ML20141H602

to PP-07, Discrepancy Repts

ML20141H602
Person / Time
Site:	Millstone
Issue date:	07/29/1997
From:	AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20141H601	List: ML20141H596 ML20141H602
References
PP-07, PP-7, NUDOCS 9707310194
Download: ML20141H602 (12)

Text

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" PARSONS PP-07 i MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

4 Discrepancy Reports 1

) REVISION 3 l i

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Prepared by: .

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Approved by: @ Date: 7/Af/9) ana r, Company Ou ity Program Sc/ fd Approved by: Date:

Project Director REVISION HISTORY REVISION DATE REVISION DESCRIPTION 0 04/03/97 Procedure Initiation 1 06/09/97 incorporation of initial NRC Comments 2 06/26/97 incorporate NRC Comments 3 07/29/97 incorporate NRC Comments 9707310194 970729 ~~

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PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 3 DATE: 07/29/97 PAGE 2 OF 12 LIST OF EFFECTIVE PAGES PAGE No. RmstoN No. PACE No. Revision No.

1 3 7 3 2 3 8 3 3 3 9 3 4 3 10 3 5 3 11 3 6 3 12 3 TABLE OF CONTENTS 1.0 PURPOSE...............................................................................................3 2.0 RE F E R E N C ES .. ....... . . . ...... ............. ...... .... . ............ ... .......... . ... ........ ... .. .. 3 3.0 DEFINITIONS.....................................................................................................3 4.0 RES P O N S I B 1 LI TI ES .. ............. ................. .......... ............... .... ............. . . .. ... .... ......... . 4 5.0 PROCEDURE..........................................................................................................5 5.1 IDENTIFICATION OF DISCREPANCIES.. . . .5 5.2 EVALUATION., . .6 5.3 REVIEW, APPROVAL AND FORWARDING. .6 5.4 REVIEW OF PROPOSED CORRECTIVE ACTION . . .7 5.5 FINAL RESOLUTION.. . .8 ATTAC H M ENT 1 - DISCREPAN CY REPO RT........ ..... ... ..... ................................................ . 9 A'ITACilMENT 2 - CRITERIA FOR CATEGORIZING Tile RELATIVE SIGNIFICANCE OF D IS CRE PAN CIES ID ENTI FI E D B Y TH E ICAVP...... ...................... .... ................ ..... .............. I 1 EX111 B IT 1 EVALU ATIO N O F D ISCREPAN CI ES ................................. ................... ................ I 2 l

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PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS 1 REVISION: 3 DATE: 07/29/97 PAGE 3 OF 12 1.0 PURPOSE l The purpose of this Project Procedure is to provide guidance and instructions for the j initiation, evaluation, submittal and closure of Discrepancy Reports (DR) initiated for apparent discrepancies identified during the conduct of the Millstone Unit 2 Independent Corrective Action Verification Program (ICAVP).

2.0 REFERENCES

2.1 NRC Confirmatog Order dated August 14,1996 establishing an Independent Corrective Action Verification Program (ICAVP) 2.2 Audit Plan, Millstone Unit 2 Independent Corrective Action Verification Program 2.3 Communication Plan, PLN-02, Millstone Unit 2 Independent Corrective Action Verification Program 3.0 DEFINITIONS 3.1 ICAVP - Independent Corrective Action Verification Program established by Refercuce 2.1 to verify the adequacy of Northeast Utilities' (NU) efforts to establish adequate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications since issuance of the initial facility operating license.

3.2 Discrepancy Report (DR) - The mechanism for documenting an apparent discrepancy identified during the Millstone Unit 2 ICAVP.

3.2 Discrepancy - A condition , such as an error, omission, or oversight which prevents consistence among the physical configuration, information sources (e.g. documentation and databases), design basis and/or regulatory requirements. A discrepancy may identify programmatic, procedureal or design conditions.

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E PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 3 DATE: 07/29/97 PAGE 4 OF 12 1

3.3 Design Bases - Information that identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted state-of-the-art practices for achiesing i l

ftmetional 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

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component must meet its functional goals.'

l 3.4 Originator - An ICAVP Team Member who identifies an apparent Discrepancy.

4.0 RESPONSIBILITIES 4.1 Project Director - Responsible for approval of DRs prior to concurrent reporting to NNECo, NEAC, and the NRC in accordance with the Communications Plan (PLN-02).

4.2 Deputy Project Director - Responsible for:

• review of DRs to ensure completeness and clarity and to identify possible duplications of existing DRs; e forwarding DRs to the Project Director for approval; ensuring tracking and monitoring of DRs; e approval of ICAVP Team comments concerning proposed corrective actions by Northeast Nuclear Energy Company (NNECo).

4.3 ICAVP Group Leader - Responsible for:

e evaluating DRs originated within his group; e validating their bases; clodng those for which the bases are found to be invalid; 1

3 l 10 CFR Part 50, Paragraph 50.2

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E MILLSTONE UNIT 2 ICAVP PP-07 PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 3 DATE: 07/29/97 PAGE 5 OF 12 e commenting on the proposed resolution by NNECo.

4.4 Originator - Responsible for documenting in accordance with this procedure any apparent Discrepancy identified during the conduct of the Millstone Unit 2 ICAVP. The Origir.ator additionally may be asked by the ICAVP Group Leader to provide comments on the proposed resolution by NNECo.

, 5.0 PROCEDURE 5.1 IDENTIFICATION OF DISCREPANCIES 5.1.1 During the course of the Millstone Unit 2 ICAVP, any Team member may identify an apparent Discrepancy and originate a Discrepancy Report (DR) (Attachment 1). Further i

evaluation by the ICAVP Team may be required to confirm the basis for the Discrepancy, as documented on the DR form. The DR process is depicted in Exhibit 1.

5.1.2 The Originator will obtain a DR Log number from the Project Administrator. The following information, as a minimum, will be recorded for all DRs for tracking purposes:

. DR number

. Date e Title e NNECo response date e Response / resolution review date 5.1.3 The Originator will ensure that the Initiation portion of the DR form is filled out as completely as possible, including, as applicable, a description of the discrepancy, system or process name, procedure name and number, drawing name and number, affected engineering discipline, and source authority or reference used to identify the discrepancy.

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. MILLSTONE UNIT 2 ICAVP PP-07 E PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 3 DATE: 07/29/97 PAGE 6 OF 12 5.1.4 The Originator should provide a categorization of the significance of the identified discrepancy to one of the four levels per the criteria of Attachnsent 2. This section should include a brief statement of the rationale for selection of significance level. Evaluation of discrepancies to the formal NRC reporting requirements is the responsi'vility of NNECo.

5.1.5 The Originator will sign the form, and forward it to the Group Lead for evaluation.

5.2 EVALUATION 5.2.1 The DR will be evaluated by the responsible Group Lead, based on discussion with the Originator and other Team Members, as appropriate, to determine ifits basis is valid and to ensure that all known aspects of the Discrepancy are adequately described on the DR.

In addition, the Group Lead will review the significance level and discussion prepared by the originator.

5.2.2 If the basis for the DR is determined not to be valid, the responsible Group Lead may close the DR.

5.2.3 DRs for issues that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management Plan shall be noted as such and closed following such evaluation.

i 5.2.4 The responsible Group Lead will record the results of the evaluation on the DR form, check the appropriate box (es), sign the form and forward it to the Deputy Project Director.

5.3 REVIEW, APPROVAL AND FORWARDING 5.3.1 After a DR has been evaluated by the responsible Group Lead, it will be forwarded to the Deputy Project Director for review. Following that, the DR will be fonvarded to the Project Director for approval. After approval, the DR will be repoited concurrently to the NRC, NEAC, and NNECo in accordance with the Reference 2.3. The approval and forwarding of a Discrepancy Report is documented on the DR form (Attachment 1).

EX MILLSTONE UNIT 2 ICAVP PP-07 M PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 3 DATE: 07/29/97 PAGE 7 OF 12 5.3.2 DRs will be posted on the World Wide Web in accordance with Reference 2.3. DRs will be reported on the Parsons World Wide Web page 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (2 working days) after reporting the DRs to NNECo, NEAC, and the NRC. This includes DRs that were closed following a determination that the basis was not valid and for DRs that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management Plan.

5.3.3 Questions that arise during the review or approval of DRs will be resolved by the Deputy Project Director following discussions with the Group Lead and Originator, as necessary.

5.4 REVIEW OF PROPOSED CORRECTIVE ACTION 5.4.1 Proposed corrective action by NNECo in response to a DR will be forwarded to the ICAVP Group Leader responsible for evaluating the DR.

5.4.2 The ICAVP Group Leader will prepare comments on the proposed corrective action, consulting with the originator, as necessary, to ensure the proposed resolution correlates to the original concern. Comments should focus on the perceived adequacy of the proposed action to resolve the discrepancy and prevent recurrence, consistent with the purpose of the ICAVP (refer to Definition 3.1 and Reference 2.2). Comments on the NNECo response will be documented on the DR form.

5.4.3 A copy of the proposed corrective action will be sent to the Originator after approval.

5.4.4 The ICAVP Group Leader will forward the DR to the Deputy Project Director for review, prior to releasing the conunents per Reference 2.3.

5.4.5 The ICAVP Project Director will approve comments and forward comments to the NNECo, NEAC, and the NRC per the Communications Plan (PLN-02).

5.4.6 A summary of the NNECo response and approved comments will be posted on the WWW per the Communications Plan (PLN-02).

. P) MILLSTONE UNIT 2 ICAVP PP-07 E PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 3 DATE: 07/29/97 PAGE 8 OF 12 5.5 FINAL RESOLUTION 5.4.1 If the proposed corrective action by NNECo will resolve the Discrepancy, the Deputy Project Director will close the DR by signing the Final Resolution section.

5.4.2 If, in the opinion of the ICAVP Team, the proposed corrective action by NNECo is not likely to resolve the Discrepancy, the Deputy Project Director w;11 identify the DR as an open item.

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E MILLSTONE UNIT 2 ICAVP PP-07 ,

< > PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS - ATTACHMENT 1

, REVISION: 3 DATE: 07/29/97 PAGE 9 OF 12 1 ATTACIIMENT 1 - DISCREPANCY REPORT l

PARSONS POWER GROUP INC. 2675 Alorgantown Road, Reading, PA 19607 l

('") "52"" ' """5525" ICAVP MILLSTONE UNIT 2 i DISCREPANCY REPORT l i

i DR NU51 DER: DR-XXXX DR TITLE: j REVISION:

ISSUE DATE: XX/XX/XX 4

ORIGINATING GROUP:

SIGNIFICANCE LEVEL:

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. DISCREPANCY Originator Group Date EVALUATION O BASIS VALID D BASIS INVALID - CLOSED 0 PREVIOUSLY IDENTIFIED BY NNECo - CLOSED Group Lead Date

S MILLSTONE UNIT 2 ICAVP PP-07 E . PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS- ATTACHMENT 1 REVISION: 3 DATE: 07/29/97 PAGE 10 OF 12 REVIEW AND APPROVAL Reviewed:

Deputy Project Director Date Approved:

Project Director Date Forwarded to NNECo, NEAC, and NRC:_ Posted to WWW:

5 liste Date i

SUMMARY

OF NNECo PROPOSED CORRECTIVE ACTION 4

COMMENT ON NNECo RESPONSE Prepared:

Group lead Date Reviewed:

Deputy Project Director Date Approved:

Project Director Date Forwarded to NNECo, NEAC, and NRC: Posted to WWW:

FINAL RESOLUTION Deputy Project Director Date

EN MILLSTONE UNIT 2 ICAVP PP-07 E .

PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS - ATTACHMENT 2 REVISION: 3 DATE: 07/29/97 PAGE 11 OF 12 ATTAClIMENT 2 CRITERIA FOR CATEGORIZING TIIE RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED BY TIIE ICAVP 1

. SIGNIFICANCE LEVEL 1 A discrepancy (')that identifies that the system does not meet its licensing and design bases and cannot perform its intended function, i.e., has the potential to  !

simultaneously affect redundant trains.

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e SIGNIFICANCE LEVEL 2 A discrepancy") that i,dentifies that a single train of a redundant system does not meet its licensing and design bases and that the train cannot perform its intended function.

. SIGNIFICANCE LEVEL 3 A discrepancy (0that identifies that a system does not meet its licensing and design bases but the system is capable of performing its intended function.

• SIGNIFICANCE LEVEL 4 A discrepancy (D that identifies that the systems meet its licensing and design bases, however, there exists minor erros such as minor arithmetic errors that do not significantly affect the results of a calculation or inconsistencies between documents of an editorial nature. j l

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l (O I A discrepancy may identify programmatic, procedural, or design issues or editorial inconsistencies.

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D' MILLSTONE UNIT 2 ICAVP PP-07 PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS - EXHIDIT 1 l REVISION: 3 DATE: 07/29/97 PAGE 12 OF 12 )

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Communication Plan V~

Reviewed DR Approved DR Issue issued DR p m m m Review Basis Invalid DR E Approve ICAVP Basis Invalid DR E Discrepancy Issued Comment E

.p ICAVP Annroved Comment oC Activities Closed DR C Report Closed DR C Activities NNEco Response Proj. Suppeth Dep. Proj. Did( Proj.Did World Wide Web I

DR Dasis invalid DR Cnmment nn NNECn Remnnte Perform Tieri Prooosed NNECo DR Corrective Action Activities - -

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Perform D** " A* s"* > Evaluate Tier 2 Discrepancy Report, (DR) m Disciepancy Activities w/ Desenption & Safety Sigdcance " Report, (DR)

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