ML20203F666
| ML20203F666 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/03/1998 |
| From: | Bass K, Neri A SARGENT & LUNDY, INC. |
| To: | |
| Shared Package | |
| ML20203F653 | List: |
| References | |
| PI-MP3-04, PI-MP3-4, NUDOCS 9803020021 | |
| Download: ML20203F666 (10) | |
Text
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INSTRUCTION PI-MP3-04 PROJECT E
REV. 4 l
INSTRUCTION t
eilant-Northnant Utilitlan Mintinn-LAilktnna Iinti M
Title:
PROGRAMMATIC REVIEWS
[ Safety Related Non Safety Related Reviewed By:
Approved By:
System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification -
Lead Mitigation Committee Team Mana er Dak A*3* f Lead Chairman i
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Add Scope for Corrective Action Implementation Reviews e
Corrected Temporary Alteration Procedure Number e
I 9003020021 900225 Page 1 of 9 l PDR ADOCK 05000423
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PROJECT INSTRUCTION PI-MP3 04 REV. 4 l
INSTRUCTION 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 physica:
configuration reviews. The programmatic reviews are conducted on a horizontal basis (scross systems) for the purpose of determining if the actions taken by Northeast Utilities (NU) to correct previously identified probl9ms have been effective and if the NU change processes are effective.
The scope of the programmatic reviews willinclude:
Licensee Initiated Corrective Actions As part of its Configuration Management Program (CMP), NU has performed a vertical slice review of safety significant and risk significant systems and has ident;fied degraded or non-conforming condit!ons. For the degraded or non-conforming cond;tions NU is initiating corrective actions. The programmatic review, t 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.
Chanae Processes NU's current plant change processes will be reviewed for both their adequacy with respect to industry standards and for the effectiveness by which they are being implemented. Both design change processes and procedure change processes will be included in this review. For changes made in the past, selected changes will be reviewed for technical adequacy to assure that the plant licensing basis or design basis was not compromised.
2c0 References 2.1 NRC Confirmatory Order Establishing independent Corrective Action Verification Program.
Millstone Nuclear Power Station, Units 1,2 and 3 2.2 Millstone ICAVP Oversight inspection Plan, app,oved 12/19/96 2.3 PI MP3 09, Preparation and Approval of Checklists 2.4 PI-MP311, Discrepancy Report Submittal and Closure 2.5 NUMARC 9012, Design Basis Program Guidelines 2.6
- PI MP3-12, Project File Index Page 2 of 9 l
PROJECT INSTRUCTION PI-MP3-04
' INSTRUCTION.
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2.7 CK k 04, Series checklists us follows:
CK MP3 04-01 Corrective Actions CK MP3-04 02 Change Process Review CK MP3-04-03 Change Procedure implementation
. CK MP3-04 04 Setpoint Change Review CK MP3-04 05 MEPL Determination Reww CK MP3-04 06 Commercial Grade Dedication Review CK MP3-04 07 NCR/EWR Review CK MP3-04-08 Corrective Action implementation Ngie: Checklists used in the performance of this Pl are not included as l
attachments to the Pl. Checklists are prepared and controlled as separate documents per PI MP3-Og, Soo Definitions 3.1 Programmatic Review Group (PRG) The subgroup of the ICAVP Verification Team responsible for performing the reviews of corrective actions and change processes.
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 Ilfe of the license) that are docketed and are in.
effect. Ths CLB includes the NRC regulations contained in 10 CFR Parts 2, ig,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 1. )nsee'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 (ERG) 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.
3.5 Design Bases The information which identifies the specife functions to be performed by a structure, system or component of a facility, and the specirc 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) requiiements derived from analysis of the effects of a postulated accident for
= which a structure, system or component must meet its funclanal goals.
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PROJECT INSTRUCTION PI-MP3-04 REV 4 l
INSTRUCTION 3.6 Vertfler The individual assigned to review engineering atiributes within his area of responsibility.
3.7 Discrepancy Report (DR) The mechanism for documenting the discrepent conditions identified by the ICAVP and reporting an apparent error, inconsistency, or procedural violation with regard to licensing commitments, specifications, procedures, codes or regulations.
4;0 Responsibilities 4.1 The Programmatic Review Group Lead shall be responsible for assigning the verifier for each programmatW review and for overall coordination of the Programmatic Review effort. He shall also approve checklists that are prepared for each program review, and he shall p ovide concurrence after the review is performed that the checklist is complete.
4.2 The Verifier shall be responsible for performing the programmatic review and completing the appropriate checklist. The Verifier or any other appropriate team member shall prepare checklists prior to a program review.
Sc0 Procedure l
l 5.1 Corrective Actions l
5.1.1 General NU identified deficiencies for the ICAVP sample systems where corrective actions have been determined shall be included in the programmatic review. This will include all corrective actions associated with CMP identified condition reports and unresolved items and a sample of previously identified design related deficiencies identified by the architectiengineer before initial operation. For the remaining systems in the CMP vertical slice which have been completed by NU, a sample of NU corrective actions shall be reviewed.
l 5.1.2 Review Process The NU CMP findings / corrective action documents shall be obtained from the SRG for the ICAVP sample 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 appropriate team member for the review of corrective action avaluations. Using the checklist, the PRG Verifier shall assess the corrective actions for adequacy of the following:
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cd iPROJECT INSTRUCTION PI-MP3-04 INSTRUCTION REV. 4 l
a) Root cause determination - what is the fundamental cause, which, if corrected, will provsnt recurrence of the condition? Are plant processes or procedures affected?-
b) Extent of condition determination the extent to which other systems, structures, components, or activitias are affected.
- c) _ Plant restart is the corrective action required prior to restart?
d) Content - is the corrective action adequate in resolving the issue?
After reviewing the checklist for completeness, the PRG Lead shall file the checklist in.
accordance with PI-MP3-12.
In addition to the review of corrective action evaluations, the acceptability of implementatior; of certain corrective actions resulting from these_ evaluations for the ICAVP sample systems VAll L
be assessed. The corrective actions whose implementation will be assessed include start-up L
required items that involve engineerirsg assessments, major calculations, significant proceduie l
changes, significant FSAR changes, training and personnel qualification requirement changes, E
new test procedures, inspection acceptance criteria changes, and major changes to design or.
installstion specifications. Examples of items that will not require implementation _ review include physical plant changes, drawing changes, Unit 3 Technical Specification changes, database updates (PMMS, GRITS, etc.), Design Bases Document updates, and data sheet updates.
Checklist CK-MP3-04-08, ' Corrective Action implementation" shall be prepared by an -
appropriate team member for the review of corrective action implementation. Using the checklist, the Verifier shall assess the corrective actions for adequacy of the following:
a.
Completion - Has each corrective action assigned by the approved evaluation been completed?
b.
Consistency - Does the corrective action meet the approved Unresolved item Report (UIR) or Condition Report (CR) corrective action plan?
c.
Adequacy - is the corrective action technically correct? This involves verifying the technical adequacy of items such as calculations, FSAR O.anges and procedure chang 6s.
1 After reviewing the checklist for completeness, the ICAVP Verification Team Group Lead shall file the checklist in accordance with PI-MP3-12.
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PROJECT Yf INSTRUCTION PI-MP3-04 INSTRUCTION
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5.1.3 Discrepancies The Veiifier shall prepare a Discrepancy Report in accordance with PI-MP3-11 for any discrepancies identified during the corrective action review.
5.2 Chance Processes 5.2.1 General As part of the ICAVP system reviews, the SRG and the ORG will assess the plant modifications made on the systems sampled in the ICAVP 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 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 t'e performed as controlled by this Pl. The various change processes reviewed shallinclude the following:
Process Conssoondina MP3 Procedure drawings NUC DCM Chapter 7-specifications NUC DCM Chapter 6 calculations NUC DCM Chapter 5 procedures DC1,DC2,DC3,DC4 temporary alterations WC 10 l
minor modifications NUC DCM Chapter 3 modifications NUC DCM Chapter 3 licensing documents NGP-4.03 vendor manuals NUC DCM Chapter 8 like for like replacements NGP 6.12 setpoints NUC DCM Chapter 3 Page 6 of 9 l
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- "y-INSTRUCTION PI-MP3-04 PROJECT L 1
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l 11NSTRUCTION f 5.2.2-Review Process
- A.
Assess Adequacy of Current Process -
The current MP3 procedure for the processes listed in Section 5.2.1 will be evaluated
- for 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 malatsined consistent with-the '.icensing basis. The evaluation will be based on guidance provided in the following.
. Reg. Guide 1.33 Quality Assurance Program Requirements (Operation) e: NRC Inspection Manual INPO guidelines ration Managementin the Nuclear e
INPO 87-006 Report on Confie e
-Industry
. NEl guidelines 1 Checklist CK MP3 04-02, " Change Process Review" shall be prepared by an appropriate team member for the evaluation of the current MP3 procedures according to the above. Using the checklist, the PRG Verifier shall assess the adequacy of each procedure, After reviewing i io checklist for completeness, the PRG Lead shall file the -
checklist in accordance with PI-MP312.
B.
- Assess implementation of Procedures
. The adequacy of NU's implementation of the change process procedure will be.
. evaluated by reviewing actual plant change documentation. The evaluation will determine if the procedure is being followed, that the required checklists are being accurately and completely filled in, and that all other documentation is complete and procedurally adequate. This evaluation shall bc performed for the plant changes to the
- selected ICAVP systems that were made under the current change process procedures noted in Section 5.2.1. If a suitable sample of these changes for a particular process is not captured in the system reviews, a suitable sample outside the selected ICAVP systems will be t wiewed. Since the system review will assess the technical adequacy of the change, the programmatic review will enluate only the procedural adequacy of
- the change.- For samples outside the ICAVP systems, both procedural and technical adequacy will be evaluated.
Checklist CK-MP3-04-03, " Change Procedure implementation" shall be prepared by a quaPied 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 Lead shall file the checklist in accordance with PI-MP3-12.
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PROJECT Y
INSTRUCTION PI-MP3-04
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INSTRUCTION
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C.
Assess Adequacy of Past Ohanges Change processes have evolved over time, and the level of control of changes has also changed, in order te determine if changes may have been made that affected the plant design basis or licensing basis without proper control, a review select past changes will bc made. This review will generally be from systems covered in NU's CMP outside the selected ICAVP systems.
in the ICAVP system vertical slice reviews, all plant modifications will be reviewed for technical adequacy (PI MP3-03). This review will include all changes associated with the modifications including numerous drawing, calculation, and specification changes.
Therefore, the programmatic review of past changes will focus on changes made in systems beyond the selected ICAVP systems for the following change items:
procedures (normal, abnormal, emergency operating; ISI/IST; l
e surveillance; maintenance) temporary alterations e
licensing documents e
vendor manuals e
like for like replacements e
setpoints e
DCNs not associated w/ Mod's (drawings and specifications)
. - Material, Equipment and Parts Litt (MEPL)
Commercial Grade Dedication Non-Conformance Reports / Engineering Work Requests (dispositioned use-as-is/not implemented)
ASME Section XI repairs and replacements For each of these processes, a suitable sample of changes during each five-year interval will be reviewed for their technical adequacy, to assure that they did not compromise the unit's design or licensing basis. The sample size will be determined with the NRC's concurrence after changes are identified. The changes will be selected from lists of the various changes as related to the controlling / initiating procedure applicable a' :he time of the change Controlling / Initiating procedures may include processes such as Design Change Notices (DCN), Engineering Work Requests (EWR),
Maintenance Support Engineering Evaluations (MSSE), Authorized Work Orders (AWO), etc. The " process specific questions"in checklist CK-MP3-04-02 shall be used to assess the adequacy of the change. Applicable checklists used in the SRG and the ORG (e.g. CK-MP3-03 20 and CK-f!P3-0612) may be used to evaluate the technical adequacy of eech change. In addition, the following PRG checklists shall be used, as applicable:
CK MP3-04-04 Setpoint Change Review CK-MP3-04-05 MEPL Determination Review CK-MP3-04-06 Commercial Grade Dedication Review CK MP3-04-07 NCR/EWR Review Page 8 of 9 l 4
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PROJECT INSTRUCTION PI MP3 INSTRUCTION REV 4 l
Using the appropriate check'ist(s), the PRG Verifier shall assess the adequece each past change. Altomately, SRG or ORG verifiers may perform this review. A n..
reviewing each checklist for completeness, the PRG Lead shall file the checklist in accordance with PI-MP312.
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
-lCAVP Process Flowchart, ' Programmatic Reviews" (1 page)
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Pi44P3 04.1 g
Geher Programmenc Documents-AITTS Usene
-PRG ir Propero Checklets PRO ir Obtain Change ir ir Perform Change SRG,NU Select Corrective Process Procedure Action Gamples Review PRG
, (.h V
PRG PRG
-4 3,
l Perform Process Perform Poet Chenee l
implementation Review 3,
Review Perform Correcove PRG PRG Ac6cn Review 1P Were Discrepancies !
Nc O
identified?
Yes 1lr 1r Process Discrepancy File Checdot per Report per PI-MP1-11 PI-MP1-12 PRG PRG ICAVP PROCESS FLOWCHART Programmatic Reviews