ML20210U374

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Rev 2 to PI-MP3-03, Review of Plant Mods Prepared After Receipt of Operating License for Technical Adequacy & for Configuration Control
ML20210U374
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/16/1997
From: Bass K, Neri A, Tom Ryan
SARGENT & LUNDY, INC.
To:
Shared Package
ML20210U355 List:
References
PI-MP3-03, PI-MP3-3, NUDOCS 9709190126
Download: ML20210U374 (14)
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Text

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PROJECT lNSTRUCTION

  • f*"' ,) INSTRUCTION PI-MP3-03 REV. 2 l

l Client: No'theast Utilities Station: Millstone Unit 3

Title:

REVIEW OF PLANT MODIFICATIONS PREPARED AFTER RECEIPT OF OPERATING LICENSE FOR 4

TECHNICAL ADEQUACY AND FOR CONFIGURATION CONTROL h Safety-Related Non Safety-Related Reviewed By: Approved By:

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

, Date: $*l$*

!L /4s ('dK k k 71 - M4 % asu hQ M9MI~ -

Description

(/ V Rev.2 Revised PI to:

  • Allow the modification screening functions to be performed by either the SRO Imd or the Lead Verifier.

x Page 1 of 13 9709190126 970917 PDR ADOCK 05000423 P PDR

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PROJECT INSTRUCTION PI-MP3-03

. INSTRUCTION .- REV. 2 l 1.0 PURPOSE This instruction establishes the requirements for the review of modifications to systems included in the scope of the Independent Corrective Action Verification Program (ICAVP). The purpose of the modification review is to verify the adequacy of the engineering design and configuration control processes.

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2.0 REFERENCES

2.1 NRC Inspection Manual Procedure 93801, Safety System Functional Inspection 3

2.2 10CFR50.2, Definitions 2.3 NRC Confirmatory Order Establishing Independent Correction Action Verification Program - Millstone Nuclear Power Station, Units 1,2, and 3 V

, 2.4 NUMARC 90-12, Design Basis Program Guidelines a

2.5 PI-MP3-02, Review of System Design for Compliance with Design &

Licensing Basis i 2.6 PI-MP3-04, Programmatic Reviews 2.7 PI-MP3-05, Physical Plant Configuration Walkdowns 2.8 Pl-MP3-06, Operations and Maintenance and Testing Procedures and Training Documentation Reviews 2.9 PI-MP3-09, Preparation and Approval of Checklists 2.10 PI-MP3-11, Discrepancy Report Submittal and Closure 2.11 PI-MP3-12, Project File Index b

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PROJECT INSTRUCTION 7 " "' INSTRUCTION PI-MP3-03 REV 2 l 2.12 CK-MP3-03, Series Checklists as follows:

CK-MP3-03-01 Modification Review Administrative Checklist CK-MP3-03-02 Modification Screening Checklist CK-MP3-03-03 Mechanical Systems Design Review CK-MP3-03-04 Electrical Design Review CK-MP343-05 l&C Design Review CK-MP3-03-06 Structural Design Review CK-MP3-03-07 ALARA Design Review CK-MP3-03-08 Security Review CK-MP3-03-09 Appendix R Compliance Review CK-MP3-03-10 Electrical Equipment Qualification Review CK-MP3-03-11 Seismic Qualification Review CK-MP3-03-12 Radiological Environmental Review CK-MP3-03-13 Non-Radiological Environmental Review CK-MP3-03-14 Station Blackout Review CK-MP3-03-15 Control Panel Design Review CK-MP3-03-16 Piping Design Review CK-MP3-03-17 Setpoint Database Design Review O CK-MP3-03-18 Hazards /HELB Program Review CK-MP3-03-19 Fire Protection Review CK-MP3-03-20 Licensing Review CK-MP3-03-21 PRA Review l CK-MP3-03-22 Quality Software Design Review CK-MP3-03-23 Installation Plan Review CK-MP3-03-24 Test Plan Review CK-MP3-03-25 Project Closeout Review M913: Checklists used in the performance of this Pl are not included as attachments to the Pl, Checklists are prepared and controlled as separate documents per PI-MP3-09, 3,0 DEFINITIONS 3.1 Operations & Maintenance and Testing Review Group (ORG) - The -

subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training materials for the systems within the scope of the ICAVP.

3.2 - System Review Group (SRG) - The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the 4

systems in the scope of the ICAVP, Page 3 of 13 l

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PROJECT

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  • p- INSTRUCTION PI-MP3-03  !

( INSTRUCTION .

REV. 2 l 3.3 Configuration Review Group (CRG)- The subgroup of the SRG responsible for walkdowns to verify the carent as built conditions are in conformance with the design output docu;nents.

3.4 Design Bases - The information which identifies the specific functions to be performed by a structure, system or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted " state of the art' practices for achieving functional goals or (2) requirements derived from analysis of the effects of a postulated accident for which a structure, system or component must meet its functional goals (Reference 2.2).

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

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

3.7 Current Licensing Basis (CLB)- The set of NRC requirements applicable to a specific plant, and a licensee's written commitments for assuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19, 20, 21, 30, 40, 50, 51, 55, 72, 73,100 and appendices thereto; orders; license conditions; exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented in the most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 and the licensee's commi'ments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports. (Reference 2.7) 3.8 Verifier - The individual assigned to review engineering attributes within his area of responsibility.

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PROJECT $ ""' INSTRUCTION PI-MP3-03 G INSTRUCTION / REV.2 V ....

l 4.0 RESPONSIBILITIES 4.1 The Verification Team Manager shall be responsible for defining final report format and for overall management of the Verification Team.

4.2 The SRG Lead shall be responsible for assigning the Lead Verifier for each system in the ICAVP scope and for overall coordination of the SRG effort.

1 4.3 The Lead Verifier shall be responsible for reviewing modif% tion elements 4

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

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

, 5.0 PROCEDURE 5.1 General O The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in Section 2.0 of this PI requires Northeast Utilities (NU) to implement the ICAVP. The confirmatory order also defines the scope of the ICAVP. Item 1 of the scope nf the ICAVP described on page 13 of the confirmatory order requires the Licensee to perform a review of the engineering design and configuration control processes. The scope of the review encompasses the modifications to the selected systems since initiallicensing.

This procedure provides the instructions for performing en orderly review 3

of the modifications to the selected systems in ordar to comply with the confirmatory order and applies to both major modifications (DCR's) and minor modifications (MMOD's). DCN's generated to support the DCRIMMOD processes shall be included in the scope of the modification review. DCN's which support the like for like replacement

process, the maintenance support engineering evaluation process and the NCR disposition process are not included in the scope of this review. Adequacy of the engineering design process will be determined by performing detailed technical reviews of the modification design elements including verification of design inputs and changes to design process documents and design output documents. Adequacy of the O configuration control process will be determined by verifying that changes Page 5 of 13

k PROJECT

) INSTRUCTION

' "/ $"" INSTRUCTION PI-MP3-03 J REV.2 l resulting from the modification have been reflected in design output 1

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

Configuration control as it relates to plant physical configuration and plant procedures is covered by PI-MP3-05 and -06, respectively Review of NU's design change process procedures is covered by PI-MP3-04.

The review of the system modifications shall be performed in

' chronological order because of the impact subsequent modifications can have on previous modifications. The SRG shall also be responsible for clearly identifying prior to the CRG and ORG review of the system modification, which portions of modification packages were subsequently revised by later modification. The SRG shall also clearly identify which modifications have not yet been installed or have been partially installed. These measures are needed to prevent generation of erroneous discrepancy reports during the CRG system walkdowns i

and the ORG review of plant procedures.

The systems included in the scope of this review and the applicable modification packages were identified and retrieved as part of the system

review process described in PI-MP3-02. The specific tasks associated l with the review of modifications include: i
a. Screening of affected modification elements,
b. Review of affected modification design elements. -

, c, Review of Installation and Test Plans.

d. Review of Changes to Licensing Documents.  ;

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e. Review of Modification Close-out.
f. Discrepancy Report Preparation and Closure.
g. Final Report Preparation.

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

5.2 Screenina for Affected Modification Elements b

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PROJECT INSTRUCTION "p *"

INSTRUCTION PI MP3-03 REV.2 J l 1

i 5.2.1 The SRG Lead shall screen the system modifications to identify whether the modification is a Mechanical, Electrical, l&C or Structural I modification. The SRG Lead shall then assign a Lead Verifier from the applicable discipline to perform the modification review. The SRG Lead shall document this assignment on the Modification Review Administrative Checklist (Checklist CK-MP3-03-01).

5.2.2 The SRG Lead or Lead Verifier shall screen the modifications for l impact on modification elements by completing the Modification Screening Checklists (CK-MP3-03-02 Checklists). This task involves responding to a series of questions intended to minimize unnecessary discipline / program personnel' = view. The Lead Verifier may seek assistance as needed from os.or members within the SRG to respond to questions outside his area of expertise.

5.2.3 The SRG Lead, Lead Verifier and Verifier (s) shall respond "yes" or l

  • no" to each question on the checklists and shall initial each response.

The topics addressed in the screening checklist include:

. MECHANICAL SYSTEMS DESIGN REVIEW l

. ELECTRICAL DESIGN REVIEW e I&C DESIGN REVIEW

. STRUCTURAL DESIGN REVIEW e ALARA DESIGN REVIEW e SECURITY REVIEW

. APPENDIX R COMPLIANCE REVIEW e ELECTRICAL EQUIPMENT QUALIFICATION REVIEW e SEISMIC QUALIFICATION REVIEW e RADIOLOGICAL ENVIRONMENTAL REVIEW e NON-RADIOLOGICAL ENVIRONMENTAL REVIEW

. STATION BLACKOUT REVIEW e CONTROL PANEL DESIGN REVIEW e PIPING DESIGN REVIEW

. SETPOINT DATABASE DESIGN REVIEW e HAZARDS /HELB PROGRAM REVIEW e FIRE PROTECT!ON REVIEW

. LICENSING REVIEW e PRA REVIEW

. TRAINING PROCEDURES REVIEW e EMERGENCY PREPAREDNESS PROGRAM REVIEW e PLANT PROCEDURES REVIEW Page 7 of 13

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PROJECT INSTRUCTION PI MP3-03

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(OPS, MAINTENANCE, SURVEILLANCE, TESTING) e CONFIGURATION CHANGE REVIEW QUAllTY SOFTWARE DESIGN REVIEW 5.2.4 When the screening process has been completed, the SRG Lead or Lead Verifier shall indicate on the Modification Screening Checklist Summary Sheet (CK-MP3-03-02) which modification elements are affected.

5.2.5 The SRG Lead or Lead Verifier shall then assign Verifiers from the l applicable discipline to perform a detailed review of the affected modification elements in accordance with Subsection 5.3 of the project instruction, if the screening process identifies that physical plant configuration or plant procedures may be affected by the modification, the SRG Lead or Lead Verifier shall forward the completed l Modification Screening Checklist (CK-MP3-03-02) and a copy of the modification package to the CRG and ORG for their review. ORG concurrence is required on the section of the modification screening checklist regarding procedure impacts. This step shall not be performed until after all modifications to the system have been screened, the impact of subsequent modifications to previous modifications has been assessed, and the identification of modifications not yet installed or partially installed has been completed. Note: CRG and ORG modification reviews are covered by PI-MP3-05 and 06, respectively. Also, as part of their procedure review process, the ORG may request SRG to verify perameters in the plant procedures. This verification shall be documented by the SRG m the applicable ORG checklist (PI-MP3-06 checklist).

5.2.6 The Lead Verifier shall document on the Modification Review Administrative Checklist (CK-MP3-03-01) that the affected modification element screening process has been completed and shall file the Modificatiori Screening Checklist in the project file per PI-MP3-12, 5.3 Review of Affected Modification Elements 5.3.1 The Verifier (s) assigned by the Lead Verifier shall perform a detailed review of the affected modification design elements within his area of responsibility. The detailed review shallinclude a verification of the technical adequacy of the design inputs and of changes to, or new, O

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PRO, LECT INSTRUCTION *[ s INSTRUCTION PI-MP3-03 REV. 2 l_

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} design process documents and design output documents prepared for the modification.

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

Checklist No. D_escription

! CK-MP30343 MECHANICAL SYSTEMS DESIGN REVIEW i CK-MP343-04 ELECTRICAL DESIGN REVIEW i CK-MP3-03-05 l&C DESIGN REVIEW j CK-MP343-06 STRUCTURAL DESIGN REVIEW i

CK-MP3-03 07 ALARA DESIGN REVIEW

j. CK-MP3-03 SECURITY REVIEW

{ CK-MP3-0349 APPENDIX R COMPLIANCE REVIEW CK-MP3-03-10 ELECTRICAL EQUIPMENT QUALIFICATION REVIEW

! CK-MP3-03-11 SEISMIC QUALIFICATION REVIEW j CK-MP3-03-12 RADIOLOGICAL ENVIRONMENTAL REVIEW j CK-MP3-03-13 NON-RADIOLOGICAL ENVIRONMENTAL l REVIEW CK-MP3-03-14 STATION BLACKOUT REVIEW

[ CK-MP3-03-15 CONTROL PANEL DESIGN REVIEW

CK-MP3-03-16 PIPING DESIGN REVIEW l CK-MP3-03-17 SETPOINT DATABASE DESIGN REVIEW

! CK-MP3-03-18 HAZARDS /HELB PROGRAM REVIEW CK-MP3-03-19 FIRE PROTECTION REVIEW 3

CK-MP3-03-21 PRA REVIEW CK-MP343-22 QUALITY SOFTWARE DESIGN REVIEW t

! These checklists are intended to identify topics which should be j reviewed for each element. The Verifier shall indicate on the checklist l whether the topic has been addressed satisfactorily, was not .

addressed satisfactorily or is not applicable to the modification.

! comments needed to substantiate the Verifier (s) response shall be j entered on the comment sheets included with each checklist.-

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

yq 5.3,4 The Verifiers shall perform a technical review of new or revised design iV output documents including drawings, specifications and or lists. The Page 9 of 13

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review is a line by line review to verify the changes made to the design
output documents are technically correct and consistent with the level I of detail previously shown on the drawings.

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

5.3.6 The Verifier shall genomte a discrepancy report for any discrepancies -

I identified during the review in accordance with Subsection 5.7 of this

! project instruction.

4 I 5.3.7 The Lead Verifier shall indicate on the Modification Review i Administration Checklist (CK-MP3-03-01) that the affected modification element detailed review process has been completed, i

The Lead Verifier shall assemble and file the CK-MP3-03 series detailed element review checklists in the project file per PI-MP3-12.

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5 5.4 Review of installation & Test Plant iO

! 5.4.1 The Lead Verifier shall review the modification scope and confer with j other modification verifiers to determine installation and test (s)

{ requirements. The Installation Plan Checklist (CK-MP3-03-23) and

! the Test Plan Checklist (CK-MP3-03-24) shall be used as the basis for

! identifying these requirements.

l I 5.4.2 Once instsilation and testing requirements have been identified, the

{ Lead Verifier shall assign verifiers to review the installation plan and test plans contained in the modification package.

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5.4.3 The Verifier (s) shall review the installation plans utilizing Checklist CK-MP3-03-23. This review is intended to verify that appropriate installation squirements including welding procedures, ASME Section XI, NDE requirements, etc., are specified. Upon completion of their reviews, the Verifiers shall sign and date the checklists. Justification for responses entered on the checklists may be entered on the checklists comment sheet.

5.4.4 The Verifier (s) shall review the test plans utilizing Checklist CK-MP3-03-24. The review is intended to verify that adequate test requirements including code required preservice tests and O inspections, component level tests, system level tests and integrated Page 10 of 13

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PROJECT INSTRUCTION Pl-MP3-03 INSTRUCTION REV 2 l i

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

[ shall sign and date the checklists. Justification for responses entered

on the checklists may be entered on the checklist summary sheet. If l post modification tests are required, the SRG Lead Verifier shall

] submit the test requirements and acceptance criteria and Checklist j CK-MP3-03-24 to the ORG for review.

) 5.4.5 Discrepancies identified during the installation and test plan review

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

! inadequate, i

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

Verifier.
5.4.7 The Lead Verifier shall indicate on the Modificatior
Review

{ Administrative Checklist (CK-MP3-03-01) that the installation and test i plan review process has been completed and shall file the applicable checklists in the project file in accordance with PI-MP3-12.

5.5 Review of Chances to Licensina Documents 5.5.1 The Lead Verifier shall perform a review of changes to licensing l documentation including changes to the FSAR, Technical 3

Specifications, and Environmental Plan, Security Plan, Emergency j Plan to ensure accuracy and completeness. The Lead Verifier shall i- perform a review of the 10CFR50.59 safety evaluation or safety

! evaluation screening to verify completeness and accuracy.

I 5.5.2 The Lead Verifier shall review the Licensing Document changes using  !

l Checklists CK-MP3-03-20. The intent of this review is to verify that i changes due to modifications have been reviewed for impact on the FSAR, Technical Specifications, and Environmental Plan, Security l Plan, and Emergency Plan, if it is determined that a change is l j required, the Lead Verifier shall verify changes were processed and )

i shall review these changes for consistency with the modification. l

Upon completion of the review, the Lead Verifier shall complete  !
Checklist CK-MP3-03-20, enter any comments on the checklist l i comment sheet and sign and date the completed checklist. i 4 1 l

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5.5.3 The Lead Verifier shall review the safety evaludion prepared for the modification using Checklist CK-MP3-03-20. The intent of this review is to verify the modification is safe and satisfies the requirements of 10CFR50.59. Upon the completion of the review, the i.ead Verifier shall complete Checklist CK-MP3-03-20, enter any comments on the checklist comment sheet and sign and date the completed checklist.

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

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

5.6 Review of Modification Close-out Activities 5.6.1 The Lead Verifier shall perform a review to verify adequate O modification close-out. The intent of this review is to verify that changes identified in the modification package have been processed to incorporation or are identified as open changes. The scope of this review includes those design output documents, design process documents and licensing documents within the SRG scope. These documents as a minimum include:

a. Calculations
b. Specifications

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c. Drawings
d. Lists and Databases
e. Engineering Program Documents
f. FSAR
g. Technical Specifications 5.6.2 The Lead Verifier shall review modification close-out activities using Checklist CK-MP3-03-25.

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

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

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

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

1 5.7.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in accordance with PI-MP3-11.

j 5.8 final Report 5.8.1 The Lead Verifier shall draft a final report summarizing the results of '

the system modification review. The results of the review tasks

described above shall be used to determine that adequacy of both
design and configuration control processes for the development of
modifications after receipt of the operating license.

5.8.2 The report format shall be determined by the Verification Team

Manager.

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

6.0 ATTACHMENTS 6.1 ICAVP Process Flowchart, " Review of Modifications". ( 1 page)

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Pl-MP3 03, REV.1 ,

  • - ICAVP PROCESS FLOWCHART - ATTACHMENT 6.1 1 REVIEW OF MODIFICATIONS O'

d Screen Mod Pkgs, to identify Lead Discipline SRG l

v Screen Mod Packages

to identify Affected Elements Submit Mod Scope l Package to CRG Does Mod SRG  %% Submit to ORG for for Review + Yes change Physical effect oesMainu Yes+ Review oer PI-MP3-05 Con 6g? U surven. Test? per PI-MP3-06 Review Affected Engr. SRG SRG ,

Elements No SRG No

+ 4 4

CRG ORG Rh Review Rh Not Ucensing Changes Not Required & Safety Eval. Required

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SRC

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Pedorm instal. & Test Requirement &

Acceptance Criteria SRG Submit Test Inst. &

Were All Criteria to ORG

-Ya Discrepancies  : ": Is Post Mod-Test Yu-a for Review identified? Required? per PI-MP3-06 v SRG Process Discrepancy No No Reports Y +

(PI-MP3-11)

ALL v v Prepare Report SRG EYSTirrN"

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