ML20198Q018

Rev 5 to PP-7 Discrepancy Reports

ML20198Q018
Person / Time
Site:	Millstone
Issue date:	01/20/1998
From:	External (Affiliation Not Assigned)
To:
Shared Package
ML20198Q012	List: ML20198Q008 ML20198Q018
References
PROC-980120, NUDOCS 9801220316
Download: ML20198Q018 (13)

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" PP-07 PARSONS ,

MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

Discrepancy Reports REVISION 5 l Prepared by: , h_

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///a/s Date: /Jo[7f gI / I Approved by: 9 /hr o Date: / 0 ff f nager, Company Cfuality Program Approved by: mu Project Direclor 1 /" / h - Date: /dd[M _

REVISION HISTORY REVISION DATE REVISION DESCRIPTION O 04/03/97 Procedure inhiation 1

06/09/97 incorporation of Initial NRC Comments 2 06/26/97 incorporate NRC Comments 3 07/29/97 incorporate NRC Comments 4 09/12/97 incorporate Technical Advisory Group Review 5 01/16/98 Incorporate NRC Corrments D 0 36 P PDR

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• TITLE: DISCREPANCY REPORTS REVISION: 5 DATE: 01/18/98 PAGE 2 OF 13 LIST OF EFFECTIVE l' AGES pat:t No. RrmioN No.

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TABLE OF CONTENTS 1.0 P U RPO S E......... .. ........ ..... .... .....................................................................3 2.0 REFERENCE5...................................................................................................3 3.0DEFINITlONS.....................................................................................................................3

4. 0 R E S P O N S I Il l L I T1 E 5 .... .............................. ......................... .......... .. . . ...... .............. . ...... . . ..... 4 N 5.0 PROCEDURE...............................................................................................................................5 5.1 IDENTIFICATION OF DISCREPANCIES.. . . . .5 5.2 EVALUATION.. . . . . . . .4 5.3 REVIEW, APPROVAL AND FORWARDING. . . . ..7 5.4 REVIEW OF PROPOSED CORRECTIVE ACTION . . .7 5.5 FINAL RESOLUTION.. , , , , , . . . . . . . .8 t

ATTACllMENT I DISCREPANCY REPORT.. . . . . . .10 ATI'ACllMENT 2 CRITERIA FOR CATEGORIZING Tile RELATIVE SIGNIFICANCE OF D IS C R E PA N Cl ES I D E N TI FI E D 11 Y TI I E I CAVP............. .. . ................................ ...... ............ I 2 EX11I11IT I EVALU ATIO N O F DISCR E PANClES ........ ........ ....... .... ................ .. ................. I 3 i

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SD MILLSTONE UNIT 2 ICAVP PP-07 E >

PROJECT PROCEDURES TITLE:

DISCI 1CPANCY REPORTS REVISION: 5 DATE: 01/16/98 PAGE 3 OF 13 1.0 */URPOSE He purpose of thiti Project Procedure is to povide guidance and instructions 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 niablishing an Independent Corrective Action Verification Program (ICAVP) 2.2 Audit Plan, Millstone Unit 2 Independent Corrective Action Verification Program 2.3 Communication Plan, PLN-02, Millstone Unit 2 Independent Corrective Action Venfication Program 3,0 DEFINITIONS 3.1 ICAVP - Independent Corrective Action Verification Program established by Reference 2.1 to verify the adequacy of Northeast Utilitics' (NU) efforts to estatilish adequate design bases and design controls, including translation of the design bases into operating procedures and maintenance and testing practices, verification of syuem performance, and implementation of modifications since issuance of the initial facility operating license.

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

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

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MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES PP-07 (N TITLl:

DISCREPANCY REPORTS

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REVISION: 5 DATE: 01/16/98 PAGE 4 OF 13 3.3 Design Bases - Information that identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted stne-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 cornponent must meet its functional goals.'

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

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

4.2 Deputy Project Director - Responsible for:

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; e validating their bases; closing those for which the bases are found to be invalid; f)

C' ' 10 CFR Part So, Paragraph 50.2

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TITfE: DISCREPANCY REPORTS REVISION: 5 DATE: 01/16/98 PAGE 5 OF 13 e commenting on the proposed resolution by NNECo.

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

4.5 Technical Adsisory Group (TAG) Responsib!c for reviewing and commenting on all Significance Level 1,2 and 3 discrepancy reports, NNECO responses and Parsons comments on corrective action, prior to closure, 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 Repon (DR) (Attachment 1). Further evaluation by the ICAVP Team may be required to confinn the basis for the Discrepancy, as documented on the DR fonn. The DR process is depicted in Exhibit 1.

5.1.2 %c Originator will obtain a DR Log number from the Pro.iect Administrator. The following information, as a minimum, will be recorded for all DRs for trac \ing purposes:

• DR number e Date

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• NNECo response date e Response / resolution review date O

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PROJECT PROCEDURES O

V llTLE: DISCREPANCY REPORTS l

REYlSION: 5 DATE: 01/16/98 PAGE 6 OF 13 j 5.1.3 The Originator will ensure that the initiation portion of the DR form is filled out as 1 completely as possible, including, as applicabic, a description of the discrepancy, system or process name, procedure name and number, drawing none and number, afTected engineering discipline, and source authority or reference used to identify the discrepancy.

5.1.4 The Originator should provide a categorization of the significance of the identined discrepancy to one of the four levels per the criteria of Attachment 2. This section should include a brief statement of the rationale for selection of signincance level. Evaluation of discrepancies to the formal NRC reporting requirements is the responsibility of NNECo.

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

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

In addition, the Group Lead will review the signi6cance level and discussion prepared by the originator.

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

5.2.3 DRs for issues that are evaluated and found to have been identif.ed previously by NNECo as part of their Con 6guration Management Plan shall be noted as such and closed following such evaluation.

5.2.4 'Ihe responsible Group Lead will record the results of the evaluation on the DR form, check the appropriate bos(es), sign the form and fonvard it to the Deputy Project Director.

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MILLSTONE UNIT 2 ICAVP PRO.!ECT PROCEDURES PP-07 flTLE: DISCREPANCY REPORTS REVISION: 5 DATE: 01/16/98 PAGE 7 OF 13 5.3 REVIEW, APPROVAL AND FORWARDING 5.3.1 After a DR has been evaluated by the responsible Group Lead, it will be fonvarded to the Deputy Project Director for review. Following that, the DR will be fonvarded to the Project Director for approval. After approval, the DR will be 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).

5.3.2 DRs will be posted on the World Wide Web in accordance with Reference 2.3. DRs will be reported on the Parsons World Wide Web page 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (2 working days) after reporting the DRs to NNECo, NEAC, and the NRC. 'Ihis includes DRs that were closed following a determination that the basis was not valid and for DRs that are evaluated and found to have been identified previously by NNECo as part of their Configuration O Management Plan.

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5.3.3 Questions that arise curing the retiew or apprevel 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 fonvarded to the 1

ICAVP Group Leader responsible for evaluating the DR.

5.4.2 The ICAVP Group Leader will prepare comments on the proposed corrective action, consulting with the originator, as necessary, to ensure the proposed resolution correlates to l the original concern. Comment < sould focus on the perceived adequacy of the proposed action to resolve the discrepancy and prevent recurrence, consistent with the purpose of the ICAVP (refer to Defmition 3.1 and Reference 2.2). Conunents on the NNECo response i

will'x documented on the DR form.

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

MILLSTONE UNIT 2 lCAVP PP-07 PROJECT PROCEDURES TITLE: DISCREPANCY REPORTS REVISION: 5 DATE: 01/16/98 PAGE 8 OF 13 5.4.4 The ICAVP Group Leader will fonvard the DR to the Deputy Project Director for review, prior to releasing the comments per Reference 2.3, 5.4.5 All DR's will be forwarded to TAG. TAG is required to comment on all Significance Level 1,2 and 3 DR's.

5.4.6 After comment resolution, the ICAVP Project Director will approve the DR and fonvard it to NNECo, NEAC, and the NRC per the Communications Plan (Reference 2.3).

5.4.7 A summary of the NNECo response and ICAVP review of the NNECo corrective action (s) will be posted on tbc WWW in accordance with the Communications Plan (PLN 02)

(Reference 2.3).

5.5 FINAL RESOLUTION 5.4.1 If the response and supporting documentation by NNECo will resolve the Discrepancy, the Deputy Project Director will close the DR by signing t' e Final Resolution section.

5.4.2 The DR can be closed for the following reasons:

a. NNECo agrees that the DR is a new discrepant condition and Parsoic agrees with the proposed corrective action (Closed-Confirmed DR).

b. NNECo has shown and Parsons agrees that the specifics of the DR were previously identified by NNECo during CMP (Closed Previously identified).

c. NNECo has shown through providing additional information and Parsons agrees that the condition identified in the DR is no longer valid (Closed Non Discrepant).

5.4.3 If, in the opinion of the ICAVP Team, the proposed corrective at on by NNECo is not complete or is not likely to resolve the DR, the Deputy Project Director will identify the DR as an open item.

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l PROJECT PROCEDURES TITLE: DISCREPANCY "EPORTS REVISION: 5 DATE: 01/18/98 PAGE 9 OF 13 5.4.4  !!ased upon the comments prosided on the NNECo response additional information may be required from NNECo in order to close the response.

5.4.5 If after a minimum of two NNECo responses Parsons has not accepted the resolution, the DR may be classified as Unresolved. The NRC will make final detennination on the condition of Unresolved DR's.

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TITLE: DISCREPANCY REPORTS ATTACHMENT 1 REVISION: 5 DATE: 01/16/98 PAGE 11 OF 13 HEVIEW AND APPROVAL Reviewed _

Deputy Prejul Director Date Appteved:

Project Director Date Forwarded to NNLCo. NEAC, and NRC: postedto w w W:

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SUAthtARY OF NNECo PROPOSED CORRECIIVE ACTION COMMENT ON NNECo RESI'ONSE Prepared:

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Deput) Projnt Director Date Approsed:

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

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• TITLE: DISCREPANCY REPORTS ATTACHMENT 2 REVISION: 5 DATE: 01/16/98 PAGE 12 OF 13 mmamma ATTACllMENT 2 CRITERIA FOR CATEGORIT.ING Tile RELATIVE SIGNIFICANCE OF DISCREPANCIES IDENTIFIED llY Tile ICAVP e SIGNIFICANCE LEVEL 1 A discrepancy"'that identines that the system does not mcct its licensing and design bases and cannot perform its intended function, i c., has the potential to simultaneously affect redundant trains.

• SIGNIFICANCE !.EVEL 2 A discrepancy") that identifies that a single train of a redundant system does not meet its licensing and design bases and that the train cannot perform its intended p function.

• SIGNIFICANCE LEVEL 3 A discrepancy"' that identines that a system does not meet its licensing and design bases but the system is capable of perfonning its intended ftmetion.

i e SIGNIFICANCE LEVEL 4 A discrepancy") that identines that the systems meet its licensing and design bases, however, there esists minor errors such as minor arithmetic errors that do not signincantly affect the results of a calculation or incoasistencies between documents of an (Jitorial naturc.

") A discrepancy may identify programmatic, procedural, or design issues or cd;torial inwnsistencies.

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