ML20141G683

Forwards Discrepancy Repts DR-MP3-0007 & DR-MP3-0008, Identified During Programmatic Review Activities for ICAVP

ML20141G683
Person / Time
Site:	Millstone
Issue date:	07/07/1997
From:	Schopfer D SARGENT & LUNDY, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
9583-100, NUDOCS 9707100164
Download: ML20141G683 (4)

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Don K. Schopfer Vice President 312 209-6078 July 7,1997 Project No. 9583-100 Document No. 50-423 Northeast Nuclear Energy Company Millstone Nuclear Power Station, Unit No. 3 Independent Corrective Action Verification Program United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 I have enclosed the following two (2) discrepancy reports (DRs) identified dusing our Programmatic Review activities for the ICAVP. These DRs are being distributed in accordance with the Communications Protocol, PI-MP3-01.

DR No. DR-MP3-0007 DR No. DR-MP3-0008 Please direct any questions to me at (312) 269-6078.

Yours very truly, 2.z L D. K. Sc opfer Vice President and ICAVP Manager DKS:pah Enclosures '

i Copies:

E. Imbro (1/1) Deputy Director, ICAVP Oversight ipQ

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l Northcast Utilities ICAVP DR No. DR44P3-0007 Minstone unit 3 Discrepancy Report ReviewGroup: Programmatic DR VALID Review Element: Change Process Potential operabiuty seeue <

Diecipline:Other C Yes Discrepancy Type: Design Control Procedure b N' System / Process:N/A Date Published:

Discrepancy:Use of Unverified information l

Description:

We have reviewed Millstone Station Procedure DC 2, Rev.1, Change 3 (effective 3/3/97), titled " Developing and Revising Millstone Procedures L and Forms". Based on this review, ve have noted the following discrepancy.

When, while revising a procedure, reference information is not available, paragraph 1.2.8.b and Attachment 2 of DC 2 require the Procedure Writer to place an empty basis box in the appropriate location (of the procedure) with the following content: " Reference information not currently available."

During the procedure verification and validation process, the independent Reviewer, with the Department Head's concurrence, determines whether the document can be approved without verifying reference information. .

Thus, a procedure can be revised with unavailable reference information.

There is no review by the PORC/SORC or a subcommittee to evaluate the risk of implementing the procedure with this missing information, and no requirement is imposed to try to recreate the reference material later. This is a discrepancy because unverified information could be used as the basis i for a procedure.  !

Review .

Valid invalid Needed Date initiator: Sheppard, R. P. O O O 7/7/97 i

VT Lead: Ryan. Thomas J O O O 7/7S7 i VT Mgr: Schopfer, Don K O O O 7/787  :

IRC Chmn: Singh, Anand K O O O 7/7/97 Date:

INVALID:

Date:

RESOLUTION:

Review Accept Reject Needed Date Initiator: Sheppard, R. P. O O O VT Lead: Ryan, Thomas J O O O ,

VT Mgr: Schopfer, Don K O O O l IRC Chmn: Singh, Anand K O O O Date:

REJECTION:

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Northeast Utilities ICAVP DR N . DR-MP3-0008 l Ministone unit 3 Discrepancy Report ReviewGroup: Programmatic DRVAUD  ;

Review Element: Change Process potential operabmty issue l Discipline:Other C Yes Discrepancy Type: Design Control Procedure No System / Process:N/A l Date Published:

Discrepancy: Procedure Step Sequence ,

l

Description:

We have reviewed Millstone Station Procedure DC 4, Rev. 3 (effective 1/17/97), titled " Procedural Compliance". Based on this review, we have noted the following discrepancy.

Paragraph 1.4.1 of procedure DC 4 allows, for continuous or general level '

of use procedures, unless otherwise stated in the procedure, a First une '

i Supervisor or, in the case of operations procedures, the Shift Manager or Unit Supervisor to authorize deviation from the specified step sequence, as long as the intent of the procedure is neither changed nor compromised.

l This is not consistent with the standard industry approach for continuous use procedures, especially for operations procedures.

I Continuous level of use procedures as defined in Attachment 1 to DC 4 are '

procedures which " . require step-by-step use to prevent immediate effects j on nuclear or personnel safety ..." l l The continuous use procedure steps should be performed in the sequence l stated in the procedure. See, for example, XVI.C.2.0 of INPO Guideline 85-l 017, Rev. 2, titled " Guidelines for the Conduct of Operations at Nuclear i Power Stations", which states in part: " Training on this sequence, reinforced l with procedures that show the same sequence, will serve to improve operator performance by development of pattems of action that are more easily remembered. If a procedure step must be performed out of the sequence specified, a procedure change should be completed prior to performing the step unless the procedure specifically states that the step l may be performed in any order" l l

In addition, paragraph 5.2.3 of INPO Preliminary Good Practice OA-106 titled " Technical Procedure Use and Adherence", which is referenced in DC l 4, states: "The policy (on procedure use and adherence) provides direction  !

for performing some technical procedures in other than the normal step-by- I step manner and identifies conditions requiring procedure changes. For l l example, procedures that allowlimited portions to be performed or the i, sequence of steps to be changed will include specific instructions on the conditions under which this use is appropriate. Otherwise, procedure changes are required to be initiated and approved prior to performance of the limited portions of the procedure or changing the sequence of steps."

Review I

Valid invalid Needed Date l Initiator: Sheppard. R. P. O O O 7aS7 VT Lead: Ryan. Thomas J O O O 7aS7 VT Mgr: Schopfer, Don K O O O 7"S7 IRC Chmn: Singh, Anand K O O O 7aS7 Date:

INVAUD:

Pnnted 7aS7 321:19 PM Page 1 of 2

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Northeast Utilities ICAVP DR No. DR-MP3-0008 Millstone unit 3 Discrepancy Report Date:

RESOLUTION:

Review Accept Reject Needed Date initiator: Sheppard, R. P. ,

VT Lead: Ryan, Thomas J @

VT Mgr: Schopfer, Don K g IRC Civnn: Singh, Anand K O O -

Date:

REJECTION:

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