ML20203F693
| ML20203F693 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/20/1998 |
| From: | Neri A SARGENT & LUNDY, INC. |
| To: | |
| Shared Package | |
| ML20203F653 | List: |
| References | |
| PI-MP3-11, NUDOCS 9803020026 | |
| Download: ML20203F693 (20) | |
Text
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INSTRUCTION Pl-MP3-11 PROJECT INSTRUCTION
~]f""" .- REV. 6 l Client: NortheastiAltitles C:stion: Millstone Unit 3 _
Title:
DISCREPANCY REPORT SUBMITTAL AND CLOSURE 4
S Safety Related _
Non Safety Related Reviewed By: Approved By:
System i ead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman j)n , DateA M 9T
[ME YbMM MJud d ,,'/ g AQ "hT/ P4? _
Description Rev.6 Revised P1 to:
- Add instructions for processing of NU standardized response:; to lact 4 DRs which meet a predetermined deferral criteria.
- Add details for S&L resiew of NU responses.
. Add deferral criteria for DR corrective action implementation.
Page 1 of 12 l 9803020026 980225 PDR ADOCK 05000423 P PDR
PROJECT / ""** " ' INSTRUCTION PI MP311 l INSTRUCTION - REV.6 l 1.0 P_URP_QSE This instruction establishes the requirements for the preparation, submittal and closure of Discrepancy Reports for descrepant conditions identif!ad by the Independent Corrective Action Verification Program (ICAVP) Team. This instruction addresses the preparation of DRs by the ICAVP team, the review of proposed resolutions developed by Northeast Utilities and the trending of DRs ger. orated by the Verification Team.
2.0 REFERENCE 2.1 NRC Confirmatory Order Establishing Independent Correction Action i Verification Program - Millstone Nuclear Power Station, Units 1,2, and 3 2.2 PI-MP3-01, ICAVP Communication Protocol 2.3 Pl-MP3-02, Review of System Design for Compliance with Design &
Licensing Basis 2.4 PI-MP3-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control.
2.5 PI-MP3-04, Programmatic Reviews 2.6 PI-MP3-05, Physical Plant Configuration Walkdowns 2.7 PI-MP3-06, Operations and Maintenance and Testing Procedures and Training Documentation Reviews 2.8 PI-MP3-07, Review of Accident Mitigation Systems 2.9 PI-MP3-10, Differing Professional Opinions 2.10 PI-MP3-12, Project File Index Page 2 of 12 l
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PROJECT i INSTRUCTION PI MP311 INSTRUCTION .- REV.6 i 3.0 DEFINITIONS 3.1 Accident Mitigation Review Group (ARG)- The subgroup of the ICAVP Verification Team responsible for review of critical characteristics of accident mitigation systems to ensure those systems can perform their raquired safety functions.
3.2 Internal Rcylew Committee 'IRC)- A committee comprised of senior S&L management personnel responsible for overall technical oversight of the ICAVP.
3.3 Operations & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training materials for the systems within the scope of the ICAVP.
3,4 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.
3.5 Configuration Review Group (CRG)-The subgroup of the SRG Verification Team responsible for walkdowns to verify the current as built conditions are in conformance with the design output documents.
3.6 Programmatic Review Group (PRG)- The subgroup of ti;3 ICAVP Verification Team responsible for review of the processes used to change the facility design or the operation, liialntenance and testing of the facility, The PRG is also responsible for 'icrifying the adequacy of NU's corrective actions.
3.7 Discrepancy Report (DR)- The mechanism for documenting the discrepar.1 conditions identified by the ICAVP and reporting the condition to NU for ree,olution.
3.ti Discrepancy - A discrepancy is a condition, such as an error, omission or oversight which prevents consistency among the physical configuration, information sources (e.g. documentation and databases),
design basis and/or regulatorv requirementr.
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PROJECT t INSTRUCTION PI-MP3-11 INSTRUCTION ,
REV. 6 l 4.0 RESPONSIPILITIES 4.1 Initiator - Responsible for preparation of DR in accordance with the instructions contained in this project instruction.
- Responsible for review of proposed NU resolutions in accordance with the instructions contained in this project instruction.
4.2 Verification Group Lead - Responsible for first ievel review of DRs prepared by Initiator.
- Responsible for review of S&L's dispositions to proposed NU resolutions.
- Responsible for resolving comments with l the Initiator.
4.3 Verificatior. Team Manager - Responsible for reviewing initial DRs and S&L dispositions to proposed NU resolutions.
- Responsible for resolving comments with the Verification Group Lead and the Initiator.
I - Responsible for overall control of DR process including maintenance of DR log, trending data and external distributions.
4.4 IRC Members / Chairman - Responsibla for reviewing all DRs initiated by the Verification Team, for reviewing dispositions of proposed NU resolutions to Level 1,2 and 3 DRs, and for resolving any comments with the Verification Team.
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PROJECT INSTRUCTION PI MP3-11 INSTRUCTION -
REV.6 l 6.0 PROCEDURE The Nuclear Regulatory Commissinn (NRC) Confirmatory Order (Reference 2.1) requires Northeast Utilities (NU) to iroplement the ICAVP. References 2.3 through 2.8 provide the instructions for !mplementing the reviews included in i the scope of the ICAVP. Discrepant conditions identified by the Verification Team members during the performance of these reviews will reouire the initiation of a DR. This project instruction provides the requirements for initiating, processing and closure of DRs. DRs shall not be generated for findings already identified by NU during implementation of their Configuration Management Plan.
Note: DRs shall be generated as soon as practical after the condition has been l identified. Those DRs which may be potential operability concerns shall be expedited through the review and approval process and NU shall be notified per Subssdion 5.5.1 of this instruction.
The DR process involves the following tasks:
- a. DR initiation
- b. DR resolution and closure
- c. DR log and trending data
- d. DR distribution DRs shall be generated in an electronic format using a DR Access Database.
Attachments 6.2 through 6.5 of this project instructions illustrate sample database input screens. Hardcopies of the DRs, a DR Log, DR status reports and DR trend reports can be generated from the database.
The detailed instructions for each of the above task are described in sub-sections 5 2 through 5.5. Attachment 6.1 is a flow chart illustrating the DR process.
5.2 DR Initiation 5.2.1- Members of the ARG, CRG, ORG, PRG and SRG Verification Teams shall initiate a DR for any discropant condition identified during their respective reviews. The individual initiating the DR shall be referred to as the Initiator.
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PROJECT INSTRUCTION PI-MP3-11 INSTRUCTION s REV. 6 l 5.2.5 The IRC shall review the DR. The review process shall be consistent with the instruction contained in Subsections 5.2.3.1 through 5.2.3.5 above, except that any comments or invalid dispositions shall be reviewed with the Initiator, VT Lead and VT Manager.
5.2.6 The VT Manager shall distribute approved DRs to the NRC, NEAC, NU and the Public in accordance with Subsection 5.5 of this project instruction.
5.3 DR Resolution and Closure 5.3.1 Proposed resolutions submitted by NU shall be reviewed in a manner similar to the DR initiation process described in Subsection 5.2 of this project instruction except that NU resolutions to Level 4 DRs are not l
required to be reviewed by the IRC. Level 1,2, and 3 DR resolutions must be reviewed by the IRC. The DR proposed resolution shall first be reviewed by the Verification Team and then the IRC (where applicable). Concurrent review by VT members, Leeds, and Manager are permitted. The proposed NU DR resoldlon shall be posted on the internet in accordance with section 5.5.
5.3.2 The initiator shall electronically transfer the proposed NU resolution on the *NU Resolution Screen", Attachment 6.4. Concurrence by the VT members shall be indicated on the screen, Attachment 6.4. After review of the proposed NU resolution the initiator shall indicate the nature of the DR status by highlighting 'yes" or 'no' to the following questions:
. Previously identified by NU?
(NU has documented where the discrepancy was previously identified).
- Non-Discrepant Condition?
- (NU has provided additional information which estabil5%s the acceptability of the condition) e Resolution Pending?
(NU has proposed to complete corrective actions prior to restart to resolve the discrepancy - for significance level 3 or above. S&L finds the planned corrective action acceptable, but needs to review the completed actions).
Page 8 of 12 l
PROJECT INSTRUCTION PI MP3-11 INSTRUCTION .- REV. 6 l
. Resolution Unresolved?
(After NU's second response, all or part of the response is determined not to be acceptable)
The DR shall be distributed to the NRC, NEAC, NU and the Public per Section 5.5 of this project instruction.
5.3.3 For certain Level 4 DRs which meet a specified deferral criteria, NU will submit a standardized response which states:
'NU has concluded that Discrepancy Rep *rt, DR MP3-XXXX has identified a condition not previously discovered by NU which requires cor action. This discrepancy meets the criteria specified in NRC letter 816901 and 17010. It has been screened per U3 PI-20 criteria and found to have no operability or reportability concerns and meets the Unit 3 deferral criteria. CR M3-XX-XXXX has been written to develop and track resolution of this item per RP-4.*
For these DRs, S&L review shall verify the following:
l a. The corrective action .s apparent from the description of the DR. If the corrective action is not apparent from the DR description, the DR shall be returned as 'Not Accepted' with a comment requesting clarification of the proposed corrective action,
- b. Meets the deferral criteria contained hi Attachment 6.9. It if is determined that the condition does not meet the deferral criteria, the DR Resolution shall be returned as 'Not Accepted' with comments clarifying why it is believed the deferral criter's is not met.
For all other DRs , S&L review shall verify the technical adequacy of NU's proposed resolution as well as the implementation schedule shown on the implementing corrective action report. Attachment 6.9 of this Pl shall be used for determining whether DR implementation can be deferred to after startup. DR significance level shall also be reviewed and revised as needed, depending upon NU's response.
Page 9 of 12 l
PROJECT INSTRUCTION PI MP3-11 INSTRUCTION - REV.6 l 5.3.4 If the Initiator, VT L ead, VT Manager or IRC do not concur with the l proposed resolution, the non-concurring party shall document their justification for not accepting the resolution on the 'S&L Comment Screen", Attachment 6.5 and obtain concurrence on the
- Resolution Screen" from other members in accordanco with Subsection 5.3.1.
Resolutions not accepted shall be distributed to the NRC, NEAC, and NU in accordance with Subsection 5.5 of this project instruction.
5.3.5 Revised proposed resolutions submitted by NU in response to S3t. l comments shall be reprocessed in accordance with Subsection 5.3.1 through 5.3.3. Only one additicnal resolution cycle pe. discrepancy is anticipated.
5.3.6 If all groups, (the VT members and the IRC) caruot reach agreement l on acceptanco of the proposed NU resolutions and anyone has a l safety coorn, then the provisions of PI-MP3-10 for differing profecslonal opinions DPO may be invoked.
5.4 DRJ oa and Trendina Data 5.4.1 DR Log 5.4.1.1 The DR database shall automat,r. ally assign DR Nos, status and revision. Hardcopy logs can be generated from the database.
5.4.2 Trending Data 5.4.2.1 The DR database can be sorted by the entries on Attachment 6.6 to generate trend reports.
5.5 DR Distribution 5.5.1 Initial issues 5.5.1.1 The VT Manager shall distribute DRs ' , the NRC, NEAC, NU and the Public per Subsection 3.3 of PI-MP3-01. Distribution to the NRC and NEAC shall be in the form of hardcopies, Distribution to NU shall be in the form of electronic mail and hardcopy. Distribution to the public shall be via the electronic bulletin board. Po= ting of the DR's on the electronic bulletin board will be approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after hard-copies are mailed to NUINRCINEAC. Since generation of Page 10 of 12 l v _
PROJECT INSTRUCTION PI-MP3-11 INSTRUCTION - REV. 6 l DR's will be by electronic media with database security provisions, signatures shall not be required.
5.5.1.2 The VT Manager will fax DRs which may pose potential operability concern to the NU Point Of Contact identified in PI-MP3 01. The date sent shall be entered on the Discrepancy Screen.
5.5.2 Proposed Resolutions 5.5.2.1 The VT Manager shall distribute DR rern'utions to the NRC, NEAC, ;
NU and the Public in accordance with 5,ousection 3.4 of PI-MP3-01. !
Hardcopies shall be sent to the NRC, NEAC, and NU. NU shall also be sent electronic copies,
)
j 5.5.2.2 The VT Manager shall post DR rer 'ations submitted by NU on the electronic bulletin board upon re and entry into the database.
l 5.5.2.3 The VT Manager shall distribute S&L comments on the proposed resolutione to the NRC, NEAC, and NU, in accordance with Subsection 3.4 of PI-MP3-01. DR interaction between NU and the ;
VT shall be posted on the electronic bulletin board.
6.0 ATTACHMENTS 6.1 Process Flowchart, Processing Findings & Resolutions (1 page).
6.2 Sample Discrepancy Screen (1 page).
6.3 Sample invstid Screen (1 page).
6.4 Sample Resolution Screen (1 page).
6.5 Sample Comment Sheet (1 page) 6.6 Summary of Available Entries for Pulldown Menus (2 pages) 6.7 Criteria for Operability Determination (1 page).
6.8 Criteria for Categorizing the Relative Significance of Discrepancies identified by the ICAVP.
Page 11 of 12 l
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PI MP3 011, Rev. 6 Attachment 6.6 Page1of2
SUMMARY
OF AVAILABLE ENTRIER FOR PUI 1.rnOWN MENUS 1
i flE12 ENTRIES Review Group CRO t
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ORO PRO l 4
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ARO Review Element System Design 4 Modification Design System Installation Modification Installation Operating Procedures Test Procedure Maintenance Procedure '
Training Procedure Change Process ;
Corrective Action Process -
Discipline Mechanical Design Electrical Design I&C Design Stmetural Design .
Piping Design Equipment Qualification Operations -
Maintenance Training Other Discrepancy Type Drawing Component Data Calculation Licensing Document Test Requirements Test Implementation Installation Requirements ,.
Installation Implementation O&M&T Procedure O& MAT Implementation Corrective Action Corrective ActionImplementation Procedure Implementation Design Control Procedure -
PloMN.011, Rev,6 Attachment 6,6 Page 2 0f 2 System / Process DGX HVX N/A NEW QSS RSS SWP L
- Potential Operabilitylasue Yes No l
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PI MP3-11, Rev. 6 l Attachment 6.7 CRITERIA FOR POTENTIAL OPERABILITY ISSUE The following criteria shall be used to determine if a DR poses potential operability issue:
Note: Potential Operability issues apply only to those systems that are required ;
to be operable in the current mode of the Unit (Mode 5 or 6 as defined in Table '
1.2 of the Technical Specifications).
- 1. Any departure from the conditions of the operating license, Technical Specifications.
- 2. Any occurrence or plant condition that requires notification to the NRC or other regulatory agency in accordance with the Configuration Management Plan,
- 3. Failure to meet the provisions of the Technical Requirements Manual.
- 4. Conditions resulting in a Maintenance Rule Functional Failure (MRFF) l (10CFR50.65).
l
- 5. Any occurrence that appears to jeopardize radiological protection, or may be a violation of a program, pro?3 dure or regulation with radiological implications.
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Pl MP311, Rev. 6 l
. Attachment 6.8 CRITERIA FOR CATEGORIZING TIIE RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED BY TIIE ICAVP e SIGNIFICANCE LEVEL 1 A discrepancy (U that identifies that the system does not meeting its licensing and design bases and cannot perform its intended function, i.e., has the potential to l simultaneously affect redundant trains. l e SIGNIFICANCE LEVEL 2 A discrepancy (0 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 function.
- SIGNIFICANCE LEVEL 3 A discrepancy to that identifies that a system does not meet its licensing and design bases but the system is capable of performing its intended function.
- SIGNIFICANCE LEVEL 4 A discrepancy (" that identifies that a systems meets its licensing and design bases, however, there exists minor errors such as minor arithmetic errors that do not significantly affect the result: of a calculation or inconsistencies between
- documents of an editorial nature.
NOTE (1) A discrepancy may identify programmatic, procedural, or design issues or editorial inconsistencies.
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PI MP3 11 Rev. 6
. Attachment 6.9 Page 1 of 2 The screening criteria given below are used to determine If an item is required to be completed prior to startup e Functional discrepancies in Operations Critical Drawings (as defined in EDI 30250, " Design l Drawing Maintenance and Control") where errors in configuration or arrangement of the system or component have a direct impact on plant safety, operation or reliability.
e Non-functional discrepancies in Operations Critical Drawings where errors, if uncorrected, may confuse or mislead the user. Examples: duplicate component ID numbers, calve symbols, etc. Note that enhancements to drawings (which improve and clarify the users understanding by adding, rearranging and restating information) may be deferred, e Discrepancies between the FSAR and Technical Specifications.
- Discrepancies between the FSAR and design basis documents widch have a direct impact on -
plant safety, operation or reliability, e Discrepancies between the FSAR and the Safety Evaluation Report (SER) including supplements requiring FSAR Change Requests.
- Discrepancies between the FSAR and approved plant procedures which have a direct impact on plant safety, operation or reliability.
- FS AR described safety related or risk significant function not initially tested or analyzed to validate design, e Periodic test required in FSAR but not performed per periodic test requirements in FSAR.
. Fit Protection compliance issiles that affect operability of plant Fire Protection features.
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PI-MP3-11 Rev. 6
+ Attachnnnt 6.9 Page 2 of 2
- Findings arTecting operability of Maintenance Rule Group 1 and 2 systems.
- Safety significant discrepancies affecting plant technical specifications.
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.* Pre-restart licensing commitment.
- e Discrepancies in documentation that have operability and/or reportability concerns associated with them.
. Plant labeling discrepancies which have a direct impact on plant configuration, operation or personnel safety. Other labeling discrepancies (e.g. use of dashes instead of asterisks in labels)
. may be deferred, o Environmental /' :harge issues that, if not resolved, would restrict or limit plant operation.-
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l PROJECT INSTRUCTION PI-MP3 INSTRUCTION - REV.2 l Client: Northeast Utilities Station: Millstone Unit 3
Title:
REVIEW OF ACCIDENT MITIGATION SYSTEMS
[ Safety-Related Non-Safety-Related l Reviewed By: Approved By:
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System Lead - Programmatic O&M Lead Accident QA Engineer internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman
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Date: el*/4
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Description
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ReU,2 Revised P1 to:
- Allow Verifiers to limit the scope of documentation reviewed to those drawings which are applicable and appropriate, e Provide generic verification metnodologies for certain types of critical characteristics.
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PROJECT _[*" INSTRUCTION PI-MP3-07 '
INSTRUCTION ,- RW2 l-1.0 PURPOSE This procedure estab'ishes the requirements for the ICAVP Verification Team to identify and review the critical design characteristics for the accident mitigating systems to provide reasonable assurance that these system parameters meet their design and licensing requirements as discussed la References 2.1 and 2.2.
2.0 REFERENCE 2.1 NRC Confirmatory Order establishing indepenoant Corrective Action Verification l Program - Millstone Power Station Units 1,2 ano 3, 2.2 Millstone Independent Corrective Action Verificat:on Program - Oversight -
Inspection Plan dated 12/19/96.
2.3 S&L Project Instruction PI-MP3-01, ICAVP Communications Protocol i
2.4 S&L Project Instruction PI-MP3-02, Review of System Design for Compliance with Design and Licensing Basis 2.5 S&L Project instruction PI-MP3-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control 2.6 S&L Project Instruction PI-MP3-06, Operations and Maintenance and Testing Procedures and Training Documentation Reviews 2.7 S&L Project Instruction PI-MP3-09, Prepantion and Approval of Checklists 2.8 S&L Project Instruction PI-MP3-11, Discrepancy Report Submittal and Closure 2.9 S&L Project Instruction PI-MP3-12, Project File Index 2.10 CK MP3-07 Series Checklists as follows:
CK-MP3-07-01 FSAR Ch 15 Accidents, Syrterr 3 & Components (Not included in this PI)
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PROJECT INSTRUCTION PI-MP3-07
.lNSTRUCTION - REV. 2 l 3.0 DEFINITIONS
' 3.1 Accident Mitigation Systems Review Group (ARG) The subgroup of the ICAVP Verification Team responsible for the identification and review of the
- critical design characteristics for the accident mitigating systems to ensure that they can perform their required safety functions, 3.2 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of t' ae system in tile -
Scope of the ICAVP, 3.3 Operations & Maintenance and Testing P.eview Group (ORG)- The subgroup of the ICAVP Verification team responsibie for the review of the operating, maintenance and testing procedures, and training manuals for the systems within the scope of the ICAVP, 3.4 Independent Corrective Action Verificat!on Program (ICAVP)- The program l required by NRC Confirmatory order, Reference 2.1 to vc,ify the adequacy of ,
the correctivo actions taken by NU for their configuration management of design and licensing basis of the unit.
l l 3.5 - - Discrepancy Report (DR) - The mechanism for documenting the discrepant j- conditions identified by the ICAVP and reporting an apparent error, inconsistency, or procedural violation with regard to licensing commitments, specifications, procedures, codes or regulations.
3.6 Verifier -The individual assigned to review engineering attributes within his area of responsibHity,
. 3.7 System Critical Characteristics - The system design features and component performance parameters that must be met to perform the safety related function
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of accident mitigation.
4.0 RESPONSIBILITIES
- 4,1 The Vedfication Team Manager shall be responsible for providing overall' guidance and n,anagement to the teams.
4.2 The ARG Lead shall be responsible for assigning the discipline verifiers for Mentifying the accident mitigating systems and a review of their critical design characteristics necessary to perform their safety function (s).
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PROJECT INSTRUCTION PI-MP3-07
!NSTRUCTION - REV 2 l 4.3- The Discipline Verifiers shall be responsible for identifying the critical systom characteritics for the FSAR accidents and verifying that for the accident mitigating systems that the component parameters meet the plant carrant design basis in accordance with this instruction.
5.0 - PROCEDURE The process discussed below shall be used by the ARG to develop the system critical
- characteristics for the accident mitigating systems.- Sections 5.1,5.2 and 5.3 -
discussed below shall be the responsibility of the ARG for all the accident mitigation systems. ARG shall be responsible for the remainder of the Sections 5.4 through 5.8 l for only those accident mitigation systems which are not included in the detailed Vertical Slice Review (VSR) which shall be done by ORG and SRG. These reviews are
- addressed in the Project Instructions References 2.4 through 2.6.
5.1 The ARG Lead and Discipline Verifiers shall review the accidents analyzed in
[ - the FSAR, for Millstone Unit 3 and identify the accident mitigating systems, l- components within the system and specific component parameters which are required to mitigate the event. As a result of this review the ARG Lead or his designee shall create a database consisting of the following items: a) Analyzed '
Accidents, b) Mitigating Systems, c) Components, d) Component Parametais and e) References to the accidents and associated documents. The component parameters shall be identified in Parts 1 & 2 of Checklist CK-MP3-07-01 (Ref 2-10). These component parameters are tho inputs and or assumptions in the accident analysis.
5.2 The ARG Lead or his designee shall sort the database in Section 5.1 to facilitate the verification of the system critical characteristics in the following order: a)
Mitigating Systems, b) Components, c) Component Parameters, d) References -
and e) Analyzed Accidents. The list of systems and associated critical' characteristics shall be submitted to the NRC for approval.
5.3 The portion of the database consisting of the accident mitigation systems in the VSR shall be given to the ORG and SRG for their review of the Critical Characteristics.
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-PROJECT INSTRUCTION PI-MP3-07 INSTRUCTION < REV.2 l 5A Where applicable the ARG_ Verifiers shall verify the System Critical l-Characteristics listed in Section 5.2 using a documented System / Component
- test, and or Surveillance test from the Milbtone Unit 3 Technical Specification or Post Maintenance Tests. The verification shall on documented on the ORG -
Checklist CK-MP36-15 from Reference 2.7 which tihall be signed and dated.
To facilitate this review, those component parameter s which are identified for review using a test approach shall be listed on ORG Checklist CK-MP3-06-01 from Reference 2-7< The results of the verification and documents used shall be identified on the database contained in CK-MP3-07-0_1-(Reference 2-10).
5.5 In addition to the verification of the Critical Characteristics by test reviews discussed in Section 5.4, where appropriate the design calculations, l specifications, ver: dor documents sad drewings shall be obtained and reviewed for confomiance with the design requirements of the accident analysis.
Request for documentation shall be processed in accordance with Reference 2.3.
5.6 Verification of the Critical Characteristics using design calculations, shall be documented on the SRG Checklist CK MP3-02-03 (Ref. 2.4) which shall be signed and ' dated. For a Mechanical, l&C or Electrical Calculation, the section of this checklist covering each discipline shall be completed to verify the numerical accuracy, modeling accuracy, assumptions, engineering judgment, design inputs, methodology and results associated with each calculation. The results of the verification and documents used shall be identifed on the -
database contained in CK-MP3-07-01 (Reference 2-10).
5.7 If the Cntical Characteristics cannot be verified the review conclusions shall be i documented on the appropriate Checklist (s) and a Discrepancy Report shall be processed in accordance with Reference 2.8. The ARG Lead or his designee ,
shall verify that the checklists have been property completed and indicate -
concurrence with his signature and date. He shall file the documents per Reference 2.9.
5.8 Generic verification methodologies are identified in Attachments 6.2
- through 6.5 for the following specific characteristic types:
- 1) Instrumentation Actuation b) Pump Flow c) Operator Action d) Emergency Diesel Generator 5.9 The ARG Lead shall draft a final report summarizing the results of the review. l The report format shall be determined by the Verification Team Manager.
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PROJECT / INSTRUCTION PI-MP3-07 INSTRUCTION REV. 2 l 6.0 ATTACHMENTS 6.1 ICAVP Review of Critical Characteristics for Accident Mitigation Systems (1 page) 6.2 Instrumentation Actuation Verification Methodology 6.3 Pum, Flow Verification Methodology 6.4 Operator Action Verification Methodology 6.5 Emergency Diesel Generator Verification Methodology ,
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t Finure 1 ICAVP Review of Critical Characteris'.ics
< for Accident Mitigating Systeme Review Piant Accident initiating Events ARG sir Create a Database Submit Critical Accidents, Systeme. Characteristics to Components, NRC for Approval Parameters, -*
Referenices ARG ARG/NRC Verify CrilTcal '-
Characteristics Using Tech. Spec., Provide Critical Dcaign Cales, Characteristics for Specifications, vendor VSR Systems to documents / drawings ]> ORG/SRG for Review per PI-MP3-02 & 06 ARG AMU Were No Discrepancie[s identified?
, ,Yes Procets DRs PI-MP3-1'l i
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ARG v
,r Propare Report ARG
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Attachment 8.2 Instrumentation Actuation Verification Methodology 1)' Verify the input assumption as stated for the critical characteristics in the accident analysis _ is conservative with regard to the Technical Specifications.
- 2) Verify the instrument channel is properly calibrated in the calibration - '
procedure / surveillance including appropriate output signals for this accident. Verify _
that the calibration procedures includes and/or references setpoint margins for drift, inaccuracy, etc., and that these margins are considered in the calibration procedures.
- 3) Verify the response time of instrument channel, as required, for this accident.
'4) Verify that RPS/ESFAS generates a signal to the appropriate end device (breaker, valve, etc.).
- 5) Verify the end device response (verify response time if required),
Notes:
A). The above review process will consider the last test data available.
B). For each critical parameter _ or characteristic of the accident mitigating system, the review will address only one instrument channel for all the reviewed accidents.
- However, if the same instrument is used for different system critical characteristics, -
then additional channels will be verified for each system critical characteristic. j (Example: Hi pressurizer Level and Lo Pressurizer Level).
C). Verification of items 4 and 5 will be accomplished by a review of appropriate logic
= diagrams ~and by a review of surveillance procedure test results.
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L Attachment 6.3 Pump Flow Verification Methodology
- 1) Verify fluid source parameters (i.e. capacity, chemistry, temperature, etc.) using surveillance data.
- 2) Verify flow path from fluid source to delivery point. (P&lD review,-integrated ESFAS test and valve line-up surveillance tests).
- 3) Verify performance through IST, surveillance, startup tests and manufacturer and other plant test data.
Notas:
L A). The above review process will consider the last test data availricle.
B) The signal to actuate pump flow has been verified under the instrument actuation verification methodology. (Attachment 6.2).
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7 Attachment 6.4 Operator Action Verification Methodology
- 1) If the operator action relies on instrumentation, the instrumentation actuation will be verified in accordance with the " Instrumentation Actuation Verification Methodology",
items 1 and 2 (See Attachment 6.2),
- 2) For those operator actions associated with a main control board annunciator input, the annunciator response guide for that annunciator will be reviewed to ensure appropriate operator direction is provided either in the guide itself or by referencing other appropriate procedures.
a) the operator is made aware of the event, b) the operator has adequate guidance for instrumentation response and that appropriate action is defined in the procedures, and c) the opolator has adequate guidance for manual operations to mitigate or i terminate tf'e event.
- 4) Verify the Reactor Operator training records for emergency operation. This w;ll be acccmplished by a review of a sample of the confidential, personal operator trEining records maintained at the Millstone Site Training Center.
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4 Attachment 6.5 Emergency Diesel Generator Verification M9thodology Subsequent to establishing the methodology for emergency diesel generator verification, the Diesel Generator System was picked as one of the Tier 1 systems.
Therefore, as part of the Tier 1 roview the Operations Review Group (ORG) will perform
- 1) a review of the diesel generator surveillance procedures and last test results (including trending) to assure diesel generator operability and availability and
- 2) a review of the surveillance procedures and last test results pertaining to ESF load sequencing onto the diesel generator.
Notes:
A review of the design documentation and system requirements associated with the emergency diesel generator system will be reviewed by the Systems Review Group
- (SRG) as part of the Tier 1 review.
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