ML20210U692
| ML20210U692 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/12/1997 |
| From: | Curry D, Hellbish J External (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210U689 | List: |
| References | |
| PP-07, PP-7, NUDOCS 9709220030 | |
| Download: ML20210U692 (12) | |
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E.3 PARSONS PP-07 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES
Title:
Discrepancy Reports REVISION 4 l
Prepared by:
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Approved by:
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REVISION HISTORY REVISION DATE REVISION DESCRIPTION O
04/03/97 Procedure initiation 1
06/09/97 incorporation of Initial NRC Comments 2
06/26/97 incorporate NRC Comments 3
07/29/97 incorporate NRC Comments 4
09/12/97 lacorporate Technical Advisory Group Review 9709220030 070917 PDR ADOCK 05000336 p
33 MILLSTONE UNIT 2 lCAVP PP-07 E
PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS HEVISION: 4 DATE: 09/12/97 PAGE 2 OF 12 1 lST OF EFFECTIVE PAGES Pwr No.
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TAllLE OF CONTENTS 1.0 PURPOSE.............................................................................................................3
2.0 REFERENCES
......................................................................................................3 3.0 DEFINITIONS............................................................................................................3 4.0 R ES P O N S t H I Li T 1 ES............................................................................................. 4 5.0 PROCEDURE.................................................................................................5 5.1 IDENTIFICATION OF DISCREPANCIES..
5.2 EVALUATION...,.....
.. 6 5.3 REVIEW, APPROVAL AND FORWARDING.
...7 5.4 REVIEW OF PROPOSED CORRECrlVE ACFION.
....7 5.5 F1NAL RESOLUTION..
.......8 A'ITACilM ENT 1 - DISCREPAN CY REPO RT.................
......... 9 ATTACilMENT 2 - CRITERIA FOR CATEGORIZING Tile RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTlFIED llY Tile ICAVP.....
.I1 EX11IBIT I EVALU ATION O F DISCREPAN ClES............................................... I 2
2.3 MILLSTONE UNIT 2 ICAVP PP-07 L
PROJECT PROCEDURES TITLE.
TSCREPANCY REPORTS REsiS10N: 3 DATE: 07/29/97 PAGE 3 OF 12 1.0 PURPOSE 1 he purpose of this Project Procedure is to provide guidance and instructions for the initiation, evaluation, submittal and closure of Discrepancy Reports (DR) initiated for apparent discrepancies identified duing the conduct of the Millstone Unit 2 Independent Corrective Action Verification Program (ICAVP).
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2.0 REFERENCES
2.1 NRC Confirmatory Order dated August 14, '.996 establishing an Independent Corrective Action Verification Program (ICAVP) e 2.2 Audit Plan, Millstone Unit 2 Indcoendent Correcuve Action Verification Program 2.3 Communication Plan, PLN-02, Millvone Unit 2 Independent Corrective Aceion Verification Program 3.0 DEFINITIONS 3.1 ICAVP -Independent Coirective Action Verification Program established by Reference 2.1 to ve-ify the adequacy of Northeast Utilities' (NU) efforts to establish adequate design bases and design controls, includicg translation of the design bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications since iccuance of the initial facility operating license.
3.2 Discrepancy Report (DR) - The mechanism for docementing an apparent discrepancy identified during the Millstone Unit 2 ICAVP.
3.2 Discrescy - A condition, such as an error, omission, or oversight which prewis consistence among the physical configuration, information sources (e g. documentation and databases), design basis and/or regulatory requirement. A discrepancy may identify programmatic, procedural or desir conditions.
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MILLSTONE UNIT 2 ICAVP PP-07 M
PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS REVISION: 3 DATE: 07/29/97 PAGE 4 OF 12 3.3 Design Bases - Information that identifies the specific functions to be performed by.a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted state-of-the-art practices for achieving
, %w functional goals or (2) requirements derived from analysis (based on calculation and/or e
cxperiments) of the efTects of a postulated accident for which a structure, system, or b
component must meet its functional goals.'.
3.4 Originator - An ICAVP Team Member who identifies an apparent Discrepancy.
D 4.0 RESPONSIBILITIES 4.1 Project Director - Responsible for approval of DRs prior to concurrent reporting to NNECo, NEAC, and the NRC in accordance with the Communications Plan (PLN-02).
4.2 Deputy Project Director - Responsible for:
review of DRs to ensure completeness and clarity and to identify possible a
duplications of existing DRs; fr <arding DRs to the Project Director for approval; cruuring tracking and e
monitoring of DRs; approval ofICAVP Team comments concerning proi sed corrective actions by e
Northeast Nuclear Energy Company (NNECo).
4.3 ICAVP Group Leader - Responsible for.
evaluating DPe originated within his group; e
validating their bases; closing those for which the bases are found to be invalid; e
8 10 CFR Part 50, Paragraph 50.2
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MILLSTONE UNIT 2 ICAVP PP-07
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PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS 7.EVISION: 4 DATE: 09/12/97 PAGE 5 OF 12
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m commenting on the proposed resolution by NNECo.
e 4.4 Originator - Responsible for documenting in accordance with this procedure any apparent Discrepancy identified during the conduct of the Millstone Unit 2 ICAVP. The Originator additionally may be asked by the ICAVP Group Leader to proside comments on the preposed resolution by NNECo.
4.5 Technical Advisory Group (TAG)- Responsible for reviewing and commenting on all Significance Level 1,2 and 3 discrqv.ncy reports, NNECO responses and Parsons comments on corrective action, prict to closure.
3.0 PROCEDURE 5.1 IDENTIFICATION OF DISCREPANCIES 5.1.1 During the course of the Millstone Unit 2 ICAVP, any Team membvr may idertify an apparent Discrepancy and originate a Discrepancy Renort (DR) (Attachment 1). Further evaluation by the ICAVP Team may be required to confirm the basis for the Discrepancy, as documented on the DR form. The DR process is depicted in Exhibit 1.
51.2 he Originator will obtain a DR Log number from the Project Administrator. The following information, as a minimum, will be recorded for all DRs for tracking purposes:
DR munber Date Title NNECo response date Response / resolution review date s
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MILLSTONE UNIT 2 ICAVP PP-07 M
PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS REVISION: 4 DATE: 09/12/97 PAGE 6 OF 12 5.1.3 The Originator will ensure that the initiation portion of the DR form is filled out as completely as possible, including, as applicable, a description of the discrepancy, system or process name, procedure name and number, drawing name and number, affected engineering discipline, and source authority or reference used to identify the discrepancy.
5.1.4 The Originator should provide a categorization of the significance of the identified discrepancy to one of the four levels per the criteria of Attachment 2. This section should include a brief statement of the rationale for selection of significance level. Evaluation of discrepancies to the wrmal NRC reporting requirements is the responsibility of NNECo.
5.1.5
%e Originator will sign the form, and forward it to the Group Lead for evaluation.
5.2 EVALUATION 5.2.1 The DR will be evaluated by the responsible Group Lead, based on discussion with the Originator and other Team Members, as appropriate, to determine ifits basis is valid and to ensure that all known aspects of the Discrepancy are adequately desenbed on the DR.
In e.dditien, the Group Lead will review the signifie.ance level and discussion prepared by the originator.
5.2.2 If the basis for the DR is determined not to be valid, the responsible Group Lead may close the DR.
5.2.3 DRs for issues that are evaluated and found to have been identified presiously by NNECo as part of their Configuration Management Plan shall be noted as such and closed following such evaluation.
5.2.4 He responsible Group lead will record the results of the evaluation on the DR form, check the appropriate box (es), sign the form and forward it to the Deputy Project Director.
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MILLSTONE UNIT 2 ICAVP PP-07 M
PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS REVISION: 4 DATE: 09/12/97 PAGE 7 OF 12
.x 5.3 REVIEW, APPROVAL AND FORWARDING 5.3.1 After a DR has been evaluated by the responsible Group Lead, it will be fonvarded to the Deputy Project Director for review. Following that, the DR will be fonvarded to the Project Director for approval. ADer approval, the DR will be reported concurrently to the NRC, NEAC, and NNECo in accordance with the Reference 2.3. The approval and fonvarding of a Discrepancy Report is documented on the DR form (Attachment 1).
5.3.2 DRs will be posted on the World Wide Web in accordance with Reference 2.3. DRs will be reported on the Parsons World Wide Web page 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (2 working days) after reporting the DRs to NNECo, NEAC, and the NRC. This includes DRs that were closed following a det;nnination that the basis was act valid and for DRs that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management Plan.
5.3.3 Questions that arise during the review or approval of DRs will in resolved by the Deputy Project Director following discussions with the Group Lead and Originator, as necessaiy.
5,4 REVIEW OF PROPOSED CORRECTIVE ACTION 5.4.1 Proposed corrective action by NNECa in response to a DR will be fonvarded to the ICAVP Group Leader responsible for evaluating the DR.
5.4.2 The ICAVP Group Leader will prepare comments on the proposed corrective action, consulting with the originator, as necessary, to ensure the proposed resolution correlates to the original concern Comments should focus on the perceived adequacy of the proposed action to resolve the discrepancy and prevent recurrence, consistent with the purpose of the ICAVP (refer to Definition 3.1 and Reference 2.2). Comments on the NNECo response will be documentec on the DR form.
5.4.3 A copy of the proposed correctiw action will be sent to the Originator after approval.
"d MILLSTONE UNIT 2 ICAVP PP-07 E
PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS REVISION: 4 DATE: 09/12/97 PAGE 8 OF 12 5.4.4 The ICAVP Group Leader will forward the DR to the Deputy Project Director for review, prior to releasing the comments per Reference 2.3.
5.4.5 All DR's will be fonvarded to TAG. TAG is required to conunent on all Significance Level 1,2 and 3 DR's.
5.4.6 After comment resolution, the ICAVP Project Director ipprove the DR and forward it to NNECo, NEAC, and the NRC per the Communications Plan (Reference 2.3).
5.4.7 A summary of the NNECo response and ICAVP review of the NNECo corrective action (s) will be posted on the WWW in accordance with the Communications Plan (PLN-02) l Reference 2.3).
5.5 FINAL RESOLUTION 5.4.1 If the proposed corrective action by NNECo will resolve the Discrepancy, the Deputy Project Director will close the DR by signing the Final Resolution section.
5.4.2 If, in the opinion of the ICAVP Team, the proposed corrective action by NhECo is not likely to resolve the Discrepancy, the Deputy Project Director will identify the DR as an open itein.
d MILLSTONE UNIT 2 ICAVP PP-07
'J.
PROJECT PROCEDURES TIT (E:
DISCREPANCY REPORTS - ATTACHMENT 1 l
DATE: 07/29/97 PAGE 9 OF 12 REVISION: 3 ATTACilMENT 1 - DISCREPANCY REPORT PARSONS POWER GROUP INC, 2675 Morganton n Road, Reading, PA 19607 ICAVP MILLSTONE UNIT 2
(oi sss2m. mn6ioi sss2m DISCREPANCY REPORT DR NUMBER: DR XXXX DR TITLE:
REVISION:
ISSilE DATE: XX/XMX ORIGINATING GROUP:
SENIFICANCE LEVE12 DISCREPANCY Originator Group Date EVALUATION O BASIS VALID 0 BASIS INVALID - CLOSED D PREVIOUSLY IDENTIFIED BY NNECo - CLOSED Group Lead Date
N MILLSTONE UNIT 2 ICAVP PP-07 E
PROJECT PROCEDURES TITI.E:
DISCREPANCY REPORTS - ATTACHMENT 1 REVISION: 3 DATE: 07/29/97 PAGE 10 OF 12 ItEVIEW AND APPitOVAI, Resiewed:
Deputy Project Director Date Approsed:
Project Director Date Forwarded to NNECo, NEAC, andNRC:
Posted to WWW:
Date Date
SUMMARY
OF NNECo PROPOSED CORRECTIVE ACTION COMMENT ON NNECo RESPONSE Prepared:
Group lead Date Reviewed:
Deputy Project Director Date Approved:
Project Director Date Forwarded to NNECo, NEAC, and NRC:
Posted to WWW:
FINAL RESOLUTION Deputy Project Director Date
ED MILLSTONE UNIT 2 ICAVP PP-07 M
PROJECT PROCEDURES
- TITLE:
DISCREPANCY IrEPORTS - ATTACHMENT 2 REVISION: 3 DATE: 07/29/97 PAGE 11 OF 12 ATTACIIMENT 2 CRITERIA FOR CATEGORIZING Tile RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED BY Tile ICAVP SIGNIFICANCE LEVEL 1 e
A discrepancy"'that identifies that the system does not meet its licensing and design bases and cannot perform its intended function, i.e., has the potential to simultaneously affect redundant trains.
SIGNIFICANCE LEVEL 2 A discrepancy (Dthat 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 (0that 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 (0that identifies that the systems meet its licensing and design bases, however, there exists minor errors such as minor arithmetic errors that do not a
significantly atTect the results of a calculation or inconsistencies between documents of an editorial nature.
(O A dires epancy ir sy identify programmatic, procedural, or design issues or editorial inconsistencies.
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MILLSTONE UNIT 2 ICAVP PP-07 an E
PROJECT PROCEDURES TITLE:
DISCREPANCY REPORTS - EXHIBIT 1 REVISION: 4 DATE: 09/12/97 PAGE 12 OF 12 EXillHIT I EVALUATION OF DISCREPANCIES P P-0 7
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