ML20210U392
| ML20210U392 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/16/1997 |
| From: | Bass K, Neri A, Tom Ryan SARGENT & LUNDY, INC. |
| To: | |
| Shared Package | |
| ML20210U355 | List:
|
| References | |
| GL-83-28, GL-91-18, PI-MP3-06, PI-MP3-6, NUDOCS 9709190133 | |
| Download: ML20210U392 (20) | |
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INSTRUCTION .y/ INSTRUCTION PI MP3-06 REV. 2 Client: Northeast UtHitles St:*lon: Millstone Unit 3
Title:
Project instruction PI MP3 06 b Safety Related Non Safety Related l
Reviewed By:
Approved By:
System Lead Programmatic O&M Lead Accident QA Engineer internal Review Lead Venfication Mttigation Committee j Tsam Manager
) Lead Chairman D h i=/d* D
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D/k 8Mdwd M(p4 M N 4%^%L Descr1(Alcn:
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1.
Clarified steps to complete ORG SRL and SRC activities according to PI-02 instructions including electronic database method.
2.
3.
Clartfled Instruction for ORG referral to SRG for bases verification to include ' supporting references *,
Revised ORG Mod Review steps to exclude entry and disposition of Mod items from the SRL and SRC. Added appropriate references to CK MP3-06-11.
- 4. Revised Pl-06 flow chart to remove SRC update decision step.
- 5. Miscellaneous editorial changes.
- 6. Clarified performance history review to be for last two operating cycles.
- 7. Clarified review of past changes of procedures for PRG reviews.
- 8. Clarified use of checkika.
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9709190133 970917 PDR ADOCK 05000423 PDR P Page 1 of 19
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(NSTRUCTION PI MP3-06 c INSTRUCTION / REV. 2 1 PURPOSE The purpose of the Operations, Maintenance and Testing (O&M&T) portion of the Independent Corrective Action Venfication Program (ICAVP)is to determine whether the design and licensing bases for Millstone, Unit 3, have been adequately translated into operating, maintenance and test procedures for the selected systems. The O&
M&T portion of the ICAVP will also verify that changes made to Unit 3 since issuance of the operating license were implemented by appropriate procedure changes and testing.
Training program procedures and other Significant Support / Interacting Systems and Related Activities required for proper' implementation of these procedures and testing will also be evaluated. The O&M&T will also confirm that current testing requirements, maintenance, and post modification testing are adequate to verify system performance.
2 REFERENCES 2.1 NRC Inspection Manual Procedure 93801, Safety System Functional inspection.
2.2 10 CFR 50.2, Definitions.
2.3 NRC Confirmatory Order Establishing Independent Corrective Action Venfication Program Millstone Nuclear Power E,tation, Units 1,2, and 3.
2.4 NRC ICAVP Oversight and Inspection Plan, dated December 19,1996, 2.5 Regulatory Guide 1.33, Revision 2, Quality Assurance Program Requirements (Operations) 2.6 NUMARC 90-12, Design Basis Program Guidelines, 2.7 NRC Generic Letter 90-03, Relaxation of Staff Position in Generic Letter 83-28, Item 2.2, Part 2, Vendor interface for Safety Related Components.
2.8 NRC Generic Letter 91 18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability.
2.9 PI-MP3-01, independent Corrective Action Verification Program Communications Protocol.
2.10 PI MP3-02, Review of System Design for Compliance with the Design and Licensing Basis.
2.11 PI-MP3-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control.
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I 2.12. PI MP3 04 Programmatic Reviews i
2.13 PI MP3-05, Physical Plant Configuration Walkdowns. '
2.14 PI MP3 07 Review of Accident Mitigation Systems 2.15 PI MP3-09, Preparation and Approval of Checklists.
2.16 PI MP311, Discrepancy Report Submittal and Closure.
2.17 Pl MP312, Project File index.
CK MP3-06 Series Checklists as follows:
CK MP3-06-00 System Review Checklist index CK MP3-06-01 Accident Mitigating Systems Critical characteristics Checklist CK MP3 06-02 Bases / Change Features Checklist CK MP3 06-03 System Modes / Phases Checklist CK MP3-06-04 P&lD Checklist CK MP3-06-05 Significant Support / Interacting Systems and Related Activities Checklist.
O CK MP3-06 06 Supplemental Documents Checklist CK MP3-06-07 Process Indications Checklist CK MP3 06 08 Vendor Manuals / Files Checklist CK MP3 06-09 Performance History Files Checklist CK MP3-06-10 Procedure Bases Verification Checklist CK MP3 06-11 Mod Procedures Checklist CK MP3-0612 PRG Change Process Procedures Checklist CK MP3-0613 Training Materials Checklist CK MP3 0614 Testing Requirements Checklist CK MP3 0615 Testing Requirements Review Checklist CK-MP3 06-16 Test Procedure Adequacy Checklist CK-MP3 06-17 Testing Records Review Checklist CK MP3 06-18 Procedures Observed in The Field Checklist Note: Checklists used in the performance of this P1 are not included as attachments to the Pl. Checklists are prepared and controlled as separate documents per PI MP3-09.
2.19 Northeast Utilities Configuration Management Plan (CMP) 2.20 Audit Plan For indepenoent Corrective Action Verification Program (ICAVP)
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V REV. 2 3 DEFINITIONS 3.1 Operations & Maintenance and Testing Review Group (ORG) The subgroup of the ICAVP Verification Team responsible for 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 Venfication Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.
3.3 Configuration Review Group (CRG) The subgroup of the SRG Verification Team responsible for walkdowns to verify that the current as built conditions are in conformance with the design output documents.
3.4 Accident Mitigation Review Group (ARG) The subgroup of the ICAVP Verification Tearn responsible for the review of the critical system attributes of the systems used to mitigate the consequences of an accident.
3.5 Programmatic Review Group (PRG) The subgroup of the ICAVP Verification g Team responsible for performing a review of the design control and corrective I i action processes in the scope of the ICAVP.
U 3.6 Current Licensing Basis (CLB) The set of NRC requirements applicable to a specific plant, and a licensee's wntten commitments for aasuring compliance with and operation within apphcable NRC requirements and the plant specific design basis (including all modifications and additions to such commitments over the hfe 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 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. (Reference 2.7) 3.7 Design Bases - The information which identifies the specific functions to be performed by a structure, system or component of a facikty, 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 i 6 LJ Page 4 of 19
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'v which a structure, system or component must meet its function goals.
(Reference 2.2) 3.8 Design Output Documents Controlled plant documents such as specifications, drawings, vendor drawings, datasheets, lists and databases.
(Reference 2.5) 3.9 Design Process Documents Documents such as calculations, analyses, evaluations or other documented engineering activities that substantiate the final design. (Reference 2.5) 3.10 Verifier The individual assigned to review engineering attributes within his area of responsibility.
3.11 Significant Support / Interacting Systems and Related Activities As used in this Pi Significant Support / Interacting Systems and Related Activities refers to those process systems, activities, or procedures that are considered essential and significant by the ORG Verifiers in accomplishing the Design or License Basis item that is being evaluated. It is not intended that this consideration of Significant Support / Interacting Systems and Related Activities be viewed as an A all encompassing chain of all possible support and related activities. As an b example, if an operator or maintenance worker must be trained with specific skills to perform particular procedures, then the existence of apploved training procedures will be verified to accomplish that specific skill training. Neither the entire training program nor the skills nor qualifications of the trainers will be evaluated as part of meeting the subject design basis item being evaluated.
4 RESPONSIBILITIES 4.1 The Verification Team Manager shall be responsible for overall management of the Verification Team.
4.2 The ORG Lead shall be responsible for assigning a Lead Venfier for each system in the ICAVP scope, for assigning other verifiers as necessary to support the Lead Verifier, and for overall coordination of the ORG effort.
4.3 The ORG Lead Verifier shall be the primary person for an assigned system responsible for compiling and listing the bases information on the System Requirements Checklist, and for performing a review of procedures, vendor manuals, tralning materials and plant simulator configuration as desenbed in this instruction. An ORG Lead Verifier may serve as a verifier for other reviews.
4.4 The ORG Verifiers shall be responsible for providing a technical review of the bases information listed on the System Requirements Checklist, and for (3
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INSTRUCTION I INSTRUCTION PI-MP3-06 O REV.2 performing reviews within their area of expertise in accordance with this instruvion. An ORG Verifier may serve as an ORG Lead Verifier.
5 INSTRUCTIOtig 5.1 General The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in l Section 2.0 of this PI requires Northeast Utilities (NU) to implement the ICAVP.
The Confirmatory Order also defines the scope of the ICAVP. This scope ;
includes verification that design and licensing bases requirements are translated into operating, maintenance and testing procedures. The ORG includes as part of this verification a check that functional and performance requirements, identified by the SRG in the licensing and design bases of the selected systems, are implemented in the operating, maintenance and testing procedures and training material. The ORG will also review modifications to the system to verify that the appropriate procedures correctly reflect the changes made. The ORG will also verify system performance through review of test records, maintenance history, and ebservation of selected testing. Walkdowns will be used as appropriate to verify adequate control of operational, maintenance, test and surveillance procedures, operator training, and control of the plant simulator configuration.
5.1.1 The ORG Verifier shall begin the assembly of checklists for the system being reviev,ed by filling out a copy of Checklist CK MP3-06-00.
Instructions for the use of this checklist are included with the checklist.
5.1.2 Additional Significant Support / Interacting Systems and Related Activities may be luontified during reviews in order that procedures governing such activities can be evaluated for adequate implementation of Design Bases items. Refer to Definition 3.11 of this Pl for clear understanding of this action.
5.1.3 Any parameters, or modes of operation, or configuration lineups, or numerical or setpoint limitations that are not identified in the System Requirements Checklist shall be forwarded to the SRG for verification as described in Sections 5.4.3.a.1,5.5.8.a.1, and 5.6.9.a.1 of this PI 5.2 Document Retrieval and Review 5.2.1 Refer to Project Instruction PI MP3-02 for a detailed breakdown in the division of responsibility within the ICAVP Verification Team for gathering documents. The ORG shall gather documents for the selected system from the following list of examples of operating and maintenance documents; Page 6 of 19
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- a. Operating Procedures including Emergency Operating Procedures
- b. Maintenance Procedures
- c. Surveillanc9 Test Procedures
- d. VendorManuals
- e. System Training Procedures
- f. Other Significant Support and/or Related Procedures
- g. Operational Data needed to support review of Design Process '
Documents 5.2.2 l The ORG shall use the station document index to determine the types of documents or records to be gathered and to identify specific procedures and %sts applicable to the system being reviewed.
! 5.2.3 The ORG shall request relevant documents which are not in the ICAVP i
Library, from NU in accordance with subsection 3.1 of Pl MP3 01. -
5.2.4 The ORG shall complete the applicable section of the System Reference -
List (SRL) with the documents identified in 5.2.2. Checklist CK MP3 01 instructions shall be used for the SRL.
O 5.2.5 The ORG Lead Verifier and the other ORG Verifiers assigned to review the system shall review the appropriate documentation in order to achieve an in-depth understanding of the system as it relates to their area of expertise.
I 5.2.6 Prior to the ORG review of system modifications which have occurred since the issuance of the operating license, the SRG shall provide the ORG a clear description of portions of modification packages which were subsequently revised by later modifications. The SRG shall also clearly describe for the ORG the modifications which are complete and implemented, and those that have not yet been installed. These measures are required, in part, to prevent generation of erroneous discrepancy reports during the ORG review of procedures and other supporting material.
5.2.7 The SRG screens the modifications using a Modification Screening Checklist (CK MP3 03-02 ). Among the topics addressed by the checklist is a screening of the modification for impact un training procedures and plant procedures (operations, maintenance and surveillance). The SRG Lead Verifier shall forward a copy of the checklist and the modification package to the ORG for review. The ORG Verifier shallindependently review the modification packages forimpact on procedures, and indicate concurrence by signing the checklist O
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PROJECT ""O"" # INSTRUCTION PI MP3-06 OV INSTRUCTION REV. 2 5.3 jdentification of System Roouirements 5.3.1 As described in PI MP3-02, the SRG shall use a Systems Requirements Checklist (SRC), Checklist CK MP3 02 02, to identify the functional, performance and other design requirements for the system being !
reviewed.
5.3.2 The ORG shall also use the Systems Requirements Checklist (SRC),
Checklist CK MP3 02 02 to identify operating, maintenance, and testing requirements. The ORG shall review the functional and performance requirements entered on the SRC, by the SRG, for ORG applicability.
5.3.3 The ORG Lead will assign a Lead Verifier for each of the systems being l
reviewed.
5.3.4 The ORG Verifier shall tabulate the requirements along with a reference l
on the System Requirements Checklist (CK MP3-02-G ').
5.3.5 The information tabulated on the System Requirements Checklist shall (y 9 be independently reviewed by another verifier as described in PI MP3-02.
5.3.6 Any conflicts of bases requirements identified on the System Requirements Checklist shall be processed as discrepancies.
5.3.7 The ORG Lead shall approve each ORG input on the SRC.
l 5.3.8 The ORG Verifier shall plan and schedule plant walkdowns as appropriate for the purpose of observing system performance and to verify adequate control of procedures through observation of selected act vities and testing, as desenbed in Section 5.6.11 of this Pl. The ORG Verifier shall refer to PI MP3 05 for guidance in planning walkdowns, and coordinate the walkdown plan with the CRG Lead.
5.4 Bases Reauirements Review 5.4.1 The ORG Verifier shall perform a detailed review of the appropriate procedures listed on the SRL to evaluate them for implementation of tne bases sequirements as listed on the SRC. Those procedures that contain parameters, or modes of operation, or configuiation lineups, or numerical or setpoint limitations, that are not identified in the System Requirements Checklist or supporting references shail be venfied to be within appropriate limitations, assumptions, and calculations consistent with the system bases. The ORG Verifier shall forward these v
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INSTRUCTION PI MP3-06 INSTRUCTION N O REV. 2 procedures to the SRG for verification of the bases before the procedures are reviewed for proper implementation. During the detailed review, the ORG Verifier should conalder the need to identify specific Significant Support / Interacting Systems and Related Activities to be reviewed for implementation of the bases requirement being evaluated based on initial reviews or results of questions considered as described in Section 5.4.3.d of this Pl. The Verifier shall refer to Definition 3.11 of this PI for clarification.
5.4.2 The ORG Verifier shallidentify the appropriate checklist (s) to be used to adequately evaluate each ORG assigned SRC requirement, modification / change item or relevant Operations, Maintenance, Testing 1
' or Training procedure. The ORG Verifier shalllist the procedures, P&lDs, or other references evaluated during the review. Partial reviews of procedures shall be adequately documented by noting the specific sections reviewed.
5.4.3 The ORG Verifier shall review relevant procedures, P&lDs, and other references to;
- a. Verify that the design bases features and the current licensing basis p( features are adequately translated into the referenced procedures.
The Verifier shalllist the features and document the results of his review on Checklist CK MP3-06-02.
Any parameters, or modes of operation, or connguration lineups, or numerical or setpoint limitations, that are not identified in the System Requirements Checklist shall be venf;ed to be within appropriate limitations, assumptions, and calculations consistent with the system bases. The ORG Verifier shalllist each procedure on a copy of Checklist OK MP3 06-10 and forward the checklist along with a marked up copy of the procedure highlighting the requirements that need to be resolved to the SRG for verification of the appropriate bases before the procedure is reviewed for proper implementation, Upon retum from the SRG, the ORG Verifier shall process any discrepancies for insppr:,,priate items. Procedures with appropriate bases shall be reviewed according to the following steps of this Pl.
- b. Verify by reviewing the procedures that all modes and phases of the selected system are adequately operated, maintained, and tested.
Where appropriate, the review shall verify that any required manual operator actions can be performed under accident conditions. The Verifier shalllist the appropriate modes and phases and any required accident conditions and manual operations and document the results of his review nn Checklist CK MP3-06-03.
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- c. Verify that the various system configurations described in the procedures will perform their intended functions by reviewing the i appropriate P&lD's. The ORG Verifier shalllist the appropriate P&lD's and document the results of his review on Checklist CK MP3-06 04.
- d. Verify that any required Significant Support / Interacting Systems and Related Activities (refer to Definition 3,11 of this PI for clarification) adequately provide for proper performance of the system being reviewed to accomplish its bases requirements.. The ORG Verifier shall complete Checklist CK MP3 06 05 to evaluate the need for further items to be reviewed. The Verifier shall add any requirements to the SRC in accordance with Section 5.3 of this Pl. The Verifier shall add any necessary references to the SRL in accordance with Section 5.2.4 of this Pl. The Verifier shall document the results of his review on Checklist CK MP3-06 05 NOTE' This step is not intended to verify the adequacy of supporting systems and functions, but is merely intended to verify that procedures for supporting systems and functions reflect the ICAVP systems' requirements,
- e. Verify that sections of vendor manuals, equipment operating instructions, drawings, or ot.c supplemental documents that are referenced, or used directly as operating or maintenance procedures receive the same level of MP3 review and approval as the initial procedures. This is not a review of the technical adequacy of the documents. The Verifier shalllist any such documents and document the results of his review on Checklist CK MP3 06-06,
- f. Verify that the instruments and controls identified in the procedures to be used for remote and local operation are consistent with the installed configuration. The Verifier shalllist any such instruments and controls, identify whether they are local or remote. and document the results of his review on Checklist CK MP3 06-07.
- g. Verify that vendor manuals / files adequately support the bases requirements for the system being reviewed. The Verifier shalllist the appropriate vendor manuals and files, and document the results of his review on Checklist CK-MP3 06-08,
- h. Verify that performance history files adequately support the bases requirements for the system being reviewed. This verification shall cover the key components of the system for the recent two operating cycles, and shall include reviews to identify recurring equipment problems, and dete,rmination of any trends. Additionally, the Page 10 of 19
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REV.2 verification shallinclude review of the technical adequacy of maintenance activities, performance of appropriate post-maintenance tests, and satisfactory demonstration of equipment operability. The verifier shalllist the files and specific items reviewed. Specific references shall be indicated on the checklist.
The Verifier shall document the results of his review on Checklist CK-MP3 06 09.
- i. It may be appropriate to walkdown procedure usage in the field to observe for procedure control, and to witness some of the review items from the above sections. Refer to Section 5.6.11 of this Pl for a description of the walkdown arrangements. The Verifiel shall clearly identify any items verified by walkdown on the appropriate Checklist, and document the results of his review with comments on the appropriate checklist.
5.4.4 The verifier shall note any comments identified during the review on the comment section of each checklist used in the above reviews. Additional copies of the checkhsts and cornment sections shall be used as required to thoroughly document the results of the reviews.
O 54.5 Q The ORG Lead Verifier and the other Verifiers bhall also review the findings and corrective ections that terulted from NU's Configuration Management Plan (CMP). S&L shall not duplicate findings identified by the NU CMP.
5 4.6 The ORG Verifier will complete the verification of the procedures versus the system requirements by dispositioning each requirement on the System Requirements Checklist (Checklist CK MP3-02 02).
5.4.7 The Verifier (s) shall identify on the System Requirements Checklist, the procedures that verify the system requirements are satisfied. The Verifier (s) shallindicate that the procedure is technically adequate or describe any deficiencies. The Verifier shall also identify missing procedures, if applicable.
5.4.8 The Venfier(s) shall follow the instructions for CK MP3 02 02 to complete and disposition all entries in the System Requirements Checklist.
5.4.9 The ORG Lead shall review the disposition in the System Requirements Checklist (CK MP3 02 02) for completeness and technical accuracy. The ORG Lead shallinoicate his concurrence according to the instruction: for CK MP3-02-02.
5.4.10 The Venfier(s) shall generate a Discrepancy Report per Subsection 5.7 of this Pi for any discrepancies not previously identified by the NU CMP.
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5.4.11 The ORG Lead shall verify the checklists have been properly completed and shallindicate concurrence by signing and dating the checklists. The ORG Lead will file the checklist',in the project file in accordance with PI MP312.
5.5 Review of Chances 5.5.1 The ORG Verifier shall independently review the Modification Packages and appropriate Modification Screening Checklists (CK MP3 03 02) that have been forwarded from the SRG as described in Section 5.2.7 of this Pl. The intent of this review is to identify the specific procedures to be reviewed by the ORG for those modifications that were determined to either have procedura impact, or may have procedure impact, by the SRG.
5.5.2 The ORG Verifier shalllist the Modification Package Identification Number on the Mod Procedures Checklist, CK MP3 0611.
5.5.3 Based on a technical review of the modification packages forwarded to the ORG from the SRG, the ORG Verifier shall confirm th::t the
('N appropriate procedures for the modification or changes being evaluated V are listed on Checkht CK MP3 0611.
5.5.4 Any newly identified procedures that are not in the ICAVP Library should be requested from MP3 in accordance with section 3,1 of PI MP3 01.
5.5.5 The ORG Verifier shall perform a detailed review of the appropriate procedures for eac.h modification or change to evaluate them for implementation of the changes identified. During the detailed review, the ORG Verifier should cons. der the need to identify specific Significant Support / Interacting Syst6ms and Related Activities to utso be reviewed for implementation of the above identified changes, based on initial reviews or results of questions considered as desenbed in Section 5.5.8.d of this Pl. The Verifier shall refer to Definition 3.11 of this Pl for clarification 5.5.6 The ORG Verifier shall verify '. hat the design and operation changes identified by the SRG in Section 5.2.7 above, or identified by the reviews of this section of the Pl, or the changes identified by the PRG as described in Section 5.5.4 above, are adequately reflected in operating, maintenance, and testing procedures, in training materials, and in the simulator configuration as appropriate. The ORG Verifier shalllist each modification or change process to be evaluated on each checklist used in Section 5.5.8 below. The Verifier shalllist each procedure that is q being evaluated for implementation of the changes also on each Page 12 of 19
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checklist used in Section 5.5.8. The ORG Verifier thall also list the specific procedure section as a reference for each item that is being evaluated.
5.5.7 The ORG Verifier will review the relevant procedures to
- a. Verify that operation and maintenance of the system is consistent with any modifications to the design bases and current licensing basis features for the system being reviewed. The Verifier shalllist the features and document the results of his review on Checklist CK-MP3 06-02.
Any parameters, or modes of operation, or configuration lineups, or numerical or setpoint limitations, that are not identified in the System Requirements Checklist or supporting references shall be venfied to be within appropriate lim!!stion6, assumptions, and calculations consittent with the system bases. The ORG Verifier shalllist these procedures on Checklist CK MP3 0610 and forward the checklist to the SRG for verification of the appropriate bases before the procedures are reviewed for properimplementation. Upon retum from the SRG, the ORG Verifier shall process any discrepancies for
/~ lnappropriate items. Procedues with appropriate bases shall be reviewed according to the following steps of this Pl.
b, Verify by reviewing the procedures that all modes and phases of the selected system are adequately operated, maintained, and tested to reflect the changes. The Verifier shalllist the appropriate modes and phases and document the results of his review on Checklist CK-MP3-06-03.
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- c. Verify that the variour system configurations described in the procedures will perform their intended functions to reflect the changes by reviewing the appropriate P&lD's. The ORG Verifier shall list the appropriate P&lD's and document the results of his review on Checklist CK MP3 06-04.
- d. Verify that any required Significant SupporVinteracting Systems and Related Activities (refer to Definition 3.11 of this PI for clarification) adequately provide for proper performance of the systam being reviewed to accomplish the changes. The ORG Verifier shall complete Checklist CK MP3-06 05 to evaluate the need for further items to be reviewed. The Verifier shall add any necessary references to the SRL in accordance with Section 5.2.4 of this Pl.
The Verifie, shall document the results of his review on Checklist CK-MP3-06-05 O
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( INSTRUCTION REV.2 NOTE: This step is not intended to venfy the adequacy of supporting systems and functions, but is merely intended to verify that procedures for supporting systems and functions reflo:t the ICAVP systems' requirements,
- e. Venfy that sections of vendor manuals, equipment operating instructions, drawings, or other supplemental documents that support the change that are referenced, or used directly as operating or maintenance procedures receive the same level of MP3 review and approval as the initial procedures. This is not a review of the technical adequacy of the documents. The Venfier shalllist any such documents and document the results of his review on Checklist CK-MP3 06-06.
- f. Verify that the instruments and controls that support the change that are identified in the procedures to be used for remote and local operation are consistent with the installed configuration. The Verifier shalllist any such instruments and controls. Identify whether tiay are local or remote. and document the results of his review on Checklist CK MP3-06 07.
O g. Verify that vendor manuals / files adequately support the requirements V for the change. The Verifier shalllist the manuals / files reviewod, and document the results of his review on Checklist CK MP3 06 08.
- h. Verify that performance history files adequately support the citange requirements for the system being reviewed. This venfication shall include reviews to identify recurring equipment problems, and determination of any trenos. Additionally, the verification shall include review of the technical adequacy of maintenance activities, performance of appropriate post maintenance tests, and satisfactory demonstration of equipment operability. The verifier shalllist the files and specific items reviewed. Specific references shall be indicated on the checklist. The Verifier shall document the results of his review on Checklist CK MP3-06-09.
- i. Verify that training materials, especially operator training materials, have been appropriately updated to reflect the change. The Verifier shall also identify any required simulator configuration changes to evaluate. The Verifier shalllist the training materials reviewed, and any simulator changes evaluated, and document the results of his review on Checklist CK MP3-06-13.
J. It may be appropriate to walkdown some of the changes in the field (g to observe for procedure control, and to witness some of the review items from the above sections. Refer to Section 5.6.11 of this PI for Page 14 of 19
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INSTRUCTION PI MP3-06 O REV. 2 a description of the walkdown arrangements. The Verifier shall cleany identify any items verified by walkdown on the appropriate Checklist, and document the results of his review with comments on the appropriate checklist.
5.5.8 The verifier shall note any comments identified during the review on the comment section cf each checklist used in the above reviews. Additional copies of the checklists and comment sections shall be used as required to thoroughly document the results of the reviews 5.5.9 The ORG Load Verifier and the other Verifiers shall also review the findings and corrective actions that result d from NU's Configuration Management Plan (CMP). S&L shall not duplicate findings identified by the NU CMP.
5.5.10 The ORG Verifier will complete,the verification of the procedures versus the change requirements by dispositioning each requirement on the Mod ,
Procedures Checklist, CK MP3-0611.
5.5.11 The Venfier(s) shallidentify on the Mod Procedures Checklist, the procedures that satisfy the change requirements. The Verifier (s) shall O indicate that each procedure is technically adequata or identify any deficiencies. The Verifier shall also identify missing procedures, if applicable. '
5.5.12 The Verifier (s) shall sign the Mod Procedures Checklist when completed.
5.5.13 The ORG Lead shall review the disposition of the Mod Procedures Checklist CK MP3-06-11 for completeness and technical accuracy. The ORG Lead shall indicate his concurrence with signature and date in the appropriate column. The ORG Lead shall notify the ARG Lead that either all critical characteristics for accident mitigation systems have been satisfied or he shallidentify which have not been. The ORG Lead shall also notify the PRG Lead about the results of the PRG procedure reviews.
5.5.14 The Verifier (s) shall generate a Discrepancy Report per Subsection 5,7 of this PI for any discrepancies.not previously identified by the NU CMP.
5.5.15 The ORG Lead will verify the checklists have been properly completed and willindicate concurrence by signing and dating the checklists. The ORG Lead will file the checklists to the project file in accordance with PI MP3-12.
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5.6 Review of Testina 5.6.1 The ORG shall use input from the SRG to assist in the identification of required testing for the system. Modification functional test requirements and acceptance criteria are contained in the modification packages and are being reviewed by the SRG per PI MP3-03. The ORG Verifier shall lirt the test requirements for the modification tests forwarded by the SRG, on Testing Requirements Review Checklist CK MP3-0615.
5.6.2 The ORG Verifier shall also identify other testing requirements for the system bel. g reviewed by using Testing Requirements Checklist CK.
MP3-0614, as guidance The Verifier shall review the resource material for each category on CK MP3 06-14 to identify any additional required testing for the system being reviewed. The ORG Verifier shall list the specific tc:t vulrements for each category on Checklist CK MP3-0614 and th9 specific prov%es that implement each required test as a reference on CK MP3-0614. ine procedures identified on CK MP3 06-14 shall be listed on CK MP3-06-15 along with the procedures listed as described in Section 5.6.1, above, of this Pl.
5.6.3 The ORG Venfier shall also list.the Surveillance tests required to verify f) v the critical characteristics for the Accident Mitigation Systems, forwarded by the ARG, on Checklist CK MP3-0615, 5.6.4 The ORG verifier shall use the station document index to identify the specific testing procedures and the data /caiculation/ review sheets for each category on the list.
5.6.5 The ORG Verifier shall request relevant documents, which are not in the ICAVP Library, from NU in accordance with subsection 3.1 of PI MP3-01.
5.6.6 The ORG Verifier shall enter related procedures that were not on the SRL to the SRL according to the instructions. Additionally, any requirements that were identified in Section 5.6.1 and 5.6.2 above, that were not on the System Requirements Checklist, shall be entered on the checklist according to the instructions.
5.6.7 The ORG Verifier shalllist each test requirement item from Section 5.6.1,5.6.2, and 5.6.3, above on a copy of Checklist CK-MP3-0615, along with the specific procedure or procedure sections as references.
The Venfier shall use CK-MP3-06-15 to complete the reviews described in Section 5.6.9 of this Pl.
5.6.6 The ORG Verifier shall select periodic tests to review based on the g required frequency of the specific test item. For test items with e i ) frequency of regular intervals within each refuel cycle, select the most Page 16 of 19
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j-g PROJECT INSTRUCTION *]* "" / INSTRUCTION PI MP3-06 REV. 2 current three performances of the specific test. For test frequencies that are once per refuel cycle, select the last time the test was performed.
The verifier shall identify the test frequency on the appropriate checklist for each item. For tests that are one time performance, such as post maintenance tests or specla' tests, the Verifier shall select three items to review for each test category as described in Section 5.6.2 above of this Pl.
5.6.9 The ORG Verifier will review er,ch test item to;
- a. Verify that test data and results have been appropriately reviewed l and approved. Specific data and results identifications shall bJ listed for each item on CK MP3 0615. The Verifier shall document the results of his review on the CWk!ist. It may be appropriate to conduct field walkdowns to verify the results for some of the tests to be reviewed. The process for the walkdowns is described in Section 5.6.11 of this Pl below.
Any parameters, or modes of operation, or configuration lineups, or numerical or setpoint limitations, that are not identified in the System Requirements Checklist or supporting references shall be verified to l
O be within appropriate limitations, assumptions, and calculations consistent with the system bases. The ORG Verifier shalllist these procedures on C1ecklist CK MP3-0610 and forward the checklist to the SRG for venfication of the appropriate bases before the procedures are reviewed for proper implementation. Upon retum from the SRG, the ORG Verifier shall process any discrepancies for inappropriate items. Procedures with appropriate bases shall be reviewed Occording to the following steps of this Pl.
- b. Verify that acceptance criteria have been met. The Verifier shalllist the specific acceptance criteria, and document the results of his review on Checklist CK-MP3 0615.
- c. Verify that each test appropriately tests for the requirements identified in Section 5.6.1,5.6.2, and 5.6.3 and listed on CK MP3 15 The Verifier shalllist the bases requirements, and document the results of his review on Checklist CK MP3 0615
- d. Assess the adequacy of the test procedure and of the actions taken as a result of the tests, ( e.g., test " trend"information and root cause analyses for test failures; where appropriate, retesting; compliance with Limiting Conditions for Operations; condition reports). The Verifier shall list the items to be reviewed on Checklist CK MP3 16, and document the results on the Checklist.
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- e. Verify that testing records are appropriately maintained, and are retrievable. The venfier shallidentify the specific records reviewed, ;
and document the results on Checklist CK MP3 0617. i 4
l 5.6.10 The verifier shall note any comments identified during the review on the comment section of each checklist used in the above reviews. Additional copies of the checklists and comment sections shall be used as required to thoroughly document the results of the reviews 5.6.11 The ORG Verifier may identify activities to walkdown and observe for actual performance in the field. The walkdown may be used to aid in verifying system performance, and to aid in verifying adequate control of the appropriate procedures, and to observe for proper conduct of the activity according to the approved procedures. This walkdown can be used for witnessing conduct of any of the procedures subject to review by this Pl. This includes; operating procedures, maintenance procedures, surveillance procedures, and simulator training performance. The verifier shallidentify any activities to be observed on Checklist CK MP3-0618. The ORG Verifier shall refer to PI MP3-05 for guidance in walkdown planning, or discuss the walkdown plan with the CRG Lead.
5.6.12 The ORG Verifiers shall also review the findings and corrective actions that resulted from NU's Configuration Management Plan (CMP). S&L shall not duplicate findings identified by the NU CMP.
5.6.13 The ORG Verifier will complete the venfication of the testing procedures versus the system testing requirements by dispc,sitioning each requirement on the System Requirements Checklist (Checklist CK-MP3 02-02).
5.6.14 The Vcnfier(s) shallidentify on the System Requirements Checklist, the testing procedures that verify the system testing requirements are satisfied.
The Verifier (s) shallindicate that the procedure is technically adequate or describe any deficiencies. The Verifier shall also identify missing procedures,if applicable.
5.6.15 The Verifier (s) shall complete and disposition all entries in the System Requirements Checklist.
5.6.16 The. ORG Lead shall review the disposition in the System Requirements Checklist for completeness and technical accuracy. The ORG Lead shall indicate his concurrence according to the instructions for CK MP3-02-02, 5.6.17 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.7 O of this Pl for any discrepancies not previously identified by the NU CMP.
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REV. 2 5.6.18 The ORG Lead shall verify the checklists I ave been properly completed and shallindicate concurrence by signing and dating the checklists. The i ORG Lead shall file the checklists to the project file in accordance with '
Pl-MP3-12.
5.7 Discrecancy Report Preoaration and Closure 5.7.1 i Discrepancy Reports for discrepancies identified during the review process shall be prepared and processed in accordance with PI MP311.
Olscrepancy Reports shall not be initiated for findings already identified oy NU during implementation of the CMP.
I 5.7.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in accordance with PI MP3-11. '
5.8 Final Report
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5.8.1 The ORG Lead Verifier shall draft the section of the final report summarizing the results of the ORG system reviews.
5.8.2 - The report format shall be determined by the Verification Team haanager.
6 ATTACHMENTS 6.1 O&M&T Process Flow Chart page (1 page) l O
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