ML20154G539
| ML20154G539 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/06/1998 |
| From: | Hilbish J External (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20154G456 | List: |
| References | |
| PP-07, PP-7, NUDOCS 9810130220 | |
| Download: ML20154G539 (13) | |
Text
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" PARSONS PP-07 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES
Title:
Discrepancy Reports REVISION 6 l Prepared by: /NA -[/ Date: /d -[- 98 Approved by: Date: E6'I Y Mana er, Compa y Quality Program Approved by: -
////M Date: 8d' Project Director l
l REVISION HISTORY l
REVISION DATE REVIS!CN DESCRIPTION 0 04/03/97 Procedure Initiation 1 06/09/97 incorporation of Initial NRC Comments l 2 06/26/97 incorporate NRC Comments
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3 07/29/97 incorporate NRC Comments l 4 09/12/97 Incorporate Technical Advisory Group Review l 5 01/16/98 incorporate NRC Comments l 6 10/05/98 General Update p]
'u 9810130220 981000
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S MILLSTONE UNIT 2 ICAVP PP-07 PROJECT PROCEDURES TITLE: DISCREF ANCY REPORTS REVISION: 6 DATE: 10/05/98 PAGE 2 OF 13 LIST OF EFFECTIVE PAGES PAGE No. REVISION No.
All 6 I TABLE OF CONTENTS 1.0 PURPOSE .
.. 3
2.0 REFERENCES
_3 3.0 DEFINITIONS - _
._ 3 4.0 RESPONSIBILITIES _ -
. . .. 4 5.0 PROCEDURE _ _ -
5.1 TDENTIFICATION OF DISCREPANCIES.. . . . . . . .. .5 5.2 EVALUATION...- . .. .. . . . . .6 5.3 R'2 VIEW, APPROVAL AND FORWARDING.. . . . . .7 5.4 REVIEW OF PROPOSED CORRECTIVE ACTION . . . . . . .7 5.5 FINAL RESOLUTION.. . . . .. . . . ..8 ATTACHMENT 1 - DISCREPANCY REPORT... . . . . . . . . 10 NITACHMENT 2 - CRITERIA FOR CATEGORIZING THE RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED BY THE ICAVP ~ 12 EXHIBIT 1 EVALUATION OF DISCREPANCIES . . . 13 s
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PROJECT PROCEDURES i b
O TITLE: DISCREPANCY REPORTS REVISION: 6 DATE: 10/05/98 - PAGE 3 OF 13 l
1.0 PURPOSE The purpose of this Project Procedure is to provide guidance and instructions for the initiation, evaluation, submittal and closure of Discrepancy Reports (DR) initiated for apparen: discrepancies identified during the conduct of the Millstone Unit 2 Independent Corrective Action Verification Program (ICAVP).
2.0 REFERENCES
2.1 NRC Confirmatory Order dated August 14,1996 establishing an Independent Corrective Action Verification Program (ICAVP) l 2.2 Audit Plan, Millstone Unit 2 Independent Corrective Action Verification Program
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'(& 2.3 Communication Plan, PLN-02, Millstone Unit 2 Independent Corrective Action Verification Program '
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3.0 DEFINITIONS 3.1 ICAVP - Independent Corrective Action Verification Program established by Reference 2.1 to verify the adequacy of Northeast Utilities' (NU) efforts to establish adequate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications since issuance of the initial facility operating license.
3.2 Discrepancy Report (DR) - The mechanism for documenting an apparent discrepancy identified during the Millstone Unit 2 ICAVP.
3.2 Discrepancy - A condition , such as an error, omission, or oversight which prevents consistence among the physical configuration, information sources (e.g. documentation and databases), design basis and/or regulatory requirements. A discrepancy may identify O
O programmatic, procedural or design conditions.
ED MILLSTONE UNIT 2 ICAVP PP-07 E -
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TITLE: DISCREPANCY REPORTS REVISION: 6 DATE: 10/05/98 PAGE 4 OF 13 3.3 Design Bases - Information that identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted state-of-the-art practices for achieving functional goals or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals.'
3.4 Originator - An ICAVP Team Member who identifies an apparent Discrepancy.
f 4.0 RESPONSIBILITIES 4.1 Project Director - Responsible for approval of DRs prior to concurrent reporting to NNECo, NEAC, and the NRC in accordance with the Communications Plan (PLN-02).
4.2 Deputy Project Director - Responsible for:
a review of DRs to ensure completeness and clarity and to identify possible duplications of existing DRs; e forwarding DRs to the Project Director for approval; ensuring tracking and monitoring ofDRs; e approval ofICAVP Team comments concerning proposed corrective actions by Northeast Nuclear Energy Company (NNECo).
4.3 ICAVP Group Leader - Responsible for:
e evaluating DRs originated within his group; e validating their bases; closing those for which the bases are found to be invalid; n
' 10 CFR Part 50, Paragraph 50.2
P3' MILLSTONE UNIT 2 ICAVP PP-07 M PROJECT PROCEDURES l
v) TITLE: DISCREPANCY REPORTS REVISION: 6 DATE: 10/05/98 PAGE 5 OF 13 l
commenting on the proposed resolution by NNECo.
4.4 Originator - Responsible for documenting in accordance with this procedure any apparent l Discrepancy identified during the conduct of the Millstone Unit 2 ICAVP. The Originator additionally may be asked by the ICAVP Group Leader to proside comments on the proposed resolution by NNECo.
4.5 Technical Advisory Group (TAG) - Responsible for reviewing and commenting on l proposed actions from the sample population of valid Significance Level 1,2 and 3 discrepancy reports. l l
l 5.0 PROCEDURE 5.1 IDENTIFICATION OF DISCREPANCIES O
v 5.1.1 During the course of the Millstone Unit 2 ICAVP, any Team member may identify an apparent Discrepancy and originate a Discrepancy Report (DR) (Attachment 1). Further evaluation by the ICAVP Team may be required to confirm the basis for the Discrepancy, as documented on the DR form. The DR process is depicted in Exhibit 1.
l 5.1.2 The Originator will obtain a DR Log number from the Project Administrator. The following infonnation, as a nummum, will be recorded for all DRs for tracking purposes:
. DR number e Date l
. Title
. NNECo response date e Response / resolution resiew date i
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PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS w/
REVISION: 6 DATE: 10/05/98 PAGE 6 OF 13 l l
5.1.3 he Originator will ensure that the Initiation portion of the DR form is filled out as completely as possible, including, as applicable, a description of the discrepancy, system or process name, procedure name and number, drawing name and number, affected engmeering discipline, and source authority or reference used to identify the discrepancy.
5.1.4 The Originator should provide a categorization of the significance of the identified discrepancy to one of the four levels per the criteria of Attachment 2. This section should include a brief statement of the rationale for selection of significance level. Evaluation of discrepancies to the formal NRC reporting requirements is the responsibility of NNECo.
5.1.5 He Originator will sign the form, and forward it to the Group Lead for evaluation.
5.2 EVALUATION 5.2.1 The DR 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.
In addition, the Group Lead will review the significance level and discussion prepared by the originator.
5.2.2 If the basis for the DR is determined not to be valid, the responsible Group Lead may close j the DR.
5.2.3 DRs for issues that are evaluated and found to have been identified presiously by NNECo as part of their Configuration Management Plan shall be noted as such and closed following such evaluation.
5.2.4 The responsible Group Lead will record the results of the evaluation on the DR form, check the appropriate box (es), sign the form and forward it to the Deputy Project Director.
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1 E) MILLSTONE UNIT 2 ICAVP PP-07 E .
PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 6 DATE: 10/05/98 PAGE 7 OF 13 5.3 REVIEW, APPROVAL AND FORWARDING 5.3.1 After a DR has been evaluated by the responsible Group Lead, it will be forwarded to the Deputy Project Director for review. Following that, the DR will be forwarded to the Project Director for approval. After approval, the DR will be reported concurrently to the NRC, NEAC, and NNECo in accordance with the Reference 2.3. The approval and fonvarding of a Discrepancy Report is documented on the DR form (Attachment 1).
5.3.2 DRs will be posted on the World Wide Web in accordance with Reference 2.3. DRs will be reported on the Parsons World Wide Web page 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (2 working days) after reporting the DRs to NNECo, NEAC, and the NRC. This includes DRs that were closed following a deternunation that the basis was not valid and for DRs that are evaluated and found to have been identified previously by NNECo as part of their Configuration p Management Plan.
U 5.3.3 Questions that arise during the review or approval of DRs will be resolved by the Deputy Project Director following discussions with the Group Lead and Originator, as necessary.
5.4 REVIEW OF PROPOSED CORRECTIVE ACTION 5.4.1 Proposed corrective action by NNECo in response to a DR will be forwarded to the ICAVP Group Leader responsible for evaluating the DR.
5.4.2 The ICAVP Group Leader will prepare comments on the proposed corrective action, consulting with the originator, as necessary, to ensure the proposed resolution correlates to the orighial concern. Comments should focus on the perceived adequacy of the proposed action to resolve the discrepancy and prevent recunence, consistent with the purpose of the ICAVP (refer to Definition 3.1 and Reference 2.2). Comments on the NNECo response will be documented on the DR form.
5.4.3 A copy of the proposed corrective action will be sent to the Originator after approval.
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PROJECT PROCEDURES
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U) t TITLE: DISCREPANCY REPORTS REVISION: 6 DATE: 10/05/98 PAGE 8 OF 13 5.4.4 The ICAVP Group Leader will forward the DR to the Deputy Project Director for resiew, prior to releasing the comments per Reference 2.3.
5.4.5 After comment resolution, the ICAVP Project Director will approve the DR and forward it to NNECo, NEAC, and the NRC per the Communications Plan (Reference 2.3).
5.4.6 A summary of the NNECo response and ICAVP review of the NNECo corrective action (s) will be posted on the WWW in accordance with the Communications Plan (PLN-02)
(Reference 2.3).
5.4.7 TAG will review and comment on proposed corrective actions for all samples Significance Level 1,2 and 3 DR's.
5.5 FINAL RESOLUTION C/ 5.4.1 If the response and supporting documentation by NNECo will resolve the Discrepancy, the Deputy Project Director will close the DR by signing the Final Resolution section.
5.4.2 The DR can be closed for the following reasons.
- a. NNECo agrees that the DR is a new discrepant condition and Parsons agrees with the proposed corrective action (Closed Confirmed DR).
- b. NNECo has shown and Parsons agrees that the specifics of the DR were presiously identified by NNECo during CMP (Closed-Previously Identified).
- c. NNECo has shown through providing additional information and Parsons agrees that the condition identified in the DR is no longer valid (Closed-Non-Discrepant).
5.4.3 If, in the opinion of the ICAVP Team, the proposed corrective action by NNECo is not complete or is not likely to resolve the DR, the Deputy Project Director will identify the DR as an open item.
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MILLSTONE UNIT 2 ICAVP PP-07 1
PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS l
REVISION: 6 DATE: 10/05/98 PAGE 9 OF 13 5.4.4 Based upon the comments provided on the NNECo response additional information may be required from NNECo in order to close the response.
5.4.5 If after a muumum of two NNECo responses Parsons has not accepted the resolution, the DR may be classified as Unresolved. The NRC will make final determmation on the condition of Unresolved DR's.
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E) MILLSTONE UNIT 2 ICAVP PP-07 E .
PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS - ATTACHMENT 1 3 REVISION: 6 DATE: 10/05/98 PAGE 10 OF 13 ATTACHMENT 1 - DISCREPANCY REPORT i
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DR NUMBER: DR-XXXX DR TITLE:
RIVISION:
ISSUE DATE:XX/XX/XX ORIGINATDIC CROUP:
SIGNIFICANG LEVEL:
DISCREPANCY Originator Group Date EVALUATION O BASIS VALID D BASIS INVALID-CLOSED D PREVIOUSLY IDENTIFIED BY NNECo - CLOSED O
Group Imd Date
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PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS - ATTACHMENT 1 REVISION: 6 DATE: 10/05/98 PAGE 11 OF 13 REVIEW AND APPROVAL Renewed:.
Deputy Project Director Date Approved:
Project Director Date Forwarded to NNECo, NEAC, and NRC: Posted to WWW:
Date Date l
SUMMARY
OF NNECo PROPOSED CORRECTIVE ACTION I
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>U COMMENT ON NNECe RESPONSE Prepand:
GroupLead Date Reviewed.
Deputy Project Director Date Approved:
Project Director Date I
Forwarded to NNECo, NEAC, and NRC: Posted to WWW:
FINAL RESOLUTION I
.G Deputy Project Director Date l
53 MILLSTONE UNIT 2 ICAVP PP-07 m
PROJECT PROCEDURES
[ TITLE: DISCREPANCY REPORTS - ATTACHMENT 2 REVISION: 6 DATE: 10/05/98 PAGE 12 OF 13 ATTACHMENT 2 l CRITERIA FOR CATEGORIZING THE RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED BY THE ICAVP
- SIGNIFICANCE LEVEL 1 I 0
A discrepancy )that identifies that the system does not meet its licensing and design l bases and cannot perform its intended function, i.e., has the potential to .
simultaneously affect redundant trams 1
. SIGNIFICANCE LEVEL 2 A discrepancy") that identifies that a single train of a redundant system does not meet its licensing and design bases and that the train cannot perform its intended n function. l bl e SIGNIFICANCE LEVEL 3 g 0
A discrepancy ) that identifies that a system does not meet its licensing and design ;
bases but the system is capable of performing its intended function. I e SIGNIFICANCE LEVEL 4 0
A discrepancy ) that identifies that the systems meet its licensing and design bases, however, there exists minor errors such as minor arithmetic errors that do not significantly affect the results of a calculation or inconsistencies between documents 4 of an editorial nature.
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A discrepancy may identify programmatic, procedural, or design issues or editorial inconsistencies.
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PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS - EXHIBIT 1 REVISION: 6 DATE: 10/05/98 PAGE 13 OF 13 EXHIBIT 1 EVALUATION OF DISCREPANCIES PP-07 Discrepancy Report Process 7$ d' i D6screpancy Check:
Identified W-idenN MNNANN DR Log OF DISCREPANCY D6screpency nificance Number Report initiated mination l
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Yes P.
I tWied No l Dep.Proj. Otr. l l Dep. Pro). Dir. l l Project 06 rector l l Project Director l REVIEW, APPROVAL ;
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AND FORWARDING l NOTIPICATION l NU lN Cl 2
l _ NU Response l REVIEW OF llCAVP Team Rev PROPOSED and Comment H tao I CORRECTIVE ACTION
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O l Close l FINAL , , Unresolved l RESOLUTION y l NOTIFICATION l O l WWW l
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