ML20140D799

Rev 1 to Independent Corrective Action Verification Program Millstone Unit 2 - Audit Plan

ML20140D799
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Site:	Millstone
Issue date:	06/09/1997
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References
PROC-970609, NUDOCS 9706110093
Download: ML20140D799 (190)

Text

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l RARSONS POWER .

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l INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM MILLSTONE UNIT 2 '

AUDIT PLAN l

Revision 1

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Prepared By: Ad# -

Date: June 9,1997 l Deputy Project Dir,ector Approved By: k/[d Date: June 9,1997 l iger, Company Qualitf Program Approved By: (d IA7 Date: June 9,1997 l Project Director l

l 9706110093 970609 PDR ADOCK 05000336 l s P PDR l w

- PARSONSPOMR -

l Audit Plan Revision 1 June 9,1997 l

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MILIATONE UNIT 2 AUDIT PLAN REVISION IDG Section Ervision No. Description Dalc l

All 0 Initial Issue April 3,1997  ;

l All 1 Incorporation of NRC Comments June 9,1997 l

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'Ihis list delineates sections of this manual that are currently in effect. The latest changes are indicated by a vertical line in the right hand margin of the affected pages, k

Audit Plan Revision 1 I June 9,1997

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i MIIIRTONE UNIT 2 AUDIT PLAN LIST OF EFFECTIVE PAGES Page No. Revision No. Page No. Revision No.

i 1 61 1 I il 1 6-2 1 l lii 1 6-3 1 iv 1 7-1 1 1-1 1 7-2 1 2-1 1 l

3-1 1 3-2 1 3-3 1 1

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3-5 1 34 1 4-1 1 4-2 1 4-3 1 4-4 1 I 4-5 1 44 1 4-7 1

4-8 1 4-9 1 4-10 1 4-11 1 4-12 1 4-13 1 4-14 1 4-15 1 4-16 1 4-17 1 4-18 1 4-19 1 4-20 1 4-21 1 4-22 1 4-23 1 4-24 '

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- PARSOES POWER - i Audit Pi n Revision 1 I ii June 9,1997

i MILIETONE UNIT 2 ICAVP AUDIT PLAN TABLE OF CONTENTS -

Section Iliin P_ age

1.0 INTRODUCTION

1-1 2.0 OBJECTIVES 2-1 3.0 ORGANIZATION 3-1 3.1 Team Member Responsibilities 3-1 3.2 Technical Advisory Group 3-4 3.3 Quality Assurance 3-4 3.4 Assignment of Staff 3-5 3.5 Location of Work 3-6 4.0 APPROACH TO ICAVP AUDIT 4-1 4,1 System Vertical Slice Review (Tier 1) 4-3 4.2 Accident Mitigation Systems Review (Tier 2) 4-10 O 4.3 4.4 4.5 Process Review (Tier 3)

Regulatory Review 4-16 4-23 ,

ICAVP Acceptance Criteria 4-26 l 4.6 Project Procedures & Instructions 4-26 l l

5.0 DISCREPANCY REPORTS 5-1 l 5.1 Identification, Evaluation, and Reporting of Discrepancies 5-1 5.2 Review of Proposed Response to Discrepancies 5-1 6.0 ICAVP FINAL REPORT 6-1 6.1 Compile and Assess System Reports 6-1 1 6.2 keview of NNECo Corrective Actions 6-1 l l 6.3 Prepare ICAVP Final Report 6-2 6.4 Issue ICAVP Final Report 6-2

,6.5 Project Closecut and Records Turnover 6-2 7.0 SCHEDULE 7-1 i

Audit Plan Revision 1 ui June 9,1997

MILIETONE UNIT 2 ICAVP O EXmBirS l

EXmBIT NO. TITLE PAGE 3-1 ICAVP Project Organization 3-2 4-1 Approach to ICAVP 4-2 l 4-2 System Vertical Slice Review 4-5 4-3 Accident Mitigation Systems Review 4-12 4-4 Critical Safety Function Diagram 4-14 4-5 Tier 3 Process Summary 4-17 4-6 Regulatory Review 4-25 4-7 Project Procedures & Instructions 4-27 I O- 5-1 Discrepancy Reports 5-3 l l

l 6-1 ICAVP Final Report Outline 6-3 7-1 Project Schedule 7-2 l l

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Audit Plan Revision 1 iv June 9,1997 l

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1.0 INTRODUCTION

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(,) The purpose of the Independent Corrective Action Verification Program (ICAVP) is 1

to provide the Nuclear Regulatory Commission (NRC), Northeast Nuclear Energy Company (NNECo), and the public with an independent review to confirm the adequacy of NNECo's efforts to establish that Millstone Nuclear Power Station Unit 2 physical and functional characteristics are in conformance with its licensing and design bases.

On August 14,1996, the NRC issued a confirmatory order requiring completion of an ICAVP before the restart of any Millstone Unit. The scope of the ICAVP will encompass all documented modifications made to the selected systems since initial licensing and will include:

1. Review of engineering design and configuration control processes,

2. Verification of current, as-modified conditions against design and licensing bases documentation,

3. Verification that the design and licensing bases have been translated into (3 operating procedures, and maintenance and test procedures, V

4. Verification of system performance through review of specific test records and/or observation of selected testing,

5. Review of proposed and implemented corrective actions for licensee-identified design deficiencies The ICAVP Audit Plan will implement the ICAVP contractor portions of the August 14,1996 Confirmatory Order and the NRC Oversight Plan.

The ICAVP Audit Plan will employ the approach noted below for assessing Millstone Unit 2 effectiveness at identifying and correcting licensing bases deficiencies. The scope of the ICAVP Audit will provide confidence that Millstone Unit 2 conforms to its design and licensing bases through the following audit activities:

• Vertical Slice System Review of selected systems (Tier 1) e Review of Accident Mitigation Systems (Tier 2) e Review of various design change processes (Tier 3)

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• Regulatory Review

- PARSON 8 P8WER -

Audit Plan Revision 1 1-1 June 9,1997

2.0 OBJECTIVES The objective of the ICAVP, as stated in the August 14,1996 NRC Confirmatory -

Order, is to confirm that Millstone Unit 2 physical and functional characteristics are in conformance with its licensing and design bases. The ICAVP audit is expected to provide independent verification, beyond NNECo's quality assurance and j management oversight, that NNECo has: i e identified and satisfactorily resolved existing non-conformances with the design and licensing bases, e Documented and utilized the licensing and design bases to resolve 4

nonconformances, 1 l

l l . Established programs, processes, and procedures for effective configuration management in the future i NNECo's programs include efforts to identify and understand the root causes of the i

licensing and design basis issues that led to NRC issuance of the 10 CFR 50.54 (f) letters to NNECo and to implement corrective actions to ensure NNECo will

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maintain the plant's configuration and compliance with its design and licensing bases.

NNECo has indicated that the scope of its corrective programs will include those j systems that it has categorized as either Group 1 (safety-related and risk-significant) l or Group 2 (safety-related or risk significant), using criteria developed in carrying out i the Maintenance Rule. The ICAVP audit will provide insights into the effectiveness  ;

i of the Millstone Unit 2 programs so that the results can be reasonably extrapolated to 1 the structures, systems, and components that were not reviewed in the ICAVP audit.  ;

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s 3.0 ORGANIZATION The Millstone Unit 2 ICAVP Project organization that will implement the ICAVP

• Audit Plan is shown in Exhibit 3-1. The following project organization responsibilities are discussed in this section.

• Team Member responsibilities e Technical Advisory Group

= Quality Assurance

• Assignment of Staff a Location of Work 3.1 TEAM MEMBER RESPONSIBILITIES The Millstone Unit 2 ICAVP Audit Team is based on key project personnel who will be assisted by a core team of technical specialists and additional support resources as required. Responsibilities of Project Director, Deputy Director, Group Leaders, Core Team personnel and support resources are:

Project Director Overall management of the task will be provided by the Parsons Power (Parsons)

Project Director. He will be responsible for the task schedule, budget, senior client interface, and compliance to the NNECo contract requirements. He will be the primary interface with NNECo and the NRC.

The NRC and the Connecticut Nuclear Energy Advisory Council (NEAC) have established a memorandum of understanding that permits NEAC to participate and/or observe NRC's oversight activities for the ICAVP. The NRC is responsible for interface and communication with NEAC.

Deputy Project Director The Deputy Project Director will assist the Project Director in the overall management of the task. He will be responsible for compliance to the ICAVP Audit Plan and the technical adequacy of the final reports.

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Eshibit 3-1 MILLSTONE UNIT 2 - ICAVP PROJECT ORGANIZATION i I

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Parsons Quality W Manager '**l President I

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-- '---- Project Director Project Manager Deputy Technical Project Director Advisory Group 1

Regulatory System Review- Accident Support TierI Mitigation System geyyew - Tier 3 W

Review - Tier 2 Support I

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Mechanical Electrical I&C "" E Structural Systems Systeens Systems Reviews %s ns Specialists t

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, Group Leaders t

v) The Group Leaders will be responsible to the Deputy Project Director for managing -

their assigned resources to complete the assigned items in their respective project areas. They are responsible for compliance to the ICAVP Audit Plan and the technical adequacy of their deliverables. They will be actively involved in the performance of the work in their respective project areas. Group Leads will be assigned for each of the following project areas:

• System Reviews - Tier 1 (lead assigned for each system reviewed)

. Accident Mitigation System Review - Tier 2

• Process Model and Design Control Review - Tier 3

• Regulatory Support l

• Project Support Core Team Personnel The Core Team has been selected based upon experience and particular areas of expertise. They are responsible for the performance of the systems audits, regulatory

- reviews, process review, document review, technical research and the generation of the d,y necessary reports in their respective areas. These personnel work directly for the Group Leaders. The mechanical, structural, civil, electrical and instrumentation engineers have been selected because of their expertise in nuclear plant designs, modifications, assessments and programmatic knowledge. The operations specialists bring specific experience in operations, maintenance, procurement, configuration management and regulatory compliance. Technical specialists in specific areas, e.g.,

Equipment Qualification, will be utilized on an "as needed" basis across all inspection teams rather than being assigned to only one team.

Support Resources Support resources work for the Group Lead of Project Support and provide the following support functions for ICAVP activities:

• Scheduling and Project Controls

. Administrative / Clerical

• Information Services

• Document Control

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Audit Report Revision 1 3-3 June 9,1997

i rm 3.2 TECIINICAL ADVISORY GROUP

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An advisory group of industry experts will essist with ICAVP Audit Plan implementation and other activities as assigned by the ICAVP Project Deputy Director. The ICAVP Deputy Project Director will convene the entire group or selected members of the advisory group based on the activity being performed.

3.2.1 Resnonsibilities The Technical Advisory Group (TAG) will have the following responsibilities:

• The TAG provides advice, expert technical opinions and review services to the ICAVP Audit Team The TAG will review the ICAVP Final Report and the individual reports from the various inspections and audits performed by the ICAVP Audit Team (s).

Refer to Section 3.2.2 ror TAG review of the ICAVP final report.

• The TAG will review all discrepancy reports and the ICAVP Audit Team review of NNECo's proposed resolution.

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• The TAG will review all Differing Professional Opinions 3.2.2 Final Conclusions l

The TAG will prepare a separate section of the Final Report documenting their observations and opmions.

33 QUALITY ASSURANCE Parsons overall Quality System is described in Parsons Power Quality Management Manual (QMM) which incorporates the principles of Total Quality Management.

Quality Assurance (QA) activities shall be performed in accordance with the requirements of the Parsons Power Nuclear Quality Assurance Program, which is docuinented in Addendum 2 of the Parson's Quality Management Manual (QMM).

This program meets the requirements of 10CFR50, Appendix B, and ANSI N45.2.

Engineering activities shall be performed in accordance with the programmatic elements of the Company Procedures Manual (CPM) as augmented by Project Procedures and Instructions which implements the requirements of the QMM.

- PAR 88Es P9WER -

Audit Report Revision 1 3-4 June 9,1997

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l 3.3.1 Mananer of Company Ouality q

b The Manager of Company Quality (MCQ) has been assigned the responsibility for -

1 monitoring effective implementation of the Parsons Power Nuclear Quality Program.

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The MCQ reports directly to the President of Parsons Power and has the independence, freedom and authority to assess the effectiveness of quality activities and to provide mechanisms to initiate corrective measures when necessary.

The MCQ is assigned to this project and directs all QA Program activities for this Project. The MCQ serves as the primary quality interface betmen the project and other Parsons Power units which contribute to the QA Program.

The MCQ will routinely review all aspects of the Quality Program accomp!'shments and status. Evidence of deficiencies in procedures, processes, or systems shall prompt appropriate corrective action.

3.3.2 Internal Audits and Surveillances The project may be audited through the Corporate Internal QA Audit Program.

p Audits will be planned, scheduled, coordinated, and performed in accordance with V Parsons internal procedures. Audits will be performed by properly trained, experienced, and certified personnel not engaged in the activity being audited.

Surveillances may be performed at any time during the course of the project activities.  :

These surveillances shall follow the guidelines of the ASQC Surveillance Handbook and Guidelines. Surveillances will be performed using applicable elements of internal l audit procedures, with the intent to evaluate and improve both performance and process. Surveillances should be in-process evolutions. Personnel trained in auditing )

techniques will be utilized to perform these surveillances.

3.4 ASSIGNMFRf OF STAFF All personnel assigned to the project, either Parsons employees or consultants, will be evalu'ated for their independence from Mills'one Unit 2 design and design review j activities and their financial independence from Northeast Utilities. All personnel initially assigned to the project may be interviewed by the NRC and other interested parties [i.e., Connecticut Nuclear Energy Advisory Committee (NAEC)). All personnel additions or substitutions will be processed in accordance with Project

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Audit Report Revision 1 3-5 hoe 9,1997

o Procedure PP-06, " Substitution or Addition of Personnel". NRC notification is f

. required for all personnel substitutions or additions.

l 3.5 IDCATION OF WORK l

The Millstone Unit 2 ICAVP Project Team will perform the majority of their work in the Parsons Power Reading, Pennsylvania offices. A small field office located near the Millstone Unit 2 site will be maintained to support site walkdowns, conferences, scheduled meetings and document retrieval. Millstone Unit 2 ICAVP Audit Team personnel will visit the field office and Millstone Unit 2 as required to support ICAVP information needs.

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'- h 4.0 APPROACH 'IO ICAVP AUDIT The ICAVP Audit Plan will employ the approach noted in Exhibit 4-1 for assessing -

Millstone Unit 2 effectiveness at identifying and correcting licensing bases deficiencies. he ICAVP audit is based on the requirements identified in the August 14,1996 Confirmatory Order and the ICAVP Oversight Plan issg2 as an attachment to SECY 97-003. The scope of the ICAVP Audit will provide umfidence that Millstone Unit 2 conforms to its design and licensing bases thr4h the following multi-tier approach:

System Vertical Slice Review (SVSR) of selected systems (Tier 1)

He objective of the SVSR inspection (Tier 1 Review) will be to confirm, through an inspection sample of at least 4 systems selected by the NRC, that the Millstone Unit 2's physical and functional characteristics are in conformance with its licensing and design bases, and encompass all l modifications made to the selected systems since initial licensing. In l addition, the inspection will examine the thoroughr.= of the Millstone l Unit 2's Corrective Action Plan for identifying and resolving

!- nonconformances with the design and licensing bases. The system reviews will be based in part on guidance provided by NRC Inspection Manual l Chapter 2535, " Design Verification Programs" and Inspection Procedure

( 93801, " Safety System Functional Inspection".

l Review of Accident Mitigation Systems (Tier 2) l The Tier 2 review will identify and evaluate " Critical Design j l

Characteristics" for Millstone Unit 2 accident mitigation systems. Critical l 1

Design Characteristics are identified by reviewing the functional i requirements of accident mitigation itystems and components to ensure  !

that they can perform their specified safety functions. i l'

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Review of Various Design Change Processes (Tier 3) j ne Tier 3 review will verify the adequacy of the programs currently -

l j being implemented by NNECo which are directed at identifying and I resolving existing design and configuration management deficiencies associated with past change processes. This will be accomplished by a l

" horizontal slice" inspection of examples of past changes to the facility design, pranices, and documentation.

i A " going forward" evaluation of the effectiveness of the Millstone Unit 2 l

configuration management program effectiveness will be addressed by others and is not included in the review, Regulatory Review Selected Millstone Unit 2 Regulatory documents will be reviewed and l

summarized. He summary will key on required licensee actions, a review l of the licensee dxketed response, and a review of the current Updated Final Safety Analysis Report. Specific items identified will be verified l within the System Vertical Slice Review (Tier 1), Accident Mitigation System Review (Tier 2), or Process Review (Tier 3), as appropriate.

l 4.1 SYSTEM VERTICAL SLICE REVIEW (Tier 1) ne objective of the System Vertical Slice Review (SVSR) inspection of the j Independent Corrective Action Verification Program (ICAVP) will be to confirm, through an inspection sample of at least 4 systems, that the Millstone Unit 2's physical i 1

and functional characteristics are in conformance with its licensing and design bases, and encompass all documented modifications made to the selected systems since initial licensing. In addition, the inspection will examine the thoroughness of the l

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Millstone Unit 2's Corrective Action Plan for identifying potential nonconformances l with the design and licensing bases.

l l Selected systems will be reviewed in depth, including design bases, impact on design bases by system modifications, safety margins, maintenance, operations, surveillance, training, and corrective actions for previously identified deficiencies. The system )

j reviews will be based in part on guidance provided by NRC Inspection Manual  !

j Chapter 2535 " Design Verification Programs" and Inspection Procedure 93801

- passessreu m - j Audit Plan Revision 1 4-3 June 9,1997 l

(~N " Safety System Functional Inspection".

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x.y Following system selection by the NRC, the SVSR will be performed as shown in -

Exhibit 4-2. Project Procedure PP-01 " System Vertical Slice Review" and Project Instruction PI-01 " Conduct of SVSR will be used to perform the inspection. The SVSR is based on the activities noted below and discussed in the following paragraphs:

• Select System for SVSR e Determine System Boundary

• Identify Licensing and Design Basis Requirements e Prepare System Specific Checklist e Evaluate System Configuration Management

• Prepare SVSR Final Report 4.1.1 Select Systems for SVSR Parsons Power Group has developed criteria for NRC use in selecting systems for the vertical slice review. The initial systems to be reviewed will be selected from those systems categorized as Group 1 using criteria developed as part of maintenance rule

{ implementation (10CFR50.65). Systems are categorized as Group 1 based safety related and risk significance. It is recommended that the NRC use an Expert Panel to participate in the selection process and make the final determination of system selection.

The Parsons Tier i system selection criteria will supplement the Maintenance Rule criteria (risk and safety significance) based system function, operational and configuration history, regulatory history, and professional opinion. A major factor that will be considered will be previous opportunities for introducing inappropriate changes to the system or design bases (a high number of modifications or significant system reconfigurations), and previous problems with the system (at both the plant level and industry wide).

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Audit Plan Revision 1 4-4 June 9,1997 I

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~ p EXIIIBIT 4-2 SYSTEM VERTICALSLICE REVIEW SYSTEM SELEC110N DEFINE FROM NTC  ;

SYSTEM '

BOUNDARY l +

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Define System

• Scope /BounJary 4 meetw h [

Considerations Regulatory Reqmrements + ]f LICENSING / DESIGN ' Current Licensmg Basis REQUIREhENTS AND Review CIIECKLIST Progrannatic + Y DEVELOPMENT Regulatory Inputs f

Design Basis I W Requirements Checkhst g ________________________________

y__________________

1 EVALUATE e e e CONFIGURATION Input to System Mod ls the Corr weActm Def Other g l MANAGEhENT g ,

AllMads Management Reviews of the system CONSIDERATIONS p List p System Mod q l y CAP Review Procedures Testing, Review l Walkdowns,etc. I Corrective Reviews Action List l System Mod Systema CAP System Requirement Checklist Requirement Checklist ConfigurationChecklist

> INSPECDON ACTIVmES BASED ON CIECKLIST REQUIREMENTS b

E Mechanical Training Prograrn Specialists y" Electrical P. - ._; and Technical Reps Conferences Walkdowns R[

.* g, IAC Civil as Required a

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Parsons will consider a system as a likely candidate for an'SVSR if the system: t

• Has experienced a high number of modifications. -

Has had a major modification or a number of major modifications involving a  ;

design change with internal interfaces between major discipline areas and/or '

external interfaces with the NSSS vendor, component vendors, and engineering ,

service organizations.

Has a high level of risk significance based on PRA insights as determined by a panel of individuals familiar with the Plant PRA.-

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Has an identified history of deficiencies or operating problems based on plant or industry operating experience.

' die NRC Expert Panel will make the final determination of the relative ranking of the systems based on the results of the system selection survey, system boundaries, industry experience, and their own knowledge of the systems and the requirements of the ICAVP. The NRC Expert Panel should bias their weighting for the selection of.

systems using consideration of issues identified as part of the August 14,1996 I confirmatory order.

Additional detail on system selection criteria is provided in PP-01, System Vertical Slice Review Procedure.

4.1.2 Determine System Boundary The System Boundary will define the scope of the SYSR in regards to the selected system. Interfaces with, and portions of other systems may be included within the boundary of the selected system to the extent they are necessary to support the functional requirements of the selected system. In additions, system boundaries may be defined at appropriate components that provide physical isolation, as long as the selected boundary does not split the component between systems. The NRC and NNE'Co will review the system boundary for agreement in interpretation of SYSR scope.

-PassessFeues-Audit Plan Revision 1 4-6 June 9,1997

[ ,q 4.1.3 Identify IJcensine and Damien n ic n e -A------ 2 U

j Following system selection and boundary determination, the SVSR Tier 1 Team will review appropriate licensing documentation, including the Updated Final Safety Analysis Report (UFSAR), Technical Specifications, and other regulatory and design documentation and list the Licensing and Design Bases requirements for the system.

These requirements will establish the inspection requirements criteria and will be itemized in the inspection system specific checklists.

4.1.4 Prenare Svytem Snecific Chekilst l The inspection team will review and assess pertinent design and operational aspects of the selected systems, using checklists based on functional system and design l engineering considerations. The checklists will be developed specifically for the Millstone Unit 2 system being inspected and will serve to maintain inspection focus and to ensure a complete and thorough review.

The checklists, incorporating the input of each inspector and the team leader, will be I

developed in a team environment to ensure maximizing the expertise of the entire group. They will be developed following the announcement of system selection. The checklists will stipulate inspection conditions for each inspector and will include  ;

inspection targets, validation, and verification requirements, and details of the current l and original license bases, system history and configuration. i The SVSR Team will use the checklists to guide the inspection process during major I

inspection activities such as:

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• Document and calculation review

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• System walkdowns 4.1.5 Evaluate System Confiruration Man ==ement The system vertical slice review (SVSR) will entail a comprehensive engineering revieiv of the selected systems by a team of mechanical, electrical, instrumentation &

control, maintenance and operations specialists. The team, supported by a staff of regulatory and nuclear licensing specialists, will employ a broad based but focused  !

examination process of sufficient depth to probe all aspects of the selected systems

, design, history and configuration. '

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Audit Plan Revision 1 l 4-7 June 9,1997 l

. Emphasis will be on verifying that the subject systems processes, practices and procedures used to perform engineering design, design change control document control and records updating cf the design bases have been successful in maintaining the system configuration in accordance with regulatory requirements. Operations, Maintenance, and Test Procedures will be reviewed to verify that correct licensing and design bases information have been incorporated into the procedures.

The SYSR Team will provide ongoing reports which will detail the status, on a system i specific basis, of the progress of the SYSR for each of the selected systems. As discrepancies are identified during the review, they will be immediately communicated to management for evaluation. Each discrepancy will be provided with a comp! ate

! description, including all peninent information per the requirements of Project Procedure PP-07 "" Discrepancy Reports."

l The anticipated sample size of 4 systems for the SVSR is predicated on the l assumption that the assessment will not find significant discrepancies. Additional systems may be added to the SVSR if the number of discrepancies encountered during I l

the SVSR meet the specified criteria for Tier 1 expansion. 1 Evaluation of configuration management considerations will be focused on licensing and design bases requirements. Evaluations and will utilize appropriate level documentation (drawings, calculations, design documents, etc.) to the inspection detail l necessary to verify and validate conformation to requirements. The vertical slice reviews will emphasize design control and will verify that:

• The current configuration accurately reflects the licensing-bases, including the l updated FSAR.

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• Calculations and analyses were performed using recognized and acceptable analytical methods and that assumptions made in calculations or analysis supporting changes are technically sound.

. . The results of calculations or analysis supporting the unmodified portions of the original configuration and design changes are reasonable (based on engineering judgment) for the scope of the change.

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Millstone Unit 2 considered the effect of a change on design margins and that d the design changes received the appropriate level of engineering and management review during the design phase and prior to implernentation.

o Millstone Unit 2 considered the effect of a change on pre-operational, startup or system baseline acceptance test results.

l Design changes are accurately reflected in operating, maintenance, and test l procedures, as well as in training meerials.

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Proposed design changes, subsequently canceled, were not replaced by procedural changes that imposed excessive burdens on plant operators.

Adequate control of operational procedures, maintenance procedures, test and l-L surveillance procedures, operator training e d control of the plant simulator ,

configuration.  !

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The current configuration is consistent with the licensing bases at the level of j detail contained in piping and instrumentation diagrams (P& ids) or system flow

, l j diagrams, piping isometric drawings, electrical single-line diagrams, and l l emergency, abnormal and normal operating procedures.  ;

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'Ihe analyzed configuration is consistent with the current plant configuration.

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. Equipment location and identification numbers are as indicated on the P&lD or process flow diagram, and equipment name plate data is consistent with design specifications and analyses.

The location of pipe supports, snubbers, and other pipe restraints is consistent with design specifications and piping stress analyses.

Divisional separation of safety-related systems, structures and components, l

seismic II/I, and other topics addressed by the licensee's hazards analyses are

' . reflected in the current plant configuration.

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4.1.6 Prenare SVSR Mnal haa t A SVSR Final Report will be developed for each system reviewed by the SVSR Team.

The Final Report will summarize the results of each system reviewed and will contain the details of all associated discrepancy reports. Included in the report will be an assessment of the Millstone Unit 2 licensing / design basis and adequacy of the configuration management program. The system final report will consist of, as a minimum, the sections noted below. The SVSR Final Report will be included in the overall ICAVP Report.

• Summary a System Description & Boundaries e Licensing and Design Basis Requirements Review e Configuration Management Review e Discrepancy Report Summary e Appendices 4.2 ACCIDENT MITIGATION SYS'TEMS REVIEW (Tier 2)

The Tier-2 portion of the ICAVP will identify and verify the " Critical Design O

V Characteristics" for the Millstone Unit 2 Plant as defined by reviewing accident mitigation systems requirements, and assessing critical design characteristics for systems and components to ensure that they can perform their specified safety functions.

Each characteristic will be identified from calculations, analyses and other documentary evidence that supports the Chapter 14 Analysis in the updated FSAR.

The review will be based in part on guidance drawn from Appendix E of NUREG-1397 "An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Industry."

Assessment of the critical design characteristics for the accident mitigation systems l will be performed in accordance with Project Procedure PP-02 " Accident Mitigation System Review." Exhibit 4-3 presents a summary of the review process. The accident mitigation systems review (AMSR) consists of the following major activities:

e Identification of Critical Design Characteristics e Preparation of Composite Characteristics Database 4

- NBOOOS POWII-Audit Plan Revision 1 4-10 June 9,1997

. Verification of Critical Design Characteristics '

s e Preparation of AMSR report 4.2.1 Identify Critical Design Characteristics '

In order to determine critical design characteristics, it is necessary to determine the critical functions that must be performed. A critical function is the set of actions, as a whole, that must take place in order to prevent or mitigate the effects of a Design Bases Events (DBEv), or reduce the consequences of an accident.  !

Chapter 14 of the updated Final Safety Analysis Report (FSAR) is the description of all credible accidents that will be addressed. The FSAR (updated) has been selected as the license Design Basis benchmark source, or that point where all changes that affect the ability of the plant to meet the critical function should have been captured. Based ,

l on this review, the DBEv are identified as: I J

e Incr2ase in Heat Removal by the Secondary System

)

e Decrease in Heat Removal by the Secondary System

. Decrease in Reactor Coolant System Flow i

g

• Reactivity and Power Distribution Anomalies

• Decrease in Reactor Coolant Inventory

. Radioactive Release from a Subsystem or Component e Non-Sta.alard Review Plan Events i i

Each DBEv requires a specific set of activities to occur for different plant

configurations in order to ensure that the plant is returned to and maintained in a safe

! condition. These activities are called " Critical Functions". Each of the Critical Functions will be developed to determine the critical actions between the different systems within the plant to ensure that all of the critical interfaces have been identified. For example, if the Critical Function is reactor core cooling, then there will be critical actions necessary in the delivery system to the reactor, the source of the water, the motive power for delivery, the source of the motive power, and the initiating l l controls.

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Audit Plan Revision 1 4-11 June 9.1997 l

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l A generic critical function diagram will be developed presenting the active functions -

that must be executed for the spectrum of DBEv along with the identified component configuration. An example of a critical function diagram is shown in Exhibit 4-4. This set of conditions will ensure the development of a complete set of Critical Design Characteristics.

e' The Emergency Operating Procedure (EOP) will be reviewed as part of this process. The EOP review will be limited to that portion covering the DBEv as l analyzed in Chapter 14 of the FSAR and rechecking a controlled conditions for i

the reactor.

i 4.2.2 Prepare Characteristics Database A critical design characteristic is defined as that aspect of a component or system that must be included in the design to ensure that the component or system will perform l its critical safety function. The critical design characteristics are an accumulation of the system design characteristics, and the system's components critical characteristics, coupled with the plant and component configuration at the time of the DBEv. These characteristics will be determined based on the existing information contained in the I

licensing basis for Millstone Unit 2. The data will be used to perform the systems verification.

The following list representa a core group of documents that contain a significant amount of information about the critical parameters for the plant: I l

e Updated FSAR for Millstone Unit 2 e Technical Specifications for Millstone Unit 2

• System Design Bases Documents e Probabilistic Risk Assessment for Millstone Unit 2 e Combustion Engiaaering Owners Group Documents >

+ System Design Calculations 1

l - , -

Audit Plan Revision 1 4-13 June 9,1997

l q Exhibit 4-4 (j CRITICAL SAFETY FUNCTION DIAGRAM Loss of Feedwater j Flow i

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l O Component Critical V Design Criteria The review of applicable documents will;

1) confirm continuity across the documents,

2) determine the root document that defines the critical parameter or function,

3) ensure that the accident mitigation systems critical design characteristics have been captured for each accident;

4) confirm assumptions made in calculation are in place in the field; and,

5) Ensure results from calculations are appropriate and reasonable, and 1

6) ' confirm that the analytical techniques used were valid.  ;

t j The Team will review the DBEv and derive the critical safety functions, critical i l characteristics and critical safety parameters. In addition, the team will review the l accident mitigation systems to identify the critical design parameters and ,

O d - - , -

Audit Plan Revision 1 4-14 June 9,1997 i

1 t

characteristics that have been incorporated. Differences between the two sets of data will be evaluated and compared against the results from the NNECo corrective action programs. As discrepancies are identified during the review they will be reported per the requirements of Project Procedure PP--07 " Discrepancy Reports".

A listing of the critical design characteristics will be prepared. His listing of critical design characteristics will be the source data base to be used by the Review Team for the systems that will be covered in the SVSR and AMSR process.

4.2.3 Verification of Cdtical Design Charactedstics The critical design characteristic will be verified to show that the current configuration reflects the Heense bases. Verification will be based on several methods and will include review of calculations, alternate calculations, test data, inspections or a combination of methods. All discrepancies will be documented.

Another aspect of the verification program is to perform a review of operations, surveillance and testing procedures. The information collected will be used to validate the critical characteristics and parameters.

This verification process is independent from the one performed by the SVSR Team.

Those characteristics associated with the systems being reviewed by the SYSR Team will be given to the SVSR team to verify.. The results of SVSR Team verification will be incorporated into the AMSR report for completeness.

4.2.4 Preparation of AMSR Report A final report will be prepared identifying the critical design characteristics by system and by DBEv. Included in the report will be the listing of the characteristic and how it was verified . De AMSR Report will be included as part of the ICAVP Final Report, and will contain the following:

• Summary

• ~ Critical Sefety Function by system by DBEv e Critical Design Characteristics by System

. Discrepancy Reports summary i

k _ ,sesses,sses _

Audit Plan Revision 1 4-15 June 9, wn

(.

t 4.3 PROCESS REVIEW (Tier 3)

In accordance with NRC direction, a review to determine whether Millstone Unit 2 -

processes and procedures have been established for effective configuration management on a going-forward basis will be addressed by others and is not included in this review.

The Tier 3 (Process Review) portion of the audit will verify the adequacy of the Millstone Unit 2 CMP to identify and correct design and configuration management deficiencies associated with past change processes. Tne Tier 3 process review is not an evaluation of change procedures used in the past but rather a review to determine the effectiveness of the Millstone Unit 2 CMP to identify and correct deficiencies that may have resulted from the ineffectiveness of past change processes. This will be accomplished by a " horizontal slice" inspection of examples of past changes to the facility design, practices, and documentation. The horizontal slice program verification cuts across plant systems and is a technical review to determine if:

Changes to the plant meet the current design and licensing basis documentation, e

Design and licensing basis requirements have been translated into operating, maintenance and testing procedures, The performance of systems / components has been verified through testing, e design and plant information contained in databases and documents are accurate and consistent with the plant, and a

CMP corrective actions, associated with the examples of past changes selected for review, have adequately corrected the deficiency.

1 Exhibit 4-5 illustrates the Process Review steps. The Process Review of Millstone Unit 2 processes and procedures will be performed in accordance with Project l Procedure PP-03 " CMP Performance Horizontal Slice Review". Conduct of the review is based on the activities noted below and discussed in the following sections.

• Identify Change Processes

• CMP Horizontal Slice Review

= Report

- f,isisees reum -

Audit Plan Revision 1 4-16 June 9,1997

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8 Tier 3 Process Summary ewua.s -

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Audit Plan Revision 1 l 4-17 June 9,1997

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l 4.3.1 Identify Change Processes

(

In preparation for performing the process review and the System Vertical Slice -

Review, NNECo procedures will be reviewed and a process model prepared to identify how various changes are performed and controlled, the organizations involved, titles of various documents, and where documents and information can be found. This is done to efficiently and consistently familiarize the ICAVP team )

members with what they will be reviewing and the organizations and kinds documents i they will need to consider.

l l

The process model will contain the various change processes based on the a review of current procedures. The model will be a high level depiction of how changes to facility design or plant characteristics are accomplished and controlled. To prepare for development of the process model, the ICAVP Team will review procedures in the following areas:

Change Control- Plant Equipment / Structures

• Major and Minor plant modifications

/~

• Jumper, lifted lead, and bypass control

• Set point changes '

• Temporary or Emergency Changes

• EWR with use as is disposition l e Design control, including:

• Design inputs, design development, review / approval -

Identification and evaluation of cumulative effects e electrical loads e heat loads e structural loads e hydraulics e Verification / tracking of design assumptions to closure

• Process for determining if an activity is maintenance or a modification.

• Procurement and control of equipment for modifications

• Evaluation, procurement and control of replacement and spare parts

• Commercial grade parts dedication O _s,_

Audit Plan Revision 1 4-18 June 9,1997

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• Equipment /part equivalency and substitution

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Chas.ge Contsel - Design, Ilcense, Procedure Documents -

• Design and licensing document change control e Specification preparation and revision

• Drawing revision not associated with a Modification Development and change control of plant maintenance and operations procedures

• Interface with design modifications

• Maintenance and Operations initiated changes not asmciated with an equipment modification

• Development of Design Basis Document (s) (DBD) e Vendor manual update / changes Document Control e Document Control

• Document identification and retrieval e Drawing control O e Control room drawing updates l

i

. Tracking and identification of in progress or planned changes Information Management

• Engineering design software changes e Information Systems software design changes e Database information change control Assessment and Equipment Monitoring a Surveillance testing

• ASME Section XI repair and replacement o, Quality Assurance Audit & Surveillance

• NCR with use as is disposition In addition to searching procedures for change processes, organization charts will be reviewed to help understand the organizational structure that manages, performs, and supports the change activities. These would include the design and configuration U - , r- -

Audit Plan Revision 1 4-19 Juoc 9,1997

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

i l

O entities, internal and external design interfaces, and other non-design organizations that can impact the plant configuration, or the design and licensing basis.

f The current change processes will be identified using a 4-dimensional process model.

Since a work process consists of activities performed by people and tools to produce  :

products and information meeting customer, management, and regulatory  ;

requirements, the process modeling will capture and communicate these aspects of how work is accomplished: r L

The process model will be a high level depiction of:

o general activities that are performed,

[

• the controls on the activities, t e the information and documents produced, e the source and repository of the information/ documents, and e the organizations that perform or support the change activities.

i 4.3.2 CMP Horizontal Slice Review A review will be performed on a sample of past change documentation and the j

resulting plant configuration, maintenance, operations, testing, or training changes. l The review will look for:

e Unrecognized modifications to the plant, design documents or information.

• Departures from the plant licensing or design basis documents

• Acceptable documentation of the results of the change and its basis.

This review is not an evaluation of change procedures used in the past, but rcther a review to determine the effectiveness of the Millstone Unit 2 CMP to identify and correct design or licensing basis deficiencies that may have resulted from the i l

ineffectiveness of past change processes. This is a "out-come" based comparison of l i

h current conditions versus the current design and licensing basis. l For the following change, or change control, processes a sample of the process work j products or outputs, will be identified and reviewed: l l

= Revision to Ops. & Maint. Procedures e Conduct of Ops. & Maint.

• Surveillance testing 4

l l l _ posesusreus-Audit 11an Revision 1 4-20 June 9,1997

l. -- - . . . . . ,- - . . - --

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• e Master equipment list maintenance. and revision Information systems design and change control

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! e Setpoint changes .

• Specification preparation and revision e Vendor manual updates

• ISI/IST ASME Section XI repair and replacement

• Procurement of replacement parts l

• Equipment / parts Equivalency Substitution including Commercial grade dedication

• Jumper, Lifted Lead, and Bypass Control

• Temporary or Emergency Changes NCR & EWR (use as is)

• Design and Lic. Basis Document change not associated with a Mod.

= Drawing Revision not associated with a Mod

. Document Control The sample will be over and above what may be reviewed by the System Vertical Slice Review. The sample of work products or outputs will be chosen to provide, as appropriate, a cross section of attributes such as discipline, (mechanical, electrical, I&C, etc.), time frame in which the product was produced, and other characteristics which have been found by experience to be potential weakness,(e.g. numerous organizational interfaces, or past industry problems). Sampling and reviews will be

( conducted in two phases to ensure all CMP systems have been considered.

The methodology, documentation requirements, depth of review, walkdown inspections, etc. for this program verMication review is similar to what is described in the System Vertical Slice Review procedures except this review is focused on change processes instead of systems. j 4.3.2.1 Prenare Review Checklist Review checklists will be developed specifically for the change control processes 1 l

identified above. The checklists will serve to maintain inspection focus and to ensure a I complete and thorough review.

The checklists, incorporating the input of each inspector and the team leader, will be developed in a team environment to ensure maximizing the expertise of the entire  !

I group. The checklists will identify programmatic evaluation criteria, (i.e. quality j assurance, regulatory, etc.) for each of the inspection areas and will utilize the SVSR source book for specific technical review criteria..

b.

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-n-Audit Plan Revision 1 4-21 June 9,1997 1

_ ___ . _ _ _ _ ~ _ _ . . . . . . _ - _ . _ . _ _ . _ . _ . _ _ . . _ _ . . . . _ _ _ . __ __

i 43.2.2 Conduct the Review he review will entail a comprehensive engineering review of the above change s processes by a team of mechanical, electrical, instrumentation & control, maintenance, operations, document control, configuration management, and information management specialists. He team, using the inspection area checklist will review the selected sample of change process outputs, confirm database accuracy and consistency, ,

and perform plant walk downs.

l l

l l If discrepancies are identified during the review, they will be immediately communicated to management for evaluation. Each discrepancy will be provided with a complete oescripisii, huuding all pertinent information per the requirements of Project Procedure PP-07 " Discrepancy Reports". Based on discrepancies identified during this review and the SVSR review, additional samples may be chosen to

! investigate the extent of potential problems, or to ensure that a individual discrepancy is an isolated incident.

j 43.4 Review Activity Renort l

l A process review report will be developed for each change process inspection area. A final report will summarize the results of each process review report and will contain the details of any associated discrepancy reports. Included in the report will be an assessment of the effectiveness of the Millstone Unit 2 CMP to identify and correct design and configuration management deficiencies associated with past change processes. The process review final report will consist of the sections noted below.

The process review final report will be included in the overall ICAVP report.

The report will include:

• Summary e Review method and sample of the various change processes e Results by change precess reviewed

. . Corrective actions review results Discrepancy Reports summary and Appendices f

l - PRESMB POWIB -

Audit Plaa Revision 1 4-22 June 9,1997 l

CN 4.4 REGULATORY REVIEW As part of the Millstone Unit 2 ICAVP, a Regulatory Review will be performed of - l selected licensing documents that have been docketed for Millstone Unit 2. (Docket  ;

50-336). The Regulatory Review will include commitment identification for l l verification during the System Vertical Slice Review (Tier 1), Accident Mitigation Systems Review (Tier 2), and/or Process Review (Tier 3) as appropriate. The Regulatory Review will provide additional insight into NNECo's compliance with the current licensing and design bases at Millstone Unit 2.

j

l

The Regulatory Review, depicted on Figure 4.6, will be performed in accordance with Project Procedure PP-04 " Regulatory Review" The Regulatory Review consists of the following main activities

Identification of regulatory requirements, Millstone Unit 2 applicability and specific commitments identified on the docket for items within the scope of Tier 1, 2, or 3 (the scope of Tier 1 is limited to the systems selected by the NRC for l Tier 1 review). j l  ;

e Verification of Commitments and requirements validation applicable Millstone Unit 2 items e

l Preparation of a Summary Report of Regulatory Review l

l l 4.4.1 Identification of Annlicable Renawe rv Res-A-:- - ;ts. and n*Inted Ce==it==nts l

Specific regulatory documents will be included in the Regulatory Review if they are l 1

l applicable to Millstone Unit 2 and within the scope of the ICAVP. These include:

i e NRC Bulletins

• NRC Generic Letters i e Safety Evaluation Reports associated with License Amendments

= Other Safety Evaluation Reports (not associated with License j

Amendments)

• NRC Notice of Violations e Millstone Unit 2 Licensee Event Reports t'

V) _ pas , ,,a _

Audit Plan Revision 1 4-23 June 9,1997 l

. , _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . ~ . _ _ _ _ . _ _ _ _

( All documents in each of these categories will be screened for applicability Documents relating to certain programmatic areas such as security, fire protection, environmental qualification, emergency response and planning and quality assurance will not be reviewed as part of the Regulatory Review. Specialists will be employed to review pertinent aspects of these programmatic areas to support detailed Tier l reviews.. Additional details of the screening process are provided in Project Procedure PP-04, " Regulatory Review."

l Ea.:h applicable document will be summarized. The summary will key on required

licensee action. In addition, the licensee's docketed response will be reviewed and j summarized. This summary of the response will focus on the licensee's commitments.

l For each applicable document, a review of the current Updated Final Safety Analysis Report will be performed to determine if an FSAR change was requirci, and if required, whether the FSAR was updated as required by 10 CFR 50.71.

4.4.2 Commitment / Requirement Verirntion Specific commitments identified during the Regulatory Review will be verified during the Millstone Unit 2 ICAVP. The verification will be performed within the System Vertical Slice Reviews (Tier 1), Accident Mitigation Systems Review (Tier 2), or Process Review (Tier 3), as appropriate. Summary and conclusions of the verification efforts will be provided in the Regulatory Review Report.

4.4.3 Prepare Summary Report of Regulatory Review A report will be prepared summarizing the results of the Regulatory Review performed as part of the Millstone Unit 2 ICAVP. A summary will be provided for each set of documents listed in Section 4.4.1 included in the Regulatory Review. In addition, each of the completed Regulatory Review Summary Forms within the scope of the Tier reviews will be provided.

k -ressousreus-Audit Plan Revision 1 4-24 June 9,1997 1

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

Exhibit 44_-

REIULATORY REVIEW I a. -,.

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nn Seeson LO essess Mmeanne 3 as Conneure#en APpasabliny Wee NO BAR Change Regoired 7

YES if Wee Desument &

SAR NO Forwerd Change For Correedve Adequate Action

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YES ir Deaumont SAR change  ; +

+ (or non change)  ;

y seene JWI Secson 3A

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SyelerWEquipment Vertnceton bispection Performed in Tier 1,3, or 3 Rsviews VerWy Conformenee

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Audit Plan Revmon 1 4-25 June 9,1997

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4.4.3 Prepare Su===ry Reet of Red =*ary Review b

A report will be prepared summarizing the results of the Regulatory Review performed as part of the Millstone Unit 2 ICAVP. A summary will be provided for each set of documents listed in Section 4.4.1 included in the Regulatory Review, In addition, each of the completed Regulatory Review Summary Forms within the scope of the Tier reviews will be provided, i

i l 4.5 ICAVP ACCEliTANCE CRITERIA I

l Acceptance criteria for the successful completion of the ICAVP audit are noted below.

Based on ICAVP discrepancy reports, additional reviews would be required to establish a level of confidence that ICAVP objectives are being met if the following criteria are not met.

No new issues are identified which would have resulted in a negative operability l determination if the unit had been in operation.

l No issues are identified in which plant modifications, procedure changes, or  !

operational setpoints would have created an unreviewed safety question or lC l

I would have significantly degraded a safety margin.

i I e

No systematic or programmatic defects are noted in NNECo's assignment, prioritization, or implementation of corrective actions.

• Significant discrepancies, if new, are a result of program or process deficiencies  !

or weaknesses which have already been identified by NNECo and are being f formally tracked and addressed as part of the Millstone Unit 2 corrective action l program.

e l There is reasonable assurance that the plant is now maintaining conformance to its licensing basis.

4.6 PROJECT PROCEDURES & INSTRUCTIONS Project Procedures noted in Exhibit 4-7 and Parsons Power's Quality Program will be used to support implementation of this Audit Plan. Project procedures are required for major project audit activities (i.e., SVSR, Accident Mitigation System Review, rm Process Review, and Regulatory Review) and implementation of Audit Plan t]

\ _ pgggggg pggg -

Audit Plan Revision 1 4-26 kne 9,1997 l

Exhibit 47 i PROJECT PROCEDURES & INSTRUCTIONS i

PROJECT PROCEDURE TITLE PP-01 System Vertical Slice Review PP-02 Accident Mitigation Systems Review PP-03 Process Review, CMP Horizontal Slice l PP-04 Regulatory Review PP-05 Differing Professional Opinion 3 l

PP-06 Substitution or Addition of Personnel  !

PP-07 Discrepancy Reports  !

1 PROJECT INSTRUCTION TITLE PI-01 SVSR Implementation Checklists and Workbook l

l  !

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-Paessesrose-Audit Plan Revision 1 4-27 June 9,1997

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lq 5.0 DISCREPANCY REPORTS l

G l During the course of the Millstone Unit 2 ICAVP, any Team member may identify an -

I apparent discrepancy and originate a Discrepancy Report (DR) in accordance with Project Procedure PP-07. A discrepancy is an adverse condition, such as an error, omission, or oversight which prevents consistence among the physical configuration, information sources (e.g. documentation and data bases, design basis and/or regulatory requirements.

1 The process for evaluation of Discrepancy Reports is presented in Exhibit 5-1. '

l 5.1 IDENTIFICATION, EVALUATION AND REPORTING OF DISCREPANCIES l

! All DRs 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.

If the basis for the DR is determined not to be valid, the responsible Group Lead may close the DR. DRs for issues that are evaluated and found to have been identified previously by I

NNECo as part of their Configuration Management Plan shall be noted as such and closed following such evaluation.

V After a DR has been evaluated by the responsible Group Lead, and resiewed by the Deputy Project Director, it will be forwarded to the Project Director for approval.. After approval, the DR will be reported concurrently to the NRC, NEAC and NNECo in accordance with the Communications Plan (PLN-02). DRs will be posted 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 to NNECo, NEAC and the NRC. This includes DRs that were closed following a determmation that the basis was not valid and for issues that are evaluated and found to have been identified previously by NNECo as part of their Configuration Management Plan.

l 5.2 REVIEW OF PROPOSED RESPONSE TO DISCREPANCIES Proposed corrective action by NNECo in response to a DR will be forwarded to the ICAVP Group Leader responsible for validating the DR. The ICAVP Group Leader will prepare comments on the proposed corrective action. Once comments on the proposed l resolution have been approved they are forwarded to the NRC, NNECo and NEAC. A

, /(7 j - missirews -

Audit Plan Revision 1 5-1 June 9,1997 l

l

4

?,

i summary of proposed NNECo resolutions and Parsons comments will be reported on the Parsons World Wide Web in accordance with the Communications Plan (PLN-02).

5 i

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- P333333 POWER -

Audit Plan Revision 1  !

5-2 3""* ' 1#  !

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Exhibit 5-1 Discrepancy Reports i

. l Comrnunication Plan Y

m Reviewed DR m Approved DR Issue Review m issued DR m Basis Invalid DR E Approve ICAVP Basis Invalid DR E Discrepancy lssued Comment E ICAVP y Avivoved Cornment i Activities Clom! DR C Report Closed DR E Activities NNECo Response m "

Dep, Proj. DM Proj. Sh Proj. Did World Wide Web NNEco DR P--

DR Basis Invalki DR u

da I C - --- - ? rm NNFCn Rom .-

Perform Tier i NNI?Co DR Response l Activities c ,

NNEco CMP Corrective Actions l 4 _

Perform " m C - Evaluate Tier 2 Discrepancy Report. (DR) & DiscrTancy Activities Reprt. (DR) w/ Descripton & Safety Siaruficance {

Grwp Lead (s)d Perform TeamMembers Tier 3 NNECo DR Response Activities th

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m Perform Assign r 3 Workina Ouestion m Working Ouestion m  % s Regulatory w/ Basis Tracking #

[ p[s Review w/ Basis + a Trackmg 8" Discrepancy -

• & Tracking Data Base

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, _. Proj. Suryort #

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l 6.0 ICAVP FINAL REPORT i

j. Preparation of the ICAVP Final Report will complete project activities and include the -

I following:

l e Compile and assess system reports i

i e Review of NNECo corrective actions e Psepare the ICAVP Final Report

)

! . Issue theICAVP Final Report 6.1 COMPILE AND ASSESS SYSTEM REPORTS l

System / Process reports developed during the ICAVP Audit will be compiled and assessed prior to their incorporation into the ICAVP Final Report. After the ICAVP system reports have been compiled, the lead engineers will evaluate the results based on guidance and objectives contained in NRC Inspection Manual Section 2535, " Design Verification Programs". The entire " system story" including discrepancies identified and corrective actions taken will be evaluated to:

l e Verify that the corrective action programs on selected systems are representative of

/ and consistent with those of other systems.

Measure the effectiveness of the NNECo Configuration Managernent Program (CMP) to identify problems, resolve existing problems, and preclude repetition.  !

6.2 REVIEW OF NNECo CORRECTIVE ACTIONS i

l A sample of NNECo corrective actions associated with the NNECo configuration management corrective action programs that were not previously reviewed as part of the i ICAVP SVSR inspection activities will be identified by the NRC. This sample of NNECo  ;

corrective actions will be evaluated in parallel with ICAVP system / process report compilation and assessment.

The review of NNECo corrective actions will verify the adequacy of NNECo's corrective actions and assess the implementation or proposed implementation of all corrective actions for systems and processes within the Millstone Unit 2 ICAVP scope. NNECo's corrective l

actions will be evaluated using the corrective actions checklists in project instruction PI-01

! "SVSR Implementation Checklists and Workbook" The evaluation ofNNECo corrective 5 \v - pggggg pggg -

Audit Plan Revision 1 6-1 June 9,1997 l

l t -

actions that have not been fully implemented will be identi6ed in the ICAVP Final Report

,- to facilitate future review and evaluation of NNECo implementation activities.  :

l . >

i 6.3 PREPAREICAVP FINAL REPORT After completion of audit plan activities, an ICAVP Final Report will be prepared to summarize all project activities. A suggested table of contents the Fi tal Report has been included as Exhibit 6-I. In parallel with completion of audit plan activities this outhne will be updated and will be forwarded to the NRC and NNECo for review and concurrence After NNECo and NRC concurrence, ICAVP engineers will be assigned to l prepare individual sections. l 6.4 ISSUE THE ICAVP FINAL REPORT i

The draft ICAVP Final Report will be reviewed by the Technical Ad5isory Group for completeness and technical accuracy prior to issue to the NRC and NNECo. ICAVP group leaders will assist with the incorporation of the Technical Advisory Group l

comments. The ICAVP technical editor will be responsible for final editing and issue of the ICAVP Final Report. The ICAVP Final Report will be issued to the NRC and l NNECo.

6.5 PROJECT CLOSEOUT AND RECORDS TURNOVER Concurrent with the issue of the ICAVP Final Report, the Parsons Power team will perform project closcout and demobilization /re-assignment of project personnel.

Applicable project documentation not previously transmitted to NNECo will be cataloged ,

and turned over. Project files will be cataloged, indexed, and transferred to the Parsons l Records Center for retention. .

I l

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! l

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1 k - reassesromis -

I Audit Plan Revision 1 N June 9,1997 l

_ _ . . _ _ _ _ _ _ - _ _ ._ ___ _ _ _ . ~ . _ . _ - . _ . __ ._ .

l l

i q Exhibit 6-1 (

ICAVP FINAL REPORT OUTLINE l 1.0 Executive Summary l

2.0 Technical Advisory Group Report 3.0 ICAVP Results Summary & Conclusions 4.0 Conduct ofICAVP Audit 4.1 Objectives 4.2 Project Orgamzation 4.3 Approach to ICAVP Audit 4.4 Reporting of Discrepancies 5.0 System Vertical Slice Review 5.1 Conclusions - SVSR 5.2 SVSR Review Summary 5.3 Discrepancy Report Summary 6.0 Accident Mitigation System Review 6.1 Conclusions - AMSR 6.2 Critical Design Chameteristic Resiew Sununary 6.3 Discrepancy Report Furnmary 7.0 Process Review 7.1 Conclusions - Process Review 7.2 Process Review Summary 7.3 Discrepancy Report Summary 8.0 Regulatory Review 8.1 Conclusions - Regulatory Review 8.2 Discrepancy Report Summary l 9.0 NNECo Corrective Action Review i

Appendices

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Audit Plan Revision 1 6-3 June 9,1997 l

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' l 7.0 SCHEDULE j

Exhibit 7-1 provides the project schedule for Millstone Unit 2 ICAVP audit activities. -  !

Exhibit 7-1 is a sumrnary level schedule (provided for NRC planmng activities). This schedule represents the scope of work necessary to complete the Millstone Unit 2 ICAVP in accordance with this Audit Pir.n. After confirmation of a project start date, all schedules will be revised to show calendar commitments. Schedule dumtions have been based on the approach discussed in this Audit Plan.- All task assumptioris and schedule logics will be discussed during the Millstone Unit 2 ICAVP Kick-off Meeting. Key schedule assumptions are noted below.

KEY SCHEDULE ASSUMPTIONS

• The NRC has approved selection of Parsons Power as the ICAVP Contractor for Millstone Unit 2.

• The NRC has approved the Parsons Power's Audit Plan.

l e

The NRC will select SVSR systems and approve SVSR system boundary identification. A two week period is assumed for SVSR system boundary ,

identification and approval.

• NRC will select up to 3 SVSR systems to start the ICAVP. 1 Nominal inspection periods have been assumed (no allowance for sample expansion, special evaluation, or excessive discrepancy report processing).

i e Allowances for public meetmgs and NRC oversight activities will be determined on or befor; the Kick-off Meeting.

I e The following NNECo calendar commitments have been used to establish this scluxiule revision.

NNECo has completed 50% of the Group 1 CMP systems on June 30,1997.

I NNECo has completed all Group 1 and Group 2 CMP systems en September 5,1997.

• Activity durations based on 5 day workweek.

- Passessreum -

Audit Plan Revision 1 7-1 June 9,1997 l

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PARSONS i

1 i INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM l

l MILLSTONE UNIT 2 l

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.i PLN-02 k ..

Revision 1 -

1 i

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i Prepared By:

d Date: 5 Deputy Project Director Approved By: 7 Date: 6[J 2

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Approved By: e Date: d ff

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- PARSON 8 P9MR BROUPINC.

Communication Plan Revision 1 June 5,1997 l i.

- _ . . - _. .- . . _ - _ = _- - _ _ _ - - - . . . _ - . . . - _ . _ . - _ -

MILLSTONE UNIT 2 COMMUNICATION PLAN REVISION LOG l

( Section Revision No. Description Dgg All 0 Initial Issue April 18,1997 All 1 Incorporation of NRC Comments June 5,1997 l

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This list delineates sections of this plan that are currently in effect. The latest changes are indicated by a vertical line in the right hand margin of the affected pages. '

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Communication Plan Revision 1 I June 5,1997 l

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i l MILIATONE UNIT 2 COMMUNICATION PLAN i

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LIST OF EFFECTIVE PAGES Page No. Revision No.

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2 1 3 1 4 1

! 5 1

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7 1

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9 1 10 1 11 1 1 12 1 i

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! Exhibits Revision No.

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2-1 1 2-2 1 4-1 1 i

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- PAR 8088 POWB 0063 BC.

Communication Plan Revision 1 il June 5,1997 l

I MIIIRTONE UNrr 2 COMMUNICATION PLAN TABLE OF CONTENTS l Section Illlt Eagt l l

1.0 INTRODUCTION

1  !

l 2.0 ORGANIZATIONAL INTERACTION 1 2.1 Nuclear Regulatory Commission (NRC) 1 2.2 Northeast Nuclear Energy Company (NNECo) 4 l 2.3 Connecticut Nuclear Energy Advisory Council (NEAC) 4 l 2.4 Other Interested Parties 4 2.5 Prime Contacts 5 l l

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3.0 MEDIA INTERACTION 5 4.0 PROCESSING INCOMING OR OUTGOING DOCUMENTS 5 4.1 Document Control 5 4.2 Requests for Additional Information (RAI) 5 4.3 Reports 6 l 5.0 FORMAL MEETINGS OR BRIEFINGS 6 i 5.1 Meeting Announcements 6 5.2 Meeting Summaries 6 6.0 CONFERENCES 10 7.0 PARSONS POWER GROUP INC. WORLD WIDE WEBSITE l'o 7.1 Function 10 7.2 Posting of Documents / Announcements 10 8.0 CONDUCT OF AUDIT 11 9.0 DISCREPANCY REPORTS 11 Exhibits ~

1-1 ICAVP COMMUNICATION PLAN PROCESS 2 2-1 ICAVP COMMUNICATION PLAN DISTRIBUTION MATRIX 3

! 2-2 PRIMARY AND BACKUP CONTACT LISTING 8

! 4-1 REQUEST FOR ADDITIONAL INFORMATION (RAI) 9

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Communication Plan Revision 1 lii June 5,1997 l

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1.0 INTRODUCTION

l Nuclear Regulatory Commission (NRC) Confirmatory Order issued on August 14, -

1996 for Establishing Independent Corrective Action Verification Program (ICAVP)

]

for Millstone Unit 2 requires that the ICAVP contractor (Parsons Power Group Inc.)

concurrently provide its findings to both Northeast Muclear Energy Company (NNECo) and the NRC. Further, Policy Statement SECY 97-003 requires that a communication protocol be followed that allows representatives of the NRC to i monitor interactions between Parsons Power Group Inc. (Parsons) and NNECo l whenever technical issues are discussed either by telephone or in person.

'Ihis document establishes the communication protocol that Parsons will use for written and verbal communications between NRC, NNECo, media and public that allows the NRC oversight staff to monitor interactions between Parsons and NNECo.

Exhibit 1-1 shows the process that will be followed for the receipt, handling, response and disposition of all Parsons ICAVP communications. It is the responsibility of the project team personnel to assure that these guidelines are implemented in a manner which assures the independence of the review. Parsons internal communications are unaffected by the requirements of this protocol.

Correspondence that deals with Contractual and Financial matters between NNECo and Parsons are excluded from this plan.

2.0 ORGANIZATIONAL INTERACTION 2.1 NUCLEAR REGUIATORY COMMISSION (NRC)

Office facilities will be provided at Parsons' Reading, PA offices and at the local site office for the NRC ICAVP oversight personnel to facilitate communications. Parsons will notify the NRC when they plan to talk to, meet or have information conferences l with NNECo. This requirement applies to all Parsons personnel associated with this program. Parsons will not conduct the meeting, telecon, or conferences until advised by the NRC of their intention to participate.

All Parsons correspondence addressed or copied to the NRC will be sent to the NRC ICAVP Deputy Director and the NRC Document Control Desk in accordance with the Distribution Matrix in Exhibit 2-1.

10 V

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Communication Plan Revision 1 1 June 5,1997 l

! EXHIBIT 1-1 J

i ICAVP COMMUNICATION PLAN PROCESS i

i J

- Fes Puhec/

i incoming . E-men g g, Commsmmicetion Response

. Cerveopondonce ap.

i I k

idemesh, Lee, p, ee/

Demeribute Evaluate

Caseammicehm Request

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laternal Personas E-Men h ' Neuh q Maseema T --

NRC &

Reports NNECe Ducr,ancy Raports c,g,,,,,,, l m l gig h w Re m E Meetimes I l C-. . _ 'enee L

1 f 1 f

$- Prepare,1dentih, ,

w Noti $ Leg, Distribute 7 ,

1 NRC Outgoing Dec J

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Notice Meeting i

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1 f i f Pimede Post Communication to Website Me*e l senee==mc 1

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r Communication Closecut / Records 4

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EXHIBIT 2-1 ICAVP COMMUNICATION PLAN DISTRIBUTION MATRIX O .

I oRGANIZADON/ MEL71NG LOCARON CORRESPONDENCE REPOR*I3 SUMMARIES (4) DISCREPANCY REPORTS PLAN SECTION 4.1 4.3 5.2 9.0 NRC (1) X X X X NNECo X X X X WWW X(3) X(2) X NRC Nuclear Regulatory Commission NNECo Northeast Nuclear Energy Company NEAC Connecticut Nuclear Energy Advisory Council WWW World Wide Website O

l Notes:

(1) NRC distribution includes ICAVP Deputy Director, Document Control Desk and NEAC (2) Except for non electronic information (materials exchanged at meeting)

(3) Report summaries only (4) Meeting summaries not available from NRC O

- PM80N8 PMER BROUPIBC.

communication Plan Revision 1 3 June 5,1997 l

2.2 NORTIIEAST NUCLEAR ENERGY COMPANY (NNECO)

Interaction with NNECo will be conducted primarily through formal written '

correspondence and electronic mail (E-Mail).

Periodic meetings will be conducted to appraise NNECo of the project status and to f

promote discussion with the ICAVP reviewers to assist in conducting their work in an

! efficient manner.

I i

Parsons direct verbal contact with NNECo personnel either by phone, meeting, or conferences requires prior notification to the NRC in order to allow time for observation by the MRC ICAVP oversight team.

2.3 CONNECTICUT NUCLEAR ENERGY ADVISORY COUNCIL (NEAC)

NEAC and the NRC have established a memorandum of understanding that permits NEAC to participate and/or observe the NRC's oversight activities for the ICAVP.

NRC is responsible for interface and communication with NEAC. Communication that is issued to the NRC will be copied to NEAC in accordance with Exhibit 2-1.

Office facilities will be provided at Parsons' Reading, PA offices and at the local site O office for NEAC observers or their alternates to allow direct observation of the review process and Parsons' interactions with the NRC and NNECo.

'Ihe invitation for NEAC to observe meetings or conferences between Parsons and NNECo will be extended by the NRC. It is assumed that NEAC is responsible to interface, appraise, and advise other interested State of Connecticut entities.

2.4 OTIIER INTERESTED PARTIES Notification of meetings, meeting summaries not posted by the NRC, and discrepancy reports will be posted on the World Wide Web (WWW) to facilitate public access to ICAVP information.

Formal correspondence, meeting summaries, reports, and discrepancy reports will be available in the Public Document Room (PDR) in accordance with the Distribution Matrix in Exhibit 2-1.

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communication fian Revision t 4 Junc 5,1997 l

2.5 PRIME CONTACTS Exhibit 2-2 provides the addresses and telephone numbers for the primary and backup contact (s) of the Parsons ICAVP review team personnel authorized to receive written and verbal communication and to interface with the media, public and other interested parties. No other Parsons' personnel are authorized to receive formal documents or to have direct contact with the media or public unless an alternate is designated in writing.

Other non-Parsons contacts are included in Exhibit 2-2. Control and distribution of information within the respective organization is the responsibility of the identified contact individual.

3.0 MEDIA INTERACTION All public or media request of Parsons personnel for an interview, information and/or comment concerning the ICAVP will be handled through the Project Director. The Project Director will consider the request and determine the appropriate response, f NRC and NNECo will be notified prior to news releases.

4.0 PROCESSING INCOMING OR OUTGOING DOCUMENTS 4.1 DOCUMENT CONTROL All documents received or issued by Parsons will have a document identification number. Incoming documents will be given a Parsons' unique identification number regardless of any other identification number on the document and entered into the project log. Document distribution will be in accordance with the ICAVP Communication Plan Distribution Matrix shown in Exhibit 2-1. Project correspondence will be available in the Reading, PA office for review by the NRC Oversight Team.

4.2 REQUESTS FOR ADDITIONAL INFORMATION (RAI)

Requests for additional information (RAI) are those requests that require a response to a particular question or clarification. All requests for additional information will be documented in writing to NNECo using a form similar to Exhibit 4-1 RAI's can include those requests that require a specific copy of a document. Whenever Parsons

-Passessrouenasserme.

communication Plan Revision 1 j 5 June s,1m l

requests a document that is controlled, NNECo will add Parsons to the NNECo controlled document distribution. RAI's and their NNECo response will be available in the Reading, PA office for review by the NRC Oversight Team. ,

4.3 REPORTS Parsons will issue the ICAVP reports noted below to the NRC and NNECo. All reports will be issued as final, draft reports will not be issued. Report summaries will be posted to the Parsons Website 48 (2 business days) hours after they have been distributed to NNECo and the NRC.

ICAVP Project Reports

• System Vertical Slice Review e Accident Mitigation System Review e Process Review e ICAVP Final Report 5.0 FORMAL MEETINGS OR BRIEFINGS 5.1 MEETING ANNOUNCEMENTS Formal meetings to discuss the results of the ICAVP and periodic briefings for the public will normally be scheduled in advance or initiated by the NRC. 'Ihe NRC will notify NNECo and Parsons' primary contacts at least one week in advance of the meeting. For meetings open to the public the NRC normally provides a two week natification. Parsons will also post meeting notification on the Website for meetings open to the public after the NRC has issued notification.

5.2 MFETING SUMMARIES All planned formal meetings will have a summary of the items discussed, including all material that is exchanged. The meeting summary will be prepared by the organization / individual who has called the meeting. If the NRC has the meeting transcribed, no other summaries of the meeting are required. Meeting summaries will include information requests and written material exchanged at the meeting.

Summaries will be distributed to the meeting participants. For summaries that have material exchanged during the meeting, a list of the material exchanged will be noted but copies of the exchanged material will not be posted to the Website. Summaries will be made within two weeks after the treeting.

-rasseuspsumeneurus.

communication Plan Rewseon 1 6 J e s, tm l

EXHIBIT 2-2 (page 1 of 2)

PRIMARY CONTACT LISTING MAlllNG OVE1NIGifT MAIL PHONE / E-MAIL ORGANIZATION INDIVIDUAL TTTLE ADDRESS ADDRESS FAX ADDRESS PARSONS Daniel 1. Curry (1) Project Director Parsons Paw Gmap Ise Persens Power Group Inc "

(6te) 855 -2366 - .,6:_?_ __.-e 2675 Morgantown Road 2675 Morgantown Road (618) 855 2599 FAX Reading,PA 19607 Reading,PA 19607 NRC E.V. Imbre Deputy Director USNRC USNRC (301) 415-149e exi@NRCGOV for ICAW Special Washington,D.C. 20555 11555 Rockville Pike (301) 415-1222 FAX Propet Office Reckvine, Md 20852-2738 4

NNECe Richard Imedenat ICAVP Pmgram I #

Millstone Nuclear Power Mi!Istene Nuclear Power Imedert@GWSMTF.NU.COM Director Station Unit 2 Station Unit 2 P.O. s2x 128 156 Repe Ferry Road Waterford,CT e6385 Waterford,Cr 06385 NEAC Rep. Terry Concannen Co-Chair NEAC NEAC (860) 248-8585 Later 34th Assembly District 34th Assembly Distrkt (Capitol) 76 Tinuns HDI Read 76 Theuns HIB Reed (860) 3454141 (henee)

Haddam,CT e6438 Heddam,CT e6438 NEAC Evan Weellacott Co-Chair NEAC NEAC (960) 6 5 9591 Later 128 Twrys risin Road 128 Twrys Plain Road

(% 6E9591-FAX Shustery,Cr e6e7e Shnsbury,Cr e6e7e (1) Parsons' contact for all Public, Media or Interested Par!;eS PMMMFSMRMM.

Communication Plan Revision 1 7 June 5,1997 l

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EXHIBIT 2-2 (page 2 of 2)

CJ )

BACKUP CONTACT LISTING i

MAILING OVERNICitr MAIL PHONE / E-MAIL ORGANIZATION INDIVIDUAL TTILE ADDRESS ADDRESS FAX ADDRESS ,

i PARSONS Eric Blecher Project Deputy Parsons Power Group Inc Parseas Peeer Group lac (619) 855 - 2071 Eric,A,Blocher@ PARSONS.COM Director 2675 Morgantown Road 2675 Morgantown Road (610) 855 -2509 FAX Reading,PA 19687 Reading,PA 19687 '

NRC Imren PHske Branch Chief USNRC USNRC (301) 415113e Irp@NRCGOV ICAVP Oversight Vvashington,D.C 20555 11555 Rockvine Pike (301) 415-1222 FAX Reckville, Md 20052 2738 NNECe Joe Feegere Project Manager Millstone Nuclear Peeer Millstone Neeleer Power (Ese) 444-5526 Feegeig@6MMTP.NILCOM Station Unit 2 Station Unit 2 (960) 440-4403 - FAX i l

P.O. Bem 128 156 Rape Ferry Road Waterford, CT 96385 Waterford, CT 96385 NEAC I'P. John C. Co. Chair 9 Susan Terrace 9 SesenTerrace (ese) 437-4654 1meer t Marhewicz Waterford, CF 96385 3515 Waterford,Cr 963843515 (Carteel)

(ese) 437-9355 (Henne) l (ese) 437 4645- FAX l l

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Communication Plan Revision 1 8 June 5,1997 l l

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l EXHIBIT 4-1 l REQUEST FOR ADDITIONAL INFORMATION (RAI) lO .

PARSONS POWER GROUP INC. 2675 Morgantown Road. Reading,PA 19607

(") "52" *"") "s25.

ICAVP MILLSTONE UNIT 2 REQUEST FOR ADDITIONAL INFORMATION DO E frRACKING NO.: RAI-0001 DAR: ANmm l

REV 00 REV 01 REV 02 REV 03

// // //

l Issuing Engineer l

LIST OF REOUESTED INFORMATTON Please respond to the following information as required by Section 4.2 of the ICAVP Communication Plan (PLN-02), refer to l

the RAI number and provide next revision date for all responses to this document.

t QUESTIONS AND CLARIFICATIONS NNECo RESPONSE l

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Communication Plan Revision 1 9 June 5.1997 l

l l 6.0 CONFERENCES

l. i l Parsons may request a conference with NNECo to obtain clarification or further understanding of particular items. NNECo may also request a conference to discuss l or clarify discrepancy reports issued by Parsons. Conferences can be by telephone, video conference, or in person. l In order to allow the NRC to monitor the interaction between Parsons and NNECo, Parsons will notify the NRC's designated ICAVP oversight team member (s) whenever direct contact with NNECo is required. Notification can be by phone, fax, or E-mail.

It is anticipated that for most requests, prompt NRC response will be provided to allow the interaction to take place. A twenty-four hour (one business day) notification period will be followed to allow the NRC a reasonable time period to participate.

Notes of the conference will be written and distributed to the primary contacts of the participating organization.

7.0 PARSONS POWER GROUP INC. WORLD WIDE WEBSITE l l

7.1 FUNCTION i

The Parsons Website for this project will function as the repository for the l

communications identified in Exhibit 2-1. The Website will provide the public with the '

ability to view:

a. Meeting announcements

b. Meeting summaries not available from the NRC

c. Discrepancy Reports

d. Prime Contact Information

e. Final reports summaries The Parsons WWW site will be updated periodically and can be addressed at http://www.parsonsicavp. net i 7.2 POSTING OF DOCUMENTS / ANNOUNCEMENTS Parsons meeting announcements will be updated in accordance with the frequency described in the Meeting Summaries Section of this plan. The NRC or NNECo will announce any meetings with respect to the ICAVP that they initiate or plan to chair. i l

O Communication Plan Revision 1 10 June 5,19n l

8.0 CONDUCT OF AUDIT The intent of this plan is to provide a communication protocol that Parsons will use in interfacing with the NRC, NNECo, NEAC, media and public. This plan indicates and addresses how various communications will be handled. Certain day to day and administrative conur unications are required for efficient project execution and are not part of this plan. The following are examples of administrative activities that Parsons considers not part of the communication plan:

• Badging Radiation Work Permits (RWP)

• Requests for inspection support activities (e.g. scaffolding, insulation removal, equipment tagouts, safety (OSHA) activities etc.)

In order to ascertain the availability of information or to identify the appropriate documents containing required information, the Parsons Deputy Director or one of the group leads may contact the NNECo primary contact or a designated Document Control personnel via phone. This type of interface shall only be made in the process of preparing and submittirg a request for information.

O 9.0 DISCREPANCY REPORTS Discrepancy Reports will be formally documented and issued concurrently to the NRC and NNECo. In addition, Parsons will post the discrepancy reports on the Parsons Website 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (2 business days) after they have been distributed to NNECo and the NRC. NNECo's response will be posted on the WWW by Parsons and reviewed by the project team before determining the final disposition of the discrepancy report.

PP-07 " Discrepancy Reports" provides the instructions for processing ICAVP

- discrepancy reports.

- PAR 8848 POWER 000gr MC.

Communication Plan Revision 1 11 June 5,1997 l

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l Mr1iKrONE UNIT 2 ICAVP PROJECT PROCEDURES l

PROJECT PROCEDURE TITLE REVISION PP-01 System Vertical Slice Review 1 PP-02 Accident Mitigation System Review 1 PP-03 Process Review, CMP Horizontal Slice 1 PP-04 Regulatory Review 1 PP-05 Differing Professional Opinion 1 PP-06 Substitution or Addition of Personnel 1 PP-07 Discrepancy Reports 1 PROJECT PROCEDURE TITLE REVISION PI-01 SYSR Implementation Checklists and Workbook 0 O

- PABBBBB POWEB -

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PARSONS PP-01 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES 4

4

Title:

4 System Vertical Slice Review l REVISION 1 l d

, Prepared by: (L./ Date: 9[ '7 Approved by: h u Date: M )

ager, Nuclear Quality Program '

Approved by: V 64 Project Director

/dPW) y Date: /f/fh l

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i REVISION HISTORY REVISION DATE REVISION DESCRIPTION 0 04/03/97 Procedure Initiation

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1 06/09/97 Incorporation of NRC Comments i

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l P) MILLSTONE UNIT 2 ICAVP PP-01 '

i PROJECT PROCEDURES

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t ss TITLE: SYSTEM VERTICAL SUCE REVIEW I

l REVISION: 1 DATE: 06/09/97 PAGE 2 OF 26 TABLE OF CONTENTS 1.0 PURPOSE...............................................................................................................................3

1.1 BACKGROUND

.. . . . . . . ... . .. . .3 1.2 APPROACH. . . . . . . . . .4 2.0 DEFINITIONS.......................................................................................................................5 3.0 PREREQUISITES...............................................................................................................6 4.0 PROCEDURE.......................................................................................................................7 4.1 INSPECTION PREPARATION.. , . . . . . . .... .. . .8 4.2 CONDUCT 0F INSPECTION.. . . . ... . . 11 s

4.3 INSPECTION ASSESSMENT AND REPORT . .. .. . . 15 4.4 TEAM MEETINGS / REVIEWS. . . .I8 4.5 SYSTEM ASSESSMENT.. .. . . . 17  !

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5.0 REFERENCES

........................................................................................................................I8 1 1

APPENDIXA....................................................................................................................................19 I

APPENDIXB....................................................................................................................................22 APPENDIXC....................................................................................................................................23 l

APPENDIXD..................................................................................................................................25 1

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PJ MILLSTONE UNIT 2 ICAVP PP-01 8 J l PROJECT FROCEDURES l F'N l Q TITt.E: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 3 OF 26 i

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1.0 PURPOSE l

This procedure establishes the overall objectives, scope, and general approach for conducting the System Vertical Slice Review (SVSR) for Millstone Unit 2. The purpose of the SVSR is to l confirm that the selected system's physical and functional characteristics are in conformance with its licensing and design bases. The SVSR will provide independent verification, beyond Millstone

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Unit 2's quality assurance and management oversight, that they have identified and satisfactorily resolved existing nonconformances with the design and licensing bases and documented and l l

utilized the licensing and design bases to resolve nonconfonnances. I

1.1 BACKGROUND

On August 14,1996, the Nuclear Regulatory Commission (NRC) issued a Confirmatory order CT directing the licensee to contract with a third party to implement an Independent Corrective Action V l Verification Plan (ICAVP) to verify the adequacy ofits efforts to establish adequate design bases I and design controls. The ICAVP is to employ a review of selected Millstone Unit 2 systems to provide independent verification that, for the selected systems, the Millstone Unit 2 Configuration hianagement Plan (CMP) has identified and resolved existing problems, documented and utilized l licensing and design bases, and established programs, processes and procedures for effective configuration in the future.'

l The corrective action verification program was ordered to include:

e an in-depth review of selected systems which will address control of the design and design basis since issuance of the operating license for each unit;

= selection of systems for review based on risk / safety based criteria similar to these used in implementing the Maintenance Rule (10 CFR 50.65);

e development and documentation c' hn a dit plan that wili provide assumnce that the quality of results of the Licensee's problem identification and corrective action programs on the selected l

systems is representative of and consistent with that of other systems;

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' NRC Confirmatory Order, Page 11, Item 11

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P) MILLSTONE UNIT 2 ICAVP PP-01 i E > PROJECT PROCEDURES I n

i] TITLE: SYSTEM VERTICAL SLICE REVIEW REV SON: 1 DATE: 06/09/97 PAGE 4 OF 26 i e

procedures and schedules for parallel reporting of findings and recommendations by the ICAVP team to both the NRC and the Licensee; and e '

procedures for the ICAVP team to comment on licensee's proposed resolution of the findings and recommendations.2 De ICAVP audit will be a multi-tiered approach u. sing different and distinct inspection methods for each of a total of three tiers. This procedure covers Tier 1. In Tier 1, four systems will be inspected using a system vertical slice review process to test the thoroughness of the NNECo's reviews in identifying potential nonconformances with the design and licensing bases.

I,2 APPROACll The ICAVP SVSR will review the configuration of the selected system through a combination of inspecting techniques including document reviews, calculation reviews, and plant walkdowns.

(mj The SVSR will assess the CMP as it applies to the selected systems through:

e a review of engineering design and configuration control processes; e

verification of current, as-modified plant conditions against design basis and licensing basis documentation; e

verification that design and licensing bases requirements are translated into operating procedures and maintenance and test procedures; e

verification of system performance through review of test records and/or observation of testing of particular systems; and e

review of proposed and implemented corrective actions for Licensee-identified design deficiencies.'

The SVSR will examme system related activities from original design, construction, and testing to the preser t system configuration.

U 2 NRC Cordirmatory Order, Page 12, Item III & Page 14, item IV 5

NRC Confirmatory Order, Page 13, Jtem III & Page 14/15. Item IV i

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MILLSTONE UNIT 2 ICAVP PP-01 PROJECT PROCEDURES

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( TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 5 OF 26 Any discrepancies identified during the review, coupled with the type of discrepancy and its relative importance on the structure, system or components regulatory requirements, will proside the basis for SVSR reporting.

2.0 DEFINITIONS e

Design Basis ... that information that identifies the specific functic a to be performed by a structure, system, or component of a facility and the specific vaha s or ranges of values chosen  !

l for cor. trolling parameters as reference bounds for design. The e values may be (1) restraints '

tierived from c.aerally accepted state-of-the-art practices for ahieving functional goals or (2) requirements ce ved from analysis (based on calculation .ad/or experiments) of the effects of a postulated accident for which a structure, system. n: component must meet its functional goals.d 1

O v e Licensing Basis, for purposes of the SVSR, the licensing basis for Millstone Unit 2 consists of j that set ofinformation upon which the Commission, in issuing an initial operating license, based its comprehensive determination that the design, construction, and proposed operation of the facility satisfied the Commission's requirements and provided reasonable assurance of adequate protection to public health and safety and common defense and security.5 1

Current Licensing Basis (CLB) is the set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect.

The CLB includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,26,30,40, 50, 51, 54, 55, 70, 72, 73,100 and appendices thereto; orders, license conditions; exemptions; and technical specifications. It also includes the plant specific design-basis information defmed in 10 CFR 50.2 as documented in the most recent fmal safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensing correspondence such as licensee responses to b(m. d 10 CFR50.2 5

Source: NRC Letter of October 9,1996 On Maintaining Plant Design

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MILLSTONE UNIT 2 ICAVP PP-01 m

PROJECT PROCEDURES TITLE: SYSTEM VERTICAL SUCE' REVIEW REVISION: 1 DATE: 06/09/97 PAGE 6 OF 26 NRC Bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports.'

l e Engineering Design Bases (EDB) - The set of design constraints that are not included in the Licensing Basis but are implemented to achieve economics of operation, maintenance, procurement, installation, or construction. Such as:

I e

Information that describes a system, structure, or component Operating values or parameters that are not reference bounds for design l

e Information that identifies functions important for economic, maintenance, installation, or other non-safety function of design basis systems, structures, or components Information and operating values describing the functions of non-safety systems j e Calculations, descriptions, and other " outputs" it i L e

Design Verification - The process ofindependently reviewing, confirming, or substantiating the design by one or more methods to provide assurance that the design meets the specified design criteria and design inputs. The extent of design verification may range from a detailed check of the total design to a check of the design approach and the results obtained. Design verification must be performed by an individual independent of the design aspect being verified.

3.0 PREREOUISITES

• NRC announcement of the system (s) to be inspected l . ICAVP Audit Plan l

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' 10 CFR 54.3 (a)

I P) MILLSTONE UNIT 2 ICAVP PP-01 E

, n PROJECT PROCEDURES TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 7 OF 26 i l

4.0 PROCEDURE Resources Responsibilities SVSR Group Leader e Reviews and approves the System Specific Instructions and Checklists e Supervises the overall SVSR Inspections l e

Directs the course of the SVSR and maintains resiew focus e Periodically reviews functional plans and system resiew progress j

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Reviews the documenting and reporting of any s discrepancies noted during the review.

SVSR System Lead e Coordinates the admmistration of the overall system specific inspection p e Defmes system boundaries and components to be evaluated NOTE Interface with, and portions of, other systems will be included within the boundary of the selected system to the extent they are necessary to support the functional requirements of the selected system. System boundaries may be dermed at appropriate components that provide physical isolation, as long as the selected boundary does not split the component between systems. All passive devices such as support and restraints, within the system boundary are included within the scope of the SVSR.

Support system boundaries will be defined as:

Mechanical - the first level of support system interface.

As an example, at a heat exchanger, the interface will be data associated with the te'mperature and flow rate of the cooling media. The interfacing system equipment / data / design will be verified to the extent that the input parameters can be validated with respect to a verified calculation or vendor document.

Electrical - Electrical power will be verified from the actuating component or power supply to the ultimate on site source required for the component to perform its i

intended function. All selected system loads and their design parameters will be

! verified. Verification will focus on the review ofloads associated with the selected se

P3 MILLSTONE UNIT 2 ICAVP PP-01 i E >

PROJECT PROCEDURES

! O V TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 8 OF 26 system. Design documents will reviewed to the level of confirming that the intended function can be accomplished.

Instrumentation and Control -I&C will be verified from the individual field sensor to the component or device required to perform an intended function. Verification will include any portion of the instrument loop, power supplies, circuitry, interfacing hardware and range / set point required to assure the intended function is accomplished. The SVSR will concentrate on verifiying (1) signals associated with the selected system, and (2) that the instrument loop performs its prinlary function. Design documents will reviewed to the level of confirming that the intended function can be accomplished.

Piping - will be reviewed to the point of interface with the component and/or i supporting structures. Supporting structures will not be considered within the '

system boundary.

. Directs the development of the system specific review instructions, checklists and

() observation / question forms e Defines necessary resources to facilitate the review e Provides orientation and training to team members on the approach, methodology and overall project expectations e Reviews and approves system specific review instructions, checklists, and supplements.

. Develops a summary report of each system specific review and a comprehensive report of the inspection results SVSR Team Members

. Develop system specific review instmetions and checklists e Conduct the system reviews in accordance with this review plan and the system specific instructions and checklists a Develop system specific reports and make apprepnate presentations on the status of the system specific reviews to Team Supenision, Deputy Project Director, Project Director.

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1 4.1 INSPECTION PREPARATION l

4.1.1 Staff Trainine and Mobilization 1

Resources 1 Deputy Project Director SVSR Group Lead Action 4.1.1.1 Assess Project personnel needs based on selected system 4.1.1.2 SVSR Group Lead revises Team discipline composition as required to cover the selected system inspection 4.1.1.3 Develop mobilization and training schedule for Deputy Project Director approval 4.1.1.4 Complete SVSR mobilization and training completed in accordance with approved schedule l

Action Output Trained Personnel 4.1.2 jdentify System Specific Documents for Inspection Resources System Leads System Team Members Aetion 4.1.2.1 Identify a list ofdocuments and other information associated with the system. Typical information to consider:

• Details of system boundaries / interfaces O

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'F) MILLSTONE UNIT 2 ICAVP PP-01 E >

PROJECT PROCEDURES

( TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 10 OF 26 Identified system deficiencies or operating problems e

Regulatory documents containing requirements specific to selected system

. Modifications made to the selected system

. System Drawings e Calculations e System related actions from the Corrective Action Program

. Design changes e Design Basis Documents l

• Licensing changes e Procedure changes

. Original design information l

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. System test data O

O e Operating procedures e Maintenance procedures System regulatory requirements such as environmental qualifications, fire protection, I seismic qualifications Action Output u l A system specific document list.

l NOTE:

l The checklist initiated in Step 4.1.2.1 will be completed for all applicable parameters and functions the l

team can identify for the selected system. A list of typical document types is provided in Appendix B.

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!!) MILLSTONE UNIT 2 ICAVP PP-01 E

PROJECT PROCEDURES p)

( TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 11 OF 26 1

4.1.2.2 Utilizing the list of documents developed in Step 4.1.2.1, develop a matrix of specific i documents to inspect. These documents will be retrieved and evaluated during the inspection.

4.1.2.3 Develop list of organizations (internal and external) associated with the items identified.

4.1.2.4 Develop schedule for inspection.

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I Action Output An inspection list that will preside:

• Document retrieval requirements I e Inspection organizational interface requirements e Detailed Schedule for resource planning l

x. 4.2 Conduct OfInspection j

The inspection will be conducted in multiple phases, altemating between ineffice document review and verification and in-plant walkdowns. Walkdowns will be used to obtain additional information, clarify information, verify commitments, and answer working questions.

I NOTE The typical process will be in-office review ior 2 to 3 weeks, followed by walkdown actisities at the site for one to two weeks duration. The process will be repeated as necessary to complete the inspection. The actual length of each inspection phase will be a function of the system and the inspection scope.

A 100% review of the system against licensing and design basis shall be performed during Tier 1. The review will include (but not be limited to) mechanical, electrical, I&C, and civil / structural requirements such as calculations, analysis, assumptions, and conclusions. _

Appropriate design documents and data for the selected system and the system components shall be reviewed to the extent necessary to verify 100% of the selected system requirements.

lfQ For repetitive, standard, or identical functional components the verification will include a V screening process to confirm that the components are repetitive and identical followed by validation of the licensing or design basis requirement using a component group process.,

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E MILLSTONE UNIT 2 ICAVP PP-01 l >

PROJECT PROCEDURES TITLE: SYSTEM VERTICAL SUCE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 12 OF 26 4.2.1 Evaluate Documents Resources l

l System Lead System Team Members Action ,

1 4.2.1.1 Retrieve necessary documents 1

4.2.1.2 Review system documents and record the results of the evaluation. The review should '

I determine whether: 1 1

The system current configuration accurately reflects the licensing-bases, including the updated FSAR.

. b e 'ne system calculations and analyses were performed using recogmzed and acceptable  !

analytical methods.

• l The assumptions made in any calculations or analysis supponing the change are technically 1 sound.  !

The results of calculations or analysis supporting the unmodified portions of the original configuration and design changes are reasonable (based on engineeringjudgment) for th: scope of the change.

NNECo considered the effect of a change on design margins and the design changes received the appropriate level of engineering and management review during the design phase and prior to implementation.

NNECo considered the effect of a change on pre-operational, startup, or system baseline acceptance test results.

l e Design changes were accomplished in accordance with approved procedures.

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P) MILLSTONE UNIT 2 ICAVP PP-01 ,

E PROJECT PROCEDURES i TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 13 OF 26 ] l e Design changes are accurately reflected in operating, maintenance, and test procedures, as well as in training materials.

NOTE Procedures will be reviewed in detail to verify that correct licensing and design bases information have been incorporated into the procedures and that modifications, corrective actions, and changes in system licensing bases have not invalidated preoperational and/or startup acceptance.

• Proposed design changes, subsequently canceled, were not replaced by procedural changes that imposed excessive burdens on plant operators.  ;

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E MILLSTONE UNIT 2 ICAVP PP-01 l PROJECT PROCEDURES TITLE: SYSTEM VERTICAL SLICE REVIEW l REVISION: 1 DATE: 06/09/97 PAGE 14 OF 26 4.2.1.3 As documents aro eviewed, prepare walkdown checklists detailing items needing additional information or clarification.

Action Output A list ofinspection walkdown requirements A record of documents reviewed and their disposition l NOTE:

Typical design input requirements to be used in evaluating system documents are listed in Appendix C.

Typical design review questions to be used in evaluating system documents are listed in Appendix D.

4.2.2 Plant Walkdowns

\ Resources System Lead System Team Members Action 4.2.2.1 Develop Walkdown Package. Typical contents will be:

• System components and/or area to inspect during the walkdown

• Specific modification package elements to inspect System specific Corrective Actions identified by the Millstone Unit 2 Configuration Management Program to inspect and evaluate e Measurements / observations to make e System procedures to walkthrough

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• Location of components or structures l

• Marked up drawings showing walkdown requirements O

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1 P) MILLSTONE UNIT 2 ICAVP PP-01  ;

E PROJECT PROCEDURES

\ TITLE: SYSTEM VERTICAL SUCE REVIEW  ;

REVISION: 1 DATE: 06/09/97 PAGE 15 OF 26 4.2.2.2 Obtain clearance and/or access permits. Examples:

i e Radiation work permit i e Scaffolding

. Specialoperational requirements l

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4.2.2.3 Conduct the walkdown, emphasizing:

NOTE l The system vertical slice reviews will be focused on licensing and design bases requirements and will utilize appropriate level documentation (drawings, calculations, design documents, etc.) to the inspection detail necessary to verify and validate conformance to the requirements.

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control of operational procedures, maintenance procedures, test and suiveillance procedures, l operator training, and control of the plant simulator configuration.

e configuration control consistency with the licensing bases at the level of detail contained in piping and instrumentation diagrams (P&lDs) or system flow diagmms, piping isometric drawings, electrical single-line diagrams, and emergency, abnormal, and normal operating procedures.

e engineering design and configuration control processes; e verification of current, as-modified plant conditions against design basis and licensing basis documentation; e verification that design and licensing bases requirements have been and are being translated into operating procedures and maintenance and test procedures; l e verification of system performance through review of specific test records and/or observation of selected testing of particular systems; and

• review of proposed and implemented corrective actions for Millstone Unit 2 identified design deficiencies.

P) MILLSTONE UNIT 2 ICAVP PP-01 E

! A PROJECT PROCEDURES l TITLE: SYSTEM VERTICAL SUCE REVIEW REVISION: 1 DATE: Ofi/09/97 PAGE 16 OF 26 Action OutDut Completed Walkdown Package 4.2.3 Conduct Structured Data Gatherine l

Resources SVSR Team Members SVSR System Leader Action 4.2.3.1 Prepare a list of specific information to be obtained based on a need for clarification, information that the SVSR team can not find, or further investigation into answering a working question. This will help ensure that the information requirement is focused.

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%J 4.2.3.2 Identify the organization orjob function that may be able to supply the specific information. Arrange for a data gathering conference to obtain needed information.

NOTE All data gathering conferences will be conducted in accordance with the Communication Plan (PLN-02).

Action Output e Guidance and clarifications regarding NNECo positions or decisions

. Additional information 4.3 INSPECTION ASSESSMENT AND REPORT Resources Deputy Project Director SVSR Group Leader SVSR System Lead SVSR Team Members

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jA Action iG

l P3 MILLSTONE UNIT 2 ICAVP PP-01 E

PROJECT PROCEDURES TITLE: SYSTEMVERTICAL SLICEREVIEW REVISION: 1 DATE: 06/09/97 PAGE 17 OF 26 43.1 Collect and assess the results of the inspection preparation and system inspections from each of the inspection teams 4.3.2 Prepare a draft report of the SVSR activities, results, and conclusions. The report is to consist of, as a muumum:

e input to an executive summary, e a summary description of the methods used, e a summary of what was reviewed, e results of the vertical slice reviews, and a the conclusions that can be drawn from the results of the reviews.

The conclusions are to include a determination of whether:

/ e the current configuration accurately reflects the licensing-bases. including the UFSAR, at the level of detail contained in piping and instrumentation diagrams (P& ids) electrical single-line diagrams, and plant operating procedures.

calculations and analyses were performed using recognized and acceptable analytical methods and that assumptions made in calculations or analysis supporting changes are technically sound.

. the results of calculations or analysis supporting the unmodified portions of the original configuration and design changes are reasonable (based on engineering judgment) for the scope of the change. l NNECo considered the effect of a change on design margins and that the design changes l received the appropriate level of engineering and management review during the design l phase and prior to implementation.

NNECo considered the effect of a change on pre-operational, startup, or system baseline acceptance test results. )

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, design changes are accurately reflected in operating, maintenance, and test procedures, as well as in training materials.

i E3 MILLSTONE UNIT 2 ICAVP PP-01 E

PROJECT PROCEDURES .

p l Q TITLE: SYSTEM VERTICAL SUCE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 18 OF 26 )

e proposed design changes, subsequently canceled, were not replaced by procedural changes that imposed excessive burdens on plant operators. 1 4.3.3 Support internal ICAVP reviews of the draft report as necessary.

4.3.4 Resolve comments and finalize the report for issue. j Action Output 1

Final Report i Project backup documentation 4.4 TEAM MEETINGS / REVIEWS j l

During the SVSR, meetings and status reviews will be heldp' eriodically. The following guidelines I shall govern the regularly scheduled meetings.

• Meetings of the individual system teams shall be held daily.

The daily meetings shall be chaired by the System Lead and shall cover inspection status, progress, working questions under review, and discrepancies to date.

• Combined Team meetings shall be held at least weekly.

The weekly meetings shall be chaired by the SVSR Group Lead or the Deputy Project Director and shall cover the overall progress of the inspection including working questions under l

review and discrepancies to date in all areas.

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4.5 SYSTEM ASSESSMENT .

1 System Assessment 1

As Working Questions are identJied by the SVSR Team Members, they are to be documented for I further investigation.

l Follow up by SVSR Team Members will determine that either 1) upon obtaining further information, no question exista, or 2) it is an identified discrepancy with a documented basis. Discrepancies are evaluated per Project Procedure PP-07. Each discrepancy fonvarded for

f P) MILLSTONE UNIT 2 ICAVP PP-01 E PROJECT PROCEDURES l t TITLE: SYSTEM VERTICAL SUCE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 19 OF 26 PP-07 review will be provided with a complete description, including all pertinent background l information.

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5.0 REFERENCES

l NRC Inspection Procedure 93801, Safety System Functional Inspection (SSFI)

NRC Inspection Manual Chapter 0350, " Staff Guidelines for Restan Approval" NRC Inspection Manual Chapter 2535, " Design Verification Programs" Millstone Unit 3 Restan Assessment Plan j NRC Confirmatory Order to Northeast Utilities Energy Company dated August 14,1997 .

NRC ICAVP Oversight Guideline Document NRC ICAVP Oversight Inspection Plan i

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PP-01 ED MILLSTONE UNIT 2 ICAVP E .

PROJECT PROCEDURES TITLE: SYSTEM VERT: CAL SLICE REVIEW PAGE 20 OF 26 REVISION: 1 DATE: 06/09/97 ar_

l APPENDIX A SYSTEM SELECTION CRITERI A Introduction The Parsons Power Group criteria for selecting systems for vertical slice review has been deve provide an additional selection process to that criteria described by the NRC in the IC Inspection Plan.

The ICAVP Oversight Plan (page 5) stipulates that the NRC will select the systems to be in Tier 1 and that they will consider, in addition to the contractors proposed criteria, NRC criter

1. risk significance,

2. design and operating characteristics,

3. the number and complexity of changes to the system, and

4. the number of previously identified deficiencies or operating problems The focus of the ICAVP, the Millstone Unit 2 Configuration Management Corrective Action P in its scope the Millstone Unit 2 systems categorized by NNECo as either Group 1 (safe significant) and Group 2 (safety-related pr risk significant). Using the Group 1 and 2 s point, the selection criteria will apply quantitative selection criteria to determine which these two groups are likely candidates for the vertical slice inspection.

The initial systems to be reviewed will be selected from those systems categorized as Grou using criteria developed as part of maintenance rule implementation (10CFR50.65). Als that the utilization of the selection criteria will be done by the NRC.

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E) MILLSTONE UNIT 2 ICAVP PP-01 N .

PROJECT PROCEDURES g

Q TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 21 OF 26 i System Selection Criteria Factors have been developed on specific system attributes that, when measured and ranked, provide the basis for determining the Tier I candidates. These attributes are measured through an intensive exanunation of system operational, configuration and regulatory history Attributes Factor #1- Risk Significance Identify those systems that have a high level of risk significance base on PRA insights as determined by a panel ofindividuals familiar with Millstone Unit 2 PRA. Cut sets (accident c sequence failure combinations) with a high level of risk significance are exammed to identify

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specific systems / components. Based on the risk significance of systems and/or components, a qualitative risk factor is developed for fmal determination of system rankmg by the expert panel.

Factor #2- Number of Modification Events (Fm)

For purpose of the ICAVP selection criteria, a modification is defined as any change to any aspect of the system (components, procedures, design, calculations, etc.) that will alter or resise in any way 1) systems design bases; 2) system maintenance; 3) system controls; and 4) system operation.

Fma is developed by reviewing all documentation for each Group 1 and Group 2 system and developing a matrix of system modifications and the count of modification events. Modification events are changes and/or revisions to design bases, maintenance, controls and/or operations of the system made during the modification. The modification events for each system are then summed to arrive at the total number. The concluding step is to compile system rankmgs as a function of the number ofmodifications events per system.

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PROJECT PROCEDURES 3

(Q TITLE: SYSTEM VERTICAL SLICE REVIEW I REVISION: 1 DATE: 06/09/97 PAGE 22 OF 26 Factor #3 - Number of Major Modifications /Icterfaces (Fuui) l The selection criteria defmes a major modification as a design change invohing internalinterfaces between major discipline areas and'or externalinterfaces with one of more of the following: the NSSS vendor, component vendors, or an engineering senice organization (s).  !

Fui is developed in matrix form by reviewing all documentation for the systems and noting the l l

l number ofinterfaces involved in the various modifications for each system. The total number of interfaces per modification and system will be derived for the total factor per system. He systems will be ranked accordingly.

Factor #4 - Plant System History (Fes)

Licensee Event Reports (LERs) provide an extensive record of system problems to be used for l system selection. LERs provide information on both the system and the system components. For purposes of system selection, an LER will be counted as applicable ifit relates in anyway, to: 1) l 1

I systems design bases; 2) system maintenance; 3) system controls; and 4) system opration. Fes is i the summed LERS for each system.

Factor #5 - Industry System History (F is) l Input for system selection for Factor #5 will be based on industry data on system and equipment failure rates. The data input will be derived on a system by system basis from the Nuclear Plant Reliability Data System and the CE Owners Group. The data and its collection will be similar to Factor #4' but on an industry wide, NSSS specific basis. The F is will be summed failure on a system by system basis.

An Expert Panel will make the fmal determination of the relative ranking of the systems based on the

[b

, ~~'$ results of the system selection survey, system boundaries, industry experience, and their own knowledge of the systems and the requirements of the ICAVP.

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E) MILLSTONE UNIT 2 ICAVP PP-01 E

PROJECT PROCEDURES l TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 23 OF 26 1

1 APPENDIX B TYPICAL DOCUMENT REVIEW / SAMPLE TOPICS FOR INSPECTION

1. System Design Review - Fluid and Material Handling Systems

2. Fluid System Diagram; System Description; for complex systems, Logic and Loop Diagrams

3. System Design Review - Structural

4. Bracing Arrangement ar.d Stability Analysis

5. System Design Review - Electrical System 6 One-line Diagram and System Description

7. System Design Review - Information Processing / Control Philosophy

8. Description of Control Philosophy

( 9. System Design Review - Facilities Design Systems

10. HVAC, Fire Protection, and Architectural l

11. Layout Design Review

12. Layout Drawing, Layout Description, Code Reviews, and Life Safety Analysis

13. Site Arrangement Resiew

14. Ultimate Site Development Plan

15. Cooling Water Source

16. Environmental Constraints

17. Common or Shared Facilities

18. Railroad Access

19. Foundation Type Resiew

20. Geotechnical Limitations

21. Soil Bearing Capacity

22. Water Table Considerations

23. Alternative Methods

24. Transmission and Distribution Design Review

( 25. Modification Packages

F E3 MILLSTONE UNIT 2 ICAVP PP-01 E >

PROJECT PROCEDURES

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Q] TITLE: SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 24 OF 26 APPENDIX C TYPICAL DESIGN INPUT REQUIREMENTS

1. Scope / Basic functions of structure, system or component

2. Performance requirements, input services (air, electricity) as well as outputs (capacity, rating)

3. Codes Standards, and regulatory requirements including applicable issue and/or addenda

4. Design Conditions such as temperature, pressure, fluid, chemistry and voltage

5. Loads such as seismic, wind, thermal and dynamic

6. Emironmental conditions anticipated, such as pressure, temperature, humidity, corrosiveness, site elevation, wind direction, nuclear radiation, electromagnetic radiation, and duration of '

l exposure including 10CFR50.49 application '

7. Interface requirements and constructability including definition of the functional and physical q interfaces including structures, systems, and components O 8. Material requirements such items as compatibility, electrical insulation properties, protective coating, and corrosion resistance

9. Mechanical requirements such as vibration, stress, shock and reaction forces

10. Stmetural requirements covering such items as equipment foundations and pipe supports

11. Hydraulic requirements such as NPSH, allowable pressure drops, and fluid velocities l 12. Chemistry requirements such as provisions for sampling and limitations on water chemistry 1

13. Electrical requirements such as source of power, voltage, raceway requirements, electrical insulation, motor requirements, load / voltage studies and EDG loading

14. Layout and arrangement requirements

15. Operational requirements under various conditions such as plant start-up, normal plant operation, plant shutdown, plant emergency operation, special or infrequent operation, and l system abnormal or emergency operation

16. Instrumentation and control requirements including indicating instruments, controls and alarms required for operation, testing and maintenance.

17. Access and adnunistrative control requirements required for plant security

18. Redundancy, diversity, and separation requirements

19. Failure effects requirements including of those events which they must withstand

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MILLSTONE UNIT 2 ICAVP PP-01 l PROJECT PROCEDURES in TITLE: SYSTEM VERTICAL SLICE REVIEW j REVISION: 1 DATE: 06/09/97 PAGE 25 OF 26

20. Test requirements including pre-operational and subsequent periodic in-plant and the condition i under which they must operate

21. Accessibility, maintenance, repair and in-service inspection requirements

22. Personnel requirements and limitations

23. Transportability requirements such as size and shipping weight

24. Fire protection or fire resistance requirements

25. Handling, storage, cleaning and shipping requirements

26. Other requirements to prevent undue risk to the health and safety of public l 27. Materials, processes, parts, and equipment suitable for application i

28. Safety requirements for preventing personnel injury

29. Quality and quality assurance requirements

30. Reliability requirements including their interactions, which may impair safety

31. Interface requirements between plant equipment and operation and maintenance personnel O

l V 32. Requirements for criticality control and accountability of special nuclear materials 1

33. Special ALARA considerations

34. Special human factors considerations 1

35. High Energy Line Breaks are affected l

36. Flooding

37. Missiles 38.10CFR50 Appendix R, including Safe Shutdown Analysis

39. Seismic Category II over I l 40. Special HVAC requirements

41. Station Blackout Analysis j 42. Post Accident Monitoring Requiremunts

43. OTHER requirements, as necessary O

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l S MILLSTONE UNIT 2 ICAVP PP-01 E

{A lV TITLE:

PROJECT PROCEDURES SYSTEM VERTICAL SLICE REVIEW REVISION: 1 DATE: 06/09/97 PAGE 26 OF 26 APPENDIX D TYPICAL DESIGN REVIEW OUESTIONS

1. Were the inputs correctly selected and incorporated into design?

l 2. Are assumptions necessary to perform the design activity adequately described and reasonable?

l Where necessary, are the assumptions identified for subsequent reverification when the detailed design activities are completed?

3. Are the appropriate quality and quality assurance requirements specified?

4. Are the appropriate codes, standards, and regulatory requirements specified?

5. Have applicable operating and construction experiences been considered?

6. Have the design interface requirements been satisf ed?

7. Was an appropriate design method used?

8. Is the output reasonable compared to the inputs?

j 9. Are the specified parts, equipment, and processes suitable for the required application?

( 10. Are the specified materials compatible with each other and the design emironmental conditions to which the material will be exposed?

j 11. Have adequate maintenance features and requirements been specified?

12. Are accessibility and other provisions adequate for performance of needed maintenance and repair?

13. Had adequate accessibility been provided to perform the in-senice inspection expected to be required during the plant life?

l 14. Has the design properly considered radiation exposure?

15. Are the acceptance criteria incorporated in the design documents sufficient to allow verification l that design requirements have been satisfactorily accomplished?

16. Have adequate pre-operational and subsequent periodical test requirements been appropriately specif'ed?

i

17. Are adequate handling, storage, cleaning, and shipping requirements specified? Are adequate identification requirements specified?

18. Are requirements for record preparation, review, approval, retention, etc., adequately specified?

P3 O  ? PARSONS PP-02 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

Accident Mitigation Systems Review l

l l

l REVISION 1 Prepared by: Date: d- - M o e '

u Approved by: 7[d Date: 6/9/ff j anager, Company Quality Program Approved by: MI' }-

, Date: h-f-f h Projechrector l

l REVISION HISTORY j REVISION DATE REVISION DESCRIPTION 0 04/03/97 Procedure initiation i

1 06/09/97 incorporation of NRC Comments I

i i

O

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g MILLSTONE UNIT 2 ICAVP PP-02  !

a PARSONS PROJECT PROCEDURES i i

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( TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 2 OF 15 TABLE OF CONTENTS l

l i

1.0 PURPOSE..................................................................................................................3 l 1

2.0 D E FI NI TI O N S ..... ................ . ..................................................... .... ..... . ...... .. 3 l 1

3.0 P RE RE Q UI S I TES ..... .............. .......... ............... ..................... ............... ................... 3 4.0 PROCEDURE...........................................................................................................4 4

4.1 DEFINE CRITICAL SAFETY FUNCTIONS . . .5 4.2 CRITICAL PARAMETER. ..8 l

1 l

4.3 CRITICAL COMPONENT / SYSTEM.. .10 i

l 4.4 CRITICAL DESIGN CHARACTERISTIC.. .. . . . 12 l

4.6 CRITICAL DESIGN CHARACTERISTIC ASSESSMENT. . .13 l

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1

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l g MILLSTONE UNIT 2 ICAVP PP-02 m  ; PROJECT PROCEDURES

, PARSONS t (^'N TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 3 OF 15 l

1.0 PURPOSE l

l The Accident Mitigation Systems Review (AMSR) will identify and verify the critical design characteristics for accident mitigation systems and their components required to i

meet the Design Bases Events (DBEv) identified in Chapter 14 of the Millstone Nuclear l Plant Unit 2 Updated Final Safety Analyses Report (UFSAR).

2.0 DEFINITIONS 2.1 Design Bases Event (DBEv) - Design Bases Events are defined as those initiating events as presented in Chapter 14 of the UFSAR and form the bases for the operating license of the Millstone Unit 2 Nuclear Power Plant.

l 2.2 Critical Safety Functions (CSF) " Critical Safety Functions" are defined as the specific set of activities that must occur in order to ensure that a success path associated with the design bases event mitigation is met and maintained.

2.3 Critical Action " Critical Action"is defined as an active change that must happen in order for the critical function to be met.

2.4 Critical Parameters " Critical Parameters" are a set of attributes that are required to be met by a system or component in order to achieve success in meeting critical actions.

2.5 Critical Design Characteristic (CDC) - A critical design characteristic is defmed as that 1

aspect of a component or system that must be provided by the designer to ensure that the l component or system will meet the performance criteria identified in Chapter 14 of the UFSAR.

3.0 PREREOUISITES

,p e Copies of:

V 1

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g MILLSTONE UNIT 2 ICAVP PP-02 m PROJECT PROCEDURES PARSONS D

\

TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 4 OF 15 l

- Chapter 14 of the UFSAR

- Accident Analyses l - Emergency Operating Procedures

- System P&lDs e System Design Descriptions (SDD) e Safety System Logic Documents e Shut Down Logic e Safety Evaluation Report (SER) e Design Bases Documents (DBD) 4.0 PROCEDURE Qveniew: Determine the critical design characteristics for systems and components that must be confirmed in order to ensure that the plant will comply with the safety analyses identified in Chapter 14 of the UFSAR. The simplified process flowchart is presented in Exhibit 2-1. The DBEv groups covered by this procedures are identified in Table 1.

l 4.1 DEFINE CRITICAL SAFETY FUNCTIONS Resources

• System Engineer e Accident Analyst

• Electrical Engineer

• Mechanical Engineer

. Controls Engineer l

l

. FSAR e Emergency Operations Procedures

. Technical Specifications

l g MILLSTONE UNIT 2 ICAVP pp.02 l 3 PROJECT PROCEDURES i

w -PARSONS TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 5 OF 16 Exhibit 21 "S'8 mae*

PreArrinary 4 CDC AMSR Review Process Review By DBEv FSAR Chapter 14m oO Pr -> Safey A --

Functens Diagram g NNECo Data eg .RM N s DBEvCDC W Cgal P amaters a 4To Tm 1

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g Analyze y, System

\V u > DeWop T2 Database Design Basis Y Critical r'

Structur, Events 8

o b

Validate FSAR R Conect 4 Compare Anahsis p- Claracteristes

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% NNECo Data -> System As. To -

g Documented A Documented Design I Validaten N

p Propere ri,, o nw &

Y Report F Y

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g~ MILLSTONE UNIT 2 ICAVP PP-02 1

m PROJECT PROCEDURES I PARSONS l

! FN l t

TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 6 OF 15

• PC database Action 1.1 Review UFSAR Chapter 14 and identify design bases events by logical groups (refer to Table 1).

1.2 Evaluate DBEv groups to identify Critical Safety Functions essential to achieve and maintain a controlled condition following an event. (e.g. RCS Heat Removal, Reactivity Control, RCS Inventory Control, etc.)

1.3 Identify Critical Safety Function objectives and system level plant processes / actions to achieve objectives.

1.4 Identify design related licensing criteria thr.t apply to UFSAR Chapter 14 DBEv mitigation. l l

1.5 Review data with NRC.

1.6 Create generic Cntical Safety Function Diagrams for each Critical Safety Function and identify system level active components that support the process or action. (Example shown as Exhibit 2-2) 1.7 Identify initiation and control signal requirements for each system level component or action identified on the Critical Safety Function Diagram.

1.8 Develop a System Boundary Diagram for each System involved with the DBEv.

1.9 Develop a critical safety function data base to record the results of each DBEv review.

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i g MILLSTONE UNIT 2 ICAVP pp 02 m PROJECT PROCEDURES PARSONS

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l i

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TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 7 OF 15 Table 1 DBEv GROUPS 1

DBEv Variation Increase in Heat Removal Decrease in Feedwater Temperature by the Secondary System Increase in Feedwater Flow Increase in Steam Flow Inadvenent Opening of a Steam Generator Relief or Safety Valve Steam Pipe Failure Inside and Outside containment Decrease in Heat Removal Loss of External Load by the Secondary System Turbine Trip Closure of Main Steam Isolation Valve Loss of Normal Feedwater Flow Decrease in Reactor Loss of Forced Reactor Coolant Flow Coolant System flow Reactor Coolant Pump Rotor Seizure i Q

(/

Reactivity and Power Distribution Anomalies Uncontrolled Control Rod Bank Withdrawal From a Subcritical or hw Power Startup Condition Uncontrolled Control Rod / Bank Withdrawal at Power Control Rod Misoperation Startup of an Inactive Imop I CVCS Malfunction That Results in a Decrease in the Boron Concentration in the Reactor Coolant I Control Rod Ejection Accident Decrease in Reactor Inadvertent Opening of a Pressurizer PRV Coolant inventory Steam Generator Tube Failure - Rad Consequences LOCA From Breaks in the RCP Boundary Radioactive Releases from Waste Gas System Failure a Subsystem or component Fuel Handling Accident Spent Fuel Cask Drop Accident Non-Standard Review Plan Containment Analyses Events Hydrogen Accumulation iu Containment Radiological Consequences of the Design Bases Accident I

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g MILLSTONE UNIT 2 ICAVP PP-02 l m PROJECT PROCEDURES I

PARSONS

>O U TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 8 OF 15 l

l Exhibit 2-2 SAFETY FUNCTION DIAGRAM Loss ofFeedwater Flow RCS Presswe & Reactmty inventory Control Heat Removal Corarol O

ag y

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.* y m* * = <

80 = ' =

=

avr Component Critical Design Criteria Action Output e System Boundary Diagrams for affected systems

• Critical Safety Function Diagram.

4.2 IDENTIFY CRITICAL PARAMETERS l

Resources e System Engineer e Accident Analyst i

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g MILLSTONE UNIT 2 ICAVP pP-02 m PROJECT PROCEDURES

, n PARSONS l [ )

V TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 9 OF 15 e PC database e Design Calculations e Regulatory Commitments e Accident Analyses e System Design Descriptions

. Emergency Operating Procedures (EOP) l

. Technical Specifications e Critical Safety Function Diagrams e System Boundary Diagrams e Electrical Systems Diagrams e System Logic and Control Diagrams 1

Q Q Action 1.1 Review each DBEv group accident analyses including , system calculations and analyses, to identify critical actions and key functional system level requirements.

1 1.2 Using the Critical Safety Function Diagrams and System Boundary Diagrams, i

evaluate each Critical Safety Function and identify the system and component critical parameters essential to achieving the safety function.

l 1.3 Identify where analyses parameters are documented and document key assumptions made.

l 1.4 Review plant design calculations, IST data, and other documents to establish the "as-designed" characteristics at the system component level. It may be necessary to review additional system level documents in order to establish any non-safety related system-level interfaces.

p 1.5 Enter DBEv critical parameter into the DBEv, Tier 2 database (T2DB) .

l l

l

l

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g MILLSTONE UNIT 2 ICAVP pp.02 m PROJECT PROCEDURES PARSONS v) TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 10 OF 15 1.6 Confirm critical parameter by reviewing the definitive references that identifies the critical parameter.

1.7 Jf an inconsistency exists, the Engineer will prepare a discrepancy report l identifying the critical parameter, and the documentation (l'it supports the discrepancy. Resolution will be in accordance with the discrepancy evaluation process (PP-07).

1.8 Review the T2DB to determine the variable range associated with a critical parameter.

1.9 Provide system and component critical design data to Tier i for Systems selected for review.

O l

Action Outnut e Database file and reports of the critical parameter for each system and DBEv safety function.

. Discrepancy reports 4.3 SYSTEM / COMPONENT ASSESSMENT Resources e System Engineer e Mechanical Engineer e Electrical Engineer e Controls and Instrument Engineer e Accident Analyst

. PC database O

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g MILLSTONE UNIT 2 ICAVP PP-02 l

I a -PARSONS PROJECT PROCEDURES O

U TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 11 OF 15 l

• Engineering Calculations

• System Design Descriptions

• Design Bases Documents

. PRA

. SER

• Electrical System Diagrams

= Control Loop Diagrams Action 1.1 Develop system composite database including all essential support systems for critical safety function systems using documented information 1.2 List component design performance requirements into the T2DB.

1.3 Document active component "as-is" performance capabilities from plant specific IST j data and logs.

1.4 Document references and source information used to identify the important-to-safety components and systems.

1.5 If a component or system is found to ce:asin a discrepancy. s discrepancy report shall be prepared. Resolution will be in accordance with the discrepancy evaluation process (PP-07),

i The discrepancy report shall contain the following information: l

• Critical component l

e Discrepancy

• Effect of Discrepancy n e Documents supporting potential findinr.,

U

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g MILLSTONE UNIT 2 ICAVP pp.02  :

m PROJECT PROCEDURES PARSONS I f,' ~

TITLE: ACCIDENT MlTIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 12 OF 15 1

l l

e References l l Action Outout System / Component Listing including performance requirements and capabilities

. Discrepancy Reports 4.4 IDENTIFY CRITICAL DESIGN CHARACTERISTIC Resources

• System Engineer

. Mechanical Engineer

. Electrical Engineer o Controls Engineer e PC database from System Assessment and Critical Parameter Identification e Accident Analyses e Engineering Calculations

• System Design Descriptions e SER e Electrical System Diagrams e EOP e Technical Specification

• Critical Safety Function Diagrams a Action 1.1 Check "as-documented" data with the T2DB to confirm component requirements.

There may be multiple requirements that are derived for different DBEv

O

. . - - . ... . -_ . _. .- __ _ _ . - = -

g MILLSTONE UNIT 2 ICAVP PP-02 m PROJECT PROCEDURES PARSONS V TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 13 OF 15 1.2 Check to ensure that all bounding infonnation has been identified in the plant documents.

1.3 Review technical specifications and Emergency Operating Procedures versus critical l parameters to determine consistency.

I l 1.4 Document the following information:

• Critical Safety Function e Applicable Design Bases Event l

• Critical Component e Critical Parameter e Critical Characteristic

= Reference source for confinnation

! 1.5 Discrepancies between "as-docu tented" and "as-analyzed" data will be identified in a discrepancy report and resolved in accordance with PP-07.

Action Outnut T2DB "as-documented" parameters for critical components and systems.

• Discrepancy Reports 4.5 CRITICAL DESIGN CIIARACTERISTIC VALIDATION ASSESSMENT Resources e Sycem Engineer e PC database e IST data l e Other test data l

i l

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g MILLSTONE UNIT 2 ICAVP pp.02 i a PARSONS PROJECT PROCEDURES w/ TITLE: ACCIDENT MITIGATION SYSTEM REVIEW REVISION: 1 DATE: 06/09/97 PAGE 14 OF 15 1

l l

Action 1.1 The AMSR team lead will extract the list of Critical Design Characteristics from the T2DB and with the AMSR team and NRC determine the CDCs to be validated.

1.2 Tier 1 personnel will verify that the Critical Design Characteristics are inplace and properly documented for the NRC selected systems.

1.3 Tier 2 personnel will verify that the critical design characteristics are inplace and  !

properly documented for the balance of the characteristics selected by the NRC for resew.

d 1.4 in those cases where the Tier 1 Team is evaluating a system having a group of Critical l

Design Characteristics, the Tier 2 team will not verify them. The SVSR Team will provide the validation through responses on the Tier 2 Validation form. An example of the Verification Form is shown as Exhibit 2-3. Identify as a discrepancy components not having the Critical Design Characteristic met. It will be compared to the results of the NNECo program fmding to determine ifit is on the list. Ifit is on the l list, the parameter will be documented as being covered under the NNECo program.

1.5 Resolution of discrepancies will be in accordance with the discrepancy evaluation i process (PP-07).

l Action Output

. Validation report containing the following information:

• Critical component

e Critical parameter

' f}

., V l

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g MILLSTONE UNIT 2 ICAVP PP-02 .

m PROJECT PROCEDURES I PARSONS '

\ TITLE: ACCIDENT MITIGATION SYSTEM REVIEW l REVISION: 1 DATE: 06/09/97 PAGE 15 OF 15 i I

, )

i i

e Critical Design Characteristic (s)

. Validation method i

j e References

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• Final Report l

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5 j

j 5xhibit 2-3 j AMSR-CDC VIrificcti::n Form AMSR- -

System:

Component:

Characteristic:

i Parameter (s):

T2 Engineer:

Date

i I

1 Comoonent Location:

1 ,

4 Testina/ Surveillance Document:

l hm:

, Number:

l Revision:

Data.iOLEMt '

4 4

4 1

1 1

1 1

4 J

j Characteristic Found -

Characteristic Verified - Discrepancy -

{ Characteristic Missing -  :

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1 1

j Assessment of Effect from missina characteristic:

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1 j Engineer Signature: Date: I 9

4' VERIFORM. DOC TIER 2 i

I E3 O - PARSONS PP-03 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

! Process Review, CMP Horizontal Slice

\

1 1

3

REVISION 1 i

1 t

Prepared by: Ar V

/ Date: fMM7

(m / \

Approved by: 9[/ Date: 6/pM 7 a 'er, Nuclear Quality Program '

Approved by: (Ai4e Project Director 6% Date: d f!f 2 j

j 1

REVISION HISTORY l REVISION DATE REVISION DESCRIPTION 0 04/03/97 Procedure initiation 1

06/09/97 incorporation of NRC Comments O

, g MILLSTONE UNIT 2 ICAVP PP-03 PROJECT PROCEDURES PARSONS t TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE f REVISION: 1 DATE: 06/09/97 PAGE 2 OF 51 -l

. TABLE OF CONTENTS l 1.0 PURPOSE . . . .... . 3 l l

2.0 DEFINITIONS . .. . . _3 l 4

3.0 PREREOUISITES . ... -

. ..... 5 l 1

1 4.0 PROCEDURE . .. _. .. . . 5 OVERVIEW:. .

.5 1

GwBAL PROCESS CONTROLE:. .

.7 1 i

4.1 GATHER DATA AND DEFINE THE MODEL STRUCTURE .7 l 4.2 PREPARE THE CHANGE PROCESS MODEL.. . . .I1 l 1

4.3 PROVIDE INPUT TO THE SYSTEM REVIEW PREPARATION.. . 12 1 4

4.4 SELECT THE CMP HORIZONTAL SLICE SAMPLE . . 13 l

> 1 4.5 PERFORM THE CMP HORIZONTAL SLICE REVIEW . .17 4.6 CHOOSE ADDITIONAL SAMPLES.. .19

!n 4.7 PREPARE REPORT.. . .20 5.o R t vE RE N CES ... .. .. . . ... . .... . ... ... .. ..... ... 21 ll APPEN D IX A .. . . . . ... .. . . . .... ... ... ... ... ..... ..... . ..... 22 l

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g MILLSTONE UNIT 2 ICAVP PP-03 m PROJECT PROCEDURES PARSONS TITLE: PROCESS REVIEW, CMP HORIZONTAL SUCE REVISION: 1 DATE: 06/09/97 PAGE 3 OF 51 -l 1.0 PURPOSE nis portion of the ICAVP will verify the adequacy of the Millstone Unit 2 CMP to identify and correct design and configuration management deficiencies associated with past change processes.

His review is a "out-come" based comparison of the current conditions versus the current design and licensing basis. It is not an evaluation of change processes used in the past, and this review

will not evaluate the adequacy of current processes to maintain configuration management. The review's horizontal slice across change processes will support an independent deternunation of whether Millstone Unit 2 currently meets its design and licensing bases.

In accordance with NRC direction, a review to determine whether Millstone Unit 2 processes and procedures have been established for effective configuration management on a going-forward basis will be addressed by others and is not included in this resiew.

2.0 DEFINITIONS pesien Bases (DB):

That information that identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted state-of-the-art practices for achieving functional goals or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a stmeture, system, or component must meet its functional goals.'

Licensinn Basis (LB):

The licensing basis for Millstone Unit 2 consists of that set ofinformation upon which the Commission, in issuing an initial operating license, based its comprehensive determination that the design, construction, and proposed operation of the facility satisfied the Commission's l requirements and provided reasonable assurance of adequate protection to public health and safety and common defense and security.2 A

\U) ' 10 CFR50.2 2

Source: NRC Letter of October 9,1996 On Maintaining Plant Design l

g MILLSTONE UNIT 2 ICAVP pP-03 l

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PARSONS PROJECT PROCEDURES t

p TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE

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REVISION: 1 DATE: 06/09/97 PAGE 4 OF 51 -l Current Licensing Basis (CLB):

The set of NRC requirements applicable to a specific plant and a licensee's wTitten commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,26,30,40,50,51,54,55,70,72,73,100 and appendices thereto; orders, license conditions; exemptions; and technical specifications. It also includes the plant specific design-basis information 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 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.'

Engineerine Design Bases (EDB):

The set of design constraints that are not included in the Licensing Basis but are implemented to achieve certain economies of operation, maintenance, procurement, installation, or construction.

Such as:

. Information which describes a system, structure, or component Operating values or parameters which are not reference bounds for design Information which identifies functions important for economic, maintenance, installation, or other non-safety function of design basis systems, structures, or components Information and operating values describing the functions of non-safety systems

. Calculations, descriptions, and other " outputs" t

I a

3 10 CFR 54.3 (a)

j gj MILLSTONE UNIT 2 ICAVP PP-03 l

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PARSONS PROJECT PROCEDURES b) v TITLE: PROCESS REVIEW, CMP HORIZONTAL SUCE REVISION: 1 DATE: 06/09/97 PAGE 5 OF 51 -l 3.0 PREREOUISITES

1. Process modeling PC network and software installed and tested.

2. Tier 1, SVSR Generic Checklist prepared prior to beguuung procedure Section 4.5,

" Perform the CMP Horizontal Slice Review" 4.0 PROCEDURE Overview:

This effort will verify the adequacy of the Millstone Unit 2 CMP to identify and correct deficiencies associated with past change processes, examples of past changes are to be reviewed.

This is a technical review of changes to the facility design or change of the characteristics,

( procedures, or practices for maintaining, operating, testing, and training on safety or risk significant systems, structures and components to determine if:

(1) the changes to the plant conditions meet the current design and licensing basis documentation, (2) design and plant information contained in databases and documents are accurate and consistent with the plant, (3) the design and licensing basis requirements have been translated into operating, maintenance, and testing procedurer, 1

(4) the performance of systems / components has been verified through testing, and (5) CMP corrective actions have adequately identified a corrective action for the deficiency associated with the examples ofpast changes selected for review. l l

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The review looks at the results of various change processes within change control, document

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l control, information management, and assessment and equipment monitoring. It compares the

( results of various change processes against design and licensing bases, and physically verifies some of the results against actual plant configuration.

MILLSTONE UNIT 2 ICAVP pp.03 g PROJECT PROCEDURES m >

PARSONS PROCESS REVIEW, CMP HORIZONTAL SUCE TITLE:

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l In preparation for performing the CMP Horizontal Slice Resiew and the System Vertical Review identified in PP-01, NNECo procedures are reviewed and a pr ocess model prepared to I identify how various changes are performed and controlled, the organizations involved, various documents, and where documents and information can be found. This is done to effic and consistently familiarize the ICAVP team members with what they will be resiewing and the organizations and documents they will need to consider.

Exhibit 1 is an illustrative summary of the Tier 3 Process.

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i Global Process Controls:

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e Communications with NNECo and the NRC are contmiled through the Millstone Unit 2  ;

j ICAVP Communication Plan. l i

1 Project admmistration items are controlled through the Millstone Unit 2 ICAVP Project Administration Manual, (PAM) l

• Team members will document the review on inspection area checklists. He team's documentation should be such that a qualified individual could trace the inspection results back to the documents used.

4.1 GATHER DATA AND DEFINE TIIE MODEL STRUCTURE Resources l

Group Lead Process Model Lead Process Model Software PC Action 4.1.1 Identify and obtain documents that provide descriptions of:

1) programs, processes, and controlling procedures and policy used to change the facility design er change the characteristics, procedures, or practices for maintaining, operating, testing, and training on safety or risk significant systems, structures, and components,

2) interfacing processes that can impact the licensing and engineering design basis

! documents,

3) organizational structures that perform the process activities and,

4) the information systems that support the process activities.

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TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 8 OF 51 -l The documents needed may address:

Change Control- Plant Equipment / Structures e Major and Minor plant modifications e Post modification installation testing

• Control and incorporation of field changes e Jumper, lifted lead, and bypass control e Set point changes e Temporary or Emergency Changes e EWR with use as is disposition

. Design control including

. Design inputs, design development, review / approval e Identification and evaluation of cumulative effects e electricalloads O e heat loads e structuralloads e hydraulics e Verification / tracking of design assumptions to closure e Process for determining if an activity is maintenance or a modification.

• Procurement and control of equipment for modifications e Evaluation, procurement and control of replacement and spare parts e Commercial grade parts dedication

. Equipment /part equivalency and substitution Change Control - Design, License, Procedure Documents

. Design and licensing document change control e Specification preparation and revision

. Drawing revision not associated with a Modification e Development and change control of plant maintenance and operations procedures

. Interface with design modifications e Maintenance and Operations initiated changes not associated with an equipment modification e Development of Design Basis Document (s) (DBD) d e Vendor manual update / changes l

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i TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 9 OF 51 -l Information and Records Management e Document Control

. Drawing control 1

e Control room drawing updatcs l e Tracking and identification ofin progress or planned changes l

• Engineering design software changes

! e Information Systems software design changes e Database information change control Assessment and Equipment Monitoring e Surveillance testing

. ISI/IST, ASME Section XI repair and replacement

. NCR with use as is disposition p).

(_, 4.1.2 Establish and maintain a list of the various changes and change control procedures that the team experience indicates should be considered for the initial process model. The list is to be updated as change control procedures are identified. The list is to include a procedure title, the procedure identification number, date, and resision.

NOTE Generic information can be bulk loaded into the modeling software as documentation is obtained on the utilities' procedures, organizational structure, and information systents. For example:

• Organization / resource titles e Information system titles, i.e. databases, work flow systems, etc.

• Process controls, i.e. procedure titles and numbers, regulations, etc.

Bulk loading data prior to starting the model development, helps to ensure uniform usage of data

information in the model and reduces model cleanup later.

l 4.1.3 Review the utility's configuration management program documentation to obtain an

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understanding of:

e the conditions which may lead to changes in: the configuration of the plant, design / licensing basis documents and information systems, or practices for maintaining, operating, testing, and training on safety or risk significant systems, structures, and components. (e.g. broken equipment, unusual operating conditions, nonconformances, regulation changes, desire for plant improvements, etc.)

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• the organizations that assess the conditions and decide whether change processes need to be implemented.

l the procedures used to control these changes.

e the organizations that perform the changes.

O 4.1.4 Develop the initial model structure and level 0 diagram. Based on the review of the utility's documentation and the experience of the Process Model Lead, decide on a initial model structure that will communicate how various Millstone Unit 2 changes are performed and controlled, the organizations involved, titles of various documents, and where documents and information can be found.

l Action Output Level 0 diagram List of the various changes and change control procedures Bulk loaded process data Process documentation to be used in developing the model l 4

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( TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 11 OF 51 -l 4.2 PREPARE THE CHANGE PROCESS MODEL NOTE The initial process model will serve as input to preparation efforts for the CMP Horizontal Slice Review and the System Vertical Slice Review (SVSR) to help familiarize the team on where design and licensing basis information can be found, the kinds of documentation produced by Millstone Unit 2, the organization (s) responsible for various parts of the change process, and a general understanding of the kinds of change processes that exist at Millstone Unit 2.

Resources Group Lead,(Tier 1&3) l Process Model Lead Process Modeler(s) i Process Model Sofhvare PC M m!

4.2.1 Prepare the process model based on the utility's procedure documents and the model structure identified by the level 0 diagram. The model is expected to be one or two levels of deconiposition illustrating the process at a high level. The model should communicate how various Millstone Unit 2 changes are performed and controlled, the organizations involved, titles of various documents, and where documents and information can be found.

The Tier 1 and Tier 3 Group Leads are to specify which procedures to be included in the initial model based on the need to prepare significant numbers ofindisiduals for conducting the Millstone Unit 2 ICAVP reviews. For example, a procedure will not be included in the model if only one or two individuals need to become familiar with it. One or two people can simply read the procedure and there is no need to prepare a model for l

efficient and consistent communication.

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- By reviewing the utility's procedures the Process Modeler will attempt to identify and diagram the following information with a 4-dimensional modeling technique:

e Activities - a description of the work step.

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l g MILLSTONE UNIT 2 ICAVP PP-03 m PROJECT PROCEDURES PARSONS TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE l REVISION: 1 DATE: 06/09/97 PAGE 12 OF 51 People, Tools, and Hardware / Software Supports - people (job title) and things used to perform the actisities.

l Information/ Product Flow - information and documents that input to an actisity and the output as the result of the activity. This includes forms, reports, design documents, test results, data sources, data storage, etc.

Controls - those things that specify when an activity is performed, how it is to be performed, or the acceptable quality level. Typical controls include regulations, quality assurance requirements, industry standards, procedures, company goals, management directives, best practices, corporate culture, experience, etc.

4.2.2 The source of the information used to develop the models is to be documented as part of l

the model, including title, identifying numbers, and revision, or date.

4.2.5 The model should identify unclear information, or areas of potential concem regarding what the procedure may produce. This information is an indicator of areas that the ICAVP team members should be aware of while performing their resiews.

Action Output Millstone Unit 2 Change Process Model 4.3 PROVIDE INPUT TO THE SYSTEM REVIEW PREPARATION Resources Process Model Lead j Process Modeler(s) l Process Model Software PC

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Action

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( TITLE: PROCESS REVIEW, CMP HORIZONTAL SUCE 1 REVISION: 1 DATE: 06/09/97 PAGE 13 OF 51 'l 1 4.3.1 Provide input to preparation efTorts for the System Vertical Slice Review (SVSR) to help familiarize the teams with:

1 e the kinds of change processes that exist at Millstone Unit 2, a where design and licensing basis information can be found, e the information systems used and its data base (s).

l l e the kind of documentation that should exist on past change actisities, e

the organization responsible for various parts of the change process.

This information will be conveyed to the System Review teams through use of the process models, and verbal transfer of process experience gained during the modeling effort.

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l 4.3.2 Provid: input to the SVSR teams on unclear information, or areas of potential concern t

regardir.g what the procedure may produce.

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.A_ction Outnut Transfer ofinformation to the System Review teams to be used in preparation for conducting their l

l technical reviewn.

4.4 SELECT TiiE CMP IIORIZONTAL SLICE SAMPLE Examples of Mdistone Unit 2 past changes to facility design, documentation, and information l systems and examples of current procedures and data will be selected for review. The resiew is a horizontal slic: across systems not selected for the ICAVP vertical slice. The technical resiew will determine if:

. Changes to the plant meet the current design and licensing basis documentation and data, e Design and licensing basis requirements have been translated into operating, maintenance, and testing procedures, e The performance of systems / components have been verified through testing, e Design and plant information contained in databases and documents are accurate and consistent with the plant, and e CMP corrective actions, associated with the examples of past changes selected for review, have, or will, adequately correct the deficiency.

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NOTE The NNECo CMP system reviews are being completed in 2 groups. Therefore, the process review sampling and evaluation are to be conducted in two phases to ensure all CMP systems have been considered in the horizontal slice.

Resources Group Lead Technical Reviewers l Project Management l Action 4.4.1 Only CMP scope systems are to be considered for the sample. The sample for the CMP Horizontal Slice Review will consist of change examples outside of the selected ICAVP systems for the System Vertical Slice Review (SVSR).

j 4.4.2 The sample is to be selected based on the personnel experience of the resiew team of where l problems may be encountered, past industry typical problem areas, and the following criteria: l l

Cross section of age - To ensure the review includes changes produced under different revisions of procedures, the selected review sample will, where i possible, consist of examples that span the period since the plant began commercial operation on August 1,1975. Examples will be selected from four

! time periods of approximately five year inten als.

l l Cross section of discipline - experience indicates that different orgardrations or groups within an organization utilize different processes for the same procedures. Therefore, the selected review sample will consist of examples from different engineering disciplines, (e.g. Mechanical, Electrical, I&C and Civil /

C Structural) or different plant groups, (e.g. Operation and Maintenance

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l departments.

Cross-section of types - of equipment, procedures, or documents as applicable.

l 4.4.3 As a minimum, choose examples of the following sixteen inspection areas for assessment: I

1. Revisions to Operat. ions & Maintenance procedures - select from current procedures a cross sedon of disciple and type.

2. Conduct of Ope stions & Maintenance - select from current procedures a cross section of discipie and type. In addition select from past maintenance work orders examples of equipment replacements for walkdown to confirm maintenance was performed correctly.

3. Surveillance testing - select a cross section of equipment and systems for review of current surveillance testing procedures and test data.

4. Database information design and change control including Master equipment list maintenance and revision - uelect examples of software changes with a cross section of age. Select examples from the Master equipment list ddi a cross section of disciplines for conformation of proper classification, consistency with other databases, and accuracy reflecting installed equipment in the plant.

5. Setpoint changes - select examples of current setpoints with a cross section ofage.

6. Specification preparation and revision - select examples of current specifications with a cross section of disciplines and age of presious revisions.

7. Vendor Technical Information updates - select examples with a cross section of disciplines, equipment type, and age oflast resision.

8. ISI/IST, ASME Section XI repair and replacement - select Section XI equipment test packages, results, and maintenance work requests examples with a cross section of equipment types.

9. Design and licensing basic document change not associated with a modification including drawing revision control not associated with a mod

- for drawing revisions, select examples with a cross section of age, discipline and type of drawings.

10. Temporary changes, including jumper, lifted lead, and bypass control -

from the list of active temporary changes select eumples for resiew l obtaining a cross section of discipline, if possible. Note: temporary changes should have a short lifetime, select for review any temporary changes that may be long lived.

11. Emergency changes -identify examples of emergency changes for review.

d By their nature these changes are short lived, or become permanent changes.

l Attempt to identify a sample that is a cross section of age, discipline, and l

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l type of change. l

12. Non-conformance report and EWR (use as is)- select a sample that has a cross section of age, discipline, and type ofnon-conformance.

13. Equivalency substitution & Commercial grade dedication- select a sample that has a cross section of age, discipline, type of equipment, and method of acceptance methods.

14. Procurement of replacement parts - select a sample from the most recent procurement that has a cross section of discipline, type of equipment and age oflast revision of the equipment specification.

15. Information and Record Management - select a sample of controlled documents for review that has a cross section of document type.

4.4.4 From NNECo list, index, etc. choose the sample to be reviewed.

Action Output l

CMP Horizontal Review sample i

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REVISION: 1 DATE: 06/09/97 PAGE 17 OF 51 ] l 4.5 PERFORM TIIE CMP IiORIZONTAL SLICE REVIEW l

Resources Group Lead Technical Leads Technical Reviewers NOTE The intent of the CMP Horizontal Slice Review is not an evaluation of change procedures used in the past, but rather a review to determine the effectiveness of the Millstone Unit 2 CMP to identify and correct design or licensing basis deficiencies that may have relutted from the ineffectiveness of past change processes. This is a "out-come" based comparison of the current conditions versus the current design and licensing basis.

He inspection will be performed on a sample of past changes to facility design, documentation, and information systems and examples of current procedures and data. The resiew will look for:

. unrecognized modifications to the plant e departures from the plant licensing or design basis documents e acceptable documentation of the results of the change and its basis.

Action 4.5.1 Starting with the review criteria contained in Appendix A of this procedure, the Review Team prepares a specific review checklist for each inspection area by drawing from the applicable SVSR generic checklists, and the SVSR Source Book of Additional Requirements. Checklists are to be produced for the following areas as a minimum:

1. Revisions to Operations & Maintenance procedures

2. Conduct of Operations & Maintenance

3. Surveillance testing

4. Data base infonnation design and change control including Master equipment list maintenance and revision

( 5. Setpoint changes

6. Specification preparation and revision I 1

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7. Vendor Technical Infonnation updates

8. ISI/IST, ASME Section XI repair and replacement

9. Design and licensing basic document change not associated with a modification including drawing revision control not associated with a mod l 10. Temporary changes, including jumper, lifted lead, and bypass control

11. Emergency changes j 12. Non-conformance report and EWR( use as is) l 13. Equivalency substitution & Commercial grade dedication

14. Procurement of replacement parts

15. Information and Records Management  !

16. CMP Corrective Actions (applicable to the sample)-

4.5.2 Obtain change package documents, procedures, etc. in accordance with the sample l

selection.

O) i 4.5.3. Obtain NNECo CMP findings / corrective actions documents associated with the areas of inspection.

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4. 5.4 In accordance with the checklist, review the change items identified in the inspection l

sample.

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4. 5.5 In accordance with the checklist, review documentation including, as appropriate, database values and perform walkdowns to determine if the systems' design bases are maintained and plant configuration properly documented.

4. 5.6 Reviewers will document conferences with NNECo personnel in accordance with the Communications Plan.

4. 5.7 Reviewers will document which records were reviewed, identifying the Millstone Unit 2 l numbers, including revision. Where no revision is designated, the document date is to be used.

, 4. 5.8 The reason for a review activity will be documented, as well as the specific basis for any (g,) conclusions drawn.

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4. 5.9 As working questions are identi6ed during the review, they are to be documented for further investigation.

4. 5.10 Working questions are to be followed up to determine that either 1) upon obtaining further information, no problem exists, or 2) it is a discrepancy with a documented basis, or 3) it can not be resolved at this time.

4. 5.11 Discrepancies are to be communicated to management for evaluation, , and distribution in accordance with procedure PP-07.

Action Output CMP Horizontal Review results CMP Horizontal Review documentation 4.6 CHOOSE ADDITIONAL SAMPLES i l

Resources Group Lead Technical Lead Technical Reviewers Project Management i

Action l I

4.6.1 If the CMP Horizontal Slice Review or the SVSR discovers valid discrepancies, the project management team will consider expansion of the inspection sample. The sample will be expanded when it will facilitate determination of whether a valid discrepancy is an isolatcd mistake or is an indication of a systematic problem, i

4.6.2 If the decision is to increase the sample size return to step 4.4 to select specific change i I

e items to be added to the CMP Horizontal Slice Review and proceed to perform the

additional reviews.

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Action OutDut Decision to expand the sample size or not Documentation of the basis for the decision l

4.7 PREPARE REPORT I Resources Group Lead Technical Lead (s)

Technical Reviewers PC Action 4.7.1 Collect the results and prepare a report for each change process inspection area.

4.7.2 Prepare a final report of the Tier 3 activities and conclusions. The report is to consist of, as a minimum:

e input to an executive summary e a summary description of the methods used e a summary of the CMP Horizontal Slice Review results including:

1 e identification of the examples selected for resiew e review results for each of the inspection areas e identification of any discrepancies e corrective action review results O 4.7.3 Support internal ICAVP reviews as necessary.

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4.7.4 Review and comment as needed on NNECo response to Discrepancy Reports 4.7.4 Resolve comments and finalize the report for issue.

Action Output l i

Final Report Project backup documentation

5.0 REFERENCES

" Guide For Operational Configuration Management Program", DOE-STD-1073-93 1

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APPENDIX A CMP Horizontal Slice Review Criteria Starting with the review criteria contained in this appendix, prepare a specific review c.hecklist by drawing from the applicable SVSR generic checklist, the SVSR Source Book of Additional Requirements, and the review team's experience. Note: This appendix does not contain any additional evaluation criteria for ISI/IST, ASME Section XI and Corrective Actions. Start with the SVSR generic checklist.

EVALUATION CRITERIA REVISIONS TO OPERATIONS & MAINTENANCE PROCEDURES

1. A process is in place to ensure that all proposed changes to procedures are screened to determine if the change can affect the functionality of a plant structure, system, or component (SSC) or some other safety related item or activity i.e., screen for "admmistrative changes" (like typos, etc.) versus O

g " intent" changes to the document. Intent changes must be processed as follows.

2. All procedures receive, as a minimum, a formal, " Technical Review" against the current design and licensing basis to determine if the document change is safe and/or reportable.

3. Trained and qualified personnel perform technical Reviews of proposed changes to procedures with access to the appropriate design and licensing basis infomation.

4. Included in the procedure clunge process is the need and ability to identify all other affected procedures, drawings, databases, etc. which must be updated as a result of the change.

5. Management reviews are performed before the document is released for use to verify that qualified engineering personnel have performed the Technical Reviews and are properly documented O

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EVALUATION CRITERIA CONDUCT OF OPERATIONS & MAINTENANCE GENERAL

1. Proposed operations and maintenance changes are identified, screened for compliance with the current design and licensing basis, and either processed as an identified " change" (per the Change Control process) or as a " routine activity" (using an approved plant procedure e.g., operations, maintenance, or procurement). j

2. Changes made within pre-approved " design envelopes ~" established by the Design Authority and included in approved procedures are considered " routine activities" and are acceptable. The permanent or temporary modification proces',es govern all other changes.

OPERATIONS

1. Functional description of how the equipment operates, including all modules and subassemblies exist.

All modes of operation as specified in the utility's equipment specification (e.g., automatic, remote, manual, emergency) and any special design feature should be described here.

2. The operating instructius contain complete, detailed, and step-by-step instructions to be followed, including precautions and warnings to be observed for starting, running, controlling, mode changing, and stopping the supplied equipment. Initial checkouts, emergency startup, and emergency shutdown instructions should be included, if applicable.

3. Procedures contain or identify where to find operating parameters for temperature, pressure, flow, current, vibration, etc., giving readings for normal operation (including ranges) and instrument setpoints for alarms, characteristic curves such as power consumption, head versus flow, efficiency, and NPSH.

4. Duty cycle limitations (i.e., number of operating cycles or other performance intervals) that are part of the equipment qualification program are clearly stated in a caution statement and also included in the tabulation of operating parameters l

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MAINTENANCE, AND CORRECTIVE MAINTENANCE INFORMATION.

I Methods exist to ensure that implementation of unauthorized changes through documents like work orders are identified and prevented or processed through the permanent or temporary modification process.

2 Maintenance data contains all data needed to keep the supplied equipment in good repair and to maintain l

the equipment so that it performs within design specification parameters. It should include the following:

. Settings, adjustments, and calibration data including tolerances and the basis foi each tolerance tabulated for all instruments associated with equipment startup, operation, shutdown, and alanns.

e Torque requirements, equipment operating clearances, and adjustments required for proper equipment operation, including rotational checks.

Lubrication specifications (e.g., lubrication points, quantities, frequency, acceptable lubricants).

Equipment specifications (e.g., oil reservoir volumes, filter flow rates, differential pressure across filters, motor winding resistance, special seals, gaskets). l 1

e Test equipment with required accuracy and special tools needed to maintain the equipment. I 1

. Emironmental qualification maintenance intervals with maximum allowable time between j

repair / replacement. l l

3. Periodic testing information contains step-by-step instructions, including precautions, w2mings, and acceptable test values necessary to verify that the equipment is operating within specifications. A schedule of recommended mechanical, electrical, and instrumentation and control performance tests should be supplied including:

. Equipment tests in all operating modes.

. Vibration monitoring.

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• Cooling water or gas analysis.

4. Preventive maintenance information contains a comprehensive, systematic, step-by-step maintenance program. This program provides a complete description of the requirements, acceptance limits with l

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action to be taken when limits are exceeded, and tasks to be accomplished. Also included are precautions and warnings for maintauung the operational capability of the equipment within

! specifications. If any item is required to maintain equipment qualification requirements, it should be clearly stated in a caution statement.

5. Corrective maintenance information provides step-by-step instructions, including precautions and warnings, required to adjust and align the equipment. Also included is the removal, repair, reinstallation, and alignment of repairable or replaceable parts, modules, subassemblies, and assemblies normally expected to require senice over the life of the equipment. If any instruction affects the equipment qualification requirements, it should be clearly stated in a caution statement. Corrective maintenance instructions should include the following:

Note: Complex tasks requiring skill and experience not normally available in the utility's organization, or manufacturer's proprietary information, should be noted as exceptions or special corrective maintenance. In these cases, manufacturer contact information should be provided.

MAINTENANCE TROUBLESHOOTING

1. Troubleshooting guidelines address possible equipment malfunctions that could be discovered during testing, operation, or maintenance.

2. Does troubleshooting data should lead the user directly from the symptom of a problem to proper potential solutions and should provide the symptoms, immediate action, probable cause, and remedy

3. Is this information should be presented in a readily usable form such as trouble analysis charts for testing, operations, and maintenance activities? For system and electronic equipment troubleshooting, this information may begin with a detailed operational check followed by troubleshooting procedures for specific sections of the equipment or system.

l 4. Do procedures prevent plant changes outside of design and licensing bases as part of troubleshooting?

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' 's TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 26 OF 51 I EVALUATION CRITERIA

, SURVEILLANCE TESTING

1. Surveillance testing in the form of post-maintenance and post-modification testing is in accordance with the design and licensing basis.

2. Inadvertent changes did not occur prior to the release of the system and/or component to the

, operations group.

3. Adequate methods for periodically monitoring equipment performance exist (such as ISI, 4

surveillance testing, and vibration monitoring) which: collect, trend, and review data; and identify 4

and conrect deviations from the design and licensing basis due to unintentional changes such as

equipment degradation.

i 4. Management monitors the results of surveillance testing, compares them to established acceptance criteria, and takes corrective action, as needed 4

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(INCLUDING MASTER EQUIPMENT LIST MAINTENANCE AND REVISION)

SOFTWARE CONFIGURATION MANAGEMENT (CM)

1. Software CM policy and guidance documents are approved by Senior Management and distributed.

2. Methods exist for reporting Software CM Program development and imp'ementation progress, l 1

problems, and successes to Senior Management.  ;

SOFTWARE CHANGE CONTROL

1. Software (application programs, data, and databases) and software design bases which are t

\ included in the CM Program have been clearly identified.

2. Information Management standard (s) exist which govems the terminology, procedures, resiews, acceptance criteria, and approval of software changes.

3. Procedures exists for controlling and updating (i.e., managing the configuration of):

a) user requirements, b) application and enterprise data models, c) software development including: design review, unit and module testing, and user acceptance testing.

d) implementation of program and database changes e) revision control of commercially procured software such as: operating systems, engmeenng design or analysis programs, and application programs.

! 4. Accurate documents and/or databases exist to ensure that the responsible software engineer has ready access to all software design inputs such as current software design, user requirements, and industry codes & standards.

/]

D S. Mechanisms exist to provide accurate information to the responsible software engineer on other l

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TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 28 OF 51 past modifications, planned modifications, modifications in progress, or partially installed modifications that may affect the modification being designed.

6. During the design phase, all cumulative efrects of the proposed software change are considered and included in the fmal design e.g., table or file size, application interfaces, processor loads.

7. Procedures require and ensure that the responsible information engineer identified all software design outputs such as: post-modification acceptance test criteria, procurement requirements, affected data maintenance procedures, application design documents (control flow diagrams, screen, menu, and report layouts), data models, databases to be updated. And these items were updated.

8. All identified changes received a formal, documented Technical Review against the current design and licensing basis to determine if the change is safe and/or reportable. j 1

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9. Analysis of user requirements, conceptual application designs, data model revisions / extensions, detailed designs, and technical reviews are performed by trained and qualified personnel (from the Software Design Authority) with access to the appropriate analysis and design information.

10. Management reviews are perfonned before implementation to verify that required technical resiews have been performed by qualified software-engineering personnel and are properly documented

11. After management review rejection, the following occurs:

f) Return the software design package to the original software design team for rework / update l

and documentation of the results.

l g) Cancel the change and document the results.

12. Deviations from the approved design, identified during implementation, are documented and described. Typical deviations include:

, a) failure to meet post-modification acceptance testing criteria for functionality such as:

benchmark testing or other forms of verification and validation as required.

b) failure to meet data integrity qualification criteria, l

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REVISION: 1 DATE: 06/09/97 PAGE 29 OF 51 -l c) any other implementation changes made for convenience or to save time and money.

13. All deviations are re-reviewed by the original engineering organization to determine if the deviation:

l a) is acceptable, as is (by re-analysis) and is consistent with the approved design, I b) should be returned to the original design configuration, c) can be slightly modified to meet the requirements, d) should be canceled, if not already installed.

14. Key aspects of the software change are documented and included in a formal Software Document I Control program. (Note: This is an important interface between Software Change Control and Software Document Control.) Software Change documentation includes as a minimum:

a) description of the change OU b) technical resiews c) management approsals d) data qualification results e) post-modification test results f) update sheets for programs affected by the change g) update sheets for databases affected by the change h) data maintenance and other procedure changes i) training changes including course material & simulator updates l

15. Software de ve:opers, testers, owners, and admmistrators are clearly identified, assigned, and knowledgeabl.: of their responsibilities (via training, procedures, etc.)

1 SOFTWARE CIIANGE CONTROL TEMPORARY AND EMERGENCY MODIFICATIONS It is recognized that emergency conditions may arise where immediate, formal processing of a software 4

change is not possible, e.g., on backshifts and during weekends. Emergency changes are defined as those s

j

) that require immediate implementation to provide personnel safety or protection of capital equipment.

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1. Procedures require all emergency changes receive an interim, documented technical review against the

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' (D TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 30 OF 51 -l current design and licensing basis to determine if the change is safe and/or reportable.

2. Installed temporary or emergency changes are described by interim, marked-up documentation.

3. On the next convenient workday, temporary or emergency changes are be formally documented and begin "after-the-fact" formal reviews and approvals consistent with the Change Control process (for  ;

permanent, temporary, and/or document changes, as appropriate).

)

4. Check database change logs to determine if any temporary or emergency modifications are active. If so, determine how long they have been active, and perform technical review of the change.

j DATA INTEGRITY l

The fundamental purpose of computerized information systems is the management of data. Whether the computer itself takes action based on a data value (as in real-time / process computers), or whether a O

Q person takes action based on a data value (as in engineering or work support applications); the "GIGO" l principle applies. Ifgarbage goes in, then garbage comes out. Good programmatic (processes and procedures) are necessary to avoid "GIGO", but not sufficient. Sufliciency is established only when the l data values under the control of an information system are a faithful representation of the entity about which an enterprise is concerned. Data quality and integrity must be assured if software configuration is to deliver both functionality and useful results. The data integrity for Millstone 2 requires the equivalence of l information derived from direct observation of the plant, data values stored in databases, and plant SSC l (system, structure, component) references contained in plant documentation (such as procedures, specification, and training material). This equivalency will be checked on a sampling basis. Part of the criteria for defining the set of values to be reviewed is based on a review of programmatic and procedures.

1. All databases (files and/or tables), used to make technical decisions and/or decisions with a safety implication, have been identified and integrated (electronically or admmistratively) to ensure:

a) semantic consistency between field defmitions and field contents, b) fidelity of transactions affecting data changes or deletions, n c) consistency amongst databases, and the d) elimination of uncontrolled redundancy

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2. " Master" sources of data are identified and used by plant personnel.

3. Data and database security controls are established and applied to selected programs and data fields so that only those with a need to know have access.

4. Data update controls are established and applied so that additions and deletions to fields (in tables, files, or databases) can only be made by the appropriate personnel.

5. Data accuracy and completeness (i.e., key and attribute values for systena, components, and structures) are ensured through a formally controlled verification and validation process that is closely linked to the Plant Change Control process.

6. Data, and database owners /admmistrators are clearly identified, assigned, and knowledgeable of their responsibilities (via training, procedures, etc.).

v CHANGE CONTROL FOR SOFTWARE DOCUMENTATION Proposed documentation changes are identified, screened, technically reviewed, processed, and approved in l a manner similar in rigor and formality to permanent software modifications. Software documentation includes: user requirements, data models, design specifications, programs, and user manuals. The following is the evaluation criteria specific to the goals and objectives of a Software CM program.

1. Procedures are in place to ensure that all proposed changes to software documentation are screened to determine if any particular change can affect the functionality of a plant information system.

Proposed documentation changes are categorized as either " administrative changes" (like typos, etc.) or " intent" changes. Intent changes must be made through the Software Change Control process consistent with the criteria in this section.

2. Documented sofhvare deficiencies (e.g., Software Non-Conformance Reports) between the as-built configuration and the requirc.ments are screened to determine what kind of change is necessary. If the deficiency is intent related, it is processed consistent with the Software Change Control criteria.

(9 3. All documentation changes receive, as a minimum, a formal, " technical review" against the current L.)

design and user requirements to determine if the document change is appropriate and does not l

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adversely affect software functionality.

4. Trained and qualified personnel (from the Software Design Authority) perform technical Reviews of proposed changes to software documentation with access to the appropriate software analysis and design information.

5. Included in the documentation change process is the need and ability to identify all other affected documentation such as: user requirements, programs, procedures, data models, databases, user manuals, etc. which must be updated as a result of the documentation change.

6. Similar to software modifications. management reviews are performed before the document is released for use to verify that the technical reviews have been performed by qualified software engineering personnel and that the technical reviews are properly documented O

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EVALUATION CRITERIA SETPOINT CHANGES

1. Proposed changes are identified, screened for compliance with the current design and licensing basis, and either processed as an identified " change" (per the Change Control process) or as a

" routine activity" (using an approved plant procedure e.g., operations, maintenance, or procurement).

Note: Changes made within pre-approved setpoint " design envelopes" established by the Design Authority and included in approved procedures are considered " routine activities. The permanent or temporary modification processes govem all other changes.

2. Accurate documents and/or databases exist to ensure that the responsible design engineer has ready access to all design inputs such as current design and licensing basis, industry codes & standards, etc., relative to the setpoints to be changed

3. Mechanisms exist to provide accurate information to the responsible engineer on other past modifications, planned modifications, modifications in progress, or partially installed modifications that may affect the setpoint to be changed.

4. Mechanisms exist to ensure that the responsible design engineer identifies all design outputs such as: post modification test acceptance criteria, procurement requirements, affected procedures, design documents, drawings, databases, etc. to be updated.

5. All identified setpoint changes receive a formal, documented Technical Review against the current design and licensing basis to determine if the change is safe and/or reportable.

For example, as a muumum, all setpoint changes should receive a documented 10CFR50.59 review for impact on the FSAR and Technical Specifications, and special topic reviews, as needed.

Special topic reviews include ALARA, EQ, fire protection, Design Basis Document (DBD) i reviews, etc.

1

6. Trained and qualified personnel, usually from the Design Authority or the Engineering l

Organization, perform technical Reviews with access to the appropriate design and licensing basis information, (n 7. Management reviews are performed before implementation to verify that the Technical Reviews have been perfonned by qualified engineering personnel and are properly documented. These

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interfaces have been established between the Change Control process and the Document Control Process. Approval for implementation is rejected or given to proceed with implementation.

8. After implementation, key aspects of the setpoint change should be documented and included in a formal Document Control program. This is an important interface betwan Change Control and Document Control. Change documentation includes as a nummum:

A. setpoint log B. set point database C. Loop diagrams and other documents O

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l g MILLSTONE UNIT 2 ICAVP pp.03 m -PARSONS PROJECT PROCEDURES j TITLE: PROCESS REVIEW, CMP HORIZONTAL SUCE REVISION: 1 DATE: 06/09/97 PAGE 35 OF 51 -l EVALUATION CRITERIA SPECIFICATION PREPARATION AND REVISION

1. Proposed specification changes are identified, screened for compliance with the current design and licensing basis and either processed as an identified " change" (per the following process) or as a

" routine activity" (using an approved plant procedure e.g., operations, maintenance, or procurement) in which case not further action is required.

l 2. Accurate documents and/or databases exist to ensure that the responsible design engineer has ready access to all design inputs such as current design and licensing basis, industry co:les & standards, etc.

3. Mechanisms exist to provide accurate information to the responsible engineer on past

% modifications, planned modifications, modifications in progress, or partially installed modificatic a

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' [V i that may affect the specification to be changed.

4. Mechanisms exist to ensure that the responsible design engineer identifies all design outputs such as: post-modification test acceptance criteria, procurement requirements, affected procedures, l design documents, drawings, databases, etc. to be updated.

5. All identified specification ch:mges receive a formal, documented Technical Review against the current design and licensing basis to determine if the change is safe and/or reportable.

For example, as a minimum, all changes should receive a documented 10CFR50.59 resiew for impact on the FSAR and Technical Specifications, and special topic reviews, as needed. Special i topic reviews include ALARA, EQ, fire protection, Design Basis Document (DBD) resiews, etc.

l l 6. Trained and qualified personnel, usually from the Design Authority or the Engineering l

Organization, perform technical Reviews with access to the appropriate design and licensing basis information.

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g MILLSTONE UNIT 2 ICAVP pp 03 m PROJECT PROCEDURES PARSONS TITLE: PROCESS REVIEW, CMP HORIZONTAL SUCE REVISION: 1 DATE: 06/09/97 PAGE 36 OF 51 -l l 7. Management reviews are performed before implementation to verify that the Technical Resiews 1

have been performed by qualified engineering personnel and are properly documented. These l reviews are the administrative controls needed to ensure that the change is safe and that the proper

! interfaces have been established between the Change Control process and the Document Control Process. Approval for implementation is rejected or given to proceed with implementation.

8. After implementation, key aspects of the change should be documented and included in a formal Document Control program. His is an important interface between Change Control and Document Control. Specifications may reside in A. Design / modification packages B. Procurement files:

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EVALUATION CRITERIA VENDOR TECHNICAL INFORMATION,(manuals, dwgs, BOM, etc.) UPDATES

1. Have key safety related equipment, (KSRE) of the population of components requiring update of vendor technical manuals been identified? Have requirements for periodic updates been defmed?

2. Review adequacy of periodic updates to vendor technical information associated with KSRE components. Have periodic updates considered:

• Plant modifications?

e Industry experience?

e Vendor changes? ,

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3. Parts and subcomponent updates to vendor technical information have been incorporated into O existing plant documentation and information systems.

4. All vendor technical information updates receive, as a muumum, a fonnal, resiew to assess applicability to installed plant equipment and the need to change existing documentation and information systems.

5. Technical and Applicability Reviews of proposed changes to other plant documents as a result of l changes to vendor technical information are performed by trained and qualified personnel, usually from the Design Authority or the Engineering Organization, with access to the appropriate design and licensing basis information.

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(a) TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 38 OF 51 -l EVALUATION CRITERIA DESIGN AND LICENSING BASIS DOCUMENT CHANGE NOT ASSOCIATED WITH A MOD.

INCLUDING DRAWING REVISION CONTROL

1. Design and Licensing basis document changes not associated with a modification are screened to determine if the change can affect the functionality of a plant structure, system, or component or other safety related activity, i.e., screen for "adnunistrative changes", like typos etc., versus

" intent" changes. Intent changes must receive a Technical Review.

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2. Existing design basis, design requirements, and regulatory requirements have been identified, collected, and used as a basis for the resiew.

3. For intent changes, compare the document change with the existing basis and technically resolve and approve any differences. Original calculations, safety margins etc, should form the basis for this deternunation.

4. The design basis and basis document changes are verified for appropriateness and validated l (preferably in the field) for accuracy and consistency with the documents and physical configuration prior to use.

5. Update the design and regulatory basis to ensure it is documented, retrievable, and available for use in plant processes and decisions such as Technical and Safety Reviews, new design changes, and special testing.

6. Ensure that the design and regulatory basis (including updates) is current, especially after plant l changes.

DRAWING REVISION

1. A process is in place to ensure that all proposed changes to plant drawings are screened to detennine if the change can affect the functionality of a plant structure, system, or component (SSC) or some other safety related item or activity i.e., screen for " administrative changes" (like typos, etc.) versus " intent" changes to the document. Intent changes must be made through the Change Control process consistent with the criteria in this section.

2. Documented deficiencies (e.g., Non-Conformance Reports) between the as-built configuration, I

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i REVISION: 1 DATE: 06/09/97 PAGE 39 OF 51 -l drawings, and the requirements are screened to determine if a hardware change is required, If so, it is processed consistent with the plant equipment Change Control criteria.

3. All drawing changes receive, as a muumum, a formal, " Technical Review" against the current design and licensing basis to determine if the document change is safe and/or reportable.

4. Technical Reviews of proposed changes to plant drawings are performed by trained and qualified personnel, usually from the Design Authority or the Engineering Organization, with access to the appropriate design and licensing basis information.

Note: Multi-disciplined reviews of proposed document changes are considered good-practices and the industry norm; but for the purposes of CM, a Design Authority (or designatee) Technical Review against the design & licensing bases is considered essential.

5. Included in the drawing change process is the need and ability to identify all other affected procedures, drawings, databases, etc. which must be updated as a result of the document change.

6. Similar to equipment modifications, management reviews are performed before the document is released for use to verify that qualified engineering personnel have performed the Technical Reviews and are properly documented. These reviews are the administrative controls needed to ensure that the document change is safe and that the proper interfaces have been established between the Change Control process and the Document Control Process.

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! EVALUATION CRITERIA l TEMPORARY CHANGES l

JUMPER, LIFTED LEADS, AND BYPASS CONTROL

1. Temporary modifications are identified and described in a manner which is analogous to pemianent

)

changes i.e., proposed temporary modifications are identified, screened for compliance with the

)

current design and licensing basis, and either processed as a " temporary modification" or as a j

" routine activity" using an approved plant procedure e.g., operations, maintenance, or test.

Temporary Modifications includejumpers, lifted-leads, and bypass control.

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2. I Accurate documents and/or databases exist to ensure that the responsible engineer has ready access 1 to all design inputs such as current design and licensing basis, industry codes & standards, etc. )

3. All temporary modifications receive a fornal, documented Technical Review against the current design and licensing basis to determine it the change is safe and/or reportable.

' O 4. Trained and qualified personnel, usually from the Design Authority or the Engineering Organization, perform technical Reviews for temporary modifications with access to the appropriate design and licensing basis information.

5. If the temporary modification is rejected as a result of the technical review:

a. Return the temporary modification package to the original design organization for rework / update and document the results.

b. Cancel the temporary modification and document the results.

6. Mechanisms exist to ensure that the responsible design engineer identifies all design outputs such as affected procedures, drawings, databases, etc. to be updated.

7. During implementation, all deviations are re-reviewed and approved by the original engineering organization.

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8. Installed temporary modifications are tagged in the field and logged in the con' m' room or other

! high traffic area.

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9. Installed temporary modi 6 cations are described by interim, marked-up drawings and procedures.

These should be made available for use by operations, maintenance, technical support, engineering, and other facility personnel as needed. Because of the short-term nature, permanent drawing and procedure updates are not required for temporary modifications.

10. Temporary modifications are tracked separately to ensure that any temporary modification older than a few months (3-6 months) is brought to the attention of plant management for reaffirmation, conversion to a permanent modification, or removal. This reaffirmation should be continued every 3 months or so until final conversion or removal.

I 1. Upon removal, provisions are made to verify that the as-left configuration and temporarily modified documents are retumed to the original configuration.

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1. Although not exempt from the requirements of the Change Control process, these changes may be j expedited through the use of senior shift personnel or on-call personnel (such as the Shift Technical  !

Advisors) prior to implementation.

2. Emergency changes are identified, screened for compliance with the current design and licensing basis, and either processed as an " emergency changes" or as a " routine activity" using an approved plant procedure e.g., operations, maintenance, or test.

3. Accurate documents and/or databases exist to ensure that the responsible shift supersisor (or non-design engineer) has ready access to relevant design inputs such as current design and licensing j basis, industry codes & standards, etc.

O 4. All emergency changes receive an interim, documented Technical Review against the current b design and licensing basis to determine if the change is safe and/or reportable.

1

5. Installed emergency changes are tagged in the field and logged in the control room or other high traffic area, and included in the shift-turnover at the end of each shift.

6. Installed emergency changes are described by interim, marked-up drawings and procedures. These should be made available for use by operations, maintenance, and other facility personnel, as needed.

7. On the next convenient workday, emergency changes should be formally documented and begin "after-the-fact" formal reviews and approvals consistent with the Change Control process (for permanent, temporary, and/or document changes, as appropriate).

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REVISION: 1 DATE: 06/09/97 PAGE 43 OF 51 -l EVALUATION CRITERIA NON-CONFORMANCE REPORT AND EWR( USE AS IS) l 1, Documented deficiencies (e.g., Non-Conformance Reports) between the as-built configuration and the requirements are screened to determine if a hardware change is required. If so, it is processed consistent with the plant equipment Change Control criteria.

2. All non-conformances receive, as a muumum, a formal, " Technical Review" against the current design and licensing basis to determine if the document change is safe and/or reportable.

3. Technical Reviews of non conformances to plant documents are performed by trained and qualified personnel, usually from the Design Authority or the Engineering Organization, with access to the appropriate design and licensing basis information.

4. Multi-disciplined reviews ofnon-conformance changes are conddered good-practices and the industry norm; but for the purposes of CM, a Design Authority (or designatee) Technical Review against the design & licensing bases is considered essential.

5. Included in the non conformance review process is the need and ability to identify all other affected l l

procedures, drawings, databases, etc. which must be updated as a result of the document change.  !

6. Similar to equipment modifications, management reviews are performed before the document is released for use to verify that qualified engineering personnel have performed the Technical Reviews and are properly documented. 'Ihese reviews are the adnunistrative controls needed to ensure that any changes which iesult from the non conformance is safe and that the proper interfaces have been established between the Change Control process and the Docmnent Control Process.

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EVALUATION CRITERIA EQUIVALENCY SUBSTITUTION AND COMMERCIAL GRADE DEDICATION GENERAL I. The required functional parameters are identified and appropriate testing is performed, i.e., seismic, hydro / pressure, chemical etc., to properly verify that the component meets these functional parameters.

2. He responsible design engineer identifies all design outputs such as: post-modification test acceptance criteria, procurement requirements, affected procedures, design documents, drawings, databases, etc. to be updated.

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3. All equivalency substitution and commercial grade dedications receive a fonnal, documented Technical Review against the current design and licensing basis to determine if the change is safe and/or reportable.

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4. Trained and qualified personnel, usually from the Design Authority or the Engineering Orgamzation, perform technical Reviews with access to the appropriate design and licensing basis information.

5. Management reviews are performed before implementation to verify that the Technical Resiews have been performed by qualified engineering personnel and are properly documented.

EQUIVALENCY SUBSTITUTION I. Equivalency substitutions receive a formal, documented Technical Resiew agamst the current design and licensing basis to determine if the change is safe and/or reportable.

2. All equipment application (s) are compared against the requirements or %nitations of pre-approved

" design envelopes" established by the Design Authority.

3. He responsible engineer has ready access to all design inputs such as current design and licensing basis, industry codes & standards, etc.

4. The responsible engineer identifies all design outputs such as: procurement requirements, affected

, procedures, design documents, drawings, databases, etc. to be updated.

O 5.

Trained and qualified personnel, usually from the Design Authority or the Engineering Organization, perform technical Reviews with access to the appropriate design and licensing basis

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information.

l 6. Management reviews are performed before implementation to verify that the Technical Resiews l'

have been performed by qualified engineering personnel and are properly documented.

7. After completion, key aspects of the equivalency substitution review should be documented and l included in a formal Document Control program. j 1

Equivalency substitution package Technical review

1. Determine how critical characteristics identified. 1

2. Determine the source (s) of part design criteria.

3. Verify how critical characteristics relate to the item's safety function.

4. Verify that technical equivalency evaluations consider the proper critical characteristics.

5. Were the component seismic and environmental design bases considered during i identification of critical characteristics?

6. Determine how equivalency evaluations are reviewed?

COMMERCIAL GRADE DEDICATION TECHNICAL REVIEW

l. Detennine if part-level safety classifications consider the parent component design functions, including normal and accident design bases.

2. Determine if part-level safety classifications consider the most severe design bases when classifications are performed on a generic basis.

3. Determine if classification methodology considers the item's design functions and credible failure modes.

4. Determine if technical / engineering personnel perform safety classifications

5. Determine the technical basis for part safety classifications.

6. Determine if safety classifications are documented. i i

7. Verify that all critical characteristics for acceptance were verified by one or more of the acceptance l

methods.

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Method 1 - Special Tests and Inspections  !

1. Determine if the appropriate critical characteristics were selected for verification i

2. Verify that sampling plans are controlled l 3. Determine if the sample sizes were selected considering lot tractability and homogeneity, complexity of l the item, and adequacy of supplier controls (i.e. technical basis for sampling).

4. Determine how tractability of dedicated CGI's is maintained.

5. Verify that measuring and test equipment is properly calibrated to industry standards. l i

I Special Receipt Tests / Inspections

1. Verify that receiving inspection activities are adequately controlled for safety-related items.

2. Verify that the tests / inspections adequately verified that the critical characteristics conform to design )

Post-Installation Testing / Inspection

1. Determine how the results of post-installation tests were documented.

2. Determine if post-installation test results are quantified. .

3. Detennine if post-installation tests verify the critical characteristics.

4. Determine if appropriate maintenance instructions were referenced and used for post-installation testing.

3. Determine how items requiring post-installation testing were controlled prior to issue.

6. Determine conditions, if any, when post-installation tests were waived.

Use ofindependent testing facilities

1. Determine how the vendor was evaluated and qualified to perform the test /mspection.

2. Determine how the vendor was provided necessary critical characteristics and acceptance criteria.

3. Determine how the results of the test / inspection were documented.

Method 2 - Commercial Grade Survey

1. Confirm that the CGI was included in the scope of the commercial grade survey p 2. Confirm that the supplier's commercial quality controls were documented in supplier procedures, lU practices, or program documents.

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3. Confirm that the survey was conducted at the location (s) where the critical characteristics were controlled

4. Determine if the commercial grade surveyors are knowledgeable in the following:

Use of performance-based survey techniques Use of surveys performed by third-parties or other utilities Resolution ofinadequate commercial quality controls

5. Determine if the surveys were conducted at appropriate times relative to the procurement.

6. Determine how the survey verified the adequacy of the supplier's control of sub-suppliers

7. Verify that certificates of conformance were requested in the purchase documents

8. Determine whether the supplier certificates of conformance adequately verified that critical characteristics conform to design requirements

9. Determine how the commercial quality controls were imposed in purchase documents

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( Commercial Grade Survey Plan and Reports

1. Determine if the scope of CGI's is clearly identified

2. Determine if appropriate critical characteristics were documented

3. Determine if supplier's commercial quality controls were documented Method 3 - Source Verification

1. Determine if source verification involve witnessing the supplier performing quality activities on the actualiterm being procured.

2. Determine the basis for source verifier qualification.

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3. Determine if hold or witness points were appropriately imposed as a means to conduct source verification.

4. Verify that rights of access were adequately imposed in the purchase document l

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1. Source Verification Plan and Report

2. Determine if the scope of CGl's is clearly identified

3. Determine if appropriate critical characteristics were documented

4. Determine if supplier's commercial quality controls were documented

5. Determine if quantified test / inspection results were documented.

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Method 4 - Acceptable Supplier / Item Performance Record

1. Determine the extent to which this method has been used.

2. Determine whether the sources ofinput include in-plant performance of the item, acceptance history, and industry-wide performance of the item and the supplier.

3. Determine if the performance record adequately demonstrates that critical characteristics conform to design through historical supplier / item performance.  ;

l Third-Party Dedications

1. Verify that 10CFR50, Appendix B and 10CFR Part 21 were imposed in purchase documents l l 2. Determine how critical charr.cteristica and acceptance criteria were provided to the third-party verifier.

3. Determine how the acceptance plan was developed and provided to the third-party verifier.

! 4. Verify that critical characteristics are based on the item safety function.

Supplier Evaluation and Qualification l 1. Determine if qualified / certified individuals conducted vendor evaluations.

2. Determine how the results of audits / surveys are documented.

! 3. Determine how audit / survey reports are made accessible to interfacing organizations.

l 4. Detennine if audits document a supplier's CGI dedication program activities, when applicable.

l Disposition of Failed Items After Installation

! 1. Determine if the root cause of failure was documented.

2. If the root cause was part defect /nonconformance, determine how the characteristic was verified during the acceptance process.

3. Determine how other identical items, either in stock or installed, were evaluated.

4. Determine if the item is installed in a location other than that evaluated during the procurement process.

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I g MILLSTONE UNIT 2 ICAVP PP-03 m PROJECT PROCEDURES i PARSONS 1 TITLE: PROCESS REVIEW, CMP HORIZONTAL SUCE REVISION: 1 DATE: 06/09/97 PAGE 49 OF 51 -l EVALUATION CRITERIA PROCUREMENT OF REPLACEMENT PARTS

1. Verify if 10CFR50, Appendix B and 10CFR Part 21 were imposed in purchase documents.

2. Verify that the supplier was audited and approved at the time of the procurement

3. Determine the basis for vendor qualification.

4. Replacement part.s are compared to the current design and licensing requirements for the original part(s) and must be found consistent with the requirements p,rior to use.

5. Determiac whether appropriate technical requirements were specified in the purchase document.

6. Verify that appropriate documentation was requested in the purchase document.

7. Verify that certified receipt inspectors performed receiving inspections. i

8. Determine how the receipt activities were documented.

9. Verify that items not meeting requirements are not available for use until item is corrected, or determined by the design authority to use as-is. ,

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10. Check a sample of Q-parts in the warehouse to confirm the proper parts are available for use.

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PARSONS PROJECT PROCEDURES I TITLE: PROCESS REVIEW, CMP HORIZONTAL SLICE REVISION: 1 DATE: 06/09/97 PAGE 50 OF 51 }

EVALUATION CRITERIA l

INFORMATION & RECORD MANAGEMENT l

1. A uniform document numbering system is in place, which ensures that all documents l l (drawings, calculations, procedures, software documentation, etc.) are uniquely numbered to enhance identification and retrieval.

2. Specific documents to be included in the CM program are clearly identified and periodically l reviewed for inclusion into the Document Control process. As a minimum, all safety-related 1

and important-to-safety documentation should be controlled in a manner consistent with this element.

I

3. Originals and master copies are stored and protected against unauthorized changes or l modifications. l

4. Only the authorized document owners are able to add new material or change the technical content of a document consistent with the requirements of the Change Control process.

5. A process is in place to ensure that revisions to controlled documents are incorporated in a timely manner with minimum bacidog and delay to the users.

6. A master distribution list exists, is kept current, and is periodically resiewed for accuracy.

7. Controlled documents are distributed, consistent with the master distribution list within time limits acceptable to the users.

8. A document information & tracking system is in place, which provides important information and status of each controlled document.

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g MILLSTONE UNIT 2 ICAVP pp-03 m PROJECT PROCEDURES

-PARSONS TITLE: PROCESS REVIEW, CMP HORIZONTAL SUCE REVISION: 1 DATE: 06/09/97 PAGE 51 OF 51 )

l

9. The document infonnation & tracking system should include:

1 a) identificatien (by discrete number) of the documents to be controlled, b) current status of each document (e.g., under development, being revised, etc.),

c) the document owner (s),

d) interfacing documents i j e) revision number f) the number of outstanding document change notices I 1 l j g) other information that may be needed for tracking such as storage location and retention times.

10. Retrieval times should be consistent with the needs of the users. The acceptability of existing retrieval 4 'd times, as determined by the users, should periodically evaluated and improvements in equipment, )

personnel, etc. made, as required.

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O = PARSONS PP-04 .

, MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

Regulatory Review Procedure REVISION 1 Prepared by: ] Date: 4[9[99- '

Q l ,

Approved by: Ndw Ma 'ager, Company Quality Program Date: 6/7/97 Approved by: (%,

Project Director Date: 0ffh REVISION HISTORY REVISION DATE REVISION DESCRIPTION O 04/03/97 Procedure Intilation 1 03/09/97 incorporation of NRC Comments O

l l

FS 7 MILLSTONE UNIT 2 ICAVP PP-04 PROJECT PROCEDURES l

( TITLE: REGULATORY REVIEW PROCEDURE l

REVISION: 1 DATE: 06/09/97 PAGE 2 OF 8 i

l TABLE OF CONTENTS 1.0 PURPOSE...........................................................................................................................3 2.0 DEFINITIONS.......................................................................................................................3 3.0 RES P O N S I B I L I TI ES ................ ........... ......... ..... .... ........... . .............. . ... .. ..... .......... ........ .. ...... .. 3 4.0 PROCEDURE..........................................................................................................................4 4.1 IDENTIFICATION OF REGULATORY DOCUMENTS . . .. .4 O 4.2 REVIEW AND SUMMARIZE REGULATORY DOCUMENTS. .4 4.3 REVIEW AND SUMMARIZE LICENSEE'S RESPONSE TO REGULATORY.. .5 DOCUMENTS 4.4 FSAR APPLICABILITY REVIEW... .5 4.5 SYSTEM AND/OR PROCESS VERIFICATION. .6 4.6 REGULATORY REVIEW

SUMMARY

REPORT . . .6 APPENDIX A - REGULATORY REVIEW

SUMMARY

FORM. . . . . .. . . .7 EXHIBIT 1 - REGULATORY ', VIEW.. . . .8 O

E) MILLSTONE UNIT 2 ICAVP PP-04 E .

PROJECT PROCEDURES l p

TITLE: REGULATORY REVIEW PROCEDURE REVISION: 1 DATE: 06/09/97 PAGE 3 OF &

1.0 PURPOSE ,

i l

ne purpose of this Project Procedure is to provide the guidance necessary to perform the j Regulatory Review portion of the Millstone Unit 2 Independent Corrective Action Verification l

Program (ICAVP). The Regulatory Review portion of the program will be performed in order to j provide a basis for an independent deternunation of whether Millstone Unit 2 licensing I

commitments have been appropriately incorporated into the licensing and design bases of the plant.

The results of this review will be used to provide additional insight into Northeast Nuclear Energy Company's (NNECo) corrective action programs.

2.0 DEFINITIONS 2.1 Current Licensing Basis (CLB) - The Current Licensing Basis (CLB)is the set of NRC A requirements applicable to a specific plant and the licensee's written commitments for ensuring U compliance with and operation within applicable NRC requirements and plant specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC regulations, orders, license conditions and technical specifications. It also includes the plant specific design basis information defined in 10 CFR 50.2 as documented in the most recent fmal safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensing correspondence such as licensee responses to NRC Bulletins, generic letters, enforcement actions, as well as licensee commitments documented in NRC Safety Evaluations or licensee event reports (LERs).

3.0 RESPONSIBILITIES The Regulatory Review is the responsibility of the Licensing Group Leader for the Project.

Additional assistance will be provided by licensing engineers assigned to assist in this effort.

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PROJECT PROCEDURES O

g TITLE: REGULATORY REVIEW PROCEDURE REVISION: 1 DATE: 06/09/97 PAGE 4 OF 8 4.0 fBOCEDURE As part of the Millstone Unit 2 ICAVP, a Regulatory Review will be performed of selected licensing documents that have been docketed for Millstone Unit 2 (Docket 50-336) necessary to I

support Tier 1, Tier 2 and /or Tier 3 reviews. This review will provide additional insight into NNECo compliance with the licensing bases at Millstone Unit 2. The Regulatory Review will be performed as shown on Exhibit 1.

4.1 IDENTIFICATION OF REGULATORY DOCUMENTS 4.1.1 Specific regulatory documents that will be evaluated in the Regulatory Review will be identified.

Documents will be identified if applicable to Millstone Unit 2. The documents will include:

e NRC Bulletins and licensee responses b

v e NRC Generic Letters and licensee responses e Safety Evaluation Reports associated with License Amendments e Other Safety Evaluation Reports (not associated with License Amendments) e NRC Notice of Violations and licensee responses (1995 to 1997) e Millstone Unit 2 Licensee Event Reports (1978 to 1997) 4.2 REVIEW AND SUMMARIZE REGULATORY DOCUMENTS 4.2.1 Documents in each category listed in Section 4.1.1 will be screened for applicability. In addition to documents which are not applicable to Millstone Unit 2, documents will not be included in the Regulatory Review for programmatic areas such as:

• Security related issues e

j Fire Protection (reviewed in Tier 1) t

! (( e Environmental Qualification (reviewed in Tier 1)

53 MILLSTONE UNIT 2 ICAVP PP-04 E

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PROJECT PROCEDURES TITLE: REGULATORY REVIEW PROCEDURE l

REVISION: 1 DATE: 06/09/97 PAGE 5 OF 8 l l 1

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• Operator Licensing ,

t 1

. Emergency Planning and Response e Radwaste Shipping

• Quality Assurance 4.2.2 Each applicable document will be summarized on a Regulatory Review Summary Form (Refer to Appendix A for example). The short discussion will key on required licensee action. I 4.3 REVIEW AND SUMMARIZE LICENSEE'S RESPONSE TO REGULATORY DOCUMENTS 4.3.1 For each applicable document, the licensee's docketed response will be reviewed and summarized

, on the Regulatory Review Summary Form (Appendix A). The summary will focus on licensee's V commitments which will be verified as part of the System and/or Process reviews as discussed in Section 4.5.

4.4 FSAR APPLICABILITY REVIEW 4.4.1 For each applicable document, a review of the current Updated Final Safety Analysis Report (UFS AR) will be performed to determine if an FSAR change was required, and if required, whether the FSAR was updated as required by 10 CFR 50.71.

4.4.2 Guidance from NEI Report # 96-05 " Guidelines for Assessing Programs for Maintaining the Licensing Basis" will be used as applicable, during this portion of the review.

4.4.3 The results of the FSAR review portion of the Regulatory Review will be provided on the Regulatory Review Summary Form (Appendix A). The results willinclude whether a change was required, and if required, which Section(s) of the FSAR were updated.

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PROJECT PROCEDURES TITLE: REGULATORY REVIEW PROCEDURE REVISION: 1 DATE: 06/09/97 PAGE 6 OF 8 4.5 SYSTEM AND/OR PROCESS VERIFICATION I i

! 4.5.1 The Regulatory Review Summary Form (Appendix A) , which has been completed through at least the Summary of Licensee Response, will be provided to the System Vertical Slice Review teams (Tier 1 Review), the Accident Mitigation Systems Review team (Tier 2 Review), and/or the Process Modeling, Analysis, and Review team (Tier 3 Review) based upon its applicability. The Tier review teams will verify the conunitments as part of their review.

4.5.2 A summary or reference of the verification resuhs will be provided on the Regulatory Review Summary Form (Appendix A) and retumed to the Regulatory Group.

4.5.3 Based upon the completion of the Verification Summary, the Regulatory Revinv of the specific item is considered closed when:

The validation of the item is complete and no further action is required, or e A Discrepancy Report (DR) has been issued in accordance with the Project Procedure PP-07 " Discrepancy Reports".

4.6 REGULATORY REVIEW

SUMMARY

REPORT 4.6.1 A report will be prepared summarizing the results of the Regulatory Review performed as part of the Millstone Unit 2 ICAVP. A summary will be provided for each category listed in Section 4.1.1 completed during the Regulatory Review. In addition, each of the completed Regulatory Review Summary Forms will be provided.

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E3 7 MILLSTONE UNIT 2 ICAVP PP-04 E .

PROJECT PROCEDURES TITLE: REGULATORY REVIEW PROCEDURE REVISION: 1 DATE: 06/09/97 PAGE 7 OF 8 l

l Appendix A l REGULTORY REVIEW

SUMMARY

FORM Document title: Document date:

Document subject: Affected system or process:

Document Description (Inch.de discussion) i l Millstone Unit 2 response reference (s):

Summary of Licensee Commitments Basis for NRC Licensing Action (e.g., for SERs, etc.)

(Include suficient details ofs/1'c mods, process mods or rwquired conditions to allow veryication afrecommended below) 1 i

Applicable ICAVP Tier: Tier 1 Tier 2 Tier 3 Regulatory review only l

FSAR Verification FSAR updated: Oyes No Not Required (Discuss below) l FSAR section(s):

Discussion. ,

1 l

l Verification Summary l Verify Recommended by RR Verification by Tier (Include Discussion *)

l S/S/C modified: Yes No ON/A Verified okay Not verified Potential discrepancy per PP-07 Process revised: Yes No N/A Verified okay Not verified Potential discrepancy per PP-07 Conditions intact: Yes No ON/A Verified okay Not verified Potential discrepancy per PP-07 aVerification discussion and recommended disposition:

Verif. complete Tier Group Lead Date RR Group Lead Date c

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

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E MILLSTONE UNIT 2 ICAVP PP-04 PROJECT PROCEDURES i

TITLE: REGULATORY REVIEW PROCEDURE REVISION: 1 DATE: 06/09/97 PAGE 8 OF 8 mee i _

e= i R.e we.asee.a EXHIBIT 1

---* Reewearr Docurnente REGULATORY REVIEW

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nn Requirements e.am Seccon 1.0 tA Requirements

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Conneureuen . l Changen/ '

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- 3,e Con #gureuon Appucebaty Wes NO SAR Change Required 7

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SAR NO Forward Chenge For Correcuve Adequate Accon

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YES

,r Document SAR change j

• (or non ehenge)

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Bests Rn Secuan3.0 Sereen 3Ag

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,,,, Updates System / Equipment Verincadon inspecuan Performed in Tier 1,2, or 3 Reviews ir vertry conformence e Physleel eenngursson e Docurnent Change e impaementauon

'f Deep Document &

M2 NO Forward conform For Corrective 7 Action YES t ir l '

com,iew aa '

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Report

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= PARSONS PP-05 l 1

MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

l I

Differing Professional Opinion l

l REVISION 1 l l l

Prepared by: Date: 4 17 Approved by: [ Date: 4/9A 7 l f anager, Company Quality Program '

Approved by: O .(,m , Date: [9/Ih Projectpector REVISION HISTORY REVISION DATE REVISION DESCRIPTION O 04/03/97 Procedure initiation 1

06/09/97 incorporation of NRC Comments I 1

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1 1

P) MILLSTONE 2 ICAVP PP-05 PROJECT PROCEDURES TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 1 DATE: 06/09/97 PAGE 2 OF 8 l

l TABLE OF CONTENTS l

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1 1.0 PURPOSE ........................................................................................................3 2.0 DEFINITIONS............................................................................................................3 3.0 RES PO N S I B I L I TI E S ....... ......... .. ....... ... .. ... ..... . ... . ........ ... . .. .. ....... ..... ... ..... .. ......... . . 3 4.0 INSTRUCTIONS......................................................................................................4 4.1 GENERAL. . . . . . . .4 l 4.2 INITIATION OF DPOS . . . . .5 1

4.3 TRACKING, RESOLUTION, AND REVIEW OF DPOS . .5 4.4 APPEAL OF DPO RESOLUTION.. .. . .7 l

4.5 CLOSE-OUT AND FOLLOW-UP OF DPOS.. . . . .7 ATTACHMENT 1 - DIFFERING PROFESSIONAL OPINION RESOLUTION . .8 O

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PP-05 rP) MILLSTONE 2 ICAVP PROJECT PROCEDURES

-E .

TITLE: DIFFERING PROFESSIONAL OPINION DATE: 06/09/97 PAGE3OF8 )

REVISION: 1 1.0 PURPOSE To encourage Parsons team members to make known their judgments on matters of technical safety significance conceming the Millstone Unit 2 ICAVP even though their judgments m from those of management positions. While discussion regarding differing siewpoints is preferable beveen individuals within the chain of command, this procedure provides a form process wb.a these differing judgments can he recogmzed and considered so that safe and appropriate actions are taken.

Nuclear Regulatory Conunission (NRC) regulations assure the employee that he/she is protec against retaliation in any form when engaged in nuclear activities as defined in 10 CFR 50.7

" Employee Protection" Additional information concerning this is posted (refer to NRC Fon on ICAVP project area bulletin boards. This includes the initiation of a Diffenng Professional Opinion (DPO).

Employees that have expressed a DPO may also input this concern into the NNECo Employe Concems Program in accordance with the instructions provided in NNECo procedure " Nuclear Safety Concerns" NGP 2.15, available in the project records office.

2.0 DEFINITIONS 2.1 Differing Professional Opinion (DPO) - A conscientious expression of professionaljudgment expressed in a written statement submitted to one's immediate supenisor ec,ncerning ma nuclear safety which differ from the prevailing Millstonc Unit 2 ICAVP team view.

2.2 DPO Resolution - A written statement providing the technical basis in support of the final ICAVP team position on a nuclear safety issue. The DPO Resolution will either confirm the validity position described in the DPO, or provide a detailed response to each issue expressed in Concurrence of the DPO initiator is not required for DPO Resolution.

3.0 RESPONSIBILITIES 3.1 Project Director (Vice President Nuclear Senis J 3.1.1 Makes the fmal determination as to the resolution of the DPO between team mem Technical Advisory Panel.

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, E3 MILLSTONE 21CAVP PP-05 E

PROJECT PROCEDURES i

) TITLE: DIFFERING PROFESSIONAL OPINION v

"IlON: 1 DATE: 06/09/97 PAGE 4 OF 8 3.2 DEPUTY PROJECT DIRECTOR 3.2.1 Makes the final determmation as to the resolution of the DPO between Core Team members.

3.2.2 Maintains tracking system for monitoring the progress toward resolution.

3.2.3 Provides a written statement describing in detail the basis for the prevailing project position that includes specific responses to the concerns identified in the DPO.

3.2.4 Obtains technical input as necessary from other affected disciplines within Parsons to fully address the issues identified in the DPO.

3.3 MANAGER- COMPANY QUALITY l

3.3.1 Advises the Project Director (Vice President-Nuclear Senices) or the Deputy Project Director, as apprcpriate, as to the resolution of DPOr.

I

\ 3.4 INITIATOR 3.4.1 Prepares written statement describing in detail the technical issue and the differing opinion, and forwards that statement and Form provided in Attachment I to the Deputy Project Director, in accordance with the requirements described in Section 4.

4.0 INSTRUCTIONS To ensure timely processing, the cover sheet (Attachment 1) should accompany all DPO documentation.

4.1 GENERAL 4.1.1 Free and open discussion of tecto: cal and nuclear safety issues on the Millstone Unit 2 ICAVP is encouraged and expected.

4.1.2 Employees should endeavor to resolve differences of professional opinion through discussions with their co-workers, immediate supenision on the project, and the project organization.

O 4.1.3 While addressing technical and nuclear safety issues through line management is encouraged, nothing in this procedure should be interpreted as interfering with or discouraging employees from

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E MILLSTONE 2 ICAVP PP-05  :

PROJECT PROCEDURES i

O, TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 1 l DATE: 06/09/97 PAGE 5 OF 8 )

exercising their rights as discussed in this procedure. In addition, team members have the i opportunity to have their concems addressed through the NNECo Nuclear Safety Concerns Program as detailed in NGP 2.15 or by the NRC.

4.2 INITIATION OF DPOS 4.2.1 The initiator shall document in writing, the unresolved difference which they believe to have actual or potential safety significance.

l Documentation may be in the form a memorandum, and should include the following with as much supporting detail as practical:

4.2.2.1 Initiate DPO Cover Sheet (Attachment 1).

4.2.1.2 A summary of the perceived Team position along with supporting documentation.

4.2.1.3 A description of the employee's professionaljudgment on the issue and how it differs from the Team position complete with supporting documentation. Each issue that is to be addressed must be clearly identified.

4.2.1.4 An assessment of the potential resultant consequences if the employee's position is not adopted.

4.2.1.5 The initiator shall forward the original DPO to the Project Deputy Project Director for Core Team Members) or the Project Director (Vice President, Nuclear Services) for Technical Adsisory Panel members, with copies sent to the laitiator's immediate project supervisor and project records.

4.3 TRACKING, RESOLUTION, AND REVIEW OF DPOS 4.3.1 The Deputy Project Director shall:

4.3.1,1 Within three working days, enter the DPO into the project tracking system and identify the tracking number on Attachment 1. A copy will be provided to the Project Director, Deputy Project Director, Group Lead and Initiator.

4.3.1.2 Upon receipt, the Project Director shall forward a copy of the initiated DPO to the NRC primary O contact in accordance with the Communications Plan (PLN-02). The name of the initiator shall be redacted on this copy.

b E3 MILLSTONE 2 ICAVP PP-05 E

PROJECT PROCEDURES O

Q TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 1 DATE: 06/09/97 PAGE 6 OF 8 4.3.1.3 All correspondence related to the DPO shall reference the DPO tracking number.

4.3.1.3 The proposed DPO Resolution must be completed within ten working days from the time the DPO is received, and may either affirm the validity of the basis for the DPO and adopt the position of the DPO initiator, or it may provide the technical basis fr,r maintaining the prevailing project position.

4.3.1.4 Should resolution not be achievable within ten workbig days, an Action Plan shall be prepared within three additional working days and approved by the Project Director. The initiator will receive a copy of the Action Plan.

4.3.1.5 The DPO status will be updated in the tmcking system to reflect that the DPO requires an Action I Plan.

4.3.5 The DPO Resolution shall include the following:

O V 4.3.5.1 A summary of the areas of technical disagrecrunt being addressed by the DPO Resolution.

4.3.5.2 A detailed response to each issue identified in the DPO, including all facts relevant to the basis for the position being adopted. The DPO Resoludon must address every issue raised in the DPO.

4.3.5.3 An assessment of the potential consequences of the position adopted.

4.3.7 The Deputy Project Director shall:

4.3.7.1 Confer with the DPO initiator and forward the DPO Closure within five working days for final status and distribution.

4.3.7.2 Update the DPO status in the tracking system to reflect that the DPO is considered closed.

l 4.3.7.3 Send DPO resolution to Project Records with a copy to the Project Director and Manager, Company Quality.

I 4.3.7.4 The Project Director shall submit a copy of the completed DPO and resolution to the NRC primary contact in accordance with the Communications Plan (PLN-02). The name of the initiator shall be redacted on the copy submitted to the NRC U

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!E) MILLSTONE 2 ICAVP PP-05 l 8 PROJECT PROCEDURES TITLE: DIFFERING PROFESSIONAL OPINION l

REVISION: 1 DATE: 06/09/97 PAGE 7 OF 8 ]

4.4 APPEAL OF DPO RESOLUTION Since the Deputy Project Director makes the final determination of the DPO Resolution after makmg a complete and impartial evaluation of all the issues (with nuclear safety being paramount),

and conferring with the DPO initiator, there will be no appeal process under this procedure.

4.5 CLOSE-OUT AND FOLLOW-UP OF DPOS l The Deputy Project Director shall:

4.5.1 Advise the Project Director, as appropriate, as to the DPO Resolution. l O

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!?,3 MILLSTONE 2 ICAVP PP-05 E '

PROJECT PROCEDURES t TITLE: DlFFERING PROFESSIONAL OPINION REVISION: 1 DATE: 06/09/97 PAGE 8 OF 8 'l ATTACHMENT 1 l DIFFERING PROFESSIONAL OPINION RESOLUTION l Tracking Number #

1. INITIATION 1.1 Document in written form the unresolved ditTerence.(Attach DPO memo and Additional j documentation as necessary). Provide Summary Statement of DPO.

I Initiator /Date I l

1.2 Forward the DPO related documentation to Deputy Project Director with copies to I initiator's supenisor, i

2. RESOLUTION 2.1 Enter the DPO into the DPO tracking system.

j Deputy Project Director /Date 2.2 Prepare written documentation with detailed basis for final project position. (Attach action plan or resolution with documentation as necessary) 2.3 Forward DPO resolution or Action Plan to initiator with a copy to the Project Director l and the Director Company Quality, i Prepared by/date Approved by/date Action Plan Resolution 2.4 Review DPO Resolution with Initiator.

Initiator /Date Deputy Project Director /Date

3. CLOSURE 3.1 DPO Closed o Deputy Project Director /Date 3.2 Send approved DPO resolution to Project Records.

53 O = PARSONS PP-06 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

Substitution or Addition of Personnel REVISION 1 l

Prepared by: /IM/ Date: 4/f,[9 /

p ,~

Approved by: f/[d Date: 6/9M 5 anager, Compan Quality Program

^

Approved by: 4MK Date: [ ' fh ProjegDirector i

1 REVISION HISTORY REVISION DATE REVISION DESCRIPTION 0 04/03/97 Procedure Initiation 1

06/09/97 incorporation of NRC Comments l O

P) MILLSTONE UNIT 2 ICAVP PP-06 E

PROJECT PROCEDURES TITLE: SUBSTITUTION OR ADDITION OF PERSONNEL v

REVISION: 1 DATE: 06/09/97 PAGE 2 OF 4 'l TABLE OF CONTENTS I.0 PURPOSE ............................................................................................................3 2.0 DEFINITIONS............................................................................................................3 3.0 RES P O N S I B I L I TI ES ............................. ....... .... .. .. ..... .. ....... ... . ...... . ... ... ... .... .. ............. 3 3.1 .4 PROJECT DIRECTOR (VICE PRESIDENT NUCLEAR SERVICES) .

3.2 GROUP LEADERS... . . . .. . . .. ... . . . . . . . .4 3.3 INDIVIDUAL TEAM MEMBERS. . . .. . . . .. .4 4.0 I N ST R U CTI O N S ..................................... .. .. ... ...... .. .................. .. ......... ..... ....... ..... .. 4 ,

l 4.1 SUBSTITUTION OR ADDITION . . . . .. . .4  ;

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Al ATTACHMENT 1 - CONFLICT OF INTEREST FORM l

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PROJECT PROCEDURES l V) TITLE: SUBSTITUTION OR ADDITION OF PERSONNEL REVISION: 1 DATE: 06/09/97 PAGE 3 OF 4 ]

1.0 PURPOSE i

I l The NRC Confirmatory Order to NNECO dated August 14,1996 requires that the ICAVP be conducted by an independent verification team whose selection must be approved by the NRC.

l The NRC Oversight Plan states that the NRC will assess the independence and qualifications of the l contractor and individual team members. It states that the staff will interview each member of the l ICAVP contractor team to verify that each has the appropriate level of knowledge and experience l to conduct the review and to ensure that none of the members has a professional or fmancial interest in the Millstone Unit 2 facility.

The original core team for the Millstone Unit 2 ICAVP was chosen based on these requirements of l qualification and independence. Once this core team has been approved by the NRC, substitutions l for personnel previously approved by the NRC or additions of personnel will be required in order to address specific issues as they develop throughout the audit. l j This procedure provides the process for substitution or addition of personnel to the Millstone Unit l 2 ICAVP.

2.0 DEFINITIONS 2.1 Substitution of personnel - replacement of personnel which have been approved by the NRC during the contractor selection process.

2.2 Addition of personnel - supplementing the personnel previously approved by the NRC due to specific requirements of the project.

3.0 RESPONSIBILITIES 3.1 PROJECT DIRECTOR (VICE PRESIDENT NUCLEAR SERVICES) 3.1.1 Approves qualifications and independence of personnel who will be provided as additions or l

l substitutions.

! 3.2 GROUP LEADERS 3.2.1 Interviews and recommends candidates for substitution or addition to the Project Director for

, approval.

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PROJECT PROCEDURES j TITLE: SUBSTITUTION OR ADDITION OF PERSONNEL REVISION: 1 DATE: 06/09/97 PAGE 4 OF 4 ]

3.3 INDIVIDUAL TEAM MEMBERS l

3.3.1 Prepares complete resumes summarizing qualifications in relation to the specific task and completes the Millstone Unit 2 Conflict ofInterest Form presented as Attachment 1.

4.0 JNSTRUCTIONS 1

l 4.1 SUBSTITUTION OR ADDITION 4.1.1 All substitute or additional team members will complete the Millstone Unit 2 Conflict ofInterest Form which is provided as Attachment 1.

4.1.2 The Responsible Group Leaders will inteniew all substitute or additional team members and recommend for approval to the Project Director. This recommendation will be based upon a review of the educational background, technical qualifications and previous professional work experience related to the individuals assignment on the project. This inteniew will also review the v/ completed Conflict ofInterest Form with the individual.

4.1.3 The Project Director will forward the resumes of qualified and independent substitute or additional personnel along with a summary description of the assigned task and the completed Conflict of Interest form (Attachment 1) to the NRC and NNECo in accordance with the Communications Plan (PLN-02).

4.1.4 Substitute or additional personnel may begin to work on the project at the time the letter has been forwarded to the NRC and NNECo.

4 1.5 If the NRC or NNECo identifies that any substitute or additional team member is not technically qualified or is not professionally or financially independent, the particular individual will be immediately taken off the project and any work performed by the individual will be re-reviewed by a qualified and independent project team member l

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Attachment 1 - PP-06 l l

l CONFLICT-OF-INTEREST STATEMENT ,

MILLSTONE IPt Corrective Action Verification Program (ICAVP) .

Parsons Power Group Inc. ,

Proposed Consultant Consultant's Employer I My participation in the Millstone Unit 2 ICAVP [( ) does ( ) does not] involve situations or relationships in which I had direct previous involvement with activities at the plant that I will be reviewing and I [( ) have

( ) do not have) conflicting roles that might bias myjudgment in relation to my work on the ICAVP, In addition

1. ( ) I have not been previously employed by Northeast Nuclear Energy Company (NNECO) or any of its predecessors.

l l () I have been previously employed by NNECO or some ofits predecessors. (State the nature of the employment.)

2. () I have not previously provided design or engineering services to NNECO for the subject Millstone unit as a contractor or a subcontractor.

() I have previously provided design or engineering services to NNECO for the~ subject Millstone

unit as a contractor or a subcontractor, 1

3. () I have no other business relations (member of NNECO's Board of Directors, member of an Offsite Review Committee, etc.) with NNECO for the subject Millstone unit that may create the  :

appearance of a conflict ofinterest.

l () I have other business relations with NNECO for the subject Millstone unit that my create the appearance of a conflict ofinterest.

4. () I have not been previously employed by the subject Millstone unit's architect-engineer (AE) ,

(Bechtel), the nuclear steam supply system (NSSS) vendor (ABB/CE), or any of their  !

predecessors associated with design or construction of the subject Millstone unit.

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() I have been previously employed by the subject Millstone unit's AE (Bechtel), the NSSS vendor (ABB/CE), or one or more of their predecessors associated with design or construction of the subject Millstone unit. (State the nature of the employment.)

l S. () I, and my immediate family, do not own or control financial interests (stocks, bonds, mutual j l funds, etc.) in NNECO, the subject Millstone unit's AE (Bechtel), or the NSSS vendor

! (ABB/CE). i I \

() I, or a member of my immediate family, own or control financial interests (stocks, bonds, mutual

, funds, etc.) in NNECO, the subject Millstone unit's AE (Bechtel), or the NSSS vendor

! (ABB/CE).

t lof 2 l l _ - - _

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[ s Parsons Power Group Inc. j Proposed Consultant Consultant's Employer.

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6. () Members of my immediate family are not employed by NNECO, the subject Millstone unit's AE (Bechtel), or the NSSS vendor (ABB/CE) associated with design or construction of the subject l l Millstone umt.  ;

() Members of my immediate family are employed by NNECO, the subject Millstone unit's AE

]

(Bechtcl), or the NSSS vendor (ABB/CE) associated with design or construction of the subject {

Millstone unit.  !

7. () My close relatives (aunts, uncles, first cousins) are not employed by NNECO, the subject l Millstone unit's AE (Bechtel), or the NSSS vendor (ABB/CE) in a management capacity. i l

( ) My close relatives (aunts, uncles, first cousins) are employed by NNECO, the subject Millstone unit's AE (Bechtel), or the NSSS vendor (ABB/CE) in a management capacity. (State the nature of the employment.) j l

8. Have you been promised any additional compensation, reward or anything of value, contingent upon the position you take on any issue being considered by you in connection with the subject Millstone unit ICAVP7 Ifyes, provide a detailed description ofthe circumstances.

j

() NO ()YES. Explain.

9. Do you know of any reasons, whether or not inquired about in this questionnaire, that would affect your ability to be completely objective in performing any of the tasks assigned to you in connection

'A with the subject Millstone unit's ICAVP? If yes, provide a detailed description of the circumstances.

i

()NO ()YES. Explain.

10. Are you aware of anything that might create a perception that you would not act with objectisity in performing any of the tasks assigned to you in connection with the subject Millstone unit's ICAVP? If yes, provide a detailed description of the circumstances.

()NO ()YES. Explain.

I certify that the statements I have made on this form are true, complete, and correct to the best of my knowledge and if the circumstances surrounding the responses change during performance of the ICAVP l for the subject Millstone unit, I will inform the NRC of those changes.

l Signature Date In the above statements, the term " employed" is construed to mean any form of employment, either direct as a contractor, or as a subcontractor. The term "immediate family" includes the interviewee's children, stepchildren, spouse, parents, stepparents.

Mother-in-law, father-in-law, brothers-in-law, sisters-in-law, or any person hymg with the interviewee.

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" PARSONS PP-07 MILLSTONE UNIT 2 ICAVP l PROJECT PROCEDURES  :

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Title:

)

Discrepancy Reports  !

REVISION 1 I

Prepared by: b/Aj/ Dr.te: / 7 y .' < -

/ /

Approved by: [ 9[h- Date: 6 7 i M ger, Company Ouality Program '

Approved by: _ t'S% Date: [ f 3_

Pro)ect Director REVISION HISTORY REVISION DATE REVISION DESCRIPTION O 04/03/97 Procedure initiation 1

06/09/97 incorporation of Initial NRC Comments O

l Y.h MILLSTONE UNIT 2 ICAVP PP-07 PROJECT PROCEDURES i'n Q TITLE: DISCREPANCY REPORTS

< REVISION: 1 DATE: 06/09/97 PAGE 2 OF 11 TABLE OF CONTENTS 1.0 PURPOSE...............................................................................................................3 f

1

2. 0 RE FE RE N C E S ............................ .... . .. . ... ... ... . . .. .... ..... ........ .. .. ..... ...... ........ .............. 3 i

1 3.0 D E FIN ITI O N S ...... . .... ......... .......... ... .. ....... ......... ............ .. . . ..... .. ...... .... . .. ........... .... . 3 4.0 RE S PONS IB ILITIES ............................................................................................. 4 1

1 5.0 PROCEDURE........................................................................................................5 '

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5.1 IDENTIFICATIO N OF DISCREPANCIES.. . ....... ............. ... ........................ 5 i

5.2 EVALUATION.........................................................................................................6

i 1 5.3 REVIEW, APPROVAL AND FORWARDING ....................... ............................... 6

. 5.4 REVIEW OF PROPOS ED CORRECTIVE ACTION.............................................. 7 5.5 FI NA L RES O L UTI O N .............................................................................................. 8 ATTACIIM ENT I DISCREPANCY REPORT.......................................................... 9 EXHIBIT 1 EVALUATION OF DISCREPANCIES................................................. I 1 d

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E MILLSTONE UNIT 2 ICAVP PP-07 i

PROJECT PROCEDURES I /

Q.

TITLE: DISCREPANCY REPORTS REVISION: 1 DATE: 06/09/97 PAGE 3 OF 11 I

1.0 PURPOSE I The purpose of this Project Procedure is to provide guidance and instmetions for the 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 Confirmatory 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 s 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 Reference 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 - An adverse condition , such as an error, omission, or oversight which l prevents consistence among the physical configuration, information sources (e.g.

f documentation and databases), design basis and/or regulatory requirements I

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P) MILLSTONE UNIT 2 ICAVP PP-07 E

l PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS l REVISION: 1 DATE: 06/09/97 PAGE 4 OF 11 l

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 a 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 (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals.'

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 l

NNECo, NEAC, and the NRC in accordance with the Communications Plan (PLN-02).

(_/

4.2 Deputy Project Director - Responsible for:

e 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 ofICAVP 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;

• validating their bases; closing those for which the bases are found to be invalid; i

'.Ob 3 10 CFR Part 50, Paragraph 50.2

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r P) MILLSTONE UNIT 2 ICAVP PP-07 E >

PROJECT PROCEDURES (v) TITLE: DISCREPANCY REPORTS REVISION: 1 DATE: 06/09/97 PAGE 5 OF 11 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. He Originator additionally may be asked by the ICAVP Group Leader to provide comments on the l proposed resolution by NNECo.

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i l 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 2). Further evaluation by the ICAVP Team may be required to confirm the basis for the Discrepancy,

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.g as do:umented on the DR form. He DR process is depicted in Exhibit 1.

l 5.1.2 The Originator will obtain a DR Log number from the Project Administrator. The 1

following information, DRs will as a nummum, will be recorded for all DRs for tracking )

i purposes:

e DR number I

i l e Date I e Title

. NNECo response date l

l 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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PJ MILLSTONE UNIT 2 ICAVP PP-07 E

PROJECT PROCEDURES

/^Nj TITLE: DISCREPANCY REPORTS REVISION: 1 DATE: 06/09/97 PAGE 6 OF 11 5.1.4 The Originator should additionally provide a brief one to two sentence description of the safety significance of the identified discrepancy on Form PP-07-1. Evaluation of l discrepancies to the formal NRC reporting requirements is the responsibility 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 Lesi, based on discussion with the Originator and other Team Members, as appropnate, to determine ifits basis is valid and to ensure that all known aspects of the Discrepancy are adequately described ot a DR.

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

! SeDR

\O l d 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.

l 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 1

1 5.3.1 After a DR has been evaluated by the responsible Group Lead, it will be forwarded to the Deputy Projeu Director for review. Following that, the DR will be forwarded to the Project Director for approval. After approval, the DR will be reported 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).

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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

'ED MILLSTONE UNIT 2 ICAVP PP-07 E

PROJECT PROCEDURES

( TITLE: DISCREPANCY REPORTS REVISION: 1 DATE: 06/09/97 PAGE 7 OF 11 l reporting the DRs to NNECo, NEAC, and the NRC. This includes DRs that were closed l

following a determination that the basis was not valid and for DRs that are evaluated and l

found to have been identified previously by NNECo as part of their Configuration l 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, A consulting with the originator, as necessary, to ensure the proposed resolution correlates to the original concern. Conunents should focus on the perceived adequacy of the proposed sction to resolve the discrepancy and prevent recurrence, consistent with the purpose of the ICAVP (refer to Defmition 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 resiew.

prior to releasing the comments per Reference 2.3.

5.4.5 The ICAVP Project Director will approve comments and forward conunents 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).

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PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 1 DATE: 06/09/97 PAGE 8 OF 11 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. l 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 will identify the DR as an open item.

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P) MILLSTONE UNIT 2 ICAVP PP-07  :

E PROJECT PROCEDURES l TITLE: DISCREPANCY REPORTS REVISION: 1 DATE: 06/09/97 PAGE 9 OF 11 l

I ATTACHMENT 1 DISCREPANCY REPORT DISCREPANCY TITLE DR Log Number j DISCREPANCY Include System / Process Name, Procedure / Drawing Name/ Number, (A ttach additional documentation as necessary) i l

Description of Safety Significance '

Provide a briefDescription ofthe safety significance ofthe identiped DR Originator Group Date EVALUATION Validation ofbasisfor Discrepancy or Closure ifnot valid (Attach documentation as necessary)

OBasis Valid OBasis Invalid - Closed OPreviously Identified by NNECo - Closed Group Lead Date REVIEW AND APPROVAL Reviewed:

Dep. Proj. Director Date Approved:

Project Director Date Fwd'd to NNECo, NEAC, and NRC: Posted to WWW l Date Date 1

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E MILLSTONE UNIT 2 ICAVP PP-07 PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 1 DATE: 06/09/97 PAGE 10 OF 11 ATTACHMENT 2 DISCREPANCY REPORT PAGE 2 DR Log Number

SUMMARY

OF NNECO PROPOSED CORRECTIVE ACTION:

COMMENT ON NNECO RESPONSE:

O Prepared: i Group Lead Date Reviewed:

Dep. Proj. Director Date Approved:

Proj. Director Date Fwd'd to NNECo, NEAC, and NRC: Posted to WWW Date Date FINAL RESOLUTION Dep. Proj. Dir. Date

!!P) MILLSTONE UNIT 2 ICAVP PP-07 E >

PROJECT PROCEDURES

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TITLE: DISCREPANCY REPORTS V

REVISION: 1 DATE: 06/09/97 PAGE 11 OF 11 PP-07 Discrepancy ReportsProcess Communication Plan V

m Reviewed DR m Approved DR m Issue issued DR m Review Basis Invalid DR E Approve ICAVP Rasis Invalid DR E Discrepancy ICAVP issued comment E p Annroved comment oC Activities closed DR C Report Closed DR C Activities NNECo Response "

Proj. Supporb Dep. Proj. din Proj. dim World Wide Web NNEco DR Resmnse Basis Invalid DR Cnmment on NNFCo Resnnner Perform Tiu 1 NNECo DR Resnonse Activities ,,---

NNECo CMP -

Conectine Actions l Validate /

Perform - Evaluate Tier 2 Discrepancy Report, (DR) m Discrepancy Activities w/ Desenption & Safety Sigmficance { Report, (DR)

Group bad (s)g TeamMembers Perform Tier 3 NNECo DR Response Activities

~~1 Perform r 3 Workine Ouestion m Assign Working Ouestion m C >

Regulatory w/ Basis Tracking # w/ Basis + a Trackmg #" Discrepancy Review

• Tracking Data Base Proj Support b '

Closed DR

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