ML20211B711
| ML20211B711 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/24/1997 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML20211B685 | List: |
| References | |
| PP-03, PP-3, NUDOCS 9709250309 | |
| Download: ML20211B711 (35) | |
Text
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PARSONS PP-03 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES
Title:
Process Review, CMP Horizontal Silce REVISION 3
[ def 4.t m
Date:
9 /7 Prepared by:
l V
9/s2.//97 Approved by:
Date:
1-nager, Company Quaiify Program Approvea by:
d>x An Date:
Sf f S Project Director p
REVISION HISTORY REVISION DATE REVISION DESCRIPTION 0
04/03/97 Procedure Initiation 1
06/09/97 incorporation of NRC Comments 2
06/26/97 incorporation of NRC Comments 3
09/22/97 incorporation of Sample Plan Approved by NRC O
hD DO K 05 0 336 P
MILLSTONE UNIT 2 ICAVP pp.03 g
m PROJECT PROCEDURES
> PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SUCE l
REVISION: 3 DATE: 09/22/97 PAGE 2 OF 18 LIST OF EFFECTIVE PAGES PaneNo.
Revision No.
All pages 3
TAllLE OF CONTENTS 1.0 PURPOSE.........................................................................................3 2.0 DEFINITIONS.......................................................................................................................3 J. 0 P R E R E Q U I S I T ES.........................
.................... 5 4.0 PROCEDURE..............................................................................................................5 Ovi nvnw;
.5 GinnAL Paoci.ss CONTRots:
7 4.1 GATilER DATA AND DEFINE TliE MODEL STRUCTURE..
.7 l
4.2 PREPARE Tile Cl!ANGE PROCESS MODEL..
. I1 l(
4.3 PROVIDE INPUT TO Tile SYSTEM REVIEW PREPARATION....
.12 4.4 f, ELECT Tile CMP llORIZONTAL SLICE SAMPLE.
. 13 4.5 PERTORM TifE CMP If 0RIZONTAL SLICE REVIEW.
, 15 4.6 CllOOSE ADDITIONAL SAMPLES..
.16 4.7 PREPARE REPORT.
.17
5.0 REFERENCES
........................................................................................................I8 ATTACllMENT A ATTACllMENT II ATTACilMENT C l
l l p t
I MILLSTONE UNIT 2 ICAVP pp.03 g
PROJECT PROCEDURES g
> PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 3 DATE: 09/22/97 PAGE 3 OF 18 l
1.0 PURPOSE This portion of the ICAVP will verify the adequacy of the Millstone Unit 2 Configuration Management Plan, (CMP) to identify and correct design and configuration management
)
deficiencies associated with past change processes. His review is a "out come" based comparison of the current conditions versus the current design and licensing basis. It is not an evaluation of change processes used in the past, and this review will not evaluate the adequacy of current processes to maintain configuration management. The review's horizontal slice across change processes will support an independent determination of whether Millstone Unit 2 currently meets its design and licensing bases, in accordance with NRC direction, a review to determine whether Millstone Unit 2 processes and procedures have been estabushed for effective configuration management on a going forward basis will be addressed by others and is not included in this review.
2.0 DEFINITIONS Dgsigoynes (DHL nat informa' ion 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. Thesc values may be (1) restraints derived from generally accepted state-of-the-art practices for achieving functional goals or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals.'
Licsmi_rigiksis_(M1 The licensing basis for Millstone Unit 2 consists of that set ofinformation upon which the Commission, in issuing an initial operating license, based its comprehensive determination that the design, construction, and proposed operation of the facility satisfied the Commission's requirements and provided reasonable assurance of adequate protection to public health and safety and common defense and security.'
- $curce: NRC Letter of October 9,19% On Maintaining Plant Design l
MILLSTONE UNIT 2 ICAVP pp.03 g
m PROJECT PROCEDURES
> PARSONS
()
TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REVISION: 3 DATE: 09/22/97 PAGE 4 OF 18 Current Lierruing Basis (CLBt The set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring 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 in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,26,30,40,50,51,54,55,70,72,73,100 and appendices thereto; orders, license conditions; exemptions; and technical specifications. It also includes the plant specific design-basis information defmed iri 10 CFR 50.2 as documented in the most recent fmal safety analysis report (FSAR) as required by 10 CFR 50.71 cnd the licensing correspondence such as licensec responses to NRC Bulletins, generic letters, and enforcement actions, as well as licensee conunitments documented in NRC safety evaluations or licensee event reports.'
E0ainting_DnignEnes EDB):
The set of design constraints that are not included in the Licensing Basis but are implemented to achieve certain economics of operation, maintenance, procurement, installation, or construction.
Such as:
Information which describes a system, structure, or component Operating values o parameters which are not reference bounds for design Infonnation which identifies functions important for economic, maintenance, installation, e
or other non safety function of dcsign basis systems, structures, or components Information and operating values describing the functions of non-safety systems e
Calculations, descriptions, and other " outputs" e
l
MILLSTONE UNIT 2 ICAVP PP-03 g
m PROJECT PROCEDURES
> PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 3 DATE: 09/22/97 PAGE 5 OF 18 l
3.0 PREREQUISITES 1.
Process modeling PC network and software installed and tested.
2.
Tier I, SVSR Generic Checklist prepared prior to beginning procedure Section 4.5,
" Perform the ChtP llorir.ontal Slice Review".
4.0 PROCEDURE Overview:
His effort will verify the adequacy of the hiillstone Unit 2 Ch1P to identify and correct deficiencies associated with past change processes, examples of past changes are to be reviewed.
This is a technical review of changes to the facility design or change of the characteristics, prxedures, or practices for maintaining, operating, testing, and training on safety or risk significant systems, structures and components to determine if:
O 1
(1) the changes to the plant conditions meet the current design and licensing basis documentation, (2) design and plant information contained in databases and documents are accurate and consi:: tent with the plant, (3) the design and licensing basis requirements have been translated into operating, maintenance, and testing procedures, (4) the performance of systems / components has been verified through testing, and
($) Ch1P corrective actions have adequately identified a corrective action for the deficiency associated with the examples of past change: selected for review.
The review looks at the results of various change processes within change control, document control, information management, and assessment and equipment monitoring. It compares the results of various change processes against design and licensing bases, and physically verifies some of the resuP.s against actual plant configuration.
- O
'g MILLSTONE UNIT 2 ICAVP PP-03 PROJECT PROCEDURES s PARSONS q
TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REVISION: 3 DATE: 09/22/97 PAGE 6 OF 18 In preparation fCr performing the CMP Horizontal Slice Review and the System Vertical Slice Review identified in PP-01, NNECo procedures are reviewed and a process mode; prepared to identify how various changes are performed and controlled, the organizations involved, titles of various documents, and where documents and information can be found. This is done to efficiently and consistently familiarize the ICAVP team members with what they will be reviewing and the organizations and documents they will need to consider.
Exhibit I is an illustrative summary of the Tier 3 Process.
a$
lier 3 Process Summary k
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c" NhlCo Proced#ei, L
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tier 1 hsoedinn Renunt.
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Sample Customge Revew J Conduct CMP
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O Select Review m
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"cw won bnce Checkhst fg Sample See NRC Review
__________________________________________911' E
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MILLSTONE UNIT 2 ICAVP pp.03 wj m
PROJECT PROCEDURES
> PARSONS Q
TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 3 DATE: 09/22/97 PAGE 7 OF 18 Global Process Controls:
Communications with NNECo and the NRC are controlled through the Millstone Unit 2 ICAVP Communication Plan.
Project administration items are controlled through the Millstone Unit 2 ICAVP Project Administration Manual (PAM)
Team members will document the review on inspection area checklists. The team's documentation should be such that a qualified individual could trace the inspection results back to the documents used.
4.1 GATilER DATA AND DEFINE Tile MODEL STRUCTURE Resources l
Group Lead Process Model Lead Process Model Software PC Action 4.1.1 Identify and obtain documents that provide descriptions of:
1) programs, processes, and controlling procedures and policy used to change the facility design or change the characteristics, procedures, or practices for maintaining, operating, testing, and training on safety or risk significant s) stems, structures, and components, 2) interfacing processes that can impact the licensing and engineering design basis l
documents, 3) organizational structures that perform the process actitities and, d
4) the information systems that support the process actisities.
l
MILLSTONE UNIT 2 ICAVP pp.03 g
he PROJECT PROCEDURES
> PA RSONS
+O/
TITLE:
PROCESS REVIEW, CMP HORIZONTAL SUCE V
REVISION: 3 DATE: 09/22/97 PAGE 8 OF 18 The documents needed may address:
Change Control-Plant Eauipment/ Structures Major and Minor plant modifications e
Post modifi ation installation testing e
Control and incorporation of field changes e
Jumper, lified lead, and bypass control e
Set point changes Temporary oi Emergency Changes e
EWR with use as is disposition Design control including Design inputs, design development, resiew/ approval identification and evaluation of cumulative efTects e
electricalloads p
e heat loads V
e e structural loads hydraulics e
Verification / tracking of design assumptions to closurc e
Process for determining if an actisity is maintenance or a modification.
e Procurement and control of equipment for modificatioiu, Evaluation, procurement and control of replacement and spare parts e
Commercial grade parts ocdication e
Equipinent/part equivalency and substitution e
Change Control - Design, License, Procedure Documents Design and licensing document change control e
Specification preparation and revisian e
Drawing revision not associated with a Modification Development and change control of plant maintenance and operations procedures Ir.?crface with design modifications e
Maintenance and Operations initiated changes not associated with an equipment e
modification Development of Design Basis Document (s)(DBD) a f
i l
\\
e Vendor manual ugiate/ changes 1
1
l MILLSTONE UNIT 2 ICAVP pp.03 g
su PROJECT PROCEDURES
- PARSONS Q
TITLE:
PROCESS REYlEW, CMP HORIZONTAL SUCE l
REVISION: 3 DATE: 09/22/97 PAGE 9 OF fB Information and Records Management
- Document Control Drawing control e
Control room drawing updates e
Tracking and identification ofin progress or planned changes e
Engineering design scftware changes e
Information Systems sonware design chang:s e
Database information change control Assessment and Equipment Monitoring Surveillance testing ISI/IST, ASME Section XI repair and replacement NCR with use as is disposition e
O V
4.1.2 Establish a list of the various changes and change control procedures that the team experience indicates should be considered for the initial process model. The list is to include a procedure title, the procedure identification number, date, and resision.
NOTE Generic information can be bulk loaded into the modeling sonware as documentation is obtained on the utilities' procedures, organizational structure, and information systems. For example:
Organization / resource titles e
Information system titles, i.e. databases, work flow systems, etc.
e Process controls, i.e. procedure titles and numbers, regulations, etc.
Bulk loading data prior to starting the model development, helps to ensure uniform usage of data information in the model and reduces model cleanup later.
O V
MILLSTONE UNIT 2 ICAVP pp.03 g
m PROJECT PROCEDURES
> PARSONS
\\
TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REVISION: 3 DATE: 09/22/97 PAGE 10 OF 18 4,1.3 Review the utility's configuration management program documentation to obtain an understanding of; the orpnizations that assess the conditions and decide whether change processes e
need to be implemented.
the procedures used to control these changes.
e the organizations that perform the changes.
e 4.1.4 Develop the initial model structure. Based on the review of the utility's documentation and the experience of the Process Model Lead, decide on a ir.itial model structure that will communicate how various Millstone Unit 2 changes are performed and controlled, the organizations involved, titles of various documents, and where documents and information O
can be found.
Action Output List of the various changes and change control procedures Bulk loaded proccus data Process documentation to be used in developing the model
MILLSTONE UNIT 2 ICAVP PP-03 g
em PROJECT PROCEDURES
- PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REV!SION: 3 DATE: 09/22/97 PAGE 11 OF 18 4.2 PREPARE Tile CilANGE PROCESS MODEL NOTE The initial process model will serve as input to preparation efforts for the CMP Hori7ontal Slice Resiew and the System E.tical Slice Resiew (SVSR) to help familiarize the team on where design and licensing basis information can be found, the kinds of documentation produced by hiillstone Unit 2, the organization (s) responsible for various parts of the change process, and a general underv.anding of the kinds of change processes that edst at Millstone Unit 2.
En2urces Group lead, (Tier I&3)
Process Model Lead Process Modeler(s)
Process Model Software PC Action 4.2.1 Prepare the process model based on the utility's procedure documents and the model structure identified by the level 0 diagunt The model is expected to be one or two levels of decomposition illustrating the process at a high level. The model should communicate how various Millstone Unit 2 changes are performed and controlled, the organizations involved, titles of various documents, and where documents and information can be found.
The Tier I and Tier 3 Group Leads are to specify which procedures to be included in the initial model based on the need to prepare significant numbers ofindisiduals for conducting the Millstone Unit 2 ICAVP reviews. For example, a procedure will not be included in the model if only one or two individuals need to become familiar with it. One or two people can simply read the procedure and there is no need to prepare a model for w./
cfficient and consistent communication.
By reviewing the utility's procedures the Process Modeler will attempt to identify and
=_
MILLSTONE UNIT 2 ICAVP pp.03 g
m PROJECT PROCEDURES
> PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SUCE l
REVISION: 3 DATE: 09/22/97 PAGE 12 OF 18 diagram the following information with a 4-dimensional modeling technique:
Activities - a description of the work step.
People, Tools, and liardware/ Software Supports - people (job title) and things used to perform the actisities.
Information/ Product Flow information and documents that input to an actisity e
and the output as the result of the activity. This includes forms, reports, design documents, test results, data sources, data storage, etc.
Controls - those things that specify when an actisity is performed, how it is to be e
performed, or the acceptable quality level. Typical controls include regulations, quality assurance requirements, industry standards, procedure:., company goals, management directives, best practices, corporate culture, experience, etc.
l O l
4.2.2 The source of the information used to develop the models is to be documented as part of the model, including title, identifying numbers, and revision, or date.
4.2.5 The model should identify unclear information, or areas of potential concern regarding what the procedure may produce. This information is an indicator of areas that the ICAVP team members should be aware of uhile perfomiing their reviews.
r l
l Action Output hiillstone Unit 2 Change Process Model 4.3 PROVIDE INPUT TO Tile SYSTEM REVIEW PREPARATION Besources
(
l Process Model Lead l
Process Modeler(s)
Process Model Software f)
PC v
l l
MILLSTONE UNIT 2 ICAVP pp.03 g
m PROJECT PROCEDURES
> PARSONS gQ TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REVISION: 3 DATE: 09/22/97 PAGE 13 OF 18 Action 4.3i Pro ide input to preparation efTorts for the System Vertical Slice Review (SVSR) to help j
familiarize the teams with:
the kinds of change processes that exist at Millstone Unit 2, where design and licensing basis information can be found, the information systems used and its data base (s).
e the kind of documentation that should exist on past change actisities, the organization responsible for various parts of the change process.
e This information will be conveyed to the System Review teams through use of the process models, and verbal transfer of process experience gained during the modeling efTort.
4.3.2 Provide input to the SVSR teams on unclear information, or areas of potential concern regarding what the procedure may produce.
m Action Output Transfer of information to the System Review teams to be used in preparation for conducting their technical reviews.
4,4 SELECT Tile CMP IIORIZONTAL SLICE SAMPLE l
Examples of Millstone Unit 2 past changes to facility design, documentation, and information systems and examples of current procedures and data will be se:ected for review. The resiew is a l
horizontal slice across systems not selected for the ICAVP vertical slice.
Attachment A, S:unple Identification For Tier 3 Process Review contains the sample identification and sample specification that is to be used in selecting and obtaining the items for review NOTE l
l l
Re NNECo CMP system reviews are being completed in 2 batches. He ICAVP Tier 3 process l
review will conduct sampling and evaluation in two phases. Phase I will select examples from the first CMP completed batch of systems. Phase 2 will select examples from the second CMP completed batch of systems. His will ensure the sampling population includes CMP systems from both batches. Attachment A identifies the total sample size for the combination of phase I and 2.
MILLSTONE UNIT 2 ICAVP PP-03 g
m PROJECT PROCEDURES
> PARSONS
(]
TITLE:
PROCESS REVIEW, CMP HORIZONTAL SUCE l
REVISION: 3 DATE: 09/22/97 PAGE 14 OF 18 Resources Group Lead Technical Resiewers Project Management Action 4.4.1 Only CMP scope systems are to be considered for the sample. He sample for the CMP llorizontal Slice Review will consist of change examples outside of the selected ICAVP systems for the System Vertical Slice Review (SVSR).
4.4.2 The sample is to be selected based on the personnel experience of the review team of where problems may be encountered, past industry typical problem areas, and the following criteria:
Cross section of age - To.nsure the review includes changes produced under 3
! (Q different revisions of procedures, the selected review sample will, where possible, consist of examples that span the period since the plant began commercial operation on August 1,1975. Examples will be selected from four time periods of approximately five year intervals.
Cross section of discipline - experience indicates that different organizations or l
groups within an organization utilize different processes for the same procedures. Therefore, the selected review sample will consist of examples from different engineering disciplines, (e.g. Mechanical, Electrical, I&C and Civil /
Structural) or different plant groups, (e.g. Operation and Maintenance departments.
Cross section of types - of quipment, procedures, or documents as applicable.
4.4.3 Based on the requirements of Attachment A, choose and obtain samples for review, Action Output
(]
CMP Horizontal Review sample V
MILLSTONE UNIT 2 ICAVP PP-03 gj m
PROJECT PROCEDURES
-PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REVISION: 3 DATE: 9/22/97 PAGE 15 OF 18 4.5 PERFORM Tile CMP llORIZONTAL SLICE REVIEW Resources Group Lead Technical Leads Technical Resiewers NOTE The ir. tent of the CMP llorizontal Slice Review is not an evaluation of change procedures used in the past, but rather a review to determine the effectiveness of the Millstone Unit 2 CMP to identify and correct design or licensing basis deficiencies that may have rgsjttd from the ineffectiveness of past change processes. His is a "out-come" based comparison of the current conditions versus the current design and licensing basis.
Th
, ection will be performed on a sample of past changes to facility design, documentation, O
and information systems and examples of current procedures and data. He resiew will look for:
unrecognized ma.lifications to the plant departures from the plant licensing or design basis documents e
acceptable documentation of the results of the change and its basis.
e Action 4.5.1 The Review Team prepares a specific review checklist for each inspection area by drawing from the applicable SYSR generic checklists, the SVSR Source 13ook of Additional Requirements, and professional experience.
4.5.2 in accordance with Attachment B, Tier 3 Review Package Checklist Guidance and Attachment C, Tier 3 Review Package Traveler, review documentation and perform walkdowns as necessary to determine if plant configuration has been properly maintained.
4.5.3.
Obtain NNECo CMP findings / corrective acthns oxuments associated with the areas of inspection.
OV 4.5.4 Reviewers will document conferences with NNECo personncl in accordance with the Communications Plan.
MILLSTONE UNIT 2 ICAVP PP-03 g
lm PROJECT PROCEDURES
> PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REVISION: 3 DATE: 9/22/07 PAGE 16 OF 18 4.5.5 As working questions are identified during the rniew, they are to be documented for further investigation.
4.5.6 Working questions are to be fc!! owed up to determine that either 1) upon obtaining further j
information, no problem exists, or 2) it is a discrepancy with a documented basis, or 3) it can not be resolved at this time.
4.5.7' Discrepar.cies are to be communicated to management for evaluation "d distribution in accordance with procedure PP-07c s
Action Output
[
CMP Horizontal Review result:.
CMP llorizontal Review doctimentation 4.6 CllOOSE ADDITIONAL SAMPLES Resources Group Lead Technical lead Technical Reviewers P oject Management Action 4.6.1 If the CMP Horizontal Slice Re view discovers valid discrepancies, the NRC may request an expansion of the inspection sample. The sample may be expanded when it will fa:ilitate determination of whether a valid discrepancy is an isolated mistake or i.; an indication of a systematic problem.
4.6.2 If the decision is a increase the sample size return to step 4.4 to select specific change p
items to be added to the CMP Horizontal Slice Rev.ew and proceed to perform the O
addition:d reviews.
r
(
g MILLSTONE UNIT 2 ICAVP PP-03 l
5 PROJECT PROCEDURES
> PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SLICE l
REVISION: 3 DATE: 9/22/97 PAGE 17 OF 18 Action Output increased sample size 4,7 PREPARE REPORT Resources Group Lead Technical Lead (s)
Technical Reviewen PC Action O-4.7.1 Collect the results and prepare a report for each change process inspwtion area.
4.7.2 Prepare a final report of the Tier 3 activities and conc!usions. The report is to consist of, as a minimum:
input to an executive summary a summary description of the methods used a summary of the CMP Horizontal Slice Review results including:
e identification of the examples selected for review review results for each of the inspection areas identification of any discrepancies e
corrective action reviev wults
=
4.7.3 Support internal ICAVP reviews as necessary.
O,w 4.7.4 Review and comment as needed on NNECo response to Discrepancy Reports l
l
MILLSTONE UNIT 2 ICAVP pp.03
'.j m
PROJECT PROCEDURES
> PARSONS TITLE:
PROCESS REVIEW, CMP HORIZONTAL SUCE l
REVISION: 3 DATE: 9/22/97 PAGE 18 OF 18 4.7.5 Resolve comments and finalize the report for issue.
Action Output riaal Report Project backup documentation
5.0 REFERENCES
" Guide For Operational Configuration Management Program", DOE-STD-1073 93 O
P O
1 l
/
O PARSONS POWER PP-03 ATTACIIMENT A SAMPLE IDENTIFICATION FOR TIER 3 PROCESS REVIEW Q
Millstone Unit 2 ICAVP O
l l
l l p TABLE OF CONTENTS ts
- 1. INTRODUCT10N 3
1.1. CONnOURADON MANAGEMENT PRINCIPLES.
.3 1.2. INSPIITION ARTAS.
.4 1.3. SAMPLE SPECinCATION/lDENTIDCATION.
.5
- 2. E NG IN E E RIN G
.. 6 2.1. SETPOINT CilANGES..
.7 2.2. SPECinCATION REVIStON (NOT ASSOCIATED %TTH A MODIDCADON)..
.7 2.3. DRAWING REVISIONS, (NOT ASSOCIATED %TUI A MODinCAT10N)..
.7 2.4. CA!IULATIONS REVISIONS (NOT ASSOCIADD Wml A MODIRCATION)..
.8 2.5. LICENSINO DOCLNENT CHANGES.
.8 2.6. NON-CONFORMANCE REPORT ( USE AS IS).
.9 2.7. ENOrNEERING WORK REQUEST..
.9 2.8. VENDOR TECIINICAL INFORMATION UPDATES.
.9
- 3. PARTS PROCUREMENT / SUPPLY...
10 3.1. COMMERCIAL GRADE DEDICATION.
.10 3.2. EQUIVALENCY SUNS 1TnrnON..
. 10 3.3. MASTER EQUIPMENT PARTS LIST (Melt)..
.10
- 4. OPERATIONS & M AINTENANCE. _.
.. I1 4.1. PROCEDURE SAMPLE SELECEON.,
.I1 4.2. ASME SECTION XI REPAIR AND REPLACEMENT.,
.13 4.3. TEMPORARY CIIANGES. INCLUDINO JUMPER. LIFTED LEAD. AND BYPASS CONTROL..
. 13 4.4. CMEROENCY CllANGES.
, 14 O
D
- PAR 88N8POURR -
PP-03, Attachment A Revision 3 Page 2 of 14
,G 1.
INTRODUCTION b
By samp!ing past changes to the plant or design documents, Tier 3 of the Millstone Unit 2 ICAVP will verify the adequacy of the Millstone Unit 2 Configuration Management Plan,(CMP) to identify and correct design and configuration management deficiencies. This document identifies the sample for the review and its basis for each l
l of the inspection areas, 1.1.
Configuration Management Principles Configuration Management, (CM) is the effective control of a facility's as-built configuration and operation to ensure compliance with approved and/or accepted technical requir-~ 4ts and governing criteria in order to meet safety and operating goals.
The classical principles of CM are Identification, Control, Verification, and Status Accounting:
Identification / Baseline - This includes both the selection of the iterns, (structures, systems, components, and computer software) that will be subject to CM, and selection of the documentation which describes its functional and physical characteristics.
Ci U
Change Control - The process by which changes to the configuration items are accomplished.
This includes approval of changes, revision to documentation when the change implementation is complete, and document revision distribution.
Verification - The substantiation that:
- configuration clumges either satisfy the original design requirements or comply with approved revisions to those requirements, or
- the resultant configuration changes are completcd and in compliance with the approved chage.
This principle also includes resolution of conflicts between documents and actual field conditions.
Status Accounting - This addresses the tracking and reporting of the current configuration items and any in-process changes thereto.
3(V
- mininws -
PP-03, Attachment A Revision 3
]
Page 3 of 14
1.2.
Inspection Areas implementation of the above principles of CM is typically the responsibility of functional areas such as Engineering Operations & Maintenance, and Parts P ocurement/ Supply. The Tier 3 inspections will look at the results of change processes in each of these three functional areas to determine the adequacy of the Millstone Unit 2 Configuration Management Plan,(CMP) to identify and correct design and confcuration management deficiencies.
To accomplish the objective of the Tier 3 inspection, specific inspection areas have been identified for review as noted below:
ENGINEERING
- 1) Setpoint changes
- 2) Specification Revision (not associated with a modification)
- 3) Drawing Revisions (not associated with a modification)
- 4) Calculations Revisions (not associated with a modification)
- 5) Licensing Document Changes
- 6) Non-Conformance Report (use as is)
- 7) Engineering Work Request
- 8) Vendor Technical Information Updates PARTS PROCUREMENT / SUPPLY
- 2) Equivalency Substitution
- 3) Master Equipment Parts List (MEPL)
OPERATIONS & MAINTENANCE
- 1) Revisions to Operations & Maintenance Procedures
- 2) ISI/IST, ASME Section XI Repair and Replacement
- 3) Temporary Changes, including jumper, lifted lead, and bypass control
- 4) Emergency changes The infomtation in this document is organized by functional area and associated inspection areas.
Exhibit 1 is a summary of the number ofitems contained in the Tier 3 sample.
A(V 1
- rasen rown -
PP-03, Attachment A Revision 3 Page 4 of 14
I G
Ethibit 1 - Summary of Sample l Inspection Area Sample Number l
Engineering /Licens!ng Documents Setpoint Changes 80 Specification Rnisions 32 Drawing Rnisions 32 Calculation Roisions 64 Licensing Document Changes 25 Non conformance Reports,(NCR) 32 Engineering Work Request, (EWR) 32 Vendor TechnicalInformation 12 vendor manuals Paris Procurement, Substitution, Dedication Commercial Graue Dedications 32 Equivalency Substitutions 32 Master Equipment Parts Lists 32 Operations and Maintenance Rnisions to Procedures 70 procedure changes ASME Section XI Repair / Replacement 20 Temporary Changes / Jumper, Lilled Leat Bypass 25 Emergency Changes No ocoulation has been identified.
TOTAL 520 1.3.
Sample Specification / Identification Based on the r. ample specification identified in this document, Parsons will select Millstone Unit 2 documents and data and perform its rniew in accordance with procedure PP-03.
Sever d of the inspection area samples will be comprised of changes representing a cross sectica of time frames when the change occurred. Four time periods of approMmately 5 year since 1975 will be used as follows:
1.
1975-1981 2.
1982 1986 3.
1987-1991 4.
1992-1997 Note: If examples do not exist or ate not retrievable for a particular time period, additional samples from other time periods do not need to be selected to maintain the tatal sample size for the inspection area. An increase in sample size of a particular area will be considered by the NRC based on the review of the initial sample.
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PP-03, Attachment A Revision 3 j
Page 5 of 14 l
(N Since 1975 many of the Millstone processes have changed names. This document identifies the change processes based on the current information available. Should further imestigation identify different or additional names for the same type of change process, the Tier 3 sample will include those items.
When selecting a sample, the following criteria will apply to all of the inspection areas:
Select iter ~ categorized as Safety Related and/or Risk Significant.
Select from systems not chosen for Tier i review.
SSm items within the systems completed by NNECo, (if applicable).
Select changes that have technical significance, e.g., do not select trisial, or editorial changes.
Experience with past industry problem areas, and/or vendors will be used when selecting between specific items that meet the above criteria.
When possible, select items which complement Tier 1 or Tier 2 inspections and will proside a more complete imestigation.
Since the CMP system reviews are being completed by NNECo in 2 batches, the ICAVP Tier 3 process review will conduct sampling and evaluation in two phases. Phase I aill select examples from the first CMP completed batch of systems. Phase 2 will select examples from the second CMP completed batch of systems. This will ensure the sampling population includes CMP systems from both batches. This
(
document identifies the total sample size for Se combination of both Phase 1 and 2
(
Choose samples for each of the review areas below. The number of sample selected and obtaine.d may exceed the sample size identified below in order to ensure enough non-trivial samples are available for review.
2.
ENGINEERING The Engineering functional area portion of the Tier 3 process review will inspect the following:
Setpoint changes Specification Revisions (not associated with a modification) e Drawing Revisions (not associated with a modification)
Calculations Revisions (not associated with a modification) e Licensing Document Changes e
Non-Conformance Reports (use as is) e Engineering Work Requests e
Vendor Technical Information Updates e
O.
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PP-03, Attachment A Revision 3 Page 6 of 14
p Tier 3 will review specification revisions, drawing revisions, and calculations revisions not associated with a modification to the physical plant. A review of modifications and the changes to engineering documents associated with a modification is part of the Tier I scope of work.
2.1, Setpoint changes Sample Identification - Unit 2 setpoint changes have been controlled by several processes. Initially they were controlled by PDCR (a plant modification process), then by procedure NGP 3.16, and now by DCR (a plant modification process). Various departments (approximately 10) control setpoints as identified by NNECo Specification SP ST-EE-329. The various departments control different types of setpoints.
Examples of setpoints from each department will be selected. The procedures for changing setpoints has changed over time, so exampics will be selected from different time periods.
Sample Specification - The Setpoint Change Record (SCR) log, and design modification logs, (PDCR and DCR) will be reviewed in order to select the sample.
Sample - Two (2) setpoint changes for each of the current controlling depattments wil.1 be selected for the four 5 year pesiods since 1975. Total sample si:e is 80 setpoint changes.
O 2.2.
Specification Revisions (not associated with a modification)
Q Sample Identification Specifications are controlled by the engineering disciplines, Mechanical, Electrical,1 & C, and Cisil/ Structural. Specifications in each discipline are further disided into Standard Design Specifications and Project Specific Specifications. Examples will be selected for each discipline for both specification types, over different time periods with a cross section of specifications generated by NNECo, the NSSS vendor, and the original plant design AE.
Sample Specification - Specification changes will be identified through the change control document process, primarily the Design Change Notice (DCN).
Sample Two (2) specifications from each controlling disc;pline, (one Project Specific specifications and one Design Standard specifications) for the four 5 year periods. Totalsample size is 32 specifications.
2.3.
Drawing Revisions,(not associated with a modification)
Sample Identification - Drawings are controlled by the engineering disciplines, Mechanical, Electrical, I & C, and Cisil/ Structural. Examples will be selected for each discipline over different time periods. The sample will look for a cross section of drawing types within each discipline including upper tier drawings, I
(P&lD, electrical one line, etc.) and lower tier drawings, (isometrics, terminal connections, etc.) Drawing l
(_}
- PAA8058 P9WER -
PP-03, Attachment A I
Revision 3 Page 7 of 14
revisions have been implemented through Design Change Notices (DCN), and Vault Drawing Changes i
I V
(VDC).
Sampic Specification Changes to design drawings will be reviewed through the change control document process, primarily the Design Change Notice (DCN), Vault Drawing Changes (VDC), and Drawing Discrepancy Information Sheets, etc.,
Sample - Two (2) drawing change documents from each controlling discipline, for the four 5 year periods.
Total sample st:e is 32 drawing change documents.
2.4.
Calculations Revisions (not associated with a modification)
Sample Identification - Calculations are controlled by the engineering disciplines, Mechanical, Electrical, I & C, and Civil / Structural. Calculation revisions could be generated by NNECo or a Vendor. Examples will be selec'ed for each discipline for both NNECo or a Vendor generated change, over different time periods.
Sample Specification The calculation examples chosen will be based on apparent complexity of the change and selected from Calculation Change Notices, (CCN's) as tracked by the Calculation Tracking Program (CTP), or other revision lists.
's Sample - Two (2) NNECo generated calculation resisions from each controlling discipline for the four 5 year periods, and two (2) discipline vendor calculation revisions for the four 5 year periods. Total sample st:e is 64 calculation revisions.
2.5.
Licensing Document Changes Sample Identification FSAR changes, Technical Specification changes, and License Amendments make up the ppulation for this area. Both Technical Specification changes and License Amendments receive detailed NRC review. Therefore the ICAVP re.iew will concentrate on FSAR Changes.
Sample Specification - Select examples from FSAR Change Requests and Technical Specification Chan;e Request. Select examples from difTerent sections or chapters of the documcats.
Sample - Five (5) FSAR changes, for the four 5 year periods will be selected. One (1) Technical Specification for the four 5 year periods. Total sample si:e is 25 licensmg documents.
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PP-03, Attachment A Revision 3 Page 8 of 14
i I
p 2.6.
Non-Conformance Reports ( use as is)
V Sample Identification - Non-Confmnance Reports (NCR) are dispositioned tr controlling discipliacs, Mechanical. Electrical, I & C, and Civil / Structural. Examples of significant NCRs will be selected for each discipline over different time periads.
Sampic Specification - Select from NCR dis,nositioned as "use-as-is",
Sample Two NCR from each controlling discipline, for the fout 5 year periods. Totas ample size is 32.
2.7.
Engineering Work Requests Sample Identification - Engineering Work Requests (EWR), previously called Project Authorizations (PA), are responded to by control ling disciplines, Mechanical, Electrical, I & C, and Cisil/ Structural.
Examples will be selected for each discipline over different time periods.
Sampic Specification - EWRs do not have a specific disposition of"use as is" EWRs were not established to be a change control mechanism The focus of the EWR/PA sample will be on EWRs and pas tnat have not been implemented but, ifimplemented, would have addressed recurring problems or minimized operator ivork around.
Sampic - Two (2) EWR/ pas from each controlling discipline, for the four 5 year periods. Totalsample stre is 32 ElmsTAr.
2,8.
Vendor Technical Information Updates Sampic Identification - A sample will be selected from vendor manuals for: key safety-related components identified as part of Millstone Unit 2 response to Generic Letter 90-03, equipment in safety related systems, and equipment in risk significant systems. The sample selection will consider (in a qualitative sense) the associated components contribution to risk and will focus on changes made to the vendor technical manuals to provide additional assurance that these changes do not effect the licensing and design basis of the equipment. This will provide a sample with a good cross section of equipment types.
Sample Specification - Vendor manuals for equipment will be selected based on the following considerations:
eqmpment for which the OEM is no longer in business e
OEM/ supplier components with multiple models e
manuals for equipment skids consisting of a collection of many components e
high use vendor manuals as identified by the number of corrective maintenance work orders e
The w:ndor manual sample will be selected from Non-Tier I systems e
Sample - Ikelve (12) Venc.br manuals will be selected for resiew.
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PP-03, Attachment A Revision 3 Page 9 of 14
V 3.
PARTS PROCUREMENT / SUPPLY The Parts Procurement / Supply functional area portion of the Tier 3 process resiew will inspect the following:
- Conunercial Grade Dedication Equivalency Substitution Master Equipment Parts List (MEPL) 3.1.
Commercial Grade Dedication Sample Identification - A cross section of equipment types and age of the Commercial Grade Dedication package will be included to resiew dedication evaluations performed by different disciplines. Qualification of a commercial grade part for use in a safety related system is accomplished by testing critical characteristics, or a combination of testing and'taking credit for somg portions of a Vendor's quality program. The sample will address both of these cases. Conunercial grade dedication programs started in the late 1980's. The sample will include a cross section of dedication evaluations performed after its implementation at Millstone Unit 2.
Sample Specification - Select from a list oi Commercial Grade Dedication packages or parts.
Sample 32 Samples. A cross section of the four disciplines spanning the time from when a commercial d
grade dedication program was in effect.
3.2.
Equivalency Substitution Sample Identificaden - A cross section of equipment and part types and age of the equivalency evaluation will be included to sample different disciplines and historical processes used in performing the equivalency evaluations.
Sample Specification - Select from a listing of the equivalency evaluations. Currently, the equivalency substitution evaluation is being performed via a item Equivalency Evaluation (LEE). Prior to Nov.1996 LEE's were called RIE's, and prior to 1995 three separate Unit i usts were maintained (PEG, TSE, and PSE).
Sampic - 32 Equivalency &aluations.
3.3.
Master Equipment Parts List (MEPL)
Sample Identification - Safety classification of components and parts are documented in a MEPL Determination. The results of this determination are captured in the Production Maintenance Management System, (PMMS), the primary database for Millstone maintenance activities. This review will focus on the v
PP-03, Attachment A Revision 3 Page 10 of 14
i I
l appropriateness of changes to component classification in regards to tbc requirements of the licensee's
\\
Appendix B Quality Assurance Program, i.e.. changes from Quality ("Q") to Non-Quality ("non Q").
Since the MEPL is a foundation for key configuration management areas, (e.g. procurement, maintenance, etc.) the sample will be selected in order to determine if accurate information is available for these activities.
Sample Specification - Samples of classifications down grades, (i.e. Quality *Q" to Non-Quality "non Q") will be selected from the MEPL change log for review of the MEPL Determination. Samples of classification upgrades,, (i.e. Non-Quality "non Q" to Quality "Q") will be selected from the MEPL change log for review against PMMS quality indicators.
Sample - 32 samples (two each for each of L four disciplines from each of the four time periods.)
4.
OPERATIONS & MAINTENANCE The Operations & Maintenance functional area portion of tl.e Tier 3 process review will inspect the following:
e Resisions to Procedures
- Operation Procedures
- Abnormal Operating Procedures p
- Emergency Operating Procedures V
- Surveillance Procedures
- Insenice Testing Procedures
- Insenice Inspection Procedures
- Maintenance Procedures ASME Section XI Repair and Replacement a
Tempora 5 Changes, including jumper, lifted lead, and bypass control Emergency changes 4.1.
Procedure Sample Selection Sampic Identification - The scope of the review of procedure changes extends back to initial operation.. A review of prior procedure chsnges that have been superseded, (i.e. the change is no longer part of the current procedure) is not necessary. Because it may not be possible to find changes to procedures that date back te initial operations, this will not ce a determining factor in selection. The sample sir.e will be based on the below guidance with a consideration (at least in a qualitative manner) of the risk significance of ti.i procedure. In selecting each of the examples, the engineering judgment of the reviewers will be used to assess change significance. The thorougimess of the review of each change example will be commensurate with its technical significance.
(%
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PP-03, Attachment A Revision 3 Page 11 of 14
l
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Operations Procedures -
A minimum of four operations procedures will be selected and all of the changes to these procedures will be reviewed. The number of procedures reviewed will be increased, as necessary, to ensure at least 10 significant changes are reviewed. (The engineeringjudgment of the Reviewer will be used to assess the significance of a procedure change.)
Abnormal Operating Procedurrs l
A minimum of four abnormal operating procedures will be selected and all of the changes to these procedures will be reviewed. The number of procedures reviewed will be increased, as necessary, to ensure at least 10 significant changes are rniewed. (The engineering judgment of the Reviewer will be used to assess the significance of a procedure change.)
Emergency Operating Procedures -
A minimum of four emergency operating procedures will be selected and all of the changes to these procedures will be neviewed. The number of procedures reviewed will be increased, as necessary, to ensure at least 10 significant changes are reviewed. (The engineering judgment of the Reviewer will be used to assess the significance of a procedure change.)
Surveillance Procedures-(
A minimum of four surveillance procedures will be selected and all of the changes to these procedures will be reviewed. The number of procedures reviewed will be increased, as necessary, to ensure at least 10 significant changes are reviewed. (The engineering judgment of the Reviewer will be used to assess the significance of a procedure change.)
Insenice Testing Procedures -
A minimum of four insenice testing procedures will be selected and all of the changes to these procedures will be reviewed. The number of procedures resiewed will be increased, as necessary, to ensure at least 10 significant changes are reviewed. (The engineeringjudgment of the Resiewer will be used to assess the significance of a procedure changc.)
Inservice inspection Procedures -
A minimum of four insenice inspection procedures will be selected and all of the changes to these procedures will be reviewed. The number of procedures reviewed will be incrcased, as necessary, to ensure at least 10 significant changes are resiewed. (The engineering judgment of the Resiewer will be used to assess the significance of a procedure ch:mge.)
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PP-03, Attachment A j
Revision 3 I
Page 12 of 14
Maintenance Procedures-O' A minimum of four mainterance procedures will be selected and all of the changes to these procedures will be reviewed. The number of procedures reviewed will be increased, as necessary, to ensure at least 10 significant changes are reviewed (The engineering judgment of the Reviewer will be used to assess the significance of a procedure change.)
4.2.
ASME Section XI Repair and Replacement Sample Identification - The Millstone Unit 2 ISI/IST Program complies with the requirements for nuclear power plant components contained in the ASME Boiler and Pressure Vessel Code,Section XI,19R0 Edition up to and including the 1981 Winter Addenda except where relief has been specifically granted by the USNRC. Implementation of the ISI/IST program is controlled by its own set of controls and prdures.
Sampic Specification This review will be directed towards repairs, replacements, and modifications made under the ASME Section XI program. The initial sample will consist of five signincant exampics from each of the identified time periods for components currently installed. The sample will (if possible) include examples cf the following major component types:
e pumps Di e
salves h
piping (including in-line components) e piping supports e
pressure vessels e
Consideration will be given to include examples of code cases, relief, or other deviations from the Section XI requirements Sample - Samples will be obtained from each of the four time periods, for each of the component types for a total of20 examples.
4.3.
Temporary Changes, including jumper, lifted lead, and bypass control Sampic Identification - The sample will encompass temporary changes not controlled by approved work procedures, e.g. instrument calibratka procedures, surveillance test procedures, etc.. The sample will contain a cross section of temporary change types and length of time installed.
The sample will be drawn from the list of safety-related and/or risk-significant systems outside the Tier 1 systems.
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PP-03, Attachment A Revision 3 Page 13 of 14
The samples will be selected from currently installed temporary alterations and from those tlutt have been
\\
removed or made into permanent changes (those that have been closed).
Sample Specification - Use the Jumper Device Index Sheets to identify existing jumpers / temporary changes. In additior. to the sample selected, the resiew will include resiew of any undocumented temporary changes observed during walk downs associated with the ICAVP.
Sample-5 examples of currently installed temporary alterations and 4 examples for each year of the preceding five years for the closed temporary alterations, total sample size of25 temporay altentions.
4.4.
Emergency changes Some nuclear utilities have a special process for emergency changes to procedures that specifies the controls and the organizational positions that can be used in a streamlined process to make changes that can not wait for nonnal processing. No procedure of this type has been identified specific to emergency changes for Millstone Unit 2 different from the normal change processes. Should such a procedure be identified, a sampic plan will be developed.
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PP-03, Attachment A Resision 3 Page 14 of 14
(~'
PP-03 ATTACHMENT B k
TIER 3 Review Package Checklist Guidance General The Review Package is comprised of the ollowing sections-Review Package Traveler Review Sample (s) e Review Checklist Attachment (s) e Re.ference Documents e
ne Tier 3 Review Package Traveler, (Attachment C to PP-03)is used by Tier 3 Reviewers to document package contents, provide a Tier 3 Package Identifier for document control purposes, and to identify the responsible package reviewer. In addition, the review package traveler includes a statement on the final status of the review and a summary of discrepancies, if warranted.
The Tier 3 Review Change Sample (s) are those documents or packages of documents within a Review Area being reviewed for conformance to licensing and design basis requirements.
Review Checklist Attachments includes the checklists, or other docutnentation containing requirements, criteria, and/or questions that the reviewer uses during the review. This attachment documents ihe resiew.
Reference Documents includes information that the review is based on as well as support documentation.
Review Packag;e Traveler The Tier 3 Review Package Traveler is comprised of three parts covering package responsibility, package contents / review results, and review and approval signatures. Each part of the checklist is required to be completed (None or Non-Applicable statements are permitted in Part A and B).
Review Area. Part AI The Reviewer is responsible for specifying the Review Area of the package. Reviews areas are described in PP-03 and represent broad review assignments that may include multiple documents and review objectives within one Change Example. In addition, the Reviewer enters the Tier 3 Package Identifier.
Ikyimy Resoonsibility. Part A2 He Reviewers name and the start date of the review is entered in Section A2 C9!1tattfaatM The identification and selection of review samples will be done in accordance with Attachment A to PP-03.
He Reviewer enters the NNECo identifier and description or title of the sample item. A single Review Package Traveler may be used for multiple sample items within a review area. The NNECo Change Example Identifier is the specific procedure or document to be reviewed.
PAR $858P9WIA PP-03, Attachment B Revision 3 Page 1 of 3 l
G Beview ResultfartR The Reviewer summarizes the overall review results as a function ofidentified discrepancies.
Discrepancies in regards to requirements are noted only. Discrepancy details are handled by PP-07 Sinnatures. Part C The Review Package is Completed by the Reviewer, Reviewed by an indisidual assigned by the Tier 3 Group Lead, and Approved by the Group Lead.
Review Checklist Attachment Clianne Sample Reayirements/ Criteria Lists De reviewer includes as attachments, lists, checklists, or other documentation containing requirements, criteria, and/or ouestions that t e reviewer will use during the review. Review h
requ;rements, criteria, and/or questions will exist as Review Package Attachments and may be developed prior to the commencement of the review or developed after the formal resiew has begun. He attachments may augmented as the review is conducted.
The attachments will nomully be formatted as a series of questions requiring yes, no, or non-applicable determinations. However, the format is at the discretion of the reviewer and may be developed in whatever format necessary to expedite an efficient but thorough resiew. He questions, requirements, and/or criteria may be %wn from the Tier I checklists, the Tier 1 PI-01 Sourcebook, or developed separately by the reviewer.
Walkdos Assignmsnts-Change Examples that require verification of physical plant status will be confirmed by Walkdowns conducted by Tier 3 personnel or site office personnel. Such assignments will be summarimd in Review Package Attachments. Walkdown assignments for validation and/or verification of requirements will also be detaid and explained in the attachment. Walkdowns requested for information pupscs only are not required to be listed.
C9mpSnsntaand Database Rsview Summary Specific components and databases reviewed during the review that play a material role in the determination of the review results are required to be documented in the Resiew Package Attachments.
Conferences Summa.ry Information specific to the Change Example obtained through a conference will uso be summarized in the Review Package Attachments. (All conferences will be conducted in accordance with the IJ WP Communication Plan) f3 O
PAR 5858 POWER PP-03, Attachment B Revision 3 Page 2 of 3 l
Summary Comments The reviewer, at his/her option, may enter comments concerning the review. The Review Package Attachments will afford comments that provide additional information, explain complicated reviews, or provide the detr",s of the Reviewer's professional opinion regarding the resiew.
Reference Documents Documents and/or references used during the review that play a material role in the determination of the review results are itemized on Package Attachments. Copics of references are included in the package at the discretion of the Reviewer.
O O
PM8888 P99fER PP-03, Attachment B Revision 3 Page 3 of 3 l
,O PP-03 ATTACHMENT C TIER 3 Review Package Traveler PART A - Packare Content Tier 3 Package Identifier:
Al - Review Area:
Change Example :
A2 - Review Responsibility l Reviewer: l l Date: l l
A3 - Contents: NNECo Change Examples [ List each example separately]
Document / Package # and Description Document / Package # and Description 11-Review Results O
The results of the review were satisfactory. No discrepancies noted.
The review resulted in discrepancies summarized below and described in the appropriate sections of the Review Documentation Attachments. Discrepancies have been forwarded for disposition via PP-07.
Discrepancy Summary:
C-Signatures:
Compbted by:
Date:
(Resiewer)
Reviewed by:
Date: __
( As assigned)
Approved by:
Date:
(Tier 3 Lead or Tier 3 Designee)
O V
PAllSM8POWIA l
PP-03, Attachment C l Revision 3 Page1ofI
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