ML20141E465

Rev 2 to Audit Plan for Independent Corrective Action Verification Program Northeast Utilities Millstone Unit 3

ML20141E465
Person / Time
Site:	Millstone
Issue date:	05/16/1997
From:	Neri A, Querio R, Raheja R SARGENT & LUNDY, INC.
To:
Shared Package
ML20141E462	List: ML20141E457 ML20141E465 ML20141E472 ML20141E487 ML20141E492 ML20141E502 ML20141E518 ML20141E532 ML20141E550 ML20141E555
References
CON-9583-100 PROC-970516, NUDOCS 9705210012
Download: ML20141E465 (41)

Text

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- r AUDIT PLAN FOR INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM (ICAVP)

REVISION 2 NORTHEAST UTILITIES MILLSTONE UNIT 3 q- PROJECT NO. 9583-100 Prepared by: 7b 6 % V W/ b/f[ '

IC D. Raheja (/' Dale  ;

Accident Mitigation Review Group Lead cc 44 S N l R. Querio Date Operations & Maintenance & Testing Review Group Lead S~fl5 l 7

. A. Neri Date Sptem e 1ew Group Lead 7

_ f 'M s-- ik7 T.[ Rya,rr/ Dite/

Programmatic Review Group Lead

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I Reviewed by: / vs#1< O'/$<- d 6 77 Ddte R. F. Czajkov/jki } j Quality Assurance' ,

l Approved by: + ~ " b '

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A. K. Singh Date IRC Chairman 3,E /D m 9) =~ $*M- f[

D. K. SMopfer 'I Date

} f Verification Team Marder 9705210012 970516  ?*

PDR ADOCK 05000423' (1)

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i 1.0 OBJECTIVE j 1 The objective of this project is to implement an Independent Corrective Action l Verification Program (ICAVP) at Northeast Utilities Millstone - Unit 3 in .i accordance with the Nuclear Regulatory Commission's (NRC) August 14,1996 - -l' con 6rmatory order. The ICAVP will be an independent veri 6 cation of the adequacy of results of the Configuration Management Plan (CMP) currently being -

implemented by Nonheast Utilities which is directed at resolving existing design  !

and configuration management de6ciencies. The ICAVP will provide indapaadaat - l verification that, for selected systems, Northeast Utilities' CMP has identified and  ;

resolved existing problems, d==aaated and utilized licensing and design bases, [

. and established programs, processes and procedures for effective configuration 2

management in the future. The ICAVP will be comprehensive, incorporating all of the appropriate engineering disciplines, such that the NRC can be confident that  !

- Nonheast Utilities has been thorough in identification and resolution of problems. l The ICAVP review will be conducted independently of Northeast Utilities and its i

. design contractors, j 2.0 SCOPE OF WORK -

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. The scope of work for the ICAVP as descri'oed in the NRC's August 14,1996 3 confirmatory order to Nonheast Utilities includes:

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a. A review of engineering and design control processes, f

b. verification of current as modified plant conditions against design bases and  !

licensing bases documentation. l

c. verification that design and licensing bases requirements are translated into  :

operating procedures and maintenance and testing procedures.' l i

c d. verification of system performance through review of specific test records and/or observation of selected testing of particular systems, and j i

y e. review of proposed and implemented corrective actions for design i deficiencies identified by Nonheast Utilities.-  !

The NRC's December 19,1996 oversight inspection plan provides further i

' direction on the scope of the ICAVP. In addition to the above items, the oversight  !

inspection funher reqmres a review of accident mitigation systems that assesses the i

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critical design characteristics to ensure that these systems and components can

, perform their specified safety functions.  !

S&L will implement the above scope of work as follows:  ;

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a. The review of engineering and design control processes will consist of an assessment of the current Northeast Utilities change process procedures, a

- technical review ofpast changes other than modifications and technical review of all plant modifications to the systems selected for a vertical slice 3

, review by the ICAVP that were prepared aRer issuance of the operating license. The review of the plant modifications will include- l

• A technical review of the changes contained in the modification  ;

f packages to system specific analysis and output documents and to  ;

topical engineering programs. ,

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i e Verification that current design output documents have incorporated  ;

the changes identified in the modification packages. l

• Verification that current system operating, maintenance, testing and i training procedures adequately reflect the modifications.

i' + Verification that the physical installation conforms with the l modification package.

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• Verification that the post modification test procedure and test results demonstrate the system is capable of performing its function. l

. Verification that no unreviewed safety question exists for the modification as documented in the 50.59 safety evaluation. j

b. The verification of current as modified plant conditions against the design bases and licensing bases will include: ,

a Review of calculations, analysis, specifications and design output l documents for consistency and for conformance with the design and j licensing bases.  ;

• A physical walkdown of the system to verify conformance with the i design output documents. l (3)

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c. The verification that the design and licensing bases are translated into  !

operating, maintenance and testing procedures will include a cross-check of - l functional and pedormance requirements identified in the licensing and design bases versus those identified in the operating, maintenance, testing ,

and tral.L.g procedures.

d. The verification of system performance will be accomplished through a  !

review of speci6c test records for recently completed surveillance and post  ;

modification functional tests. t

e. The review of proposed and implemented corrective actions for

' deficiencies identi6ed by Northeast Utilities during the CMP will include a review of all corrective ~ actions for systems selected for a vertical slice review by the ICAVP and a review of randomly selected corrective actions  !

for systems outside the scope of the vertical shce review. j i

f. The review of the accident mitigation systems will include an assessment of i the critical design characteristics to ensure that the systems and components can perform their specified safety functions.

Successful completion ~ ofitems b, c, d, e and the technical plant modification reviews of l- item a will ensure the systems selected for the vertical slice review (Tier 1) are capable of performing their functional requirements as specified in the design and licensing basis documentation. Successful completion of the reviews described in item a and the reviews l described in item e will ensure the adequacy of the NU design control process (Tier 3). l l

4 The successful completion ofitem f will ensure the accident mitigation systems are capable of performing their specified functions (Tier 2).

l 3,0 PROJECT ORGANIZATION The organizational structure will facilitate both the internal and external interfaces ,

i of the Project Team. Exhibit I shows the project organization. This section describes how the organization will function and the expected interfaces. The i roles and responsibilities of the different parts of the organization are provided.  ;

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3.1 Management Team )

I The Sargent & Lundy management team for this project is comprised of l the Project Director, Bryan Erler; the Verification Team (VT) Manager, l Don Schopfer; and the Chairman of the Internal Review Committee, l

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. :I A. K. Singh. They are collectively responsible for ensuring that the project is properly planned and implemented, that it meets the requirements of the i NRC Confirmatory Order, and that the process and the results are open l and credible to the NRC and the public. ,

. The Project Director will have the overall responsibility for Sargent &

Lundy's performance for the work. He will be responsible for facilitating the resolution of any differences between the VT Manager and the Intemal Review Committee. The Project Director will be the primary external  ;

spokesman for the ICAVP Team and will meet with and report to the NRC, and Northeast Utilities as required and as allowed by the approved .

protocol. He will be available to the press, the media, and the public when  ;

requested by the NRC and NU. The Project Director will also be signatory l to the final report produced by the ICAVP Team.  !

The VT Manager will be responsible for directing the development of and i i approving the plans and procedures for implementing the review, including recommended system selection criteria and the protocol covering [

communications between Sargent & Lundy project personnel and the other l organizations. He will manage the work through the technical leads on the

. i VT. He will be responsible for reviewing the findings produced by the VT,  ;

and, upon acceptance, submitting them to the Internal Review Committee.  !

c He may also return them to the VT Leads for additional information or ,

further review. The VT Manager will be responsible for distributing the l i

findings, including posting them on the electronic bulletin board as i' established in the approved protocol after acceptance of the findings by  ;

! IRC. Similarly, the VT Manager will resiew, accept and distribute / post the  :

VT's evaluation of the NU responses to the findings. He will be  ;

responsible for preparing the final report documenting the work of the VT.  ;

The VT Manager will also serve as the backup for the Project Director  ;

with respect to communication with the NRC, and NU when necessary.  !

I The Chairman of the Internal Review Committee will be responsible for  ;

t coordinating the actisities of that group. The roles and responsibilities of the Internal Review Committee is provided later in this section of the audit l plan. The IRC Chairman will also make himself available to the NRC, and j

NU when requested. <

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3.2 Verification Team j I

L The VT is the core of the organization and is the ' group that does the actual ,

review of the design and licensing bases and the effectiveness of the NU  !

corrective actions. The VT is organized into four functional groups. Each . l subgroup will be headed by a Lead engineer and will be responsible for a

, portion of the overall veri 6 cation program. There will be a System Review Group (SRG), a Programmatic Review Group (PRG), an Operations and ,

Maintenance and Testing Review Group (ORG), and an Accident .

Mitigation Systems Group (ARG).

l The VT has been organized functionally in accordance with the review -  !

, processes instead of by traditional engineering disciplines.' However, this is ,

not to imply a strict compartmentalized group structure or review process i i

It will function as a single project team with significant crou utilization of .

personnel among groups. It is expected that SRG and ORG personnel will L perform review functions associated with the ARG and PRG. In addition, l there will be significant interfacing among the team members and the

Review Group Leads. Periodic full project team meetings will be

- conducted by the VT Manager in addition to periodic review group meetings conducted by the Leads. During the review and discrepancy i: resolution process, it is expected that the VT Manager will have daily -l

briefings with the VT leads to discuss potential findings, share lessons i l earned, and discuss other project issues. Teamwork and frequent ,

communications is a fundamental attribute for the conduct of the ICAVP

and will be facilitated by the location of nearly all of the Chicago office project team members on the same floor of Sargent & Ix .dy's (S&L)  !

offices.

The SRG will perform the in-depth review of the selected systems. This group will review the current system output documents and analysis to verify conformance with the design and licensing bases. The SRG will also review design modifications to the selected systems made since receipt of the OL, focusing on the validity of the design process, identification of  ;

, system interface requirements, potential synergistic effects'of the modifications, and appropriate design document controls.'  :

The SRG will also be responsible for verifying that the current, as-built  :

condition of the plant matches the current design output documents. This j task includes physical and functional walkdowns of the selected systems l i

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i and will be performed by the Physical Configuration Review subgroup (CRG) of the SRG.  :

The ORG will be responsible for reviewing system operating procedures, surveillance procedures, maintenance procedures, and training documents

to confirm that the design bases and any changes made to the design bases

, have been translated correctly into these documents. This group will also  ;

confirm that current testing requirements and post modification testing requirements are adequate to verify system performance.

The ARG group will be responsible for reviewing the accident analysis contained in the FSAR to determine the accident mitigation systems and ,

their critical design characteristics. The ARG will then review the accident i mitigation systems and their critical characteristics to ensure the systems

, can perform their safety functions specified to mitigate the FSAR accident scenarios.

I l The PRG group will be responsible for the review of select NU processes for changing the facility design and for changing characteristics, procedures, or practices for maintaining, operating, testing, and training to  ;

ensure the adequacy of the change process. The PRG will also be  ;

responsible for the review of NU's corrective actions resulting from their ,

configuration management plan review. This review will determine the

adequacy of the corrective actions.

! 3.3 Role of the Internal Review Committee The Internal Review Committee will provide a S&L management technical ,

4 oversight role. It will also help to provide consistency in the review j results. It will be comprised of four very senior personnel within the '

organization that have specialized expertise in the areas being reviewed.

The IRC Chairman will be responsible for obtaining the IRC's review of the planning documents and procedures for performing the verification program. This includes the audit plan, the protocol, and the individual procedures required for the work. The IRC will review the findings of the j VT for extent and for significance. They will also review the responses by NU after they have been accepted by the VT. The IRC may also make specific recommendations regarding the scope or methodology of the verification process as the work progresses. The IRC will also review the final report of the ICAVP.

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1 Northeast Utilities - N M " "' ' ICAVP Audit Plan .

Millstone Unit 3 ,.E Revision 2 4.0 METHODOLOGY This section of the audit plan describes the methodology S&L will use to  !

implement the ICAVP. Exhibit 2 depicts the review process. In general, the ICAVP will consist of the following tasks:

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• De6ning System Boundaries

• Document Gathering

• - System Review i e' Physical Walkdowns e Operation, Maintenance and Testing Procedure Review  !

e Accident Mitigation System Review

• Programmatic Reviews o '

Processing VT Findings e Review ofNU Resolutions  !

• Issuing Final Report .

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Note: The intent of this review is to review only those systems for which NU's  ;

CMP process has been completed. Accordingly, if during the conduct of S&L's review, it becomes necessary to review items related to systems for which the NU CMP process has not been completed, a " place-holder" shall be utilized to discontinue that portion of S&L's review until such time that NU completes the CMP process for that system. Place-holders shall not be communicated outside of S&L.

4.1 Defming System Boundaries  ;

The systems to be included in the scope of the ICAVP program will be defined by the Nuclear Regulatory Commission. At the beginning of the ,

! system review process, a meeting will be held with the NRC, Nuclear Energy Advisory Council (NEAC) and NU to finalize the boundaries of the ,

selected systems and interfacing systems. In general, S&L's review for the .

vertical slice system reviews will address interfaces with the selected systems as follows:

• Mechanical Interfaces - S&L will review the interfacing system calculations to the extent needed to verify that the functions required to  !

support the selected system were addressed in the design of the

' interfacing system. S&L will review the interfacing systems drawings (8)

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' and procedures to the extent needed to verify the support functions are l addressed. This review will not include technical verification of the

< adequacy of the interfacing systems calculations, procedures or drawings.

• I&C Interfaces I&C interfaces will be treated in a slightly different

, manner compared to mechanicalinterfaces section above. We will review input signals from interfacing systems through to their signal '

source to verify that the functions required to support the system under review were addressed in the design of the interfacing system. We will ,

I review the output I&C signals for the system under review through to

- the input point of the interfacing system. The extent of this review is r

described in detail in Attachment 6.3 of PI-MP3-02.

• Electrical Interfaces - Electrical interfaces will be treated in a slightly ,

different manner. A detailed review of the electrical distribution system from the motor control center or switchgear, as applicable, to the load is included as part of the selected system review. A load path review will be performed for theTemainder of the electrical distribution system (diesel generator to switchgear or MCC). The extent of this review is described in detailin Attachment 6.2 of PI-MP3-02.

4.2. Document Gathering The next step in the ICAVP review process will be to gather the licensing and design bases documents, procedures, design process documents and design output documents needed to perform the review. The following top ,

level controlled documents have been obtained and are stored in both the l S&L Chicago office and the local offsite office:

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• Configuration Management Program  !

• Design Control Process Procedures

• Current FSAR

• FSAR at O/L

• SER and all revisions

• 10 CFR 50.59 Safety Evaluation Procedure

• Procedures for and System Specific Assessments

• Corrective Action Procedures

• List or database oflicensing commitments contained in docketed correspondence (9)

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• Description of document system and hierarchy system

• List of all modifications designed since receipt of O/L for Maintenance Rule Category I and 2 systems, soned by primary affected system, including the organization responsible for the design

• Complete index of the Unit 3 controlled documents, including calculations and drawings {

• Complete index of the procedure system for Unit 3, including corporate / administrative procedures, engineering procedures, maintenance procedures, and operating procedures including emergency operating procedures  ;

• Complete listing of Adverse Condition Reports, sorted by system Documents describing specific engineering programs that may not be included in the above listing, such as MOV program, ISI/IST program etc.

• NRC inspection reports, QA audit reports and the NU responses to them

, The following system specific documents for the systems chosen for review will be requested in accordance with the protocol outlined in PI-MP3-01, d

• Engineering Calculations (Mech, Elect, Stmet, I&C and Piping Analysis)

• Equipment Procurement Specifications

• Modification Packages

• System Descriptions

• Equipment List

• Environmental and Seismic Qualification Repons

• P& ids

• Logic Drawings

• Electrical Schematics

• Piping Drawings

• Electrical Single Line Drawings

• Panel Wiring Drawings

. Cable Routing Drawings and Databases

• Pipe Suppon Drawings

• Stmetural Equipment Mounting Details ,

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• General Arrangement / Equipment Location Drawings

• Instrument Location Drawings

• Zone Maps (Emironment/ Fire Protection, etc).

• Operating Procedures including Emergency Operating Procedures 4 i

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4 e Maintenance Procedures j

• Surveillance Test Procedures  !

e Vendor Manuals e System Training Procedures  !

4.3 System Reviews  :

The vertical slice system reviews will be performed by the SRG in  ;

accordance with PI-MP3-02 and 03. System reviews will focus on two objectives,1) to verify the system design elements being reviewed are ,

technically adequate and consistent with the licensing and design bases (PI-  ;

MP3-02) and 2) to verify the modifications implemented after receipt of the l

- operating license are technically adequate and that configuration control of  ;

design documents was maintained (PI-MP3-03).  !

The first step of the process is to review the licensing and design bases  ;

documentation to identify the functional, design, performance, operational and testing requirements of the system. These requirements will be .

individually tabulated on a system requirements checklist. The system  :

requirements checklist will be independently verified prior to its use by the i SRG and ORG as the bases for verifying design conformance to the design ,

and licensing bases. Discrepancies between the design and licensing bases l documentation identified during the development of the system requirements checklist will be processed as discrepancy reports in .

accordance with Subsection 4.8.

Following the development of the system requirements checklists, the SRG  :

will perform the four reviews described below. The purpose of thesc  ;

reviews is to verify the current system design is capable of the functional i and performance requirements identified in the design and licensing basis documentation and to ensure consistency between the various design output documents and design process documents. Verification that current system operating, maintenance and testing practices and that current configuration is in accordance with the design and licensing basis j documentation will be performed per sections 4.5 and 4.4, respectively.

. These four reviews include:

a. A review of design process documents to verify the technical ,

adequacy of each document and its conformance to the design and  !

licensing bases. This review will include mechanical, electrical, I&C, and stmetural calculations, piping analysis and equipment  !

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N Northeast Utilities - "'"'" $ " "' ICAVP Audit Plan Millstone Unit 3 / Revision 2 EQ/SQ reports. The design process document conclusions and/or assumptions will be verified against actual operating data, where  :

available.

Note: If a large population of repetitive standard type calculations  :

are identified during the review process, S&L may request the NRC to approve an appropriate sampling in lieu of a 100% review of these repetitive calculations. The request ,

shall be submitted with a sufficient technical basis for why a sample isjustified based on safety significance and the t overallICAVP process. ,

b. An upper tier drawing review including P& ids, electrical schematics, electrical single line drawings, instrument loop diagrams and logic diagrams to verify the system design is capable of performing the functional equirements described in the design and licensing bases and to venty the drawings are consistent with the design process documents.

c. A component review to verify consistency between the licensing and design bases documents and the design output documents such as, component specifications, system calculaticins, and vendor component drawings.

d. A review of hazards resulting from postulated pipe breaks in the selected systems including pipe whip, jet impingement, missiles and ,

flooding. This review will verify that the effects of these hazards on l adjacent safety systems have been included in the hazards analysis.

In addition, the SRG will evaluate the components of the selected i systems to verify they are capable of performing station blackout coping functions and Appendix R safe shutdown functions, if required. I l

The SRG will also assist the ORG with their review of procedures for the selected systems. The SRG will verify the technical adequacy of all parameters, including operating ranges and/or limitations contained in the procedures. Additionally, the SRG will review all operating modes not explicitly identified in the system requirements checklist to verify the design l and analysis support operation in this mode. The ORG will define the parameters and modes to be reviewed by the SRG.

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6 Once the reviews are completed, the SRG will enter on the systems j requirements checklist how each of the design, functional and performance requirements is satisfied. The ORG will complete the portion of the

checklist relative to operating and testing requirements.  ;

The next step will be to review the plant modifications issued aRer receipt

of the operating license The scope of the modification review will include all major modifications (DCR's), Minor Modifications (MMOD's) and all ,

DCN's generated to support the DCR/MMOD processes. DCN's l generated to support like for like replacements, maintenance support engineering evaluations and NCR disposition's are not included in the scope of this review. Each modification will Srst be screened to identify

the lead discipline (mechanical, electrical or I&C). A lead verifier from the affected design discipline will then perform a modification screening process to identify which design elements are affected by the modification.

The lead verifier will complete a checklist consisting of general questions

to facilitate the determination of which design elements are affected by the  !

modification. The design elements that will be screened include:

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a. Mechanical Design

b. Electrical Design

c. I&C Design

< d. Structural Design

e. ALARA Design

f. Security

g. Appendix R Compliance i

h. Electrical Equipment Qualification

i. Seismic Qualification

- j. Radiological Environment

!- k. Non-Radiological Environment

! 1. Station Blackout .

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m. Control Panel Design

n. Piping Design

o. Setpoint Database p, Hazards /HELB Program

q. Fire Protection

r. PRA i

s. Training Procedures

t. Plant Procedures (OPS, Maintenance, Surveillance)

u. Configuration Change Review

v. Quality SoRware Design Review r

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1 For each design element that is affected, a VT member with the appropriate  ;

technical background will perform a detailed review to verify that the  ;

design element was adequately addressed in the modification. This review  :

will verify the technical adequacy of the design inputs and of the calculations, specifications and design documents impacted by the modifications. - All reviews will be performed by the SRG with the exception ofItems s and t which will be performed by the ORG.

I The SRG will then perform a detailed review of the changes to licensing documents that were generated for each modification to ensure the  ;

modification is adequately incorporated into the FSAR, Technical  :

Speci6 cations, Environmental Plan, Security Plan and Emergency Plan.

The SRG will also review the 10 CFR 50.59 safety evaluation prepared for each modification to ensure the unreviewed safety question determination  ;

was thorough and well documented. ,

Finally, the SRG will review the installation and testing requirements including acceptance test criteria to determine that appropriate installation -

and testing requirements were specified. The ORG will be responsible for verifying that satisfactory post- modification testing was implemented.  ;

4.4 Physical Configuration Review The physical configuration review will be performed by the CRG in accordance with PI-MP3-05. This review will focus on verifying the current as built condition of the plant matches the current design documents. This group will perform a physical and functional walkdown j of the systems in the scope vertical slice review. This group will also ]

review plant modifications implemented after issuance of the OL to verify j the as built condition conforms to the modification documents and to verify l the modification documents have been accurately incorporated into the 1 affected design drawings or are posted against the affected design l drawings. The walkdown of system modifications will be a more in-depth I l

walkdown than the system functional walkdown described above. Key critical dimensions such as analysis / calculation bases and/or dimensional restrictions identified on drawings will be verified during the modification walkdowns.

After retrieving the system design drawings ard outstanding changes, the 3 CRG will create a set of walkdown documents by redlining the open I

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i amendments onto the physical drawings. The CRO will then perform a .

review of the lower tier drawings such as piping drawings, wiring diagrams, electrical physical drawings and cable schedules etc., to verify conformance to the upper tier P& ids and schematics. This review is ~;

i required to ensure the lower tier documents being used for configuration walkdowns are functionally in agreement with the upper tier documents i

- that are checked for technical accuracy by the SRG. The SRG as part of their calculation reviews will also verify calculations wit.u stress reports i

and lower tier drawings such as piping isometrics are in conformance.

Discrepancies identified by the SRG in this area will be communicated to

• the CRG. This review is not intended to be a line by line review of the lower tier documents, but only a functional check.

Prior to performing the walkdowns, the CRG will identify system boundaries on the walkdown drawings. These boundaries will be reviewed with the SRG to ensure consistency with the system boundaries previously agreed to by the NRC, NEAC, NU and the VT.

e The next step will be to perform physical plant walkdowns of the systems.

l The walkdown will check the following attributes:

a. System component location and identification are as indicated on the P&lDs and other schematic type documents.

b. Component nameplate data is consistent with component specifications and drawings.

c. System components are not physically damaged.

d. System configuration is functionally consistent with design output documents by verifying:

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• Aguration of piping including number and location of l uends, location of valves, supports and other in-line components

• Valve orientation and flow direction  ;

• Pipe support type and configuration -

• Equipment and instrumentation mounting details  :

• Configuration of conduit and tray routing

• . Cable"To and From" routings (15) ,

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• Conduit and cable size

• Conduit and tray support type and configuration +

• Tubing / electrical configuration to instruments [

• HVAC ductwork size and routing ,

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e. Divisional trains of the system are physically separated by barriers

> and or distance. Electrical separation will be checked by verifying cable is routed through applicable divisional raceway.

f. Based on NRC Approval Letter dated 4-7-97, S&L is precluded from performing reviews of seismic II/I related issues due to prior ,

S&L involvement. This review if required must be performed outside the S&L scope for the ICAVP.

As stated previously, this walkdown is not intended to check all dimensions, but is merely intended to be a functional verification.

The CRG will also perform a review of the modifications identified by the SRG as impacting system configuration drawings. The SRG will 4

provide / identify drawing changes resulting from system modifications. The '

SRG will also clearly identify which portions of the modification packages are presently installed. Upon receipt of this data, the CRG shall first review the drawing changes to ensure they are either incorporated into the current drawings or are identified as open amendments against the drawings. The CRG will then perform a detailed walkdown of the modifications which have been installed. This walkdown will include a check of critical dimensions and a review of seismic II/I attributes in addition to the other walkdown attributes described above for the functional walkdown. ,

4.5 Operation & Maintenance and Testipg Review The operating & maintenance and testing review will be performed by the ORG in accordance with PI-MP3-06. This review will focus on verifying that the system operating procedures, maintenance procedures, surveillance procedures and training documents conform to the systems design and licensing bases. This group will also review the post modification tests I performed following the installation of plant modifications to the system to verify the testing was adequate to maintain the design and licensing bases. ] ,

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j Upon receipt of the system requirements checklists from the SRG, the ORG will perform a review to verify the following: j

a. The operating procedures are in conformance with the systems functional requirements described in the Licensing and Design 1

Bases. This review willinclude all modes of system operation .

including normal, abnormal and emergency system operations. This review willinclude: ,

a.1 Review of the operating procedures against the system -

L P& ids.

a.2 Verification that instrumentation and controls described in

the procedure are consistent with the installed condition.

a.3 Verification that procedures for support systems are adequate to support the operation of the system.- l a.4 Verification that manual operator actions can be performed .;

under accident conditions.

b. The maintenance procedures are in conformance with the maintenance requirements described in the Licensing and Design Bases. The review will:

b.1 Verify that maintenance procedures and vendor manuals exist for key system components.

b.2 Check the maintenance procedures for technical adequacy.

b3 Review vendor manuals, generic communications (i.e., l Bulletin, Information Notices, Generic Letters, NSSS l Technical Bulletins) and verify applicable items have been l

. implemented into the maintenance program, l

b.4 Review component history files to identify recurring equipment problems and determine if any trends exist.

b.5 Review past maintenance activities and verify technical

" adequacy, performance' of the appropriate post maintenance (17)

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"~ ICAVP Audit Plan -

Northeast Utilities Revision 2 Millstone Unit 3 , - l J

testing, and satisfactory demonstration of equipment operability. ,

c. The review will verify that test procedures and surveillance '

procedures are in conformance with the Design and Licensing Bases. The review will focus on the following:

c.1 Review the technical adequacy of Technical Specification Surveillance Test Procedures and verification of the adequacy of test results completed during the last operating cycle.

c.2 Verify the system tests adequately ensure the system will operate as intended under postulated conditions. l c.3 Determine if surveillance test procedures comprehensively <

address system responses addressed in the licensing bases.

Upon completion of the above reviews, the ORG will complete the system requirements checklist to document how the Licensing and Design Bases requirements related to Operation & Maintenance and Testing are satisfied.  ;

4 The ORG will also review plant modifications implemented after issuance of the Operating Licensing. As stated in Section 4.2 of this audit plan, the SRG screening process will determine if plant modifications may affect the operation, maintenance or inspection requirements of a system. The ORG will independently evaluate the modifications to identify the required changes. The ORG will then review the operating, maintenance and testing '

procedures to verify the changes due to the modification have been reflected in the procedures. Additionally, the ORG will review the post  !

modification test results for each modification to verify the adequacy of the test results.

4.6 Accident Mitigation Systems Review The process discussed in this section will be used by the ARG to develop the critical characteristics or parameters for the accident mitigation systems. This process shall be implemented in accordance with PI-MP3-07.

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Northeast Utilities *E"~ ICAVP Audit Plan Revision 2 Millstone Unit 3 .~  !

The ARG Lead and Verifiers will review the initiating events in the FSAR, as they apply to Millstone Unit 3 and identify the accident mitigating systems and components within the system. The reload analysis and the i FSAR shall be used to identify the specific critical parameters which are required to mitigate the event. As a result of this review, the ARG Lead will create a database consisting of the following items: a) Analyzed Accidents, b) Mitigating Systems, . c) Components, d) Critical Parameters and e) References to the accidents and associated documents contained in the SAR. The list of systems and associated critical characteristics shall be ,

submitted to the NRC for approval prior to ARG verification of the i Pamneters. j i

The portion of the database consisting of the accident mitigation systems in the scope of the vertical slice system reviews (Subsection 4.3) will be given  !

3 to the ORG and SRG for their review of the Critical Parameters.

The ARG Verifiers will verify the Critical Characteristics (Parameters) using a documented System / Component test, and or Surveillance test from the Millstone Unit 3 Technical Specification or Post Maintenance-Tests. For example, Technical Specifications Surveillance Tests results shall be used to verify the instrument setpoint pressures and associated delay times for initiation of the Safety Injection signal assumed in the analysis.

In addition, the Critical Characteristics (Parameters) will be verified using the design calculations, specifications, and vendor documents for  !

acceptability. For example, the maximum heat removal rate of the [

containment fan coil units shall be verified by reviewing vendor  !

tests / calculations to assure the functional capability of the units following a postulated LOCA.

4.7 Programmatic Resiews The programmatic reviews will be conducted by the PRG on a horizontal bases (across systems) for the purpose of determining if the actions taken by Northeast Utilities (NU) to correct previously identified problems have been effective and if the NU change processes are effective. The programmatic reviews will be performed in accordance with PI-MP3-04.

Licensee initiated Corractive Actions .

As part ofits Configuration Management Program (CMP), NU has 1 performed a vertical slice review of safety-significant systems and has i (19)

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/ i Northeast Utilities Millstone Unit 3 h " "'

ICAVP Audit Plan Revision 2 ,

identified degraded or non-conforming conditions. For each of these degraded or non-confonning conditions NU is initiating corrective actions.

i Additionally, NU has implemented corrective actions for design deficiencies identified by the architect engineer before initial operation i

(EADCR's). The programmatic review will assess the adequacy of these corrective actions. This review will be conducted for all corrective actions 3 associated with the systems included in the scope of the ICAVP vertical  ;

slice system reviews, and for a representative sample of corrective actions associated with the other NU completed CMP vertical slice systems. .

The NU CMP findings / corrective action documents will be obtained both for the systems in the scope of the ICAVP vertical slice system review and for systems outside the ICAVP vertical slice system review.

A checklist will be prepared for the review of corrective actions. Using the checklist, the PRG Verifier will assess the corrective actions for adequacy of the following:

a. Root cause determination - the extent to which plant processes and procedures are affected.

b. Extent of condition determination - the extent to which other systems, structures or components are affected.

5

c. Plant restart - is the corrective action required prior to restart?

d. Content - is the corrective action adequate in resolving the issue?

QAnge Processes NU's current plant change processes will be reviewed for both their C adequacy with respect to industry standards and for the effectiveness by i which they are being implemented. Both design change processes and  !

procedure change processes will be included in this review.

As part of the ICAVP system reviews, the SRG and the ORG will assess

he plant modifications made on the selected systems. This review will evaluate the effectiveness of the change processes involved in these ,

modifications (i.e. if the resulting modification is found to be acceptable, it  !

can be inferred that the process used in performing the modification is J acceptable), in addition to this system review, specific process related ,

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Northeast Utilities M "'"g ICAVP Audit Plan l MillsMne Unit 3.~ Revision 2

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L reviews will also be performed by the PRG. The various change processes ,

reviewed will include the following: .;

I Process Corr ==edlem MP3 Procedure i~ drawings NUC DCM Chapter 7-specifications NUC DCM Chapter 6 {

i calculations NUC DCM Chapter 5 procedures DCl, DC2, DC3, DC4 temporary alterations NGP 8.05  :

minor modifications NUC DCM Chapter 3 ,

modifications NUC DCM Chapter 3 i

' licensing documents - NGP-4.03 l l

vendor manuals NUC DCM Chapter 8 i like for like replacements NUC DCM Chapter 1 {

I setpoint changes NGP 3.16 The current MP3 procedure for the processes listed above will be evaluated  !

for its content and completeness. This evaluation will determine if the procedure exercises adequate controls on the change process and invokes appropriate interface reviews to assure the plant design bases and i

); configuration is maintained consistent with the licensing bases. The i evaluation will be based on guidance provided in the following:

Reg Guide 1.33, Quality Assurance Program Requirements (Operation)

NRC Inspection Manual s INPO guidelines

. INPO 87-006, Report on Configuration Management in the Nuclear Industry NEI guidelines  ;

I i

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M Northeast Utilities Millstone Unit 3

" M.h"'"e ICAVP Audit Plan Revision 2 ,

The adequacy of NU's implementation of the change process procedure will also be evaluated. Since the system review will assess the technical adequacy of the change, the programmatic review is intended to evaluate only the procedural adequacy of the change. The evaluation will determine if the current procedure is being followed, that the required checklists are being accurately and completely filled in, and that all other documentation is complete and accurate. This evaluation shall be performed for the changes made to the selected systems using the current procedures. If a suitable sample of these changes for a particular process is not captured in the system reviews, a suitable sample outside the ICAVP systems will be reviewed for both process implementation and technical adequacy.

In addition to the process and implementation reviews noted above, a review of select past changes on a plant-wide basis will also be made. For each of the change processes not generally associated with modifications, a random sample of changes made during each fNe-3 ear interval following receipt of OL will be reviewed for their technical a dequacy. The changes will be selected from various systems other than ths selected systems in order to maximize plant coverage. This review will assure that these past changes did not compromise the unit's design or licensing basis. The

" process specific questions" in checklist CK-MP3-04-02 in conjunction with applicable checklists from the SRG and ORG will be used to evaluate the technical adequacy of the changes.

4.8 Erocessinn Verification Team Findings When a member of the VT identifies a discrepant condition which does not appear to meet the requirements, he shall initiate a discrepancy report (DR) per PI-MP3-11. Exhibit 3 of this Audit Plan depicts the DR process.

Examples of discrepant conditions are a disagreement between the system design bases and the FS AR, the as-built configuration of a piping system and the piping analysis, or a change to maintenance procedures, which should have been made due to a plant modification, but was not. The DR will document the discrepant condition and the documents or walkdown reports that were reviewed to arrive at that conclusion. Other technical and administrative items will be included on the DR form to help track, trend and analyze the results of the verification program. The DR will be signed by the VT member and forwarded to the VT Group Lead. l i

The VT Group Lead will review each DR with the VT member for tehical adequacy, completeness, and whether that specific issue has (22)

ICAVP Audit Plan Northeast Utilities Millstone Unit 3

/p"" Revision 2 J

already been addressed by another DR or by an existing NU corrective ,

action document. The DR could be returned to the VT member for ,

additional information or investigation; or it could be accepted and signed i f

by the VT Group Lead; or it could be determined to be not valid. For any DR's determined to be not valid, the justification for this decision will be .  ;

dscumented c.n the DR and the DR will be signed by the VT member and the VT Group Levi. Ifvalid the VT Group Lead will forward the DR to the VT Manager.

The VT Manager will review each DR with the Group Leads for technical adequacy, completeness, and whether that specific issue has already been addressed by another DR or by an existing NU corrective action document. i The DR could be returned to the VT member for adoiuonal information or investigation; or it could be accepted and signed by the VT Manager; or it ,

could be determined to be not valid. For any DR's determined to be not valid, the justification for this decision will be documented on the DR and the DR will be signed by the VT member, VT Group Lead and VT Manager.  :

< The VT Manager will submit accepted DR's to the IRC for their review.

They will review the DR's for extent of the condition to confirm that the VT looked deep enough into the issue to ensure that the problem is fully scoped; they may make recommendations to the VT to look for similar

conditions in other areas or systems. The IRC may request that the VT member obtain additional information; they could accept the DR as written, whereupon the IRC Chairman would sign the DR and return it to the VT Manager, or the IRC may conclude the DR is not valid. If the VT member, VT Group Lead, and the VT Manager agree with the conclusion that the DR is not valid based on additional information, thosejustifications shall be documented on the DR and signed by the VT member, VT Group Lead,

.. and the VT Manages.

All DR's will be transmitted to the NRC, NEAC, and NU when the above process is completed. The DR's will be transmitted in accordance with the approved protocol. Since an important part of this project is to keep the public informed of the status and results, in addition to expected monthly ,

i meetings with the public, all DR's which are sent to NU and the NRC will be posted on the Internet World Wide Web 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after their submittal ,

to the NRC/NEAC/NU.

-(23).

8 Northeast Utilities Millstone Unit 3

• [#' /

ICAVP Audit Plan Revision 2 4.9 Review NU Resolution to Verification Team Findings As shown in Exhibit 3 the handling of NU's proposed resolution of the VT findings will follow a similar process as the generation of the findings. The resolution will be submitted to the VT member who initiated the DR the VT Group Lead and the VT Manager. If the proposed resolution is determined acceptable, it is forwarded to the IRC for their review. If both the VT Team r.nd the IRC find the NU resolution of the DR to be adequate, NU, the NEAC and the NRC will be notified by the method established in the protocol. At this point we will post the accepted resolutions to the findings on the Intemet bulletin board established for public access. If NU's resolution to the finding is not considered adequate by the VT member, VT management, or the IRC, it will be returned to NU and sent in parallel to the NRC and the NEAC with a written explanation and bases for why the team did not consider it to be adequate. It is expected that NU would reconsider the irformation and resubmit it to the VT. Meetings between NU and the VT may be required to reach an understanding and resolution of particuiar issues. These meetings would be requested and held in accordance with the established protocol.

5.0 SYSTEM SELECTION CRITERI A At the public meetings on September 24,1996, the NRC indicated that they would select the systems for review rather than S&L. They also stated at those meetings that the NRC would decide on the number of systems to be selected for review.

As input to the NRC staff, S&L recommendations on the number and selection of the systems for review are provided below.

Sargent & Lundy's system selection criteria are based on NRC Inspection Manual Chapter 2535, Design Verification Program, modified to be appropriate to this situation of an operating unit. These criteria would be applied to tne list of approximately 20 systems for which the NU line organization and the NU oversight organization will have completed their review also.

1) The systems should be in the top quartile of risk significant or safety related systems.

2) The systems should involve a full cross section of engineering disciplines with internal and external organizational interfaces, such as NSSS supplier, component vendor, and engineering service organization.

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I Northeast Utilities " g ""' ICAVP Audit Plan Millstone Unit 3 / Revision 2 l

3) The oncept and implementation of the design should not be limited to the NSSS supplier or another single component supplier.

4) The systems should be generally repesentative of the safety related features ofother systems.

L L 5) The systems should be reasonably complex, requiring multiple operating modes.

6) The systems should have multiple, non-trivial modifications performed on it 3-since initial licensing, preferable by different design organizations.

i l

L With the likely selection of four systems, it is not necessary that every system meet all of the above criteria. However, each system should meet as many of the criteria as possible and each of the criteria should be met by at least two of the selected systems. The system selection may of course also be weighed more heavily to concentrate on specific known problem issues at Millstone Unit 3.

6.0 PROJECT DEpVERABLES -

.)

Deliverables for this project will include a final report which describes the scope of I the ICAVP, the methodology used, the results of the review and the conclusions regarding the adequacy of the configuration management program and the conrective action program at Millstone Unit 3. Exhibit 4 of this audit plan presents an outline of the final report.

7.0 PROJECT TEAM The current project team members are identified on the project roster included herein as Exhibit 5. The project organization chait is included herein as Exhibit 1.

Changes or additions to the project team will be communicated to the NRC in accordance with PI MP3-08, when splicable, and will not require a revision to '

the audit plan. The compilation of.Project Team position descriptions, personnel resumes, and conflict ofinterest statements is provided in Appendix A to this Audit Plan.

The selection of personnel for the ICAVP was based on their qualifications to perform the assigned reviews, their financial and technical independence from the Unit being reviewed, and NRC acceptance of the personnel. Substitution of existing personnel on the team may be required to add expertise or manpower to e fully investigate issues which are identified during the course of the program. A

25)

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4 Northeast Utilities ICAVP Audit Plan Millstone Unit 3 /@ " "' Revision 2 specific procedure (PI-MP3-08) has been written to govern the substitution and addition of personnel to the project team. NRC notification and approval is required. .

8.0 GOVERNING PROCEDURES AND TRAINING The work for this project is classified as Nuclear Safety Related and shall be performed in accordance with this audit plan, SdL's Quality Assurance Program and the following project instmetions:

Proiect Instruction No. T_ ills PI-MP3-01 ICAVP Conununications Protocol PI-MP3-02 Review of System Design for Compliance with Design and Licensing Bases PI-MP3-03 Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration

-Control PI-MP3-04 Programmatic Reviews PI-MP3-05 Physical Plant Configuration Walkdowns PI-MP3-06 Operations and Maintenance and Testing Procedures and Training Documentation Reviews PI-MP3-07 Review of Accident Mitigation Systems l PI-MP3-08 ICAVP Team Personnel Substitution and/or Addition l i

PI-MP3-09 Preparation and Approval of Checklists PI-MP3-10 Differing Professional Opinions PI-MP3-11 Discrepancy Report Submittal and Closure PI-MP3-12 Project File Index The project team members will be trained on the applicable S&L QA procedures and en the ICAVP project instmetions. The project team members will also be trained on any revisions to the applicable project instructions. Training will also  :

include beckground information about NU's activities over the recent years that led up to issuance of the NRC order requiring the ICAVP to be conducted. This portion of the training will include a review of the order itself, and the subsequent doc"ments that have p; ovided details and supporting information about the order.

Pror.ct *. cam memh:rs will be trained in the fundamentals ofinspection processes and techniques. New personnel added to the project team will be trained in the (26)

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Northeast Utilities ICAVP Audit Plan

~

Millstone Unit 3 /@ Revision 2 j applicable items prior to beginning their review activities. Training records will be

' maintained in accordance with S&L QA procedures. l 1

The project team members are expected to conduct their evaluations with a questioning attitude about the adequacy ofitems that are being reviewed and i

evaluated. Additionally, they are expected te use a conservative threshold for data interpretation and decision about adequacy ofitems reviewed.  ;

3 The Manager of the S&L Quality Assurance Division will select an audit team to i

monitor the activities of the project as it progresses. Their review will be to ensure that the process used by the project team is in accordance with the NRC Confirmatory Order and the procedures developed to implement those requirements. The QA auditors will review selected DR's identified by the VT and i will pay particular attention to any DR's that are determined to be not valid. A l summary of the QA activities related to the ICAVP and their conclusions will be j included as part of the ICAVP final report. P b

9.0 EXTERNAL PROJECT INTERFACES The purpose of this project is to obtain an unbiased assessment of the Millstone -

r

. Unit 3 configuration management and corrective action programs. Therefore, i

every reasonable effort must be made to assure that the observations and conclusions made are the result ofour Project Team's own independent assessment and not influenced or biased by outside organizations. To maintain this assurance ofindependence, communications with outside organizations will be in accordance with PI-MP3-01, "ICAVP Communication Protocol."

10.0 LOCATION OF WORK ,

The S&L VT with the exception of the CRG subgroup of the SRG will be stationed in S&L's Chicago offices. The CRG will be stationed at an offsite office located near the Millstone station. ,

The project team members stationed in the Chicago offices may make periodic trips to the S&L offsite office and to the station as needed to gather documentation, interview NU personnel, or to attend meetings to discuss NU proposed resolutions to S&L discrepancy reports. .

e j (27) c

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Northeast Utilities ICAVP Audit Plan

' Millstone Unit 3 : /- Revision 2

'i 11.0 PROJECT SCHEDULE .,

- The current project schedule is illustrated in the bar chart included herein as Exhibit 6 for information only. Schedule changes will be communicated with NU, NRC and NEAC directly, when appropriate, and will not require a revision to this audit plan.

, ' 12.0 . BUDGET DATA Applicable project number and task codes for this project are listed in Exhibit 7.

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ICAVP Project i Organization Chart  :

Northeast Utilities NRC System Al AN B. A. Erler Project Director Quality Assurance D. K. Schopfer A. K. Singh

---

Verification IR Committee Team Manager Chairman i

IR Committee System O&M and Accident Prograramatic Review Lead Testing Mitigation Review Lead K. J. Green Review Lead Review Lead A. A. Neri T.J.Ryan R. E. Querio R. D. Raheja D. P. Galle Physical Configuration Review Lead R. E. Kropp ,

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Document Reasons for- Review NU Response !  !

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1 Outline ICAVP Final Report .

Eacentive Summary ICAVP Oversight Team Report  !

Sargent & Lundy Quality Assurance Division Report I. Introduction A. Background B. Objective C. Scope D. Methodology i E. Pmject Orgamration i II. Conclusions t A. OverallConclusion '

B. Design ControlProcess C. Design Basis /T k* acing Basis Consistency  !

D. Design Adequacy E. As-built Plant Configuration F. Trantiation of design into plant maintenance and operation -

G. Adequacy ofTesting Programs '

IL Applicability ofselected sample to all Millstone 3 systems '

I. Correenve Action Program III. Review Results A. System 1 B. System 2 C. System 3  :

D. System 4 E. Accident Migitation Systems F. Corrective Action Program G. Change Processes i Appendices

1. Project Team

2. Objectivity Questionnaires *

3. Review Records 4 Discrepancy Reports

5. NU Resolutions

. 6. Project Manual

7. 1.ist of Checklists t ' s

Exhibit 5 Millstone Unit 3 ICAVP Personnel Page 1 of 2 l

NRC l C-O-l ICAVP Project Team Position Interview I Statement Resunw Management Team I

18. A. Erler Prolect Director X i X X lD. K. Schopfer lVenfication Team Manager +

X l X X internal Review Committee l l l A. K. Singh glRC Chairman i X  ! X X D. P. Galle :lRC Member i X l X X K. J. Green llRC Member X i X X W. G. Schwartz ilRC Member X X X l

Verification Team SRGlA. A. Neri SRG Lead X X X iR. Hameetman l Lead Verifier (Mechanical) X X K. R. Novatny

! Lead Venfier(Mechanical) X X X D. A. Schroeder iLead Verifier (Electdcal) X X X

l. Wamer iLead Verifier (Electncal) X X X 'l J. DeMarco l Lead Verifier (l&C) X X X N. Klaic l Lead Verifier (Structural) X X X J. L Tenwinkel jVenfier X X X R Hindia IVenfier X X X l C. M. Launi !Venfier X  ! X X

.J. M. Rich ]~[ .Venfier X  ! X X

!J. W. Johnson iVerifier l X X  ! X jP. R. Olson jVedfier -

! X X  ! X M. D. Stout iVerifier  ! X l X  ! X S. Yassin :Venfier  ! X X X

' A. Prakash 'Venfier X

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X X 7A. Patel Verifier X X X B. J. Dionne Venfier X X X J. F. Wakeland Venfier X D. J. Kendall Ven0er X X X R. Morton Venfier X X , X

_CRG;R. E. Kropg,_ CRG Lead X X X iT. L. Sarver Lead Venfier X X X

!J. W. Read Lead Verifier X X X

' R. M. Tamera Verifier X X X R. Lukes Venfier X X X

--. A_._Serrano - Venfier _. _ .- _ _ X __-.. - X -- X

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Rd'Discipline LeadVerifier ~[i['i _]{_. X

{. ],_ X X X W. J. Johnson Radiological Discipline Venfier X _X _ _,_ X _

_2 T.j_ Kang _ , System Venfier X X X

..L. AL Benggtt System Venfier X X X

, _3 E._Ba[qs System Vinfier _ _ _ X X J. Kish System Verifier X X X

Exhibit 5 Millstone Unit 3 ICAVP Personnel Page 2 of 2 NRC C-O-l ICAVP Project Team Position I interview i Statement Resume t .I t'

PRGJ. J. Ryan PRG Lead i -X X X

!To Be Determined . Verifier  !  !

lR. P. Shepyard Venfier _

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X l X rJ. E. Dombrowski FVerifier X X ,

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ORG Lead X i X X

{T. Tamlyn  : Lead Verifier / Venfier X i X X

'R. Spear iLead Venfier / Venfier  ! X '

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!R. J. Ungeran l Lead Verifier / Venfier X ; X X lJ. A. Kleam ' Lead Verifier / Verifier X ! X X iW. Pinner ' Lead Verifier / Verifier X X X i i f

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h  ? ARG Approw IJrd 3 Ao,1t Plan g

4'2997 5/16G7 8' Mobdrze and Tran Pror ect ieam 5/125E 5/D97 ' '

S tJU completes CMP on Was i systems 89 Und 3 g _.

5/27G7 Sr27S7  :

4y 7 13 tJRC Eelut test 2 Und 3 systems 5/27S 7 Sr2907 i 11 04 tan i het i s.y:. tem speufv: documents for fu st 2 systems S/b97 51257 ,

12 M+Muu w/ tJl8, tIRC, tJL AC to ayee on I st 2 system boundane *?/497 6/437 ' '

h3 ihyn ARG ruew (1 mr 2) / select tind 3 cti al characts btes 5/27S7 &13S7 ' '

14 tJRC ruww atxt acwt.t thd 3 cntical charederistics 671007 6/% 97 15 PRG perform t Ant 3 process reuew 5/27S7 6fnS7 16 PHG prepara t 44 3 unplemerAation rewew checidtst 6/10 S7 g

6/23.97 17 PRG snt ne thd 3 emplementaten checkhst to flRC tar approwl 6/2497 6/26 S 7 18 flRC approw PRG Uni 3 process implementation checklist 7/2197 7/n97 19 CorripW thd 3 ARG re*w 6/2407 875 7 20 Begin SRG. CRG ORG rewen on fust 2 Unt 3 systems (Tier 1) 5/30S7 7/18S7 '

21 iIRC lC AVP Implemertaten Inspecten 7/7S7 8/1S7 2 riu congdetes CMP on Waw 2 & 3 systems for Unt 3 7/1497 7/1497

23 fJRC Select rema

neng Una 3 systems 7n4S7 7 ASS 7

} _. . _ _ _

2 C' l 24 Otf ain ikut 3 spiem spec;fr documents for remairung systems 7/17S7 7/30S7 l -  %%

[ 25 Meeting w/ tJU. tJRC. tJEAC to agree on rem. system bounda<ies 7/22 S 7 7/22S 7 t "S

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! C VIUMC AVRSCHUhfCVP 1&3 MPP _

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hJortheast Utilities - Millstone Units 1 & 3 5*'9'" '"adr ICAVP Implementation Schedule "

rch I AprH l May 3"

_ LD _ !ask Name _____ _ Start Finish 3/16 l 3/23 l 500 l 48 l 4/13 l 4'20 l W27 l 5/4 l 5/11 15/18 l SCS 6/1 l 6/B _

28 PRG perform ur.c 3 mplemert enon rewow 7C497 8/2DS7 27 PRG pw term t hit 3 corret the at tion reh fV2G97 h5hhh 28 PRG tewew I hit 3 past deshyi citarnjes OC497 7/29 S 7 2b SRG. CRG OHG rewew remaerwy Unit 3 systems (Iset 1) 70157 9/497 33 Process and Report und 3 findings 6/2307 9/1187 31 t#U Prowde Phymsed Resouon to und 3 findings 05197 Or1U7

~

32 Hewsw f JU Preposed Resoluhon to Unt 3 fn$ags b57 9/2SS7 3 Psepain ihut 3 F mal Reput 9/12S 7 10b97 34 Gubnut Un.t 1 Audt Plan to f 4RC for approval 3/173 7 3/17S7 g  ;

35 Dewtop Und 1 rouew checkhsts 3/ITB7 4/3G7 36 flHC ee. sew Und 1 Ataid Pt.sq & Pts and psoude commerts 3/2097 411/97 37 ,

S&L resotw / nworporate f 3RC comments & resubmt 5/1907 6/2S7 ' '

38 tJHC Ag9mm (ind 1 Aemit PLui 60S7 6f30S7 ' '

5 33 Obtain non-system specatu, und 1 d%uments G'3.97 6/30S7 43 NU comptetes CMP discovery on Wave 1 systems for Unt 1 7/2207 7/22/97 41 f1HC Selmt fat,t J l And 1 sphmis 7/2257 7/2497 42 Oua.n Unit I system speatic documerits for 1st 2 systems 7/25 S 7 8/7S7 43 Meeting w/ fJtt IIRC, TJEAC to agree on 1st 2 system boundarte 7t30S7 7/30 S 7 44 Dotyn ARG endu,y (Tier 2) / selet.t ihit I utk.at clEracteristics 119 7 7/2107 45 flHC rew:w arvi sccept und t udical characteristics 7/1697 8G97 46 PRG perform Una 1 process review 7I187 7/15S7 47 PRG prepare Und 1 implementsNon rewsw checklist 3/997 7/15/97 48 PRG sadima Una 1 Implementation checklist to IkC for opproval 7/1897 51 5 i 49 fJRC approve PRG Und 1 process implementation checklist 7/24S 7 8/13/97 " c' yg 60 Complete und 1 ARG rowew 701/97 I u **

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C VitNCAVPtSCHED9CVP_1&3 MPP Page 2

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Northeast Utilities - Millstone Units 1 & 3 ~ s.rgeni a way 4f2erS7 ICAVP implementation Schedule

- - -_.-. - - ~ _ _

reh 1- Apre l Mer J

• O Tad Name . , , Start Firdsh 3f16 l 3r23 l 300 l 42 l 4rt3 l 4GD l 4/27 l Sd4 l S/11 l 5/18 l 5/25 aft l Se St Begn SRG. CRG ORG rewres on trst 2 One 1 systems (Ttot 1) 7/25G7 Of1267 _j '

. __ _; ..:_ , _ _ _ -u_._.- _ . _ _ _ _ _ 'r 82 f 40 compkdes CMP on Wave 2 & 3 systems for Une 1 _-, 9Q97 IE2G7

_ _ _ _ .53 fiRC' Sekt rammrung Und 1 systems 9/2S7 Of4G7  ;

- .: i 54 e OtAam Unt 1 system speci e f documerts for remarung systems ~ . .

9597 Bf18G7 l

65 Meetog wt fitI, f 4RC. ilEAO to a.yee on tem system t)oundmies EV10G7 9/1067 _

- 56 . PRG perform tJnt I unphnnertsum reWw 95G7 10/207 57 .. f-74G gwikum t hit I rmsinse artkin restew 9/12/97 10f16S7

~ 58 ; PRG fews 1W 1 cast desgn changes 7/1897 8/19s7 1

69 Skb. Chid. ORG reoew remanng Una 1 systems (Tier 1) Gr1997' 10/23G7 I 60 Process and Report Une 1 Findings 8/15 S7 11/4G7

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61 i10 Prow:se Proposed Reschison to Una 1 todings 8/22S 7 11/1107 g

. C2 Re4+w till Psnposed ResohAkm to urd 1 findings 8/2997 11/1807 63 Prepare the i Fkul Re pest t15G7 11/25G7 I

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_ n Northeast Utilities - Millstone Units 1 & 3 8r 5"s"d ""a'*rst 4c ICAVP Implementation Schedule -

888 383_. ] ugust l September l October l Stoveseber

. ID .

1 W114 f NZ2&ZL l.. l]@_ .... . ._

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S/15 . ..04 l , 2_. . . l f/29 j

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ICAVP Implementation Schedule

[ I August l September l October November

. 10 . st5 "* _.[G22.

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1 i

I Exhibit 7 l

l ICAVP Budget Data

Project No.: 9583-100 Task Codes: As follows:  ;

Task Code Description A00311 . Development of Project Manual A30020 Project Administration A30022 IRC Review of DRs and Disposition A30027 Development of Communications A30028 Development of Web Site 1

A30055 Training & Mobilization  ;

A30056ARG ARG - Perform Reviews / Report Findings -

A30056CRG CRG - Perform Reviews / Report Findings A300560RG ORG - Perform Reviews / Report Findings A30056PRG PRG - Perform Reviews / Report Findings A30056SRG SRG - Perform Reviews / Report Findings A30057 Evaluate Resolution of Finding:;

A30058 Final Report c

F w.. e .-.,y,. --