ML20217C830

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Rev 3 to PI-MP3-06, Project Instruction
ML20217C830
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/26/1997
From:
SARGENT & LUNDY, INC.
To:
Shared Package
ML20217C828 List:
References
PI-MP3-06, PI-MP3-6, NUDOCS 9710020093
Download: ML20217C830 (18)
v • d • e


Text

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PROJECT INSTRUCTION PI MP3-06 INSTRUCTION REV. 3 -

Client' Northeast Ulikties St: tion: Millstone Unit 3 Titir Project instruction PI-MP3 06 h Safety Related Non Safety Related Reviewed By:

Approved By:

System Lead Programmatic O&M Lead Accident QA Engineer internal Review Venfication Lead Matigation Committee Team Manager Lead Chairman gg x n h hn* Y b. b fII " hh{llt%r Wkmbia b Y

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General revision to reflect organization structure, 2.

Incorporated reviews of testing into individual process flow paths.

3. Revised PI 06 flow chart to reflect organizational structure.
4. Added reference 6.2.
5. Removed reference to checklists CK MP3 06-01,07 & 12 in section 2.17 9710020093 970930 Page 1 of 16 l PDR ADOCK 05000423 P

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PROJECT

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INSTRUCTION Pl MP3-0G INSTRUCTION REV. 3 l

1 PURPOSE The purpose of the Operations Maintenanca 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, maintenanco and tost procoduros for the selectod systems. The O&

M&T portion of the ICAVP will also venfy 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 /Interactina Systems and Related Activities required for proper implementation of these procr. sures 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 venfy 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 Verification Program - Millstone Nuclear Power Station, 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 9012, Design tasis 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 28 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 Venfication 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 Page 2 of 16 l

PROJECT INSTRUCTION Pl MP3-06 INSTRUCTION REV. 3 2.12 PI MP3 04 Programmatic Reviews 2.13 Pl 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 i

2.18 CK MP3 06 Series Checklists as follows:

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. CK MP3 06 00 System Review Checklist index CK MP3 06 01 Accident Mitigating Systems-Critical characteristics Checklist i

CK MP3 06-02 Bases / Change Features Checklist CK MP3 06 03 System Modes / Phases Checklist j

CK MP3 06-04 P&lD Checklist CK MP3 06 05 Significant Support / interacting Systems and Related Activities 1

Checklist.

CK MP3 06-06 Supplemental Documents Checklist CK MP3 06 08 Vendor Manuals / Files Checklist i

CK MP3 06-09 Performance History Files Checklist CK MP3-0610 Procedure Bases Verification Checklist i

CK MP3 0611 Mod Procedures Checklist CK MP3 0613 Training Materials Checklist CK MP3 0614 Testing Requirements Checklist CK MP3 0615 Testing Requirements Review Checklist CK MP3 0610 Test Procedure Adequacy Checklist CK MP3 0617 Testing Records Review Checklict CK MP3 0618 Procedures Observed In The Field Checklist Note: Checklists used in the performance of this Pl are not included as attachments to the Pl. Checklists are prepared and controlled as separate i

doc' - ients per PI MP3 09.

2.19 Northeast Utilities Configuration Management Plan (CMP) 2.20 Audit Plan For independent Corrective Action Verification Program (ICAVP) l 5

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i PROJECT INSTRUCTION PI MP3-06 INSTRUCTION REV. 3 3

DEFINITIONS 3.1 Operations & Maintenance and Testing Review Group (ORG) The subgroup of the ICAVP Venfication 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 Verification Team responsible for performing an in depth review of the design of the systems in the scope of the ICAVP.

3.3 Configuration Ruview Group (CRG) The subgroup of the SRG Venfication Team responsible for walkdowns to verify that the current as built conditions are in conformance witn the design output documents.

3.4 Accident Mitigation Review Group (ARG) The subgroup of the ICAVP Verification Team responsible for the review of the critical system attnbutes of the systems used to mitigate the consequences of an accident.

3.5 Programmatic Review Group (PRG) The subgroup of the ICAVP Verification Team responsible for performing a review of the design control and corrective action processes in the scope of the ICAVP.

3.6 Current Licensing Basis (CLB) The set of NRC requirements applicable to a specific plant, and a licensee's wntten commitments for assuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,30,40, 50, 51, 55, 72, 73,100 and eppendices 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 facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted " state of the art" practices for achieving functional goals or (2) requirements derived from analysis of the effects of a postulated accident for Page 4 of 16 l

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INSTRUCTION PI MP3-06 INSTRUCTION REV.3 which a structure, system or component must moet 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 Pl 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 SiCnificant SuppoMnteracting Systems and Related Activities be viewed as an all encompassing chain of all possible support and related activities. As an example, if an operator or maintenance worker must be trained with specific skills to perform particular procedures, then the existence of approved 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 Venfication 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 Venfier, 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. Additional venfiers may be assigned for performing a review of procedures, vendor manuals, training materials and plant simulator configuration as described in this instruction. An ORG Lead Verifier may serve as a venfier for other reviews.

4.4 The ORG Venfiers shall be responsible for providing a technical review of the bases information listed on the System Requirements Checklist, and for Page 5 of 16 l

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PROJECT INSTRUCTION Pl MP3-06 INSTRUCTION REV. 3 performing reviews within their area of expertise in accordance with this in:Juction An ORG Venfier may serve as an ORG Lead Venfier.

6 INSTRUCTIONS 5.1 General The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in Section 2.0 of this Pl requires Northeast Utilities (NU) to implement the ICAVP.

The Confirmatory Order also defines the scope of the ICAVP. This scope includes vert *1 cation that design and 'icensing bases requirements are translated into operating, maintenance and testi.)g procedures. The ORG includes as part of thit venfication a check that functic.ial and performance requirements, identified by the SRG in the licensing and design bases of the selected systems, ire implemented in the operating, malatenance 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 observation 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 assemble the checklists for the requirements being reviewed 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 identified 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 PI 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,5.5.4.f, and 5.6.7.a of this Pl.

5.1.4 The ORG Verifier shall use the comments section of the checklists to provide additional insights or references for Requirement dispositions, P&lD or procedure reviews, field walkdowns, etc.

5.2 Document Retrieval and Review Page 6 of 16 l

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INSTRUCTION Pl MP3-06 INSTRUCTION REV.3 5.2.1 Refer to Project Instruction PI MP3-02 for a detailed breakdown in the division of responsibility within the ICAVP Venfication Team for gathering documents. The ORG shall gather documents for the selected system from the following list of examples of operat!ng and maintenance documents:

a. Operating Procedures including Emergency Operating Procedures
b. Maintenance Procedures
c. Surveillance Test Proendures
d. Vendor Manual,
e. System Tralr<ng Procedures f.

Other SignWeant Support and/or Related Procedures

g. Operatior;al Data needed to support review of Design Process Documents 5.2.2 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 tests applicable to the system being reviewed.

5.2.3 The ORG shall request relevant documents which are not in the ICAVP Library, from NU in accordance with subsection 3.1 of PI MP3 01.

5.2.4 The ORG shall review the documents for applicability and shall add those applicable to the System Reference List (SRL). Checklist CK-MP3-02 01 instructions shall be used for the SRL.

5.2.5 The ORG Lead Verificr and the other ORG Venfiers 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.'

5.2.6 Prior to the ORG review of system modifications which have occurred i

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 desenbe 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 check;ist is a screening of the modification for impact on training procedures and plant procedures (operations, maintenance and surveillance). The SRG Lead Venfier shall forward a copy of the Page 7 of 16 l

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PROJECT INSTRUCTION PI MP3-06 INSTRUCTION REV 3 checklist and the modification package to the ORG for review. The ORG Venfier shallindependently review the modification packages for impact on procedures, and Indicate concurrence by signing the checklist.

5.3 Identification of System Reauirements 5.3.1 As desenbod in PI MP3 02, ths SRG shall use a System Requirements Checklist (SRO) to tabulate 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),

Checkilst CK MP3 02 02 to tabulate operating, maintenance, and testing l requirements. The ORG shall review the functional and performance requirements forwarded by the SRG, for ORG applicability and enter the applicable requirements on the SRC. The ORG shall also review requirements entered in the SRC by ARG for venfication thet entical characteristics for Accident Mitigation Systems are adequately addressed in Operating and Testing Procedures.

5.3.3 The ORG Lead will assign a Lead Venfier for each of the systems being reviewed.

5.3.4 The information tabulated on the System Requirements Checklist shall be independently reviewe( n another verifier as described in PI MP3 02.

5.3.5 Any conflicts of bases requirements identified on the System -

Requirements Checklist shall be processed as discrepancies.

5.3.6 The ORG Lead shall approve each ORG input on the SRC.

5.4 13.pses Reauirements Review 5.4,1 The ORG Venfier shall confirm that the base requirement as identified in the SRC has been implemented by performing a review of the appropriate documents listed in the SRL. Results of this review shall be documented in the SRC. Dequirement Disposit'on section and on the appropriate CK MP3 06 Checklists. During the review, the ORG Venfier should consider the need to identify specific Significant Supporting /

Interacting System or Related Activities. Checklist CK MP3-06-05, Significant Supporting / interacting System or Related Activities shall be i

used to document any Significant Supporting / Interacting System or Related Activities that support the implementation of a base requirement.

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PROJECT INSTRUCTION PI MP3-06 INSTRUCTION REV.3 5.4.2 The ORG Verifier shall identify the appropriate checklist (s) to be used to adequately evaluate each ORG assigned SRC requirement, modification / change item or relevant Operation 6 Maintenance, Testing or Training procedure. The ORG Venfier 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. Venfy that the design bases features and the current licensing basis features identified in the SRC are adequately translated into the l

referenced procedures. The Verifier shalllist ihe 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 shall be verified to be within appropriate limitations, assumptions, and calculations consistent with the system bases. The ORG Verifier shalllist each procedure on a copy of Checklist CK 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 return from the SRG, the ORG Verifier shall process any discrepancies for inappropriate items. Procedures with appropriate basas shall be reviewed according to the following steps of this Pl.

b. Venfy that any required Significant Support / Interacting Sys' ems and Re!sted 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 Sectiur. 5.3 Gi thin 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 intended to verify that procedures for supporting systems and functions are reflected in the system requirements checklist,

c. Identify, as appropriate, plant walkdowns to observe for procedure control, and to witness some of the review items from the above Page 9 of 16 l

PROJECT INSTRUCTION PI MP3-06 INSTRUCTION REV. 3

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i sections. Refer to Pl MP3 05 for guidance in walkdown planning.

l The Verifier shall clearly identify any items verified by walkdown on the appropriate checklists and document the results of his review with comments on the appropriate checklist.

5.4.4 The venfier 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.

5.4,5 The ORG Lead Verifier and the other Veriflors shall also review the findings and corrective actions that resulted from NU's Configuration Management Plan (CMP) to minimize duplication of findings identified by l the NU CMP.

5.4.6 The ORG Vanfier will complete the verification of the SRL documentation l versus the system requirements by dispositioning each requirernent on the Syt. tem Requirements Checklist (Checklist CK-MP3-02 02).

5.4.7 The Venfier(s) shallidentify on the System Requirements Checklist, the procedures that verify the system requirements are satisfied. The Verifier (s) shall indicate that the procedure is technically adequate or describe any deficiencies. The Verifier shall also identify missing procedures, if applicable.

5.4.8 The ORG Lead shall verify that each of the requirements has been dispositioned in the System Requirements Checklist (CK MP3-02-02). The ORG Lead shallindicate his concurrence according to the instructions for CK MP3 02 02.

5.4.9 The Venfier(s) shall generate a Discrepancy Report per Subsection 5.7 of this Pl for any discrepancies not previously identified by the NU CMP.

5.4.10 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 checklists in the project file in accordance with PI MP312.

5.5 System level Reviews 5.5.1 The ORG Lead and ORG Lead Verifier shallidentify a set of key components for each system. Key components shall be identified in accordance with the enteria contained in Attachment 6.2.

5.5.2 The ORG Verifier shall identify the operating procedures (including abnormal and emergency operating), testing procedures and Page 10 of 16 - l

PROJECT INSTRUCTION PI-MP3-06 INSTRUCTION REV. 3 maintenance procedures for the key components and applicable training materials. If these documents were not previously identified in the SRL, the documents snall be requested in accordance v..th Section 3.1 of Ph MP3-01 and added to the SRL.

J 5,5,3 The ORG Verifier shallidentify the appropriate checklist (s) to be used to adequately evaluate each ORG ass:gnod System Level requirement.

The ORG Venfier shall list 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.

5.5.4 The ORG Verifier shall review relevant proce: lures, P&lDs and other references to:

a. Verify by reviewing the procedures that all operational modes to support system requirements 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 Venfier shalllist the appropriate modes and phases and any required accident conditions and manual operations and document the results of his review on Checklist CK MP3-06-03,
b. Verify that the various system configurations (line-ups) described in the procedures will perform their intended functions. The ORG Verifier shalllist the appropriate references and document the results of his review on Checklist CK MP3-06-04.

Verify that sections of vendor manuals, equipment operating c.

instructions, drawings, or other 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,

d. Verify that vendor manuals / files adequately support the system 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,
e. Verify that performance history files adequately suppori the bases requirements for the system being reviewed. This verification shall cover the key components of the system for the recent two operating cyct:s, and shall include reviews to identify recurnng equipment protAems, and determination of any trends. Additionally, the Page 11 of 16 l

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INSTRUCTION PI MP3 06 INSTRUCTION REV. 3 verification shall include review of the technical adequacy of maintenance activities, performance of appropriate post-maintenance tests, and satisfac ory demonstration of equipment operability. The verifier shalllist the files and specific items reviewed. Specific references shall be indicat " on the checklist.

The Verifier shall document the results of his inview on Checklist CK-MP3 06-09.

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Verify that test data and results have been appropriately reviewed and approved. Specific data and results identifications shall be listed for each item on Checklist CK MP3-0615. The Venfier shall document the results of his review on the Checklist.

Any test result or acceptance criteria not in accordance with the design basis or identified in the System Requirements Checklist shall be verified to be within appropriate limitations, assumptions, and calculations consistent with the system bases. The ORG Verifier shalllist these procedures on Checklist CK MP3-0610 and forward the checklist to the SRC for verification of the appropriate bases before the procedures are reviewed for proper implementation.

Upon return from the SRG, the ORG Verifier shall process any discrepancies for inappropriate items. Procedures with appropriate basss shall be reviewed according to the following steps of this Pl.

g. Identify, as appropriate, plant walkdowns to observe for procedure control and to witness some of the review items from the above sections. Refer to PI MP3 05 for guidance in walkdown planning, The Verifier 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.

5.5.5 The Verifier (s) shallidentify on the System Requirements Checklist, the procedures that venfy the system requirements are satisfied. The Verifier shall also identify missing procedures data forms and acceptance criteria if applicable.

5.5.6 The Verifier (s) shall follow the instructions for CK MP3-02-02 to complote and disposition all entries in the System Requirements Checklist.

5.5.7 The ORG Lead shall venfy the disposition in the System Requirements Checklist (CK MP3-02-02). The ORG Lead shallindicate his concurrence according to the instructions for CK MP3 02 02, 5.5.8 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.

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INSTRUCTION PI-MP3-06 INSTRUCTION REV. 3 5.5.9 The ORG Lead shall verify the checklists have been properly completed and shallindicate concurrence by signing and dating tPe checklists. The ORG Lead will file the checklists in the project file in accordance with Pl-MP312.

S.6 Roview of Modifications l

5.6.1 The ORG Verifier shallindependently 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 s.pecific procedures to be reviewed by the ORG for those modifications that were determined to either have procedure impact, or may have procedura impact, by the SRG.

E6.2 The ORG Verifier shalllist the Modification Package identification Number on the Mod Procedures Checklist CK-MP3-06-11.

S.6.3 Based on a technical review of the modification packages forwarded to the ORG from tha SRG, the ORG Verifier shall confirm that the appropriate procedures for the modification or changes being evaluated are listed on Checklist CK MP3 06-11.

5.6.4 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.

5.6.5 The ORG Verifier shall perform a detailed review of the appropriate procedures for each modification or change to evaluate them for implementation of the changes identified. During the detailed review, the ORG Verifier should consider the need to identify specific Significant Support /Intoracting Systems and Related Activities tc also be reviewed for implementation of the above identified changes, based on initial reviews or results of questions considered as described in Section 5.5.8.d of this Pl. The Verifier shall refer to Definition 3.11 of this PI for l

clarification.

5.6.6 The ORG Verifier shall verify that the design and operation changes that resulted from the modification identified by the SRG in Section 5.2.7 above, or identified by the reviews of this section of the Pl are adequately reflected in operating, maintenance, and ter ting procedures, in training materials, and in the simulator configuration as appropriate.

The ORG Verifier shall Nt each modification or change process to be evaluated on each checklist used in Section 5.6.7 below. The Verifier shalllist each procedure that is being evaluated for implementation of the changes also on each checkust used in Section 5.6.7. The ORG Page 13 of 16 l

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INSTRUCTION INSTRUCTION PI-MP3-06 REV.3 Verifier shall also list the specific procedure section as a reference for each Hem that is being evaluated.

5.6.7 The ORG Verifier will review the relevant procedures to:

a. Verify that operation and maintenance procedures are consistent i'

with any modifications. The Verifier shalllist the changes and document the results of his review on Checklist CK MP3-06-02, I

b. Verify by reviewing the procedures that all modes and phases of the selected system are adequately operated, maintained, and tested to refiect the changes. The Verifier shalllist the appropriate modes and 4

phases and document the results of his review on Checklist CK-MP3-A-03,

c. Verify that the various 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 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 6

Related Activities (refer to Definition 3.11 of this PI for clanfication) adequately provide for proper performance of the system 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 document the results of his l

review on Checklist CK-M 33-06-05.

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 other supplemental documents that support the change that are referenced, or used directly as operating or-l 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-a MP3-06-06.

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Verify that vendor manuals / files adequately support the requirements for the change. The Verifier shall list the manuals / files reviewed, and document the results of his review on Checklist CK-MP3-06-08.

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PROJECT INSTRUCTION PI MP3-06 INSTRUCTION REV. 3 i

g. Verify that training materials, especially operator training materials, l

have been appropriately updated to reflect the change. The Verifier shall also identify any required simulator configuration changes to evaluate. The Venfier shalllist the training materials reviewed, and any simulator changes evaluated, and document the results of his review on Checklist CK MP3-06-13.

h. Verify that Modification Functional Test requirements and Acceptance Criteria are contained in the Modification Packages. The ORG Verifier shall verify that the Functional Tests were performed and the acceptance criteria were met, i.

Identify, as appropriate, plar,: valkdowns to observe for proce ure control and to witness somo o' the review items from the above sections. Refer to PI-MP3-05 for guidance in walkdown planning.

The Verifier 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.

5.6.8 The verifier shall note any comments identified during the review on the comment section of eact '.hecklist used in the above reviews. Additional copies of the checklists t a j comment sections shall be used as required to thoroughly document the results of the reviews.

5.6.9 The ORG Lead Verifier and the other Verifiers shall also review the findings and corrective actions that resulted from NU's Configuration Management Plan (CMP) to minimize duplication of findings identified by l the NU CMP.

5.6.10 The ORG Verifier will complete the verification of the procedures versus the change requirements by dispositioning each requirement on the Mod Procedures Checklist CK-MP3-06-11.

5.6.11 The Verifier (s) shallidentify on the Mod Procedures Checklist. the procedures that satisfy the change requirements. The Verifier (s) shall indicate that each procedure is technically adequate or identify any deficiencies. The Verifier shall also identify missing procedures, if applicable.

5.6.12 The Verifier (s) shall sign the Mod Procedures Checklist when completed.

5.6.13 The ORG Lead shall verify the disposition of the Mod Procedures Checklist CK-MP3-06-11. The ORG Lead shallindicate 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 Page 15 of 16 l

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systems have been satbfied or he shallidentify which have not been. The -

ORG Lead shall also notify the PRG Lead about the results of the PRG procedure reviews.

5.6.14 The Verifier (s) shall generate a Discrepancy Report per Section 5.7 of this Pl for any discrepancies not previously identified by the NU CMP.

5.6.15 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.

5.7 Discrepancy Report Preparation and Closure 5.7.1 Discrepancy Reports for discrepancies identified during the review process shall be prepared and processed in accordance with PI MP311.

Discrepancy Reports shall not be initiated for findings already identified by NU during implementation of the CMP.

5.7.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in accordance with PI MP311.

5.8 Final Report 5.8.1 The ORG Lead Verifier shall prepare 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 Manager.

3 6

ATTACHMENTS 6.1 O&M&T Process Flow Chart page (1 page) 6.2 Criteria for Selection of System Key Components 4

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...2 Criteria for the selection of System Key Components ORG is required to perform a review of Maintenance Procedures for Tier 1 of the ICAVP. This review shall cover

  • key" components rather than the review of all maintenance practices /

procedures. " Key" components shall be selected based on the following criteria:

Using guidance from the NRC Maintenance Rule,10CFR50.60, Tier 1 system P&lDs shall be reviewed to identify components whose failure will result in a loss of system or train function.

Identify components that have previously experienced significant maintenance or operational problems as identified by LERs or other problem identificatico processes.

The scope of review shall include the primary component (pump, valve, etc.), its driver and circuit breaker. It shall also include the instrumentation required to assure the function of the component can be achieved. For similar or like components, tre review shall be limited to the programmatic control procedures and a review of a sample of component specific resutis sufficient to establish confidence in the process.

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