ML20216B094

Transmits Rev 0 of Screening Criteria Which Will Be Used in Corrective Action Verification Program

ML20216B094
Person / Time
Site:	Millstone
Issue date:	04/06/1998
From:	Curry D AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUM2-PPNR-1326, NUDOCS 9804130365
Download: ML20216B094 (5)

Text

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PARSONS i

Daniel L Curry, vice Premdent Nuclear revices Parsons Energy & Chenucals Group Inc.

2675 Morgantown Road

• Reading. Pennsyivania 19G07 * (610) 855-2366

• Fax: (610) 855-2602 l

April 6,1998 Docket No. 50-336 Parsons NUM2-PPNR-1326-L ,

U.S. Nuclear Regulatory Commission j Attention: Document Control Desk j Washington, D.C. 20555 j Millstone Nuclear Power Station Unit No. 2 Lndcagliflgnt Corrective Action Verification Program (ICAVP)

Gentlemen:

This letter transmits Revision 0 of the bereening Criteria which will be used in the Corrective Action Program Review for the Millstone Unit 2 ICAVP. U. S. Nuclear Regulatory Commission review and approval of this approach is requested.

Please call me at (610) 855-2366 if you require any additional information.

Sincerely,

, , f hbl6.E4r Daniel L. Curry ef' Parsons ICAVP Project Director DLC:djv Attachment cc: E. Imbro (2) - US'NRC J. Fougere - NNECo

11. Eichenholz - USNRC Rep. Terry Concannon - NEAC R. Laudenat - NNECo Project Files > >

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o\ l 9004130365 900406 DR ADOCK 050003 6 I

I PPNR1326 doc

Millstons Unit 2 ICAVP l Tier 1 l ,

Corrective Action Program l

l The System Vertical Slice Review (SVSR) process described in PP-01 and further defined in PI-01 Exhibit 3-2, identifies objectives for the Corrective Action Program (CAP) as follows:

1. Review proposed and implemented corrective actions for Licensee-identified design deficiencies. (Confirmatory Order Action) 1

2. Verify the adequacy of the licensee's corrective actions as part of the Configuration Management Program (CMP) and in response to the Independent Corrective Action Verification Program (ICAVP) findings. (Oversight inspection Plan Actions)

3. Assess the adequacy of the licensee's effectiveness of implementation of the corrective actions developed as part of the CMP and in response to the ICAVP l findings.

l in order to achieve these objectives, and to assure the validity of the ICAVP system technical conclusions, a target population of corrective action documents has been i identified. This population contains the CMP items that require resolution or correction, ,

as well as discrepancies discovered on a continuing basis by either the licensee, the '

ICAVP contractor, or others. The overall population addressed to support the objectives of the corrective actions program includes the following.

Document type Selection Why Condition Report (CR) or Tier 1 in-scope system Verify proper Adverse Condition Report implementation (ACR)

Unresolved item Report Tier 1 in scope system - Verify that issues were (UIR) Not covered by specific effectively translated into CR/ACR corrective actions or properly dispositioned.

CR or ACR and associated Common or Generic Assess treatment of issues UIRs affecting multiple systems interfacing with the Tier 1 in-scope systems Deficiency Reports (DR) All Assess adequacy of corrective actions to ICAVP findings.

Screening of the total population existing as of February 1,1998 was used to I

determine the initial corrective actions population that would receive a detailed review.

Additional screening will be performed periodically to capture new CRs as they are issued by NNECo.

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The selection methods were as follows:

CR/ACR on Tier 1 in scope systems - Select originating documents that have safety and programmatic importance based on the criteria in the attached Corrective Action Document Selection Specification (Appendix 1).

UlR on Tier 1 in scope system - Many UIRs resulted in the initiation of CR/ACRs to properly assess and correct the deficiency that was found. These are selected through the CR/ACR process defined above and not included in this group. The remaining UlRs are screened using the Selection Specification.

CR/ACR for Common or Programmatic area and associated UlRs- The database

. for corrective actions was reviewed by Parsons to select the actions having possible direct interaction on system functionality. These typically include issues related to equipment found in multiple systems, such as relays, or processes with effects on multiple systems, such as commercial grade dedication and fuse' control.

' DRs - All DR responses will be reviewed in accordance with the PP-07 process. l Corrective actions that result from DRs will be screened in accordance with the criteria d presented in Appendix 1.

Fo! lowing application of these selection methods, the selected corrective action documents (the controlled population) will be reviewed by Parsons using a multiple question form established to direct a thorough and meaningful outcome (Appendix 2).

The review includes the actions taken to address the initial condition and any i associated causal analyses. Appropriate closure package documents will be used to confirm the proper implementation of these actions.

.I Corrective actions planned for completion after plant restart will be reviewed to validate i the acceptability of the proposed corrective action and the timing of the proposed action. Open CR/ACRs in the controlled population will be checked periodically for j closure, if closure occurs during the ICAVP, the CR/ACR closure package will be  ;

reviewed in accordance with the Corrective Action Review process.

The results of the corrective action reviews will be recorded in electronic form. If the corrective action review identifies a discrepancy in the actions taken such that the plant  ;

design or licensing basis might be compromised, a specific Discrepancy Report will be ., l initiated. Minor discrepancies (Significance Level 4), will be collected and a group DR '

1 issued via the PP-07 process.

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App:ndix 1

, CORRECTIVE ACTION DOCUMENT l

l Selection Specification l

Document Type:

Document Number:

1, is the corrective action document classified by NNECo as a Level 1 CR, or a Level A or B ACR7 if YES, a review is required.

Oyes ONo ON/A

2. Does the issue addressed by the corrective action document have significant potential of adversely affecting personnel safety or the ability of safety related equipment to perform its intended function? If YES, a review is required.

Oyes ONo

3. In the opinion of the reviewer, does the corrective a Jon document deal with a licensing or design basis issue of sufficient importance to warrant a detailed review? If YES, a review is required.

Oyes ONo

4. Does the issue addressed by the corrective action document appear to be repetitive or programmatic in nature and affect the plant licensing or design basis? If YES, a review is required.

Oyes ONo i

Note: If any of the above questions are YES a Form 4 review is required. If any of the questions are YES, the remaining questions need not be answered. If all the questions are NO or N/A, l a Form 4 review is not required, but may be performed at the discretion of the reviewer.

Parsons Reviewer- Date:

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App::ndix 2 l , Form 4 - Questions l l

1. Does the corrective action, including associated ARs, apply to the in-scope l l

i system under review? (Yes/No/NA)

2. Was the deficiency properly identified, including extent of condition? (Yes/No) j

3. Should a root cause analysis have been done? (Yes/No)

4. Was the root cause analysis done? (Yes/No/NA) i

5. Was the root cause determination adequate? (Yes/No/NA) l

6. Did the proposed resolution address the root cause? (Yes/No/NA)

7. Should a determination have been made of failure modes or the mechanism of l equipment failure? (Yes/No)

8. Was the proposed resolution clearly defined? (Yes/No)

9. Was the proposed resolution technically adequate? (Yes/No)

10. Does the corrective action, as proposed or implemented, comply with the licensing basis? (Yes/No/NA)

11. Does the resolution, as proposed or implemented, comply with tha design basis?

(Yes/No/NA)

12. Does the resolution identify configuration control elements for update?

(Yes/No/NA)

13. Has the implementation of the corrective action been completed? (Yes/No) l 14. Should the proposed corrective actions, including configuration control elements be completed before startup? (Yes/No)