ML20154G525
| ML20154G525 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/05/1998 |
| From: | Blockes E External (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20154G456 | List: |
| References | |
| PROC-981005, NUDOCS 9810130214 | |
| Download: ML20154G525 (45) | |
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j PARSONS POWER i
a INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM i
4 j MILLSTONE UNIT 2 4
- AUDIT PLAN Revision 4 1
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Prepared By: Date October 5,1998 Deputy Project Director Approved By: Date: October 5,1998 Manager, Company Quality Program Approved By: ~
M/ Date: October 5,1998 Project Director
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- PARSONS P95 FEE -
9810130214 981008 ##UT' 9g j I PDR ADOCK 05000336 l P
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l , MILLSTONE UNIT 2 AUDIT PLAN REVISION LOG Section Revision No. Description Date All 0 InitialIssue April 3,1997 1
. All 1 Incorporation ofNRC Comments June 9,1997 3, 4, 5 2 Incorporation of NRC Comments June 27,1997 I
3.2, 4, 5 3 Incorporate changes from Tier 1, September 29,1997 Tier 2, Tier 3, and Discrepancy Reports Procedure Changes 3.2, 4, 5, 7 4 General Update and Incorporation October 5,1998 ofNRC Comments O
'O This list delineates sections of this manual that are currently in effect. The latest changes are indicated by a p vertical line in the right hand margin of the affected pages.
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Audit Plan Revision 4 i October 5,1998
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MILLSTONE UNIT 2 AUDIT PLAN O LIST OF EFFECTIVE PAGES Pane No. Revision No. Pane No, Revision No.
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Audit Plan Revision 4 1 October $,1998
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MILLSTONE UNIT 2 ICAVP AUDIT PLAN O
l TABLE OF CONTENTS 1
Section .I.ith East j
1.0 INTRODUCTION
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2.0 OBJECTIVES
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3.0 ORGANIZATION 3-1 l 3.1- Team Member Responsibilities 3 , 3.2 Technical Advisory Group 3-4 '
3.3 QualityAssurance 3-4 i
'3.4 . Assignment of Staff 3-5 g
3.5 Location ofWork {
3-6 1 4.0 APPROACH TO ICAVP AUDIT 4-1 i
! 4.1 System Vertical Slice Review (Tier 1) 4-3
- 4.2 Accident Mitigation Systems Review (Tier 2) 4-10 A 4.3 Process Review (Tier 3) 4-16 !
4.4 Regulatory Review 4-21 i 4.5 ICAVP AcV- e Criteria 4-24 4.6 Project Procedures & Instructions 4-24 1 l
5.0 ' DISCREPANCY REPORTS 5-1 !
5.1 Identification, Evaluation, and Reporting of Discrepancies 5-1 5.2 Review of Proposed Response to Discrepancies 5-1 6.0 ICAVP FINAL REPORT 6-1 l
6.1 Compile and Assess System Repons 6-1 6.2 Review ofNNECo Corrective Actions 6-1 6.3 Prepare ICAVP FinalRepon 6-2 6.4 IssueICAVP FinalRepon 6-2 6.5 Project Closcout and Records Turnover 6-2 7.0 - SCHEDULE 7-1 4
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MILLSTONE UNIT 2 ICAVP l EXHIBITS EXHIBIT NO. TITLE PAGE 3 ICAVP Project Organization 3-2 4-1 Approach toICAVP 4-2 4-2 System Vertical Slice Review 4-5 4 Accident Mitigation Systems Review 4 11 4-4 Critical Safety Function Diagram 4-13 4-5 Tier 3 Process Summary 4-17 4-6 Regulatory Review 4-22 4-7 Project Procedures & Instructions 4-25
'5-1 Discrepancy Reports 5-3 6-1 ICAVP Final Report Outline 6-3 l
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l Audit Plan Revision 4
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1.0 INTRODUCTION
The purpose of the IP-* Correcuve Action Verification Program (ICAVP) is to provide the Nuclear Regulatory C-i== ion (NRC), Northeast Nuclear Energy l Company (NNECo), and the public with an indTaM-* review to confirm the l
adequacy of NNECo's efforts to establish that Millstone Nuclear Power Station Unit 2 physical and functional ch.insdes are in conformance with its licensing and design j bases.
4 On August 14,1996, the NRC issued a confirmatory order requiring comv tion of an !
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ICAVP before the restart of any Millstone Unit. He scope of the ICAVI will encompass all dar==ed modifications itale to the selected systems since initial licensing and willinclude:
1 1.
i Review of engineering design and confipratm control processes, 1
4 2.
a Verification of current, as-modified conditions against design and licensing j
bases hetecion,
! 3. Verification that the design and licensing bases have been translated into
- operating procedures, and ==iaran aca and test procedures, i s
- 4. Verification of system i imwers through review of specific test records and/or observation of selected testing,-
i i 5. Review of proposed and implanwatM corrective actions for licensee-identified
} design deficiencies i
a ne ICAVP Audit Plan will implement the ICAVP contractor portions of the August 14,1996 Confirmatory Order and the NRC Oversight Plan.
He ICAVP Audit Plan will employ the approach noted below for assessing Millstone Unit 2 effectiveness at identifying and correcting licensing bases deficiencies. The scope of the ICAVP Audit will provide confidence that Millstone Unit 2 conforms to its design and licensing bases through the following audit activities:
, Vertical Slice System Review of selected systems (Tier 1)
Review of Accident Mitigation Systems (Tier 2)
Review of various design change processes (Tier 3)
. Regulatory Review
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Audit Plan Revision 1 1-1 June 9,1997
N i 2.0 OBJECIIVES The objective of the ICAVP, as stated in the August 14,1996 NRC Confu-etury --
Order, is to confirm that Millstone Unit 2 physical and functional characteristics are in cv=fvi-asc. with its licensing and design bases. 'Ibe ICAVP audit is vad to provide W verification, beyond NNECo's quality assurance and
- management oversight, that NNECo has
t Identified and salsfactorily resolved existing non-conformances with the design and licensing bases, i
. D& =e--! and utilized the licensing and design bases to resolve nonconformanema, i
Established programs, processes, and procod= for effective configuration j management in the future i
4 NNECo's programs include efforts to identify and understand the root causes of the i
licensing and design basis issues that led to NRC issuance of the 10 CFR 50.54 (f) 3 letters to NNECo and to implement corrective actions to ensure NNECo will i maintain the plant's configuration and compliance with its design and licensing bas s.
j NNECo has indicated that the scope of its corrective programs will include those systems that it has categorized as either Group 1 (safety-related and risk-significant) or Group 2 (safety-related or risk sigM-wi), using criteria developed in carrying out j
the Maintanane* Rule. The ICAVP audit will provide insights into the effectiveness of the Millstone Unit 2 programs so that the results can be reasonably extrapolated to the structures, systems, and components that were not reviewed in the ICAVP audit.
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Audit Plan Rewsion 1 2-1 Junc 9,1997
3.0 - ORGANIZATION
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'Ibe Millmone Unit 21CAVP Project organization that will implement the 1CAVP Audit Plan is shown in Exhibit 3-1. *Ihe following project organi=tian responsibilities are diaenenad in this section.
- Team Member responsibilities Technie=1 Advisory Group
. Quality Assurance AssI& of Staff 4
Location of Work 4
i 3.1' TEAM MEMBER RESPONstraryJTIES
'Ibe Millstone Unit 2 ICAVP Amht Team is based on key project personnel who wtl be assisted by a core team of eachnical specialists and additional support resomoes en required. Responsibilities of Project Director, Deputy Director, Group Imders, Core j Team personnel and support resources are:
i Project Director 4
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Overall management of the task will be provided by the Parsons Power (Parsons) i Project Director. He will be responsible for the task schedule, budget, senior client t
interface, and compliance to the NNECo contract requirmants. He will be the -
primary interface with NNECo and the NRC.
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{ 'Ibe NRC and the Ce - N Nuclear Energy Advisory Council (NEAC) have established a mamarandum of under*== ding that permits NEAC to participate i
and/or observe NRC's oversight activities for the ICAVP. The NRC is responsible for I
interface and communication with NEAC.
Deouty Project Director
'Ibe Deputy Project Director will assist the Project Director in the overall
- management of the task. He will be responsible for compliance to the ICAVP Audit Plan and the technical adequacy of the final reports.
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Aunt Report Revision 1 3-1 June 9,1997 3
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ExhiWt31 MILISTONE UNIT 2 -ICAVF PROJECT ORGANIZATION i
nnrxo notenace Parsons Quahty l Pimiset Manager '~1 Pruident A- _ -
Nac tatertace ~~J
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Project Direcear Deputy Technical Pre $ect Director Admory Group l
Regulatory System Review - Accident Support 3 Process Project i
'd Tier 1 Review - Tser 3 Review f~ser2 Sapport
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Wha =le=1 Electrical Systems I&C Structural "" #
Systems Systems Reviews
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Audit Report Revision 1 3-2 June 9,1997
Group Imders
'Ov The Group Imders will be responsible to the Deputy Project Director for managing their assigned resources to complete the assigned items in their i@ve project areas. Dey are responsible for compliance to the ICAVP Audit Plan and the eachnie=1 adequacy of their deliverables. Dey will be actively involved in the p fvi-ggs.e of the work in their respective project areas. Group Leads will be assigned for each of the following project areas:
e System Reviews - Tier 1 (lead assigned for each system reviewed)
. Accident Mstigation System Review - Tier 2 1 . Process Model and Design Control Review - Tier 3
. Regulatory Suppon l
. Project Support l.
Core Team Personnel i
he Core Team has been selected based upon si,erh and particular areas of l expenise. They are responsible for the performance of the r,c.uns audits, regulatory
] reviews, process review, document review, technical rwJ. and the generation of the j- - 7 reports in their respective areas. nese personnel work directly for the i Group I anders. De awchaniemi, structural, civil, electrical and instrumentation engineers have been selected because of their expertise in nuclear plant designs, modifications, =<<=mante and programmatic knowledge. 'Ibe operations specialists bring specific experience in operations, maintenance, ph4 configuration management and regulatory compliance. Technical specialists in specific areas, e.g.,
Equipment Qualification, will be utilized on an "as needed" basis across all inspection teams rather than being assigned to only one team.
Support Resources Support resources work for the Group Lead of Project Support and provide the following support functions for ICAVP activities:
. Scheduling and Project Controls
. Adminietrative/ClericrJ
- Information Services
. Document Control
. Technical Editing
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Audit Report Revision 1 3-3 June 9,1997
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,A 3.2 TECHNICAL ADVISORY GROUP
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An advisory group ofindustry expens will assist with ICAVP Audit Plan implementation and other activities as assigned by the ICAVP Project Deputy Director. The ICAVP Deputy Project Director will convene the entire group or selected members of the advisory group based on the activity being performed.
3.2.I Responsibilities .
l ne Technical Advisory Group (TAG) will have the following responsibilities:
. The TAG provides advice, expert technical opinions and review services to the ICAVP Audit Team. '
e ne TAG will review the ICAVP Final Report and 'ae individual reports from the various inspections and audits performed by the ICAVP Audit Team (s). Refer to Section 3.2.2 for TAG review of the ICAVP final report.
He TAG will review and comment on proposed corrective actions for all sampled Significance Level 1,2 and 3 Discrepancy Reports (DRs).
(N.
V e ne TAG will review all Differing Professional Opinions 3.2.2 Final Conclusions The TAG will prepare a separate section of the Final Report documenting their observations and opinions.
3.3 QUALITY ASSURANCE Parsons overall Quality System is described in Parsons Power Quality Management Manual (QMM) which incorporates the principles of Total Quality Management. Quality Assurance (QA) activities shall be performed in accordance with the requirements of the Parsons Power Nuclear Quality Assurance Program, which is documented in Addendum 2 of the Parson's Quality Management Manual (QMM). This program meets the requirements of 10CFR50, Appendix B, and ANSI N45.2. Engineering activities shall be performed in accordance with the programmatic elements of the Company Procedures Manual (CPM) as augmented by Project Procedures and Instructions which implements the requirements of the QMM.
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Audit Report Revision 4 3-4 october 5.199:
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'Ibe Manager of Company Quality (MCQ) has been assigned the responsibility for monitoring effective implemeotation of the Parsons Power Nt. clear Quality Program.
'Ibe MCQ reports directly to the Pranittent of Pr* sons Power and has the indepaarie=<w, freedom and .=0.eiity to assess the effectiveness of quality activities and to provide mechanin== to initiate corrective measures when -i y.
'Ibe MCQ is assigned to this project and directs all QA Program activities for this Project. 'Ibe MCQ serves as the primary quality interface between the project and other Parsons Power units which contribute to the QA Program.
'Ibe MCQ will routinely review all aspects of the Quality Program accomplishments and status. Evidence of deficiencies in procedures, processes, or systems shall prompt appropriate correcuve action.
I 3J.2 Intenal Audits and Surveillances
'Ibe project will be audited through the Corporate Internal QA Audit Program.
Audits will be planned, scheduled, coordinated, and pa feine in accordance with Parsons internal procedures. Audits will be perforue by properly trained, experienced, and certified personnel not engaged in the activity being audited.
, Surveillances may be performed at any time during the course of the project activities.
Tnese surveillances shall follow the guidelines of the ASQC Surveillance Handbook and Guidelines. Surveillances will be performed using applicable elements of internal
, audit procedures, with the intant to evaluate and improve both performance and process. Surveillances should be in-process evolutions. Personnel trained in auditing techniques will be utilized to perform these surveillances. Copies of internal audit and surveillance reports will be sent to the NRC.
3.4 ASSIGNMENT OF STAFF All personnel assigned to the project, either Parsons employees or ceasultants, will be evaluated for their independence from Millstone Unit 2 desi;n and design review activities and their financial independence from Northeast Utilities. All personnel
. initially assigned to the project may be interviewed h the NRC and other interested P parties [i.e., Connecticut Nuclear Energy Advise;y Committee (NAEC)]. All personnel additions or substitutions will be r;oc ssed in accordance with Project
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Audit Report Revuion 2 3-5 Jon.27.1997
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Pmcedure PP-06, " Substitution or Addition of Personnel". NRC notification is l
, s required for all personnel phens or additions.
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3.5 IDCATION OF WORK The Millstone Unit 2 ICAVP Project Team will perform the --joihy of their work in the Parsons Power Reading, Pennsylvania offices. A small field office located near the Millstone Unit 2 site will be mamtsinad to support site walldowns, conferences, schedulad meetings and dc-:; =^ nerieval. Millstone Unit 2 ICAVP Audit Team personnel will visit the field office and Millstone Unit 2 as required to support ICAVP inium.edon needs.
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Audit Report Revision 1 34 ; 9,3,97
4.0 APPROACH TO ICAVP AUDIT l G The ICAVP Audit Plan will employ the approach noted in Exhibit 4-1 for assessing Millstone Unit 2 effectiveness at identifying and correcting licensing bases defidmcies. The ICAVP audit is based on the requirements identified in the August 14,1996 Confirmatory Order and the ICAVP Oversight Plan issued as an attachment to SECY 97-003. The scope of the ICAVP Audit will provide confidence that Millstone Unit 2 conforms to its design and licensing bases through the following multi-tier approach:
System Vertical Slice Review (SVSR) of selected systems (Tier 1)
The objective of the SVSR inspection (Tier 1 Review) will be to confirm, through an inspection sample of at least 4 systems selected by the NRC, that the Millstone Unit 2's physical and functional characteristics are in conformance with its licensing and design bases, and encompass all modifications made to the selected systems since initial licensing. In addition, the inspection will exanune the thoroughness of the Millstone Unit 2's Corrective Action Plan for identifying and resolving nonconformances with the design and licensing bases. The system reviews will be based in part on guidance provided by NRC Inspection Manual s
Chapter 2535, " Design Verification Programs" and Inspection Procedure 93801,
" Safety System Functional Inspection" Review of Accident Mitigation Systems (Tier 2)
' Die Tier 2 review will identify and evaluate " Critical Design Characteristics" for Millstone Unit 2 accident mitigation systems. Critical Design Characteristics are identified by reviewing the functional requirements of accident mitigation systems and components to ensure that they can perform their specified safety functions.
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Audst Plan Revision 1 4-1 June 9.1997 l
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Review of Various Design Change Processes (Tier 3) The Tier 3 review will verify the adequacy of the programs currently being implemented by NNECo which are directed at identifying and resolving existing design and configuration management deficiencies associated with past change l processes. 'Ihis will be accomplished by a " horizontal slice" inspection of l examples of past changes to the facility design, practices, and documentation I A " going forward" evaluation of the effectiveness of the Millstone Unit 2 configuration management program effectiveness will be addressed by others and is not included in the review. Regulatory Review Selected Millstone Unit 2 Regulatory documents will be reviewed and summarized. The summary will key on required licensee actions, a review of the licensee docketed response, and a review of the current Updated Final Safety Analysis Report. Specific items identified will be verified within the System Vertical Slice Review (Tier 1), Accident Mitigation System Review (Tier 2), or Process Review (Tier 3), as appropriate. 4.1 SYSTEM VERTICAL SLICE REVIEW (Tier 1) The objective of the System Vertical Slice Review (SVSR) inspection of the Independent Corrective Action Verification Program (ICAVP) will be to confirm, through an inspection sample of at least 4 systems, that the Millstone Unit 2's physical and functional characteristics are in conformance with its licensing and design bases, and encompass all documented modifications made to the selected systems since initial licensing. In addition, the inspection will examine the thoroughness of the Millstone Unit 2's Corrective Action Plan for identifying potential nonconformances with the design and licensing bases. l Selected systems will be reviewed in depth, including design bases, impact on design bases by system modifications, safety margins, maintenance, operations, surveillance, training, and corrective actions for previously identified deficiencies. The system reviews will be based in part on guidance provided by NRC Inspection Manual Chapter 2535 " Design Verification Programs" and Inspection Procedure 93801 O ro
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Audit Plan Revision 1 4-3 June 9.1997 l l
l , .p " Safety System Functional Inspection", kJ Following system selection by the NRC, the SYSR will be perfonned as shown in Exhibit 4-2. Project Procedure PP-01 " System Vertical Slice Review" and Project Instruction PI-01
" Conduct of SVSR" will be used to perform the inspection. The SVSR is based on the activities noted below and discussed in the following paragraphs:
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- Select System for SVSR l
- Determine System Boundary i e Identify Licensing and Design Basis Requirements e Prepare System Specific Checklist
. Evaluate System Configuration Management e Prepare SVSR Final Report 4.1.1 Select Systems for SVSR Parsons Power Group has developed criteria for NRC use in selecting systems for the vertical slice review. The initial systems to be reviewed will be selected from those systeins p categorized as Group 1 using criteria developed as part of maintenance mle implementation
-Q (10CFR50.65). Systems are categorized as Group 1 based on safety related functions and rist: rignificance.
The Parsons Tier 1 system selection criteria will supp!rc nt the Maintenance Rule criteria (risk and safety significance) based system function, operational and configuration history, regulatory history, and professional opinion. A major factor that will be considered will be previous opportunities for introducing inappropriate changes to the system or design bases (a high number of modifications or significant system reconfigurations), and presious problems with the system (at both the plant level and industry wide). i [ k I %
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AuditPlan Revision 4 4-4 October 5,1998 l l
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~J EXIIIBIT 4-2 SYSTEM VERTICALSLICEREVIEW SYSTEM SELECTION DEFINE FROM NRC SYSTEM BOUNDARY, Tier 2 System Functions NRCINNECo Review 3
Scope / Boundary 4 Resolve difrerences Considerations IDENEFY Regulatory Requimments + ]f LICENSING / DESIGN ' Current Licensing Basis REQUIREMENTS AND Programmatic E Review CIIECKLIST 4 - DEVELOPMENT Regulatory inputs p criticat Design chractensucas Requ C kiist b ____________________________q 7 I EVALUATE t t t t I. CONFIGURAllON Input to System Mod Is eC ec ve ^ " p h g urn ion leview unmodified portion < MANAGEMENT All Mods Management Reviews of the s3Wem CONSIDERATIONS List p g System Mod 2 I ' CAP Review Pim.: e, Testing, Review l Walkdowns,etc. Cmtive Reviews Ac. List l Systen Mod System CAP System Requirement Checklist Requirement Checklist ConfigurationChecklist ir i t i v y{ INSPECITON ACTIVI11ES BASED ON CHECKLIST REQUIREMEMFS ; j"i~ Mechanical Training ProgramSpecialists Electrical Pr x m u..cie andTechnicalReps Conferences Walkdown IAC Civil asRequired
f L i i ! h Parsons will consider a system as a likely candidate for an SVSR if the system: l U e Has experienced a high number of modifications. Has had a major modification or a number of major modifications involving a design 1 change with internal interfaces between major discipline areas and/or external ! interfaces with the NSSS vendor, component vendors, and engineering service organizations. Has a high level of risk significance based on PRA insights as deternuned by a panel of individuals familiar with the Plant PRA. i e Has an identified history of deficiencies or operating problems based on plant or industry operating experience. The NRC should make the final determmation of the relative ranking of the systems based on !- the results of the system selection survey, system boundaries, industry experience, and their own knowledge of the systems and the requirements of the ICAVP. The NRC should bias their weighting for the selection of systems using consideration ofissues identified as part of i 1 the August 14,1996 confirmatory order. Additional detail on system selection criteria is provided in PP-01, System Vertical Slice Review Procedure, 4.1.2 Determine System Boundarv i The System Boundary will define the scope of the SYSR in regards to the selected system. Interfaces with, and portions of other systems may be included within the boundary of the
' selected system to the extent they are necessary to support the functional requirements of the
.' selected system. In additions, system boundaries may be defined at appropriate components that provide physical isolation, as long as the selected boundary does not split the component between systems. The NRC and NNECo will review the system boundary for agreement in interpretation of SYSR scope.
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,p 4.1.3 ' Identify Licensine and Desien B la Reauir =.ats lV l Following system selection and boundary deternunation, the SVSR Tier i Team will review appropriate licensing documentation, including the Updated Final Safety Analysis Report (UFSAR), Technical Specifications, and other regulatory and design documentation and list the Licensing and Design Bases requirements for the system. Rese requirements will establish the inspection requirements criteria and will be itemized in the inspection system specific checklists. 4.1.4 Prepare System Specific Checklist ne inspection team will review and assess pertinent design and operational aspects of the selected systems, using checklists based on functional system and design engineering considerations. The checklists will be developed specifically for the Millstone Unit 2 system being inspected and will serve to maintain inspection focus and to ensure a complete and thorough review.' Sampling plans may be selected for use with repetitive component group
- evaluations. He sample plan and its rationale will be proposed and submitted to the NRC for their review and oversight.
( The checklists, incorporating the input of each inspector and the team leader, will be developed in a team environment to ensure maximizmg the expertise of the entire group. They will be developed followmg the announcement of system selection. The checklists will stipulate inspection conditions for each inspector and will include inspection targets, validation, and verification requirements, and details of the current and original license bases, system history and configuration. 1
- The SVSR Team will use the checklists to guide the inspection process during major inspection activities such as:
. Document and calculation review
- _ System walkdowns L4.1.5 Evaluate System Confinuration Mananement The system vertical slice review (SVSR) will entail a comprehensive engineering review of r the selected systems by a team of mechanical, electrical, mstrumentation & control, maintenance and operations specialists. He team, supported by a staff of regulatory and Audit Plan Revision 3 4-7 september 29.1997 l
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. l l l l ! l l l nuclear licensing specialists, will employ a broad based but focused examination process of ' b sufficient depth to probe all aspects of the selected systems design, history and configuration. Emphasis will be on verifying that the subject systems processes, practices and procedures used to perform engineering design, design change control document control and records updating of the design bases have been successful in maintaining the system configuration in accordance with regulatory requirements. Operations, Maintenance, and Test Procedures will l be reviewed to verify that correct licensing and design bases information have been ! incorporated into the procedures. The SVSR Team will provide ongoing reports which will detail the status, on a system l specific basis, of the progress of the SVSR for each of the selected systems. As discrepancies are identified during the review, they will be immediately communicated to management for evaluation. Each discrepancy will be provided with a complete description, including all l pertinent information per the requirements of Project Procedure PP-07 "" Discrepancy Reports." A size of at least 4 systems for the SVSR. is predicated on the assumption that the assessment will not find significant discrepancies. Additional systems may be added to the SVSR as V directed by NRC. Evaluation of configuration management considerations will be focused on licensing and design bases requirements. Evaluations will utilize appropriate level documentation (drawings, calculations, design documents, etc.) to the inspection detail necessary to verify and validate conformation to requirements. The vertical slice reviews will emphasize design control and will verify that:
. The current configuration accurately reflects the licensing-bases, including the updated FSAR.
- Calculations and analyses were performed using recognized and acceptable analytical methods and that assumptions made in calculations or analysis supporting changes are technically sound.
. The results of calculations or analysis supporting the unmodified portions of the l
original configuration and design changes are reasonable (based on engineering judgment) for the scope of the change.
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Audit Plan Revision 3 4-8 september 29,1997 l
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,o e Millstone Unit 2 considered the effect of a change on design margins and that the l design changes received the appropriate level of engineering and management review during the design phase and prior to implementation.
1 Millstone Unit 2 considered the effect of a change on pre-operational, startup or system baseline acceptance test results. l Design changes are accurately reflected in operating, maintenance, and test procedures, as well as in training materials. Proposed design changes, subsequently canceled, were not replaced by procedural l changes that imposed excessive burdens on plant operators. I 1 Adequate control of operational procedures, maintenance procedures, test and I surveillance procedures, operator training and control of the plant simulator configuration. 1
. The current configuration is consistent with the licensing bases at the level of detail I contained in piping and instrumentation diagrams (P& ids) or system flow diagrams, o
piping isometric drawings, electrical single-line diagrams, and emergency, abnormal and normal operating procedures. He analyzed configuration is consistent with the current plant configuration. Identification numbers are as indicated on the P&ID or process flow diagram, and equipment name plate data is consistent with design specifications and analyses. He location of pipe supports, snubbers, and other pipe restraints is consistent with design specifications and piping stress analyses. Divisional separation of safety-related systems, structures and components, seismic II/I, and other topics addressed by the licensee's hazards analyses are reflected in the current plant configuration. i f . ( AuditPlan Revision 3 l 49 september 29,1997 l i l l
. 4.I.6 Prenare SVSR Final Report
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. A SVSR Final Report will be developed for each system reviewed by the SVSR Team. He !
Final Report will summarize the results of each system reviewed and will contain the details of all associated discrepancy reports. Included in the report will be an assessment of the Millstone Unit 2 licensing / design basis and adequacy of the configuration management program. The system final report will consist of, as a nummum, the sections noted below. The SVSR Final Report will be included in the overall ICAVP Report. l
* ' Summary
- System Description & Boundaries l 1
- Licensing and Design Basis Requirements Review
- Configuration Management Review e Discrepancy Report Summary
. Appendices 4.2 ACCIDENT MITIGATION SYSTEMS REVIEW (Tier 2)
The Tier-2 portion of the ICAVP will identify and verify the " Critical Design l C Characteristics" for the Millstone Unit 2 Plant as defined by resiewing accident mitigation systems requirements, and assessing critical design characteristics for systems and components to ensure that they can perform their specified safety functions. Each characteristic will be identified from calculations, analyses and other documentary
- evidence that supports the Chapter 14 Analysis in the updated FSAR. The review will be based in part on guidance drawn from Appendix E of NUREG-1397 "An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Industry."
Assessment of the critical design characteristics for the accident mitigation systems will be performed in accordance with Project Procedure PP-02 " Accident Mitigation System
- Review." Exhibit 4-3 presents a summary of the review process. The accident mitigation systems review (AMSR) consists of the following major activities:
- Identification of Critical Design Characteristics e Preparation of Composite Characteristics Database
. Validation of Critical Design Characteristics e Preparation of AMSR report .( ~. t k,
J
- PS3058 POWER -
Audit Plan Revision 3 4-10 september 29,1997
O O- U,~
' Exhibit 4-3 L AMSR Review Process
- i l t l :
I t FSAR Chapter 14m 7 Tech he ' Identiff Develop Deline Each Develop System Emera On Prw Crtical M Safety 4 Generic Safety ' -
- Safety Function W Fundion 7
Boundary Diagrams Fundions Diagram NNECo Dats z w 2 , e- + O gn,9,i, priorgy DBEvCDC d Y to NRC for Review I g u + To Tier 1 o Review Develop T2 Crith;al Parameters & I b mg Determine . Characteristk:s by System ' A o Database + N Crtical
}
b Structure Basis Events Characteristics F
........................................................ t 2 ,
h Collect & Validate FSAR b NNECo Data p System [ Characteristics
% Design &
jg o Performance Data Tier.1 O Validation
,s
'a t Prepare Tier 2 Report u
.w j. g Report "
88-- o a. w GC 4 99
- _ _ _ . . _ _ _ . _ _ _ _ _ - _ _ _ _ _ - _ _ - - - - - -- - - - - - - - - - - ' --^ ^ ^
- . . - = . --- .- - , . - - -
O U 4.2.1 Identify Critical Desien Characteristics In order to determine critical design characteristics, it is necessary to determine the critical functions that must be performed. A critical function is the set of actions, as a whole, that must take place in order to prevent or mitigate the effects of a Design Bases Events (DBEv), or reduce the consequences of an accident. Chapter 14 of the updated Final Safety Analysis Report (FSAR) is the description of all credible accidents that will be addressed. The FSAR (updated) has been selected as the license Design Basis benchmark source, or that point where all changes that affect the ability of the plant to meet the critical function should have been captured. Based on this review, the DBEv areidentified as:
- Increase in Heat Removal by the Secondary System
. Decrease in Heat Removal by the Secondary System
. Decrease in Reactor Coolant System Flow L.)
e Reactivity and Power Distribution Anomalies
- Decrease in Reactor Coolant Inventory
. Radioactive Release from a Subsystem or Component l
- Non-Standard Review Plan Events Each DBEv requires a specific set of activities to occur for different plant configurations in order to ensure that the plant is returned to and maintained in a safe condition. These activities are called " Critical Functions" Each of the Critical Functions will be developed to determine the critical actions between the different systems within the plant to ensure that all of the critical interfaces have been identified. For example, if the Critical Function is reactor l core cooling, then there will be critical actions necessary in the delivery system to the reactor, i the source of the water, the motive power for delivery, the source of the motive power, and the initiating controls.
Y)
- PAB8088 PetNR -
Audit Plan Revision 3 4-12 september 29,1997 l l
__ _ _ _ _ . _ _ _ _ . _ . . ~ . _ - __ _ _ _ . . _ _ _ _ _ _ _ _ _ l l 1 i 8 4 V A generic critical function diagram will be developed presenting the active functions that must l be executed for the spectrum of DBEv along with the identified component configuration. An example of a critical function diagram is shown in Exhibit 4-4. This set of conditions will ensure the development of a complete set of Critical Design Characteristics. i l Exhibit 4-4 CRITICAL SAFETY FUNCTION DIAGRAM l l Loss of Feedwater Flow l (j ('- RCS Presswe & Inventory Control Reactmty Control Heat Reinovel Rasctor Pressure Wg g '" Component Critical Design Criteria 7_s b - - , - Audst Plan Revision 4 4-13 october 4,199: l
h V 4.2.2 Prepare Characteristics Database A critical design characteristic is defined as that aspect of a component or system that must be l included in the design to ensure that the component or system will perform its critical safety function. The critical design characteristics are an accumulation of the system design characteristics, and the system's components critical characteristics, coupled with the plant and component configuration at the time of the DBEv. These characteristics will be determined based on the existing information contained in the licensing basis for Millstone Unit 2. The data will be used to perform the systems validation. i i The following list represents a core group of documents that contain a significant amount of information about the critical parameters for the plant:
. Updated FSAR for Millstone Unit 2 and Supporting Accident Analyses
. Technical Specifications for Millstone Unit 2
. System Design Bases Documents e Probabilistic Risk Assessment for Millstone Unit 2
, e Combustion Engineering Owners Group Documents e System Design Calculations The review of applicable documents will; l) confirm continuity across the documents, ! 2) determine the root document that defines the critical parameter or function,
- 3) ensure that the accident mitigation systems critical design characteristics have been captured for each accident;
- 4) confirm assumptions made in calculation are in place in the field; and,
- 5) Ensure results from calculations are appropriate and reasonable.
l f The Team will review the DBEv and derive the critical safety functions, critical characteristics and critical parameters. In addition, the team will resiew the accident mitigation systems to identify the critical design parameters and characteristics that have been incorporated. Differences between the two sets of data will be evaluated and compared 4 . ,V
-rassesirews-Audit Plan Revision 4 4-14 Odober 5,1998 i
(
i l against the results from the NNECo corrective action programs. As discrepancies are identified during the review they will be reported per the requirements of Project Procedure PP-07 " Discrepancy Reports". l A listing of the critical design characteristics will be prepared. This listing of critical design characteristics will be the source data base to be used by the Review Team for the systems that will be covered in the SVSR and AMSR process. , l 4.2.3 Validation of Critical Desien Characteristics The AMSR will include a validation of 100% of the functional / system level critical , characteristics derived from FSAR chapter 14 and supporting analyses. This validation will I be based on review of plant test data, Technical Specifications, calculations, or other plant configuration documents such as drawings, calculations, etc. that reflect the current documented plant configuration as appropriate. The Emergency Operating Procedure (EOP) will be reviewed to determine consistency with the functional and system level critical characteristics. All discrepancies will be documented. Review of the characteristics associated with the systems being reviewed by the SVSR Team O will be coordinated with the SVSR team. The results of SVSR Team validation will be incorporated into the AMSR report for completeness. 4.2.4 Preparation of AMSR Report A final report will be prepared identifying the critical design characteristics by DBEv. Included in the report will be the listing of the characteristic and how it was validated. The AMSR Report will be included as part of the ICAVP Final Report, and will contain the following:
. Summary
. Critical Safety Function by DBEv
. Critical Design Characteristics by DBEv
. Discrepancy Reports summary f"
V]
- m smerowns -
l Audit Plan Revision 4 4-15 oaober 5.199: l
._ _ m--_ _. _ . _ . _ . __ _ _ _ _ . _ . . _ _ . _ _ _ _ . . _
l (" 4.3 PROCESS REVIEW (Tier 3) In accordance with NRC direction, a review to determine whether Millstone Unit 2 processes and procedures have been established for effective configuration management on a going-forward basis will be addressed by others and is not included in this review. l The Tier 3 (Process Review) portion of the audit will verify the adequacy of the Millstone Unit 2 CMP to identify and correct design and configuration management deficiencies associated with past change processes. The Tier 3 process review is not an evaluation of change procedures used in the past but rather a review to determine the effectiveness of the Millstone Unit 2 CMP to identify and correct deficiencies that may have resulted from the ineffectiveness of past change processes. This will be accomplished by a " horizontal slice" inspection of examples of past changes to the facility design, practices, and documentation. The horizontal slice program verification cuts across plant systems and is a technical review to determine if:
- Changes to the plant meet the current design and licensing basis documentation, e Design and licensing basis requirements have been translated into operating, maintenance and testing procedures,
(
- e The performance of systems / components has been verified through testing, design and plant information contained in databases and documents are accurate and consistent with the plant, and e CMP corrective actions, associated with the examples of past changes selected for review, have adequately corrected the deficiency. i Exhibit 4-5 illustrates the Process Review steps. The Process Review of Millstone Unit 2 l
processes and procedures will be performed in accordance with Project Procedure PP-03
" CMP Performance Horizontal Slice Review" Conduct of the review is based on the l activities noted below and discussed in the following sections.
e Identify Change Processes l
- CMP Horizontal Slice Resiew l e Report i
\
't]
- PAR 8058 POWER -
! Audit Plan Revision !
- 4-16 June 9,1997 l
c la o%' O p Tier 3 Process Summary 6 Exhibit 4-5 m
% r W ' }I g NNECo 2;
- Procedures s s Gather To TierL .
Procedures & Prepareinitial Tier 3 Change Process Model g " m w s Define Model Process Model " b NNEco Structure
+
fl Organization Chartsj { W 8
- -----. = - - _ _ _ .m N '
l Results $ M Choose "EB y Tier 1 Inspection Resulto Additional --
- Sample ,
l C 0
** ~
selection criteria NNECo Data / Doc. PP-03 Att B&C Y Y d M p Select Review Sample - . m Customize Review Checklist I Verffication Conduct CMP ReviewWorkbook O g ; Sample Sizl NRC ! Review t i
,_____em amm amm one ** ene a== = = = * * * * * * " ' " * * " " " " * " " " " " " " " " " " " ~ " ~ ~' '
,, a I := k Prepare er 3 Repod g * > 2l:
- s. Report t
I t
b l l l 'Q 4.3.1 Identify Channe Processes '\g
- In preparation for performing the process review and the System Vertical Slice Review, NNECo procedures will be reviewed and a process model prepared to identify how various changes are performed and controlled, the organizations involved, titles of various documents, and where documents and information can be found. This is done to efficiently and consistently familiarize the ICAVP team members with what they will be reviewing and the organizations and kinds documents they will need to consider.
The process model will contain various change processes based on a review of current procedures. The model will be a high level depiction of how changes to facility design or plant characteristics are accomplished and controlled. To prepare for development of the process model, the ICAVP Team will review procedures in the following areas:
- Change Control - Plant Equipment / Structures
. Change Control - Design, License, Procedure Documents, Database Information e Assessment and Equipment Monitoring The current change processes will be identified using a 4-dimensional process model. Since a (N work process consists of activities perfonned by people and tools to produce products and i 'v/ information meeting customer, management, and regulatory requirements, the process modeling will capture and communicate these aspects of how work is accomplished:
The process model will be a high level depiction of:
- general activities that are performed, e the controls on the activities, e the information and documents produced, e the source and repository of the information/ documents, and e the organizations that perform or support the change activities.
4.3.2 CMP Horizontal Slice Review A review will be performed on a sample of past change documentation and the resulting plant configuration, maintenance, operations, testing, or training changes. The review will look for: i e Unrecognized modifications to the plant, design documents or information. l
- Departures from the plant licensing or design basis documents (p . Acceptable documentation of the results of the change and its basis.
l O I
- PAR 8888 P8WER -
Audit Plan Revision 3 4-}8 september 29,1997
i i ( This review is not an evaluation of change procedures used in the past, but rather a review to k determine the effectiveness of the Millstone Unit 2 CMP to identify and correct design or l licensing basis deficiencies that may have resulted from the ineffectiveness of past change l processes. This is a "out-come" based comparison of the current conditions versus the current design and licensing basis. i To accomplish the objective of the Tier 3 inspection, specific inspection areas have been identified for review as noted below: ENGINEERING
- 1) Setpoint changes
- 2) Specification Revision (not associated with a modification)
- 3) Drawing Revisions (not associated with a modification)
- 4) Calculations Revisions (not associated with a modification)
- 5) Licensing Document Changes
. p., 6) Non-Conformance Report (use as is)
( )
- 7) Engineering Work Request l
- 8) Vendor Technical Information Updates PARTS PROCUREMENT / SUPPLY
- 1) Commercial Grade Dedication
- 2) Equivalency Substitution
- 3) Master Equipment Parts List (MEPL)
OPERATIONS & MAINTENANCE
- 1) Revisions to Operations & Maintenance Procedures
- 2) ISI/IST, ASME Section XI Repair and Replacement
- 3) Temporary Changes, including jumper, lifted lead, and bypass control l 4) _ Emergency changes
,O c) Audit Plan Revision 3 4-19 september 29,1997
1 i O The sample will be over and above what may be reviewed by the System Vertical Slice Review. The sample of work products or outputs will be chosen to provide, as appropriate, a cross section of attributes such as discipline, (mechanical, electrical, I&C, etc.), time frame in which the product was produced, and other characteristics which have been found by experience to be potential weakness,(e.g. numerous organizational interfaces, or past industry problems). Sample size and its rational will be proposed and submitted to the NRC for review and oversight. Sampling and reviews will be conducted in two phases to ensure all CMP systems have been considered. The methodology, documentation requirements, depth of review, walkdown inspections, etc. for this program verification review is similar to what is described in the System Vertical Slice Review procedures except this review is focused on change processes instead of systems. 4.3.2.1 Prepare Review Checklist Review checklists will be developed specifically for the inspection areas identified above. The checklists will serve to maintain inspection focus and to ensure a complete and thorough review. The checklists, incorporating the input of each inspector and the team leader, will be developed in a team emironment to ensure maximizing the expertise of the entire group. The checklists will identify programmatic evaluation criteria for each of the inspection areas and will utilize the SVSR implementation checklist / workbook and professional experience for specific technical review criteria. 4.3.2.2 Conduct the Review
'Ihe review will entail a comprehensive engineering review of the above inspection areas by a team of mechanical, electrical, instrumentation & control, maintenance, operations, document control, configuration management, and information management specialists. The team, using the inspection area checklist will review the selected sample of change process outputs, confirm database accuracy and consistency, and perform plant walk downs.
If discrepancies are identified during the review, they will be immediately communicated to management for evaluation. Each discrepancy will be provided with a complete description, including all pertinent information per the requirements of Project Procedure PP-07
" Discrepancy Reports" Based on discrepancies identified during this resiew and the SVSR review, additional samples may be chosen by the NRC to investigate the extent of potential
( problems, or to ensure that a individual discrepancy is an isolated incident. O _ _ .s, - Audit Plan Revision 3 4-20 september 29,1997 I ee y- - - *e 3 g
f'~N 4.3.4 Review Activity Report d a-A process review report will be developed for the Tier 3 inspection areas. The final report will summanze the results of each process review area and any associated discrepancy l repons. Included in the report will be an assessment of the effectiveness of the Millstone Unit 2 CMP to identify and correct design and configuration management deficiencies associated with past change processes. The process review report will consist of the sections noted below. He process review report results will be included in the finalICAVP report. The report willinclude:
. Summary
. Review method and the sample selected for the various inspection areas
. Summary of results by inspection area
. Corrective actions review results
.- Discrepancy Reports summary and Appendices 4,4 REGULATORY REVIEW As part of the Millstone Unit 2 ICAVP, a Regulatory Review will be performed of selected licensing documents that have been docketed for Millstone Unit 2. (Docket 50-336). The Regulatory Review will include commitment identification for verification during the System Vertical Slice Review (Tier 1). The Regulatory Review will provide additional insight into NNECo's compliance with the current licensing and design bases at Millstone Unit 2.
He Regulatory Review, depicted on Figure 4.6, will be performed in accordance with Project Procedure PP-04 " Regulatory Review" He Regulatory Review consists of the following main activities:
. Identification of regulatory requirements, Millstone Unit 2 applicability and specific commitments identified on the docket for items within the scope of Tier 1 (the scope of Tier 1 is limited to the systems selected by the NRC for Tier I review).
. Verification of commitments and requirements validation (applicable items).
. Preparation of a Summary Report of Regulatory Resiew O --
Audit Phn Revision 4 4-21 october 5.199:
i l Exhibit 4-G REGULATORY REVIEW e e.. i
/
e sea 1 sdentity a
- Retrieve
\
Regulatory Documents l
- I l
, 4 Suvmnartre . na Re,*ements ' essesa Sectlen 1.0 *
- u .a ' _ . _ ;,
4 - ide% M2 cervigursten i t' .angest : Commitments I an SeeSen 2.0
- f -
seense Meletene 2 e=._ _ a - Was NO SAR Chesge Required
?
YES u Was Doeument & SAR 98 0 Forward Change For Corresshe Adequate Astlen
?
YES i, Deciasmest SAR shenge g
* (er nest enge) :
8st Seeman 10
****** SMt Updetes k
vennesslen inspectlen Perfersned e Tier 1 Revtow ir
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- Phyeesal eenngurelles e o coment change e eme ssmensamien Does Desument &
18 2 NO Forward Centerm For Correeshe
? A880en YES 1F i
Complete I RR : an
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- a VertRcallest t
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,Yet, =
s-
~
E~ Audit Plan Revision 4 4-22 october 5. t998
. _ _ _ - . . .-- - - . . _ - - - - - =.
O 4.4.1 Identification of Applicable Regulatory Reauirements. and Related Commitments Specific regulatory documents will be included in the Regulatory Review if they are l applicable to Millstone Unit 2 and within the scope of the ICAVP. These include:
- NRC Bulletins
. NRC Generic Letters
. Safety Evaluation Reports associated with License Amendments Other Safety Evaluation Reports (not associated with License Amendments)
- Millstone Unit 2 Licensee Event Reports All documents in each of these categories will be screened for applicability Documents relating to certain programmatic areas such as security, fire protection, environmental qualification, emergency response and planning and quality assurance will not be reviewed as part of the Regulatory Review. Specialists will be employed to review pertinent aspects of these programmatic areas to support detailed Tier reviews.. Additional details of the screening process are provided in Project Procedure PP-04, " Regulatory Resiew."
Each applicable document will be summarized. The summary will key on required licensee h action. In addition, the licensee's docketed response or application as applicable will be reviewed and summarized. This summary of the response will focus on the licensee's commitments. For each applicable document, a review of the current Updated Final Safety Analysis Report will be performed to determine if an FSAR change was required, and if required, whether the FSAR was updated as required by 10 CFR 50.71. 4.4.2 Commitment /Reauirement Verification Specific commitments identified during the Regulatory Review will be verified during the Millstone Unit 2 ICAVP. The verification will be performed within the System Vertical Slice
- Reviews (Tier 1). Summary and conclusions of the verification efforts will be provided in the Regulatory Review Report.
i [ - PARSONS P9WHI - l Audit Plan Revision 4 l 4-23 october 5.1998 l
l l p 4.4.3 Prepare Summary Report of Regulatory Review V A report will be prepared summarizing the results of the Regulatory Review performed as part of the Millstone Unit 2 ICAVP. A summary will be provided for each set of documents listed in Section 4.4.1 included in the Regulatory Review. In addition, each of the completed Regulatory Review Summary Forms within the scope of the Tier reviews will be provided. 4.5 ICAVP ACCEPTANCE CRITERIA Due to the complexity of the reviews conducted by the ICAVP and the wide breadth in scope and potential severity of deficiencies than may be identified by the ICAVP; criteria can not be established that would fairly and adequately address all possible outcomes. The Parsons ICAVP Team will report all identified discrepancies to the NRC for evaluation. The discrepancy reporting process w31 also provide a brief description of the safety significance of each discrepancy. The NRC will evaluate ICAVP discrepancies both individually and collectively and take appropriate action. The Pasons ICAVP Team will prepare a fmal report as well as individual reports for each inspection tier when completed. Each of these reports will include a collective evaluation of 7_ V discrepancies. The evaluation will assess consistency of design / licensing basis, adequacy of configuration control, and acceptability of NNECo corrective actions. 4.6 PROJECT PROCEDURES & INSTRUCTIONS Project Procedures noted in Exhibit 4-7 and Parsons Power's Quality Program will be used to support implementation of this Audit Plan. Project procedures are required for major project audit activities (i.e., SVSR, Accident Mitigation System Review, Process Review, and Regulatory Review) and implementation of Audit Plan Requirements. Project Instructions are developed as required to supplement or provide clarifications for Project Procedures associated with major project inspection actisities. l l t t - PAR 80R8 P9WER - l AuditPlan Revision 3 4-24 september 29,1997 f l l i
.. .. . . . . _ . . . . . . - - . - ..-.~ . . - - . . - . . . - _ . - . . . . . . _ - . _ . , . . . . . -
l l { O l Exhibit 4-7 PROJECT PROCEDURES & INSTRUCTIONS PROJECT PROCEDURE TITLE PP-01 System Vertical Slice Resiew PP-02 Accident Mitigation Systems Review PP-03 Process Review, CMP Horizontal Slice PP-04 Regulatory Review l PP-05 Differing Professional Opinion l PP-06 Substitution or Addition of Personnel i PP-07 Discrepancy Reports PROJECT INSTRUCTION TITLE PI-01 SVSR Implementation Checklists and Workbook , n U
- mmunwu -
Audd Plan Revision 3 4-25 september 29,1997 (
l # 5.0 DISCREPANCY REPORTS l - During the course of the Millstone Unit 2 ICAVP, any Team member may identify an apparent discrepancy and originate a Discrepancy Report (DR) in accordance with Project ! Procedure PP-07, A discrepancy is a condition, such as an error, omission, or oversight which prevents consistence among the physical configuration, infonnation se urces (e.g. documentation and data bases, design basis and/or regulatory requirements. The process for evaluation of Discrepancy Reports is presented in Exhibit 5-1. 5.1 IDENTIFICATION, EVALUATION AND REPORTING OF DISCREPANCIES All DRs will be evaluated by the responsible Group Lead, based on discussion with the Originator and other Team Members, as appropriate, to determine ifits basis is valid and to ensure that all known aspects of the Discrepancy are adequately described on the DR. If the basis for the DR is determined not to be valid, the responsible Group Lead may close the DR. DRs for issues that are evaluated ud found to have been identified previously by NNECo as part of their Configuration Management Plan shall be noted as such and closed following such evaluation. O' l l After a DR has been evaluated by the responsible Group Lead, and resiewed by the Deputy Project Director, it will be forwarded to the Project Director for approval. After I approval, the DR will be reported concurrently to the NRC, NEAC and NNECo in accordance with the Communications Plan (PLN-02). DRs will be posted on the Parsons World Wide Web page 48 hours (2 working days) after reporting to NNECo, NEAC and the NRC. This includes DRs that were closed following a deternunation that the basis was not valid and for issues that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management Plan. 5.2 REVIEW OF PROPOSED RESPONSE TO DISCREPANCIES Proposed corrective action by NNECo in response to a DR will be forwarded to the ICAVP Group Leader responsible for validating the DR. The ICAVP Group Leader will prepare comments on the proposed corrective action. Once comments on the proposed resolution have been approved they are forwarded to the NRC, NNECo and NEAC. A h
-D - PARSPOS POWER -
Audit Plan Revision 4 5-1 october 5,1998
summy of proposed NNECo resolutions and Parsons comments will be reported on the Parsons Wadd Wide Web in acewdance widi the C- :>-g Ph pmq, . I r l l
'l I
! i 4 1 l
- j. .
4 l i l i i j . 1 i i l i l g - PABBANPOWB i Audit Plan Revision 1 5-2 Junc 9,1997
l l l l l Exhibit 5-1 DiscrepancyReport Process AnyICAve Team Member i Discrepancy Check: IDENTIFICATION IdeneSed MP-kientiSed OF DISCREPANCY , DR Log Descrepancy SigntScance Number Reportinitiated nation l Groupload l 2 No Vaud assis EVALUATION Yes i 1 m Yes - No l Dep.Prol.Dir. l l Dep.Prol.Dir. l .O R-EW. APPROVAL
'~>'#' >i AND _.___:
FORWARDING I l NOTIFICATION l b b .INEACl l NU Response l REVIEW OF l ICAVP Team Review and Comment PROPOSED CORRECTIVE ACTION -- . Openitem l
- Yes lCic I
. FINAL
< U RESOLUTION l NOTIFICATION l >l WWW l
, l NEAC l iO
- -- PMBAEB POWER -
AwhtPlan Revision 3 5-3 s.pi.mber 29.1997 I
6.0 ICAVP FINAL REPORT O Lw. don of the ICAVP Final Report will cornplete project actmnes and include the followng CWA and assess system reports Ramew ofNNECo cometive merian= Prepare theICAVP Final Report Issue theICAVP FinalReport 6.1 COMPILE AND ASSESS SYSTEM REPORTS System / Process reports d:-M dunng the ICAVP Audit will be cornpiled and assessed prior to their incorporanon into the ICAVP Final Report. After the ICAVP system reports have bece Wi-8, the lead engineers will evaluate the resuhs based mi guidance and objectives ==*====i in NRC 19 Manual Section 2535, " Design Verificanon Fio, ". De entire " system story"isdss ducrepaar= idermfied and corrective acnons taken willbe evaluated to: Verify that the corrective action programs on selected systems are repre=nt=tive of and -= raw with those of other systems. Measure the effecuveness of the NNECo Configurance ht=a = : Program (CMP) to idem:F" problems, resolve exisung problems, and pia rh 6.2 REVIEW OF NNECo CORRECTIVE ACTIONS A sample ofNNECo corrective actions mi=+~i with the NNECo configuration m===gana* correcciv: acti m programs that were not previously reviewed as part of the ICAVP SVSk i=& activities will be ident:5ed by the NRC. His sample ofNNECo corrective acnons will be evaluated in parallel with ICAVP system / process report compilation and ====rnent.
%e review ofNNECo corrective actions will venfy the adequacy ofNNECo's corrective actions and assess the implementation or proposed implementanon of all conective actions
, for systems and processes withm the Millstone Unit 2 ICAVP scope. NNECo's corrective 4
actions will be evaluated using the corrective actions checklists in project instruction PI-01 l "SYSRImplementation cha+1;c,3 and Workbook". De evaluation ofNNECo corrective
'\ _ pensagspaggs -
j
' Audit Plan Revision 1 6-1 June 9.1997 l
actions that have not been fully implemented will be identified in the ICAVP Final Report to f=i1*=ta future review and evalaanan of NNECo implemaat=naa activities. 6.3 PREPAREICAVP FINAL REPORT i After completion of audit plan actmnes, an ICAVP Final Report will be prepared to summarue all project activities. A suggested table of enatante the Final Report has been
$nchM as Exhibit 6-1. In parallel with completion ofaudit plan activities tLis outline j will be updated and will be forwarded to the NRC and NNECo for review and enacarrance After NNECo and NRC cancamance, ICAVP engmeers will be assigned to prepareindmdual sections.
6.4 ISSUE THEICAVP FINAL REPORT De draft ICAVP Final Report will be reviewed by the Tochacal Advisory Group for en=pleme== and terha=1 accuracy prior to issue to the NRC and NNECo. ICAVP group leaders will assist with the incorporation of the Techn=1 Advisory Group comments De ICAVP technical editor will be responsible for final editmg and issue of the ICAVP Fmal Report. De ICAVP Fmal Report will be issued to the NRC and O, i NNECo 6.5 PROJECT CLOSEOUT AND RECORDS TURNOVER Concurrent with the issue of the ICAVP Final Report, the Parsons Power team will perform project closcout and ' =--l:!:- :':dre-assignment ofproject perd Applicable project f-:-:- - -- : :'-m not previously transmitted to NNECo will be cataloged and turned over. Project files will be cataloged, indexed, and trousfm4 to the Parsons Records Center for retention e Audit Plan hvision 1 6-2 June 9,1997 l
1 Exhibit 6-1 t ICAVP FINAL REPORT OUTLINE 1.0 Executive Sununary 2.0 - Tarhaie=1 Advisory Group Reort l 3.0 ICAVP Results Sununary & Cw--L='==- 4.0 r,=whu* ofICAVP Au&t 4.1 Otsectives 4.2 Propet Organizaten 43 Approach toICAVP Au&t 4.4 Reporting afDiscrepancies 5.0 Systan Vertical Slice Review 5.1 r-h=iaa= - SVSR 5.2 SVSRReview W 53 Discrepancy Report Sunanary , 6.0 Archat Mitigation Systan Review 6.1 Conclusions - AMSR 6.2 CnticalDesign Cksh Revmw Summary 63 Discrepancy Report Summary 7.0 Process Review 7.1 Conclusions -Process Review 7.2 Process Review Summary 73 DMgy Report Summary 8.0 Regulatory Review
, 8.1 C-h= ions - Regulatory Review 8.2 DLwy Report Summary 9.0 NNECo Corrective Action Review
- Appendices x
~~~"" M M Audit Plan Rewmon 1 6-3 June 9,1997 l
1 l l 7.0 SCHEDULE .O After confirmation of a pro #ct start date, all schedules will be revised to show calendar commitments. All task assumptions and schedule logics will be discussed during the Millstone Unit 2 ICAVP Kick-off Meeting. Key schedule assumptions are noted below. Project status 'and schedule are discussed with NNECo and the NRC at periodic public I meetmgs KEY SCHEDULE ASSUMPTIONS e The NRC has approved selection of Parsons Power as the ICAVP j Contractor for Millstone Unit 2.
. & NRC has approved the Parsons Power's Audit Plan, e h NRC will select SVSR systems and approve SVSR system boundary identification. A two week period is assumed for SVSR system boundary ;
identification and approval. p e NRC will select up to 3 SVSR systems to start the ICAVP. O e Nommal inspection periods have been assumed (no allowance for sample i expansion, special evaluation, or excessive discrepancy report i processing). 1
. Allowances for public meetings and NRC oversight activities will be i determmed on or before the Kick-off Meetmg
. The following NNECo calendar commitments have been used to establish this schedule revision.
NNECo has completed 50% of the Group 1 CMP systems on June 30,1997, NNECo has completed all Group 1 and Group 2 CMP systems on September 5,1997.
.~ Activity durations based on 5 day workweek.
p-A>
- remu rn.a -
AuditPlan Revision 4 7-1 octoba 5,1998}}