutions to the NRC and NU only, in accordance with Subsection 3.4 of PI-MP3-01.

l l 6.0 ATTACHMENTS 6.1 Process Flowchart, Processing Findings & Resolutions (1 page).

i

6.2 Sample Discrepancy Screen (1 page).

O e.a SampieinveiidSoreen(4 9eoe).

6.4 Sample Resolution Screen (1 page).

l j 6.5 Sample Rejection Sheet (1 page) i j 6.6 Summary of Available Entries for Pulldown Menus (1 page) i l 6.7 Criteria for Operability Determination (1 page).

l

) Note: Attachments 6.2 through 6.4 are sample it!ustrations of the DR Access i Database data entry screens. This instruction will be revised if the data fields i

are revised. Revision to this instruction is not required for format changes to i the data entry screens.

I l

l 1

j

'O Page 10 of 10

\

initiate Discrepancy PI-MP311 Rep HDR) ATTACHMENT 6.1 PROCESSING FINDINGS  :

~ AND RESOLUTIONS vr ir Review DR VT Mgmt ir Document Basis for is DR Valid & DR noe Not Discrepant l ^ Adequate? valid V VT Yes v I

% Review DR info Required IRC l

V is DR Valid & DR not

.W7 Vand i l

Submit DR to NRC/NU

& Post on Electronic VT Mgmt I d

Provide DR Response to VT Management NU h

Review NU Response for Adequacy VTNT Mgmt Document Reasons for Rejection / Submit to 4 NU/NRC Review NU Response VT Mgmt & VT Acceptance /

n Rejection IRG ir l Document Acceptance

NU Response & Submit to NRC/NU &

Ne to DR Yes--> Post on Electronic BB

-p h% *?

VT Mgmt

r i

r t

PI-MP3-011, Rev. O Attachrnent 6. 2 [

1

?

k i

a: wepww, , ,ve.n.nnw . v.s. m.,n.

m vm-wmn n

ww=+es**Wn$

. , c ,

t ~,mm n a . . n,.~m=. ~n , - g: p .

wQ 4=Er y.mwe3n*W 4. au).stam*+. mW% v3 wW yeWt L

n $ an p,wg:g,y=

W -9 .S M d' %p ~JapiiliOf'+ JEU.-eviweW3l,pWE. -

. n n .L%vn"5

~ . .

lDR-MP3-0001 3 QDrafts f.frj-n@ tl .1 ,!

u. ~ m.

' . a e ~~ ~ -

v .

v.

@v.p gw.

1:. ,,

u g~^

, ~ q z.pu4v44isAo9 Discrepancy AltweilddwResolution:l,P Rejectiona,l;M?lExit g

. -9.~~. 5.,ag gy)t j

t IET'? 4 1, V ~ ~ TJ s'.* Jh6 i g"i "

~T

. .$ . 4.c Q# f~ y J^M . N;*.W',! @n #

.>',}_,,,.3 y '. 3#:f

(

.f

,,,4.

"~

ES$%,. f "7],T.h~.-1Miiig# W ~i WPotential OperaisiEtyllesue El VN m:n.__

wyAwwam

_ _ # : l System wReview  : ~. w ,

Group

-+n.-

g=nMF e x m w -

,a f i -

a... - 9 2 j9 x e&y Oy0~LXes:m; ' , ;;mO ;c Net 3m '.

,.ng ~na m -

t

~. .~  : -

qlModificationinstauation a.p.~N~N6fS M. ~ rG.:p;Revenesed m t o . . . . < - .  :.# y%c,w m w . n

'g$,@;"M"gRWy? fi:'s. .  % u,, m.p., 4 r z. ,

g~c. m w- c.w  ;. ,g um%a,; ,e .

os s 7 . , , .. -

ep , {

M; W e # p@a.m;mainb BiinnlPipingDesign JJ N 1ww r

[f ~'9A ~q^M@o mm,, ma. %a Awn- ,y m-

_ - - Data toam. NU:92/20/97 - - w am  :

i

-a. . .mm.

~'y Discrepancy j 9+

aw,wwn 7' . l Drawing qw@RinitiatorGlBittingham, Angelique g v. ..M i

__ -n -

u . s, e -

--m,- m%e -.-

c.m. - , , . . .

.n% .

73patesserocess:fl Residual Heat Removal 3"e, - yf . a.  % - v - Dete:@l2/20/97 l i M:mu %snww 2W ~-

p.n=ww w .u

- umw mn W @W : mv

.. . . - m.n

~- -

- C ~ i%. 2W a @m+  :

• • ., m ,

- J -:. . \

k~' ~Q y:.ej, _ -w>do - - ;. , ? . .

• ~ , :O'?*'". L; -'

. ~'*'.< - &:- * ,, ' OL 4&*' s

.., ff,  ;

Npye D vr . ~iscrogancs l Drawing Discrepancy m$

w ,4, n . x_. , , - - . . .+ -

.x . . . = -

wm mm i QQ~EDesetiption: P & ID XXX shows the highpoint vent upstream of MOV-XXX while isometric drawing .JQg  ;

.g ,&V.n :

W .- . Mn@ i number XXX shows the high point vent downstream of MOV->>X. T a

w w %. ,.m_m_.a

,w m.

_ a. . -

_s ys t n.na.p. m n; w . u . em. ~ ew -

?hff

bf

^

w. m. n.. ~, ,m. . r.a

..,c - , s -,: : ~,

yP.M. ,v-'an;q nnurNr _i w~ v c. . < wn my.~ym.w w.

. . . . ., ,vr ayun; a^ i

-~.g8 y7. . . v s m:n 4 . . ~ ,.  ; %.c.e:8

.s.es . -

,w ..n... .- w-: t -

c . v n -

_;ngw$9MAendr iM . :lNeri A

, . A. jMyalid?j F ' Dateigj2/20/97 -

B&mh < ' m ' _3_ aM w

n. ea,m,gpsw n.~

v~-- .u

- - - - - ~ ~ n wu. m. -

Aga. .,- m g=. y  ;

-n .. .?., m:.  : . a ;,.. .

1. spyJR .-MWD  %,7, 4d My..M Aft:5tI? K. !Date-M Y 4Ie 3:c,w w

en.:w%c m-...-

.gr:y lSchopfer, - -en D. K.

a+www m,w a . ..

wwe v.l2/24/97

.m L w +4.n -

w sw. , . . . w m.x- m trim ,s. . - u - ~.

WFMIRE43naniilSingh, A. K. piValid?qRf Datei3l2/26/97 p~; M .': f U Q O g M @m l Dn!2LkWidW * , nwwwm - s.tiki15522 ' Mw= ~ m rim n @ m W nd& t Input Screen for Discrepancy Report  !

t

)

I, P

I

.________.__.__._________ _ _ _______ _t

% s

[

]

PI-MP3-011, Rev. O Attachment 6. 3 h

f t

c

• g, p. . ..m;,.

magr;m 7;:n.,e .e s +, y ., . , . c.--:#a . 3 _

y

{ ,. . .m -r

. . .w t - 4 4.-. ..m...e....fs.~

. v7m;p,: 3 . a a r, w .w, m. . . .

w p q ... + ~ ., -

3 SQ ..%"4 4 _, m a wmpnm g h m..  ; f;,..

i

_y ~.ws_ .y gn4y Q-

• g , . gZ-:

Oh;e.ul NNj;.lDR-MP3-0001 g Drafty l1

@$.51NN ie%w--.,.~.

W e COldh._Mk m.t.

,- ~

c

m. .n E.s'tatus: - l 3 - Q.4, ..: ,.

. z..m .

- .m p m m.s.g

.2 ,

Resolutionh, ~ , . ... . xRejectiond, gQ Exita R @w:qf M M.M!$ N...iWMesGoto ?Discrepa._ncy?l Invalid u+ ,.4w-= , o- a.:

n jpe" lrevaliefi Justification for Invalid goes here if applicable. ,

o C:

. i

@M. . MJasstification#2 a -

r ?.ynE. l

,- . . , x.~ O&$&nT: M?.$ 7

E~$

.. 5.u].y5y . -, .

., ,.+ M;%..I.'zz > ,

.;g  ; [.i! I' )

h"5

~

a :P e W .$..C. $. ' -

"?. +- t

_. ).J  ?.wl-

1: l' ' w' ~ 7.'N "

Q i

~. 4 u .

gr,yg'6 .c ,I

-p'pMMU N' .e

. 8 u.m%pL 1

...g @ C*P ~ .

m. ,n

%.-r

n. n n.

,;-R ev.,'k 3  : y

w ,

,, w. r. a ,.

yrc,g +&. h m, -

m. - V. , l a ,

gg. my-r >w ,y

. ..M- tO.

p.mp;  ;

4R-.

. ;m- : g w.  : .s w . . . . , -

m E. .,g-ddeh + E - ?* k ,$

. - ' %..~'.2" .

, . r7 h-Qy;*

pu s-s MMy zcw&

M .m ;Aw n . .wo. ,

W--t

.x,,s --p,

.v 3.......

F;N e 4 m u-fv m,. n o-ny,,u +e7r p

.v. . c ,

g

-n

~

- : y@ff -sp QBt ;

04%.e."

- r wn,y..;y _. ., a . ;..,o , ,

.~.;'- k q--

...P,'

'*~_u

,I. ",

- *e .,

v g,..

_sd

- I. h 7 7-' y_

1.1 W5N'" [ g- 6 j

.f r h *'_

y* Mu%' .J . l y i

. ,;; ~ ..

ty =

i

+ pp. e, s . n...e ,nv g w um,u .-z .a.

. ,. . m ....,.s~ .n :::..- -. - . .. .-. , ;v, . >~

m, , -- ~~n..w+w ~ w;, + %  :

hs MpSQinitiator Concurrence 9(Invaliti Disposition? .F .Date-iy2/20/97 ESMR w $7 7

_. 2 r _* y .

_ m< - . m -

n.

_ - . . ,._m . _ , . . - m.m _ m._

atn m%u.. -

W d$s9M i VT Lead""lNeri,+ A. A. @lavalid?@.. ~ Dates l2/20/97 @@mh i ,S@,bW -

.wen w i w.m-m m %c.-., .

a ake.w . . ..,<...n

- ,- ~

_ ..: . ., . .. a .. , ae-w t

<. .; c m.m -w -

8 QSWW AVLMgr:MSchopfer, D. K. gnlavalid? RR Date:Uj2/24/97 M;;:R" Mg@x@y. q

um# , ny .

.. , ~ ~ .

. Od.h s a

, oes e +Jit.M Qghg.srertv '- -

i M6sa.'/.$' .

, g  ; '.d,- e wt

~

- aNs . r m .,,,. ,

w- ss.wW 7 ui e , ;S . .f r .

es Wy9fkiR eC Cluera::G'lSingh, A. K. gM' .. invalid? FC:--Date@l2/26/97 f!s&'%JM ,W  !

s. W 4

i.W~:.M.J,MG^* i - *- V 'l : s': v L ' % t Mt** f-6,

.* ' Y?ni A(Y: " T3 7 --5% MAW ~

. ~ .n M.) <. #" W' - ~Rs

A h%.kG$&wM t

input Screen for Invalid Justification

)

i t

+

. - .. . . , . _ _ __ . - - - - .- - - - - - . . .. - - . . - . - - - .. - . - ~ - . . . . - . _ . - . . . . - . _ . - _ -

s m >

i PI-MP3-011, Rev. O Attachment 6. 4 ,

- x,,r. , .rx.r s we . ww .w. a,.,.mmsw ,,emy-:;<,vm m m .e a s ee. - .w v , ~.,~

2, :8

<.e ,,,- - . :. .-

L

%92)w4J50148) ., _. . ; ilf lOf+fid;j*.)fM!.Ho.: -lDR-MP3-0001 . < Draft:ql 1  :

1 status: l 3 f,T,*f

_. ,__->w.x..,.

,.m. _s_-- _.w.. 5.-

~

r . n.~

..nE_.

~ - -

n... - - ,

. . s ~ . - a s ; sG,, E#gmGo ton 3 Discrepancy lMinvalid;I Resolution. TRejection! $gn ,e -

d , iExitL m

d h;.4  !

u ur.a m ~.n . - .. ~ -

n.

Pn. a me * *. - 49.w

+:~45,.:; '

5 '

. DateN., I2  :  %

ys g s -:

.,.s .p . - .

-w % ~~ m;g w.- /20/97 m -

..a WM;

, -m.;  : O n S.z. , m.np . .9 e m.

t r

es :n @ m h...e,ra,m

=: -

.f( r ,

sdNU1Hesolution-${The n: . ;: 4 b w . -- .

text of NU's resolution goes here. E, :s

-;r-q .  ?;; , .-

g .._.g

~.ty e-a ', .,

p

3. Q ' ' - e 2 a i t + ;. - q g' .h' I^ .,'.}, ,..,%'w**..

.. ~ .. .,: 7,

- . . keu v.r ;<, ,

,oep

---c;.. --m.

.a y ay g.

'~~m. ,

s

_f _

c. n p , ,

.  ;;wr:-

h  :. kh~

+-

i

~

- +Q2,, , .

h, r c, h. -  ;

+,

- ,m m. .

>v  ;

e P ,

.4 3 ~ 2,[-; h.w.<. f x "mg M-~ -. te, :l.< y_ - u s

a .: -

"'__l

, ' ):+

.m' s _

2-~

wu -

.a. :r.

r t

., ,. ,.i ;u. -

- . , .m.- , ,

, , . . . - , ,' -6: .s Is h .- 40 g d*2ndthrY$M ft f r* 4 is 4 ,,..s=c.w . ., < - ' S

( ^m'. 4 2: NM. W slnitiator@lBittingham, Angelique g Accept?l E. s Date:f,j2/20/97 1~ .,.l _ y; g' 8 C "

w .Mkp wa w,

..e

,e w

. _ _ ~,* m e 4...;:. y. 4 WWW

!+: v ky  ; ..

l 6y#M.c.?gN;VT Lead:nlSingh. j ' Accept?.~J FY DatsGl2/20/97

. eg.aa, A. K. r, . a-

--%... . . e 4 -

s.

- ~

wa , . . .

qg , ...o e

1 M MM@m ys v. OMVT Mgr-t!;l Wilson, Kitty 7 sIf #

g. . Accept?2M..,. .,Datef?l?/20/97 .

, ~ = ,m@, m r .m , .

- ii*:Gutsw v

<; .&+ ~

..m.  :: . .- ,. .

++c., "

S pgyWIRC Cham:3l Smith, John -

... , , , i y , f-e M - QjfS&

.x.a .. enade w:: x.:mm g. Accept?f,,e -pDate:yl2/20/97 - - menw u  %.o .

i t

I Input Screen for NU Resolution i 4-

+

6

h

/

PI-MP3-011, Rev. O Attachment 6. 5

. -, en w- - n,.: , e em n ea+- - ,.2_- - ~ , s , . . s-wm, - %.

, . x s.- Q T ~

.c N 'L. w 3.. s .. . &, ie+ L.- 2;p(W7.,

w ,1 ,~

, s -a; . i x 4r .a n - g- w i ~?5 h m$CId l M,n m y&~jO[,r MM..Uy1w_o.nQ3I .:glDR-MP3-0001 i Draft:ql 1 g

... m . c, - , . - ,

__.m_ .,. - . _ _ .

Status:j c __

l 3 jg@gg

.a . -.~~.- _

. _,_ n_ww m ..

k;A dsMNSMaoiMI SEllissirsguincyMihuolid MljRessiistion j Rejection EWE:idIElMt m m.w~.m. m  ::

m & Justification forW Justification for rejection goes here,if applicable. ~

M Mg$a eje

~iJT. m. R..m ,,- m ction-T y y my DL ne '*Srx_-w.

,~~~ y:- ..

. Fp.ca.::  ; f. _;. .,

iie > h'.

d . . .'y.y ,f.w a "p

qq.7,y , &

y % , e'f'

, z

-'--+

0QA t.li 9 n_ y r e x?.,2s. :r ,ww?g n

'g,.m.3 y ~ .

4 Q.i.Q '" j. ;  ;,wug , .

.4" + A d% ,, I

-.~s . r ., :

.;r + .a..c a ,. , a.:

~. *

,s .,

y

- o -' w. m,. n 2 c .m

~

r e l' W Q4 ; 1

,,a* ' n_k u .,  %' t *',,

+ . r.. :#

~-.  :{ ; 5 .%;#.~ys_

~ , y.

w .w t

1%5 ' .. ,.~

pa ., .T W ,

y n

t n .t.r:

[, - a-

m. u

' i.

,,w.. -s

. : ::. + s e :h c y m m'W

-r a

?ll^>}O{" lu;L  ; j' ,

g' . a.a - m~

L b T.

e~. .

s r *_,A'3'[ . y y @,; >

. _ }.N M.!-

., ,m .,

..b% v,y + , . ,. .x

[. n.~ ,. . ..+ no n;pg . . . . , .

_ m,. % ,. . - .m

f- } ^ = '%,p

~p.-.p p,.

.y .

t g ..,.... Reject?Wi,s/Date:Cl2/20/97.-.

nm.p .~ , m ,. _ .,

,, n

.y

. _.,. ,A. <

e  % se,ginitiatore.lBittingham, ss.n . .mn__-

Angeliqud , -n .

, u.e WC- w ,NN:W M =3 &

n

u. b.. ~-4.u .~.h.r e

- - . _. ,.n.a - ..m. . o.,.a m a n .

g.-Reject?8iMDateil2/20/97 v...w w:' -

u.p,> , u v. ^ - '

n. . WH:nu i.m & P M VLIea, &ma::lSingh, A. K. .g? OMFME;l w:7 + , .wwa: .

mm pa. . ;wu n ,

i

.nn .,ww - -w w w=m x

, ,gw%ya

..y.,. -

m

.b i-_

h,g a

can.o MM59VI? a Mar 2ln,Wilson, - . , '

Kitty .

2 fBeiect?,T..

' .> 4;.d.

r.m,

. ,n

.IEDate: yl2/20/97 A. N RWw

,f.ua ,- .: wni -

G.q$mq .w7 '

5%  :

., ip"l f.9 8 $ Ql., ' l' uE Q I ku >,.v-2M4 Je>=w.Q]JJ'dhpl JIRClChw mpm.. 3 cr.

Smith John

, 2 :- Reject?@f, :: .Md .C~ Date:Bl2/20/97 ^~

'1 gir ,.- Q MF ;li p $ X

. ,ma .n . ,. -. .

. . n. w @m

cr. . ~ ,.w,

. > ..-w L n. ,

~

~

.e L

t input Screen for Justification of Rejection of NU Resolution s

N I

i i

PI-MP3-011, Rev. O i

Attachment 6.6 I

}

SUMMARY

OF AVAILABLE ENTRIES FOR PULI DOWN MENUS HELP, ENTRIES i

Review Group CRG ORG PRG SRG

' ARG I

1 Review Element System Design i

Modification Design System Installation i Modification Installation Operating Procedures Test Procedure Maintenance Procedure

! Training Procedure l Change Process 1

Corrective Action Process

} Discipline MechanicalDesign Electrical Design I&C Design  ;

Structural Design l Piping Design Equipment Qualification l Operations Maintenance Training 4

Other

, Discrepancy Type Drawing Component Data

{ Calculation Licensing Document Test Requirements

] Installation Requirements Installation Implementation O&M&T Procedure O&M&T Implementation Corrective Action Procedure Implementation

Change Process I\

Potential OperabilityIssue Yes No i

l 4

l

! ~ PI-MP3-11, Rev. O

! Attachment 6.7 i

i i '

l CRITERIA FOR POTENTIALOPERABILITY ISSUE .

The following criteria shall be used to determine if a DR poses potential operability issue:

1. Any departure from the conditions of the operating license, Technical Specifications.

2. Any occurrence or plant condition that requires notification to the NRC or other regulatory agency in accordance with the Configuration Management Plan.

3. Failure to meet the provisions of the Technical Requirements Manual.

4. Conditions resulting in a Maintenance Rule Func'ional Failure (MRFF) l (10CFR50.65). ,

5. Any occurrence that appears to jeopardize radiological protection, or may be a violation of a program, procedure or regulation with radiological implications.

l I

O

! l 1

PROJECT INSTRUCTION PI-MP3-12 INSTRUCTION . REV.O i

j Client: Northeast Utilities i

Station

Millstone Unit 3

Title:

PROJECT FILE INDEX l

i i

1 l

h Safety-Related Non Safety-Related

Reviewed By

Approved By:

l 4

j System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team I Lead Mitigation Committee Manager

! Lead Chairman

__ , [, Date: I'd* Y7, l ML GG~ ??7L Mt% Sd,,fJ Avuge 1y4sL Description Initial Nisue i

{

i l

l l

l i

Page 1 of 5

l i

i l'

PROJECT INSTRUCTION -[" INSTRUCTION PI-MP3-12 REV.O t

1.0 PURPOSE i

2 This project instruction supplements S&L Procedure GQ-6.01 for the implementation of the Project File Index for the Northeast Utilities Millstone Unit 3 Independent Corrective Action Verification Program (ICAVP).

2.0 _ REFERENCE

\

j i

2.1 GQ-6.01, " Project Distribution List and Project File Indexes."

j 2.2 GOP 17.02, " Quality Assurance Records Control System" I

i 1

3.0 DEFINITIONS i

3.1 Project File Index - A project file index is a listing of document categories with location references for the central consolidated project file.

!O j a.2 c #ir ice # eiie tea erei cirii -ceatreioomeoiie teoprojectr'ie-include documents pertaining to a project or group of projects for a single j

client and are maintained by a project team, usually under the direction of the Project Manager or his designee. Central consolidated project files

) are interdepartmental and are the source from which the Records Center i

receives documents for long-term storage.

3.3 Project Documents - Project documents are defined in the applicable l project instructions. Examples of these documents are listed on j

a Attachment 7.1.

i

! 3.4

! Internal Project Correspondence - Intemal project correspondence includes documents generated within S&L which are not distributed l outside of S&L. Intemal project correspondence includes, but is not j .

limited to, the documents listed in Attachment 7.1.

(

l i

o m Page 2 of 5

l

! PROJECT *N 4 "

INSTRUCTION Pl-MP3-12 i

INSTRUCTION / REV.0 l

3.5 External Project Correspondence - External project correspondence includes documents generated within S&L and distributed outside of S&L, as well as documents generated outside of S&L. External project j

correspondence includes, but is not limited to, the documents listed in i

Attachment 7.1. I i

3.8 Special Project Documents - Some project documents, such as l

i purchase orders and contracts are normally filed with the Project Manager j rather than the central consolidated project file. Files containing these  ;

documents are considered part of the central consolidated project file and shall be referenced in the project file index. {

f 4.0 RESPONSIBILITIES i

i j 4.1 i

The Verification Team (VT) Manager shall be responsible for establishing the central consolidated project file, and ensuring the transmittal to file of '

l documents per Subsection 5.2.1.

O 4.2. Verification Team (VT) Group Leads shall be responsible for ensuring the treo mitteite riie ordoce m e"t per 8 eeectiem s.a.

5.0 PROCEDURE i

5.1 The VT Manager shall establish a central consolidated project file for the filing of documents.

i

5.2 Project documents shall be filed in the central consolidated project file in accordance with the project file index (Attachment 7.2). There are two general categories of project documents - generic project

! documents and task-specific documents.

j 5.2.1 The project file index contains the subcategories of the files for the i

generic project documents. It also indicates the person responsible for sending each subcategory of document to the central consolidated i project File.

l l

J m Page 3 of 5

1

)

PROJECT *~" *"

INSTRUCTION PI-MP3-12 l INSTRUCTION ,

REV.O  !

l I

5.2.2 i Task-specific documents shall be filed by Verification Team identity, l

{ Verification element (system or program) and applicable review

l checklist. The project file index lists the subcategories and I i responsibilities. l I

i 5.3 All project personnel shall clearly indicate the appropriate project file i

1 number from the index when submitting documents to the central consolidated project file. The DPD personnel assigned to maintain the central consolidated project file shall file the documents

chronologically in appropriate subcategory of the file system. If there i

are questions about the file number or no file number is shown, the DPD personnel shall resolve this with the person submitting the document or their supervisor.

5.4 Project documents shall be submitted to the project file as soon as possible after receipt / issue to keep the files current. Project personnel j may keep working files in their own work areas as necessary in the performance of their work. The use and number of working files j should be minimized. The individual is responsible for ensuring that

! the documents in the working file are current before relying upon them for quality related decisions.

5.5 Extemal project correspondence shall be filed in two places. [ Note

{

This is the only instance of permanent duplicate files on the project.]

A copy of the correspondence should be filed under generic project l files, and a copy should also be filed under the task-specific file when related to a task. The recipient, or addressee, is responsible for directing incoming external correspondence to the generic file and the task-specific file. The person signing the external correspondence is i

j responsible for submitting outgoing correspondence to the generic project file and to the task-specific files.

1 5.6 A submittal schedule for QA records which shall be retained by S&L

! shall be developed in accordance with procedure GQ-17.01. These records shall be transmitted to storage in accordance with procedure GQ-17.02. Project-related documents which are not QA records shall i

not be sent to storage until the project has been completed and the

transmittal has been authorized by the VT Manager."

i Page 4 of 5 4

l l

l PROJECT INSTRUCTION p "*"' INSTRUCTION PI-MP3-12 REV.O l

l l

l 6.0 REVISIONE

! The project file index (Attachment 7.2) may be revised by the VT Manager. The l' issue of a new or revised project file index shall not require retraining in this PI unless the VT Manager determines that, in a particular case, retraining is necessary.

7.0 ATTACHMENTS f

l 7.1 Types of project-related documents (1 page) l 7.2 Project File Index (2 pages) l 1

i lO l

2 l

i Page 5 of 5

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

N 1

w.

p/ PI-MP3-12 Rev.0 Attachment 7.1 )

i I

TYPES OF PROJECT-RELATED DOCUMENTS t

)

INTERNAL PROJECT CORRESPONDENCE 4

• Interoffice Memoranda

e Meeting Notes

• Internal Status Reports I e Internal Schedules, Lists, Estimates, and Budgets e

{

4 Internal hand-written or PC-generated Documents l Telephone Memoranda Issued Internally l

EXTERNAL PROJECT CORRESPONDENCE e Correspondence sent to S&L by Northeast Utilities , NRC and Others e Correspondence sent by S&L to Northeast Utilities, NRC and Others

• Notes of meetings between S&L and Northeast Utilities, NRC and Others

• Schedules or Status Reports e Telephone memoranda issued externally PROJECT DOCUMENTS

• Discrepancy Reports

• System Review Checklists

• Modification Review Checklists

• O&M&T Review Checklists e Programmatic Review Checklists

• Accident Mitigation Review Checklists e Walkdown Checklists e Project Instructions

• Final Report O

PI-MP3-12 j Os Rev.0 Attrhmt 7.2  ?

MILLSTONE UNIT 3ICAVP PROJECT MLEINDEX I. GENERIC PROJECT FILES -

File No Titic Position Title Responsible i for Submittina- Project Files ,

t s

MP3-1.0 Contract and Supplements VT Manager MP3-1.1 Commercial Correspondence VT Manager j MP3-1.2 ICAVP Requirements VT Manager i

MP3-2.0 Project Manual QA Coordinator MP3-2.1 Training Records QA Coordinator )

MP3-3.0 Status Reports VT Manager-MP3-4.0 General Quality Assurance QA Coordinator MP3-4.1 Internal Audits

! QA Coordinator MP3-4.2 External Audits QA Coordinator l

MP3-5.0 Project Team Meeting Notes VT Manager MP3-5.1 OtherInternalMeeting Notes VT Group Lead MP3-5.2 External Project Meeting Notes VT Manager (Not Specific to a Task) 1 MP3-6.0 Manpower Planning and Overall VT Manager '

Project Schedules MP3-7.0 Extemal Correspondence to NU orNRC VT Manager  ;

MP3-8.0 Correspondence fromNU orNRC VT Manager MP3-9.0 Discrepancy Reports VT Manager j MP3-10.0 Differing Professional Opinions VT Manager t

Page 1 of 2 e

_~,

e

l l

p PI-MP3-12 l

V Rev.O Attachment 7.2 MILLSTONE UNIT 3 ICAVP PROJECT FIIIINDEX Il TASK-SPECIFIC PROJECT FILES File No Iills Position Title Responsible for Submitting - Project Files SRG-XXX-YY-ZZ System Review Files SRG Lead CRG-XXX-YY-ZZ Configuration ReviewFiles SRG Lead ORG-XXX-YY-ZZ O&M&T Review Files ORG Lead ARG-XXX-YY-ZZ Accident Mitigation Review Files ARG Lead PRG-AAA-YY-ZZ Programmatic Review Files PRG Lead Where: XXX = 3 Letter System Desianator Assigned by ARG or SRG l Lead.

YY-ZZ = Last 4 Digits ofChecklist Number (Example: Use 02-01 for CK-MP3-02-01)

AAA = 3 Letter Program Designator Assigned by PRG Page 2 of 2

.rm_-a,L.- . .s,- a o, n4 _4 ,na4 . n .e m .-,_.E ms- a.- ,__ - a..,,_Ae _ a ma m.s a m.as-.m._ma---,m m- -m an m.- =4 -. __u,a.ma_,, ,,._m,-,,, _ mm h

i 1

a i

l i

i 1

I e

t t

I i

l f

i a

)

i j

, (CHECKLISTS UNDER DEVELOPMENT)

I l

d i

i t

i j

i

[

i 1,

t i

i A

l 1

!