ML20137N890

Independent Corrective Action Verification Program Millstone Unit 2 Audit Plan

ML20137N890
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Site:	Millstone
Issue date:	04/03/1997
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ML20137N877	List: ML20137N871 ML20137N890 ML20137N906 ML20137N911 ML20137N921 ML20137N937 ML20137N947 ML20137N955 ML20137N964
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PROC-970403, NUDOCS 9704090083
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/U AARSONS POWER INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM MILLSTONE UNIT 2 AUDIT PLAN Revision 0 0

Prepared By:

Date: April 3,1997 Deputy Project Director Approved By:

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Date: April 3,1997 h%nagqK Company Quality Program Approved By:

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MILLS'IDNE 2 AUDIT PLAN I

REVISION LOG l

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I This 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.

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MILLSTONE 2 AUDIT PLAN 4

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MILIATONE UNIT 2 ICAVP AUDIT PLAN

,O' TABLE OF CONTENTS Section Illie P.ast i

1.0 INTRODUCTION

1-1 2.0 OBJECTIVES 2-1 3.0 ORGANIZATION 3-1 3.1 Team Member Responsibilities 3-1 3.2 Advisory Panel 3-4 3.3 ICAVP Oversight Team 3-4 3.4 Assignment of Staff 3-6 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) 4-9 O

4.3 Process Review (Tier 3) 4-14 4.4 Regulatory Review 4-22 4.5 ICAVP Acceptance Criteria 4-24 4.6 Project Procedures 4-25 5.0 EVALUATION OF FINDINGS 5-1 5.1 Identification of Findings 5-1 5.2 Reporting of Findings 5-3 5.3 Review of Proposed Corrective Action 5-3 i

l 6.0 ICAVP FINAL REPORT 6-1 6.1 Compile and Assess System Reports 6-1 6.2 Review of NNECo Findings and Correctiu Actions 6-1 6.3 Prepare ICAVP Final Report 6-2 6.4 Issue ICAVP Final Report 6-2 7.0 SCHEDULE 7-1 l

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MIIIJiTONE UNIT 2 ICAVP EXIHBITS 1

EXHIBIT NO.

TITLE PAGE 3-1 ICAVP Project Organization 3-2 4-1

Approach to ICAVP 4-2 4 System Vertical Slice Review 4-5 4-3 AMSR Critical Design Characteristics 4-11 4-4 Critical Safety Function Diagram 4-13 1

4-5 Process Review 4-16 4-6 Regulatory Review 4-23 4-7 Project Procedures 4-25 5-1 Evaluation of Findings 5-2 7-1 Project Schedule 7-2 f

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1.0 INTRODUCTION

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'Ihe purpose of the independent Corrective Action Verification Program (ICAVP) is 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 systemt 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 documentati m, 3.

Verification that the design and licensing bases have been translated into h

operating procedures, and maintenance and test procedures,

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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 throup. 2e following audit activities:

Vertical Slice System review of selected systems (Tier 1)

Review cf Accident Mitigation Systems (Tier 2)

Review of various design change processes (Tier 3) e h

Regulatory Review

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2.0 OBJECTIVES v

The objective of the ICAVP, as stated in the August 14,1997 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 management oversight, that NNECo has:

Identified and satisfactorily resolved existing non-conformances widi the design and licensing bases, Documented and utilized the licensing and design bases to resolve nonconformances, Established programs, processes, and procedures for effective configuration management in the future NNECo's programs include efforts to identify and understand the root causes of the licensing and design basis issues that led to NRC issuance of the 10 CFR 50.54 (f) letters to NNECo and implementation of corrective actions that will ensure that NNECo will 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 systems that it has categorized as either Group 1 (safety-related and risk-significant) or Group 2 (shfety-related or risk significant), using criteria developed in carrying out the Maintenance Rule. The ICAVP audit will provide insights into the effectiveness of the Millstone Unit 2 programs so that the results can be reasonably extrapolated to the structures, systems, and components that were not revbwed in the ICAVP audit.

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O 3.0 ORGANIZATION L

ne 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 Advisory Panel ICAVP Oversight Team Assignment of staff e

3.1 TEAM MEMBER RESPONSIBILITIE!i The Millstone 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 NRC, and the State of Connecticut.

Deputy Project Director ne 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, f3

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Exhibit 3-1 MILLSTONE 2 - ICAVP PPROJECT ORGANIZATION f

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F Group Leaders He 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.. ney will be actively involved in the i

performance of the work in their respective project areas. Group Leads will be assigned for each of the following project areas:

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

Accident Mitigation System Review - Tier 2 Process Model and Design Control Review - Tier 3 Licensing and Risk Assessment Project Support Core Team Personnel He Core Team has been selected based upon experience and particular areas of expertise. They are responsible for the performance of the systems audits, regulatory compliance reviews, process modeling, document review, technical research and the generation of the necessary reports in their respective areas. These personnel work i

directly for the Group Leaders. The mechanical, structural, civil, electrical and instrumentation engineers have been selected because of their expertise in nuclear F

plant designs, modifications, assessments and programmatic kimwledge. The operations support personnel bring specific experience in operations, maintenance, procurement, configuration management and regulatory compliance. Industry 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.

J Support Resources Support re purces work for the Group Lead for project support and provide the following support functions for ICAVP activities:

Scheduling and Project Controls Administrative / Clerical Information Services

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e 3.2 ADVISORY PANEL An advisory panel of industry experts will assist 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 panel or selected members of the advisory panel based on the activity being performed.

3.2.1 Responsibilities The Advisory Panel will have the following responsibilities:

The Advisory Panel (AP) provides advice, expert technical opinions and review services to the ICAVP Audit Team, and consulting services to the ICAVP Oversight Team.

The AP will review the ICAVP Final Report and the individual reports from the o

various inspections and audits performed by the ICAVP Audit Team (s).

U ne AP will review and comment on all findings, and NNECo's proposed e

corrective actions.

The AP will review all Differing Professional Opinions 3.2.2 Mnal Conclusions The AP will prepare a portion of the Final Report documenting their observations and opinions.

3.3 ICAVP OVERSIGIIT TFAM in order to provide additional confidence that the ICAVP is performed competently, objectively, and independently, Parsons has formed an ICAVP Oversight Team (IOT).

ne IOT in a manner similar to a Board of Directors will review, question, advise, and assist the ICAVP Audit Team as necessary to achieve the successful and professional execution of this program. The IOT is an internal Parsons organization reporting to Parsons management to ensure that the ICAVP meets all of the process requirements and objectives specified in the NRC's Confirmatory Order. The IOT will be co.mposed Audit Report Revision 0 3-4 April 3,1997

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of persons having financial independence from Northeast Utilities and its subsidiaries, U

and independence from the designs, programs, and plant hardware being evaluated under the ICAVP. Three members are required to be present at each official meeting.

3.3.1 Rampondidlities He IOT will have the following responsibilities:

The IOT will receive briefings to provide the necessary background on the objectives of the ICAVP and the processes under which it will operate. The information will include NRC inspection and licensing correspondence and the confirmatory order as well as NNECo documents summarizing the results of internal assessments and planned corrective actions on relevant activities.

The IOT will review the independence and qualifications of the ICAVP project personnel to confirm that the criteria specified by the NRC Confirmatory Order have been satisfied. The IOT will be briefed on the procedures established to implement ICAVP work in order to understand how program and process objectives will be accomplished, i

The ICAVP Project Director will arrange for the IOT to receive periodic e

briefings to provide them with a basis for assessment of the verification process as it proceeds and the opportunity to provide timely consultation. Particular attention will be given to the criteria for acceptance of conditions verified to be

" acceptable", the criteria for expansion of the verification sample, and the basis for close out of specific issues as being adequately verified. To the extent possible, the IOT should evaluate the technical decision-making being done by ICAVP personnel. Since the IOT process is one of oversight and recommendation, rather than direction, all recommendations from IOT will be documented.

3.3.2 Repods The IOT will complete their activities by preparing a brief report which summarizes the IOT's conclusions concerning the ICAVP findings. His will be made part of the ICAVP final report. The IOT may be requested to participate in public meetings on the ICAVP.

Audit Report Rension 0 3-5 April 3,1997

I 3.4 ASSIGNMENT OF firrAFF All personnel assigned to the project, either Parsons employees or consultants, will be evaluated for their i@he from Millstone Unit 2 design or design review 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 j

(NAEC)]. All personnel changes or substitutions will be handled in accordance with Project Procedure PP4, " Substitution or Addition of Personnel". 'NRC notification is required for all personnel substitutions, additions or replacements.

3.5 LOCATION OF WORK The i filistone Unit 2 ICAVP Project Team will perform the majority of their work in the Parsons Power Reading, Pennsylvania offices. A small offsite office j

j located near Millstone Unit 2 will be maintained to support site walkdowns, interviews, scheduled meetings and document retrieval. Millstone Unit 2 ICAVP Audit Team personnel will visit the offsite office and Millstone Unit 2 as i

required to support ICAVP information needs.

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' /O 4.0 APPROACH TO 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 issued as an attachment to SECY 97-003. The scope of the ICAVP Audit will provide confidence that Millstone Unit 2 conforms to its design and licensing bases through the following activities:

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

The 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 modifications made to the selected systems since initial licensing. In addition, the inspection will examine the thoroughness of the Millstone Unit 2's Corrective Action Plan for identifying potential nonconformances with the design and licensing bases. The system reviews will be based in s

part on guidance provided by NRC Inspection Manual Chapter 2535,

" Design Verification Programs" and Inspection Procedure 93801, " Safety System Functional Inspection".

Review of Accident Mitigation Systems (Tier 2)

The Tier 2 review will evaluate " Critical Design Characteristics" for Millstone Unit 2 accident mitigation systems. The Critical Design Characteristics, which can be at the system level and/or component level, are defined by a review of accident mitigation systems requirements, that assesses critical design characteristics for systems and components to ensure that they can perform their specified safety functions.

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l 4 O Review of Various Design Change Processes (Tier 3) b i Tier 3 will provide a basis for an indqwakt determination of whether )

Millstone Unit 2 design control processes'and procedures have been

~ established for effective configuration management on a going-forward basis. To help make this determination, process modeling will be used to assess the' current processes used to change the facility design or change a the characteristics, procedures, or practices for maintaining, operating, l testing, and training on safety or risk significant systems, structures, and { ~ components. The Tier 3 review will also verify the adequacy of the programs currently being implemented by NNECo which are directed at identifying and resolving existing design and configuration management deficiencies associated with past change processes. This will be accomplished by a " horizontal slice" inspection of examples of past changes to the facility design, practices, and documentation. Regulatory Review Selected Millstone Unit 2 Regulatory documents will be reviewed and summarized. The summary will key on required licensee actions, a review of the licensee docketed response, and a review of the current Updated Final Safety Analysis Report. Specific items identified will be validated within the System Vertical Slice Review (Tier 1), Accident Mitigation t System Review (Tier 2), or Process Review (Tier 3), as appropriate. 4.1 SYSTEM VERTICAL SLICE REVIEW (Tier 1) The objective of the System Vertical Slice Review (SVSR) inspection of the 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 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 Millstone Unit 2*s Corrective Action Plan for identifying potential nonconformances with the design a.ul licensing bases. l -mm-I Audit Plan Rension 0 4-3 Apru 3,1997 l i l

i p Selected systems will be reviewed in depth, including design bases, impact on design V bases by system modifications, safety margins, maintenance, operations, surveillance, trair.ing, and corrective actions for previously identified deficiencies. The system reviews will be based in pan on guidance provided by NRC Inspection Manual Chapter 2535 " Design Verification Programs" and Inspection Procedure 93801 " Safety System Functional Inspection". 1 The SVSR will be performed as shown in Exhibit 4-2. Project Procedure PP-01 " System Vertical Slice Review" will be used to perform the inspection. Conduct of the SVSR is based on the activities noted below and discussed in the following paragraphs: Select System for SVSR Prepare System Specitic Checklist = Conduct the SYSR Prepare SYSR Final Report e 4.1.1 Select Systems for SVSR J Ag Parsons Power Group has developed criteria for NRC use in selecting systems for the vertical slice review. He 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 on 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. De Parsons Tier 1 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). (' i Audit Plan Revision 0 4-4 April 3,1997

Exhibit 4-2 SYSTEM VERTICAL SUCE REVIEW idevey System Identify System. M Boundaries Y Cornpanents U Current and Fheere System m Orgpinal Licensing Basis 4 W Pmoess g Detennhanon and Targets Phase 1 Regutetery Requirements inpA Syelem Selecean System Specme Tier 2 input 4 4 NRC Chechnet Draft Cruscal Design j( Characterielles i Tier 3 Input I Process Model & Guldence 1 I OK STATUS AN YES Has DB been NO 4 Checidist Finahzed A Conduct inspecDon + m U l .U E FINDI i D FINAL REPORT l >3- .o 1 l l l i.. - ~

f~Y Parsons will consider a' system as a likely candidate for an SVSR if the system. q V J Has experienced a high number of modifications. e 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. J Has a high level of risk significance based on PRA insights as determined by a - panel of individuals familiar with the Plant PRA. Has an identified history of deficiencies or operating problems based on plant or industry operating experience. He 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. De NRC Expert Panel should bias their weighting for the selection of O systems using consideration of issues identified as part of the August 14,1996 U confirmatory order. Additional detail on system selection criteria is provided in PP-01, System Vertical - Slice Review Procedure. 4.1.2 Prepare Systan Specific Checklist The inspection team will review and assess pertinent design and operational aspects of the selected systems, using checklists based on functional system and design 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. o He 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 l group. Hey will be developed following the announcement of system selection. The checklists will stipulate inspection conditions for each inspector and will include \\ -mm-Audit Plan Revmon 0 4-6 April 3,1997 i

inspection targets, validation, and verification requirements, and details of the current ~ and original license bases, system history and configuration. 1he SYSR Team will use the checklists to guide the inspection process during major inspection activities such as: i e Document and calculation review Personnel interviews e System walkdowns 1 4.1.3 Conduct the SYSR 4 t The system vertical slice review (SVSR) will entail a comprehensive engineering review of the selected systems by a team of mechanical, electrical, instrumentation & control, maintenance and operations specialists. The team, supported by a staff of i regulatory and nuclear licensing specialists, will employ a broad based but focused i j examination process of sufficient depth to probe all aspects of the selected systems i design, history and configuration. Emphasis will be on verifying that the subject systems processes, practices and t procedures used to perform engineering design, design change control document ( 3 control and records updating of the design bases have been successful in maintaining the system configuration in accordance with regulatory requirements. b The SVSR Team will provide ongoing reports which will detail the status, on a system specific basis, of the progress of the SYSR for each of the selected systems. As i potential findings are identified during the review, they will be immediately communicated to management for evaluation. Each potential finding will be provided i with a complete description, including all pertinent information per the requirements of Project Procedure PP47 " Evaluation of Findings". The anticipated sample size of 4 systems for the SVSR is predicated on the assumption that the assessment will not find significant defects. Additional systems may be added to the SYSR if the number of defects encountered during the SVSR meet the specified criteria for Tier i expansion. 5 - M PM - Au&t Plan Revmon 0 4-7 AprH 3,1M

. - ~.. i 4 he vertical slice reviews will emphasize design control and will verify that: De current configuration accurately reflects the licensing-bases, incicding the updated FSAR. Calculations and analyses were performed using recognized and acceptable analytical methods and that assumptions made in calculations or analysis supporting changes are technically sound. ne re a of calculations or analysis supporting the unmodified portions of the original configuration and design changes are reasonable (based on engineering 4 judgment) for the scope of the change. Millstone Unit 2 considered the effect of a change on design margins and that the design changes received the appropriate level of engineering and management review during the design phase and prior to implementation. Millstone Unit 2 considered the effect of a change on pre +perational, startup or i system baseline acceptance test results. Design changes are accurate ly reflected in operating, maintenance, and test procedures, as well as in training materials. Proposed design changes, subsequently canceled, were not replaced by procedural changes that imposed excessive burdens on plant operators. l Adequate control of operational procedures, maintenance procedures, test and i surveillance procedures, operator training and control of the plant simulator configuration. ne current configuration is consistent with the licensing bases at the level of detail contained in piping and instrumentation diagrams (P&lDs) or system flow diagrams, piping isometric drawings, electrical single-line diagrams, and emergency, abnormal and normal operating procedures. De analyzed configuration is consistent with the current pli, :onfiguration. 4 J k _, s.s _. _ Audit Plan Revision 0 4-8 Apnl 3.1907 - ]

l l 1 Equipment location and identification numbers are as indicated on the P&ID or [ process flow diagram, and equipment name plate data is consistent with design specifications and analyses. 1 De location of pipe supports, snubbers, and other pipe restraints is consistent e with design specifications and piping stress analyses. Divisional separation of safety-related systems, structures and components, i i-seismic II/I, and other topics addressed by the licensee's hazards analyses are reflected in the current plant configuration. i 4.1.4 Prepare SYSR Final Report L A comprehensive Final Report will be developed by the entire SVSR Team. The Final Report will summarize the results of each system reviewed r;xi will contain the details of all findings. Included in the report will be an assessment of the Millstone Unit 2 design process and adequacy of the configuration management program. The system final report will consist of, as a minimum, an executive summary, a detailed description of the review results, including the areas reviewed and the findings noted. The SVSR Final Report will be included in the overall ICAVP Report. 4.2 ACCIDENT MITIGATION SYSTEMS REVIEW (Tier 2)

he Tier-2 portion of the ICAVP is dedicated to the determining and verifying the

" Critical Design Characteristics" for the Millstone Unit 2 Plant. The Critical Design Characteristics, which can be at the system level and/or the component level, are defined by a Tier 2 review of accident mitigation systems requirements, that assesses 4 critical design characteristics for systems and components to ensure that they can perfor;n their specified safety functions, i The characteristics will be reviewed in depth, including calculations, analyses and other documentary evidence that supports its definition. 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." t = b - paussesreams - - Audit Plan Revraon 0 4-9 April 3,1997 i i , _,. f

l O Assessment of the critical design characteristics for the accident mitigation systems \\ will be performed in accordance with Project Procedure PP-02 " Accident System Mitigation Review." Exhibit 4-3 presents a summary of the review process. 'Ihe accident mitigation systems review (AMSR) consists of the following major activities: Identification of Critical Design Characteristics Preparation of Composite Chr.racteristics Matrix e Assessment of Current Critical Design Characteristics e Preparation of AMSR report e 1 J 4.2.1 Identification of 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 risk of an accident. Chapter 14 of the updated Final Safety Analysis Report (FSAR) is the description of all credible accidents that must be addressed in the design of the facility. This document has been selected as the license benchmark source, or that point where all changes that affect the ability of the plant to meet the critical function have been captured. Based on this review, the DBEv are as identified as: Increase in Heat Removal by the Secondary System Decrease in Heat Removal by the Secondary System Decrease in Reactor Coolant System Flow Reactivity and Power Distribution Anomalies e Decrease in Reactor Coolant Inventory Radioactive Release from a Subsystem or Component Non-Standard Review Plan Events 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 interfaces have been identified. For mU Audit Plan Revision 0 4-10 April 3,1997

1 4 Exhibit 4-3 s 1 AMSR CRITICAL CHARACTERISTIC i .+ y .... k- ] OmptergE (DBEv)) 'L. 1 b l

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% 3: Review If KeyPamvers IdentifyOitical mai,omrameristics l L Foreach DBEv lf Vaification CDCs hepareAMSR4. > Tur-3 CNF ' 2 nu8ran muitheir'msimenance Repat Ns Audit Plan Revision 0 4-1I April 3,1997

4 example,' if the Critical Function is to deliver water to the reactor, then there will be 4 critical actions m y in the delivery system to the reactor, the source of the water, the motive power for delivery and the cree of the motive po_wer. . A critical function diagram will be developed for each of the DBEv presenting the i active functions that must be executed versus the DBEv versus the plant configuration. An example of such a critical function diagram is shown in Exhibit 4-4. This set of I conditions will be the bases for identifying and developing Critical Design Characteristics to be met by the plant. 4.2.2 Prepare Composite Characteristics Matrix [ A critical design cha.racteristic is defined as that aspect of a component or system that must be inherent in the design to ensure that the component or system will meet the l safety commitment identified in the commitment criterion. 'Ihere will be very few if 4 any components or systems that have only one critical design characteristic. The system characteristics are an accumulation of the system design characteristics, the system's components critical characteristics, coupled with the plant configuration at the time of the DBEv. Thus it is expected that there will be several different design g characteristics that must be met at different times and for different situations. These characteristics will be determined based on the existing information contained in the licensing design bases for Millstone Unit 2, and from other regulatory information that applies to the type of plant. i The following list represents a core group of documents that contain a significant amount of information about the critical parameters for the plant: Updated FSAR for Millstone Unit 2 Safety Evaluation Report for Millstone Unit 2 e System Design Bases Documents e Probabilistic Risk Assessment for Millstone Unit 2 Technical Spa:ifications for Millstone Unit 2 e Combustion Engineering Owners Group Documents System Design Calculations e l System Design Descriptions i ( - renssesreu s - t Audit Plan Revision 0 4-12 April 3,1997 I

p Exhibit 4-4 V CRITICAL SAFETY FUNCTION DIAGRAM Lens of Feedwater Flow C 4 RCS Pressure f. Reactmty ht het laventary Control Control Ln u n a. u O' .O,,,.'- m':T' *."f., Oo""" T" T-' s A Component Critical b Design Criteria It will be necessary to review each of these documents to ensure; 1) continuity across the documents, 2) Determining the root document that defines the critical parameter of function, 3) to ensure that the accident mitigation system 1 critical design characteristic have been captured; 4) assumptions made in calculation have been confirmed as being in place in the field; and, 5) Results of calculations are appropriate and reasonable and that the techniques used are valid. The Audit Team will be divided into two groups. Group I will review the DBEv and derive the critical safety ftmetions followed by the critical actions and critical safety parameters. Group 2 will review the accident mitigation systems to identify the critical design parameters and characteristics that have been incorporated. This will allow an independent check of the results of the groups when the information is compared. Differences between the two groups of data will be evaluated and compared against the results from the NNECo corrective action programs. Where differences exist between the AMSR results and the NNECo results, potential findings will be i prepared. ( M/ - PMGMB M - t Audit Plan Revision 0 4-13 Aprii s.1997

l A listing of the critical design character'stics will be prepared. His lisths of critical design characteristics will be the soerce data base to be used by the Review Team for the systems that will be covered in the SVSR and AMSR process. I 4.2.3 Anasemment of Current Critical Design Characteristks ne validity if the critical design characteristic will be verified to show that the current configuration reflects the design bases. Verification will be based on several methods and will include review of calculation, alternate calculations, test data, inspections or a combination of methods. All discrepancies will be documented. Another aspect of the verific4 ion program is to penorm a field inspection including a review of operations procedures, maintenance procedures and surveillance and testing procedures. TLa data developed in the previous activities will be used to develop a set of checklists that identify the key characteristics and conditions that will be evaluated at the plant site. The will include such items as physical condition of components, environmental conditions, maintenance practices and methods, and accessibility for testing. O His validation part of the process is independent of the one performed by the SVSR Team. Those characteristics associated with the systems being reviewed by the SVSR Team will not be part of this validation process. He results of SVSR Team vertical l Slics audit will be used to augment the results of the AMSR Team. 4.2.4 Perparation of AMSR Report A comprehensive 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 and the results of determining its current condition and how it is being maintained. The AMSR Report will be included as part of the ICAVP Final Report. 4.3 PROCESS REVIEW (Tier 3) The process review will provide a basi:: for an independent determination of whether Millstone Unit 2 processes and procedures have been established for effective configuration management on a going-forward basis. To help make this Audit Plan Revision 0 4-14 April 3,1997 =___-____-___- __-__ - __-__________ __________ - _-_______ __-________

determination, process modeling will be used to assess the current processes used to ) change the facility design or change the characteristics, procedures, or practices for i maintaining, operating, testing, and training on safety or risk significant systems, q structures, and components, i-Process modeling will be employed to provide a visual representation of the various change processes, he model will be used as a tool for assessing the effectiveness of - the change processes in controlling the plant's configuration and maintaining the design and licensing basis. The model will help in the identification of any potential process weakness, or areas least tolerant of error. A process model is also an effective media to document the process review and communicate its results. I De second objective of this portion of the audit is to verify the adequacy of the programs currently being implemented by NNECo which are directed at identifying ) and resolving existing design and configuration management deficiencies associated with past change processes. His 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 4 and is a technical review to determine if: I Changes to the plant meet the current design and licensing basis documentation, Design and licensing basis requirements have been translated into operating, e maintenance and testing procedures. l De performance of modified systems / components has been verified through testing. 4 ) Exhibit 4-5 illustrates the Process Review steps. De Process Review of Millstone Unit 2 processes and procedures will be performed in accordance with Project Procedure PP43 " Process Modeling, Analysis and Review". Conduct of the Process Review is based on the activities noted below and discussed in the following sections. [ Initial Process Modeling i e Model Finalization and Assessment Program Verification Process Review Report i s mm-Audit Plan Revmon 0 4-15 Aprit s.1997 I i h -n, , +. vw-.- .e n ,w r r

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V] g 4.3.1 Initial Process Modeline The current change processes will be assessed using a 4-dimensional process modeling and analysis technology. 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 these aspects of how work is accomplished: Activities - a description of the work step. Supports - people (job title), tools, and hardware / software used to perform the activity. Information/ Product Flow - information and documents that input to an activity and the output as the result of the activity. This includes forms, reports, design documents, test results, data sources, data storage, etc. Controls / requirements - 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 O culture, experience, etc. V Initial models will be prepared of the various change processes based on the review of current procedures and other available documentation. The initial models will be high level depictions of how changes to facility design or plant characteristics are accomplished and controlled. The initial models will be used to select some of the change processes for more detailed investigation and analysis, and as input to the preparation efforts for the System Vertical Slice Reviews. To prepare for development of the initial process model, the ICAVP Team will review procedures that control or interface with various change processes: Major plant modifications Minor modifications Jumper, lifted lead, and bypass control e Setpoint changes Design and licensing document change control Computer software changes Verification of aebuilt conditions O-Suncillance testing d -n Audit Plan Revmon 0 4-17 Apru 3, M7

1 1 i f Design control ( Identification and evaluation of synergistic effects j Verification / tracking of design assumptions e Document identification and retrieval j e Configuration control e Drawing control. i Development and change control of plant operation procedures Development and change control of plant maintenance procedures Process for determining if an activity is maintenance or a modification. i e Corrective action Procurement and control of equipment for modifications e Evaluation, procurement and control of replacement and spare parts [ e. Commercial grade parts dedication f Vendor manual update / changes s Organization charts will be reviewed to help understand the orgamzational structure that manages, performs, and supports the change activities. These would include the i design and configuration entities, internal and external design interfaces, and other ' r non-design organizations that can impact the plant configuration, or the design and f licensing basis. The initial, high level depiction, process models will include representation of: i l general activities that are performed, e I l-the controls on the activities, e 1 A the information and documents produced, e the source and repository of the information/ documents, e the organizations that perform or support the change activities, and e interface organizations along with the interface communication information. e The initial models will be provided to the System Vertical Slice Review (SVSR) Teams as input to their preparation efforts. The information contained in the models will help familiarize the SYSR Teams with the source and repository of information/ documents, the kind of documentation produced as a result of change activities, the organization responsible for various parts of the change process, and a - general understanding of the kinds of change processes that exist at Millstone Unit 2. 'Ihe initial process models will also identify potential weakness or areas least tolerant - reassusreuss - Audit Plan Revmon 0 4-18 Aprii 3,1997

f of error that will be considered when selecting review areas within the systems chosen for the SYSR. 4.3.2 Model Finalization and Assessment Some of the change processes will be chosen for further investigation beyond the initial, high level, process model. The activities in the selected processes will be " decomposed" to show more detail on how an activity is accomplished. In turn those process steps will also be decomposed to show further detail to a level of detail needed to understand the process and determine if it will produce the desired results. The change processes chosen for further investigation will be selected based on: Any potential weak areas or areas least tolerant of error identified in the initial model. Past industry problem areas. Processes that have changed significantly since plant shutdown, Potential weak areas identified as part of the System Reviews, e Obtaining a good cross section of the various change process types. e ( The model detail will be expanded for the chosen change processes by obtaining further information from Millstone Unit 2 procedures, instructions, documented practices, information system descriptions, information database structure descriptions, and licensing commitment documents. In addition, structured interviews with NNECo personnel will be used to obtain process information that the ICAVP Team did not find in the documentation, or was not clear. 'Ihe interview i.s.onducted by at least two ICAVP Team members and follows a strict methodology for gathering information on each of the four process dimensions. These interviews will conducted in accordance with the Communications Plan (PLN-2). The process model elements are developed during the interview, which enables the interviewee to validate that the information has been captured correctly. The ICAVP Team members conducting the interview will be familiar with the process modeling technique and the subject matter to be modeled. The process model expert is experienced with effective process design and is skilled in how to obtain process information from individuals who perform the work. The subject matter team member has experience in the process being investigated. This person mxierstands terminology, regulatory requiremmts, and ) typical pr6olem areas, and can ask the right questions in terms that the interviewee ) v l Audit Plan Revsion 0 4-19 April 3,1997

..~ ~ l (~ can relate to. In addition, this person's experience helps him to discern what is being told to the team and to relate it into the process model. De information obtained from document reviews and interviews is used to complete i the process models. As a model is completed, an assessment effort will determine if the current process and procedures can effectively control facility design and changes to the characteristics, procedures, or practices for maintaining, operating, testing, and training on safety or risk significant systems, structures, and components. The assessment will focus on process effectiveness, i.e., is the right thing being done with the right resources, and are appropriate controls in place to produce the desired j t results? The assessment will identify any process problem areas as well as critical areas where the process may be weak, or where the impact of errors is the greatest. The process assessment will evaluate: Process Related Issues - e.g. fragmented activities with interface gaps, missing activities, overly complex process Organizational Issues - e.g. proper organizations not identified for interface, e review, or approval, matrix organization conflicts, span of control problems Information issues - e.g. lack of needed information, conflicting information, I ( e information distributing problems, information securhy Management Control Issues - e.g. conflicting controls, no controls, over control l e so there is no accountability, incorrect controls or overly complex that activities are bypassed, commitments not applied to proper activities Quality Issues - e.g. missing quality indicators, inappropriate or no metrics, lack o of timely error identification and correction, lack of performance reporting Resource / Support Issues - e.g. lack of sufficient people or skills, lack of support accountability, poor human factors 4.3.3 Program Verification j A review will be performed on a sample of past change documentation and the resulting plant configuration, maintenance, operations, testing, or training changes. The review will look for: Unrecognized modifications to the plant Departures from the plant licensing or design basis documents Acceptable documentation of the results of the change and its basis. e - Nx=s - Audit Plan Revmon 0 I 4-20 April 3,1997

-~- - His review is not an evaluation of previous change processes used in the past, but l rather a review to determine the effectiveness of NNECo's recent efforts to identify and correct design or licensing basis deficiencies that may have resulted from the j ineffectiveness of past change processes. His is a "out-come" based comparison of - 1 the current conditions versus the current design and licensing basis. A sample of the various change processes identified during the process modeling 1-effort will be reviewed. De sample will consist of the changes that have been made to the systems chosen for the System Vertical Slice Review, plus additional changes on safety or risk significant systems, structures, and components that may be needed to ensure that each of the various change processes are included in the sample. The methodology, documentation requirements, depth of review, walkdown ) inspections, etc. for this program verification review is similar to what is described in j the System Vertical Slice Review procedures except this review is focused on changes i instead of systems. I l 4.3.4 Process Review Activity Report ne Process Review Activity Report will contain models that illustrate the existing processes for configuration and design basis control, and for insuring that design changes are accurately reflected in operating, maintenance, and test procedures as l well as in training materials. He report will contain a summary of the process analysis results, which would identify any findings or concerns regarding process breakdowns, potential weak areas, areas that are least tolerant of errors, lack of process ,i j measurements, etc.. He report on the process modeling and analysis results will be a major input to an independent determination of whether Millstone Unit 2 processes and procedures have been established for effective configuration management on a going-forward basis. ne report will also document: The sample of the various change processes selected for program validation De review methods used for assessing the changes j a. Any assumptions made in performing the review 1 A description of the results of the validation including any independent Calculations or analysis performed _, names, j Audit Plan Rensson 0 4-21 AprH 3,1997 I

i f 4.4 REGULATORY REVIEW { I 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). He Regulatory Review will include commitment identification and validation during the System Vertical Slice Review (Tier 1) or Critical Characteristics r Determination (Tier 2) as appropriate. His review will provide additional insight into NNECo's compliance with the current licensing basis at Millstone Unit 2. 1 The Regulatory Review will be performed as shown on Figure 4.6. The Regulatory Review will be performed in accordance with Project Procedure PP-04 " Regulatory Review" He Regulatory Review consists of the following main activities: Identify regulatory requirements, Millstone Unit 2 applicability and specific . commitments identified on the docket 1 Commitment / requirement validaten tw ?.91"one Unit 2 e Prepare Summary Report of Regulatory Review 3 4.4.1 Identify Regulatory Requirements. Applicability and Commitments i i Specific regulatory documents will be included in the Regulatory Review if they are applicable to Millstone Unit 2. Key documents to be reviewed include: ) e NRC Bulletins e NRC Generic Letters j Safety Evaluation Reports associated with License Amendments e Other Safety Evaluason Reports (not associated with License i e Amendments) NRC Notice of Violations Millstone Unit 2 Licensee Event Reports e All documents in each of these categories will be screened for applicability as part of the review. Documents relating to certain programmatic areas such as security, emergency response and planning and quality assurance will not be reviewed as part of this program. Additional details of the screening process are provided in the project procedure for performing the Regulatory Review. -nasassesum-i Audit Plan Revmon 0 4-22 Aprii s.1997 l l m er y v

~ M 44 REQUt.ATORY REVIEW l 1-l Wenwy& .\\ Regulatory J. Deewesase em j l 7 Y I Summertse nn senses Seegen t,8 4 u %= CenAgerecen Chenoser I "~ m sessen 2.s seassa Manatene 2

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,r Ver#y C-e Physised eene wesen e e peewment chenee e impasmensesen ir Does Document & gg NO Perward w For corrective 4 g Action YES ,r l Compiele RM Seeden 40 u system Vertneeden ,r RR RR R*P='t N-d Audit Plan Revmon 0 4-23 April 3,1997

I Each applicable document will be summarized. Th s summary will key on required licensee action. In addition, the licensee's docketed response will be reviewed and summarized. This summary of the response will focus on licensee's commitments. For each applicable document, a review of the current Updated Final Safety Analysis Report 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 Commitment /Requimnent Validation Specific commitments identified during the Regulatory Review will be validated during the Millstone Unit 2 ICAVP. The validation will be performed within the System Vertical Slice Reviews (Tier 1), Critical Characteristics Determination Review (Tier 2), or Process Review (Tier 3), as appropriate. Summary and conclusions of the validation. efforts will be provided in the Regulatory Review Report. 4.4.3 Prenare Summary Resort of Rerulatory Review A report will prepared summarizing the results of the Regulatory Review perforr ed as part of the Millstone Unit 2 ICAVP. A summary will be provided for each area listed in Section 4.4.1 completed during the Regulatory Review. In addition, each of the completed Regulatory Review Summary Forms will be provided. 4.5 ICAVP ACCEPTANCE CRITERIA Acceptance criteria for the successful completion of the ICAVP audit are noted below. Based on ICAVP findings, 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 determination if the unit had been in operation. No issues are identified in which plant modifications, procedure changes, or operational setpoints would have created an unreviewed safety question or would have significantly degraded a safety margin. (D k Audit Plan Revision 0 4-24 April 3,1997 l'

l No systematic or programmatic defects are noted in NNECo's assignment, prioritization, or implementation of corrective actions. All other findings, if new, are a result of program or process deficiencies or 1 weaknesses which have already been identified by NNECo and are being formally tracked and addressed a:, part of the Millstone Unit 2 corrective action program. There is reasonable assurance that the plant is now maintaining conformance to its licensing basis. 4.6 PROJECT PROCEDURES 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, Process Review, and Regulatory Review) and implementation of Audit Plan Requirements. Project Instructions may be developed as required to supplement or provide clarifications for Project Procedures associated with major project inspection l activities. Exhibit 4-7 PROJECT PROCEDURES PROJECT PFOCEDURE TITLE PP41 System Vertical Slice Review Procedure PP-02 Accident Mitigation System Review l PP-03 Process Modeling, Analysis, and Review Procedure PP-04 Regulatory Review Procedure PP-05 Differing Professional Opinion PP-06 Substitution or Addition of Personnel 2 PP-07 Evaluation of Findings /~'N - U _,,,sses,me, _ Audit Plan Revision 0 4-25 April 3,1997

4 D 5.0 EVALUATION OF FINDINGS b A Project Procedure PP-07, " Evaluation of Project Findings", has been developed to 1 provide the guidance necessary to evaluate project findmgs developed during the conduct of the Millstone Unit 2 Independent Corrective Action Verification Program (ICAVP). The process for Evaluation of Findmgs is presented in Figure 5-1. 5.1 IDENTIFICATION OF FINDINGS During the course of the Millstone Unit 2 ICAVP, the project team member may identify and originate a Potential Findmg Further Parsons evaluation is required to determme the bases of the Potential Finding. Once a Potential Findmg has been identified, it is assigned a number for trackmg and monitoring purposes A findmg identified during the Millstone Unit 2 f%t Corrective Action Verification Program is either; e A defect A deficiency e i Or an unresolved item identified - Licensee corrective action and response is required for findmgs i A defect is any condition that results in the plant being outside its current licensing bases. This would include a condition that would be considered an unresiewed safety question in accordance with 10 CFR 50.59. It would also include a condition that would prevent a structure, system, or component (SSC) from meeting a specific docketed regulatory requirement applicable to Millstone Unit 2. i A deficiency is an error or omission in the Millstone Unit 2 licensing or design basis which is not classified as a defect. An unresolved item is a question that requires fu.ther information to reach a conclusion. Licensee response and further evaluation are required for resolution. i - M POWB - Audit Plan Revision 0 5-1 Apr0 3,1997 s .e

i Exhibit 5-1 EVALUATION OF FINDINGS i l l I Initiate l Potential g' Finding + l Log / Track Potential Finding k Review / Evaluate k-Is Close and No Poten,tial Fin &eg Document V id Basis Yes I Classify Finding if k if 4 Evaluate as Evaluate as Evaluate as Defect Deficiency Unresolved Item + Review / Approval + Concurrent Reporting of Finding to NNECO NRC per PLN-02 + NNECO

Response

+ Review / Comment on NNECO Response t + v Document Comments per PLN-02 O Audit Plan Revision 0 5-2 3pgum

5.2 REPORTING OF FINDINGS Once a Potential Finding has been determual to be a finding, it will be reported concurrently to the NRC and NNECo in accordance with the Communications Plan (PLN-02) 5.3 REVIEW OF PROPOSED CORRECTIVE ACTION Parsons will comment on the proposed corrective action prepared by NNECo in response to Findings. The group responsible for originating the Finding is responsible for commenting on the resolution. Comments will cover the adequacy of the response to bring the issue back within the licensing and design basis. Parsons conunents on the proposed corrective actions will be reviewed by the Advisory Panel prior to release to NNECo anxi the NRC. OV i i o Audit Plan Revision 0 5-3 April 3,1997

6.0 ICAVP FINAL REPORT Preparation of the ICAVP Final Report will complete project activities and include the following: Compile and assess system reports Review of NNECo findings and corrective actions Prepare the ICAVP Final Repon Issue the ICAVP Final Repon 6.1 COMPILE AND ASSESS SYSTEM REPORTS System / Process reports developed during the ICAVP Audit will be compiled and assessed prior to their incorporation into the ICAVP Final Repon. 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". He entire " system story" including deficiencies identified and corrective actions taken will be evaluated to: 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 Management Program (CMP) to identify problems, resolve existing problems, and preclude repetition. 6.2 REVIEW OF NNECo FINDINGS AND CORRECTIVE ACTIONS NNECo findings and corrective actions associated with the NNECo configuration management corrective action programs that were not previously reviewed as part of the ICAVP inspection activities will be evaluated in parallel with ICAVP system / process report compilation and assessment. The evaluation 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. The evaluation of NNECo findings and corrective actions will be incleded as a separate section of the ICAVP fmal repon OV - PARSONS POWER - Au&tPlan Revision 0 6-I Apnl3,1997

l' l .CT 6.3 PREPARE ICAVP FINAL REPORT - V After completion of audit plan activities, an ICAVP Final Report will be prepared to summanze all project activities. In parallel with completion of audit plan actisities, a suggested table of contents for the Final Report will be forwarded to the NRC and NNECo for review and concurrence After NNECo and NRC concurrence, ICAVP engineers will be assigned to prepare individual sections. 6.4 ISSUE THE ICAVP FINAL REPORT The draft ICAVP Final Report will be reviewed by an ICAVP Advisory Panel for completeness and technical accuracy prior to issue to the NRC and NNECo. ICAVP lead engineers will assist with the incorporation of Advisory Panel comments. The ICAVP technical edita will be responsible for fmal editing and issue of the ICAVP Final Report. 'Ihe ICAVP Final Ref ort will be issued to the NRC, NNECo, and interested public parties. 6.5 PROJECT CLOSEOUT AND RECORDS TURNOVER Concurrent with the issue of the ICAVP Final Report, the Parsons Power team will perform project closecut 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 Records Center for retention. [ 0 Audit Plan Revision 0 6-2 April 3,1997

/N 7.0 SCHEDULE Exhibit 7-1 provides the project schedule for Millstone Unit 2 ICAVP audit activities. ] Exhibit 7-1 is a summary level schedule (provided for NRC planning activities). This schedule represents the scope of work necessary to complete the Millstone Unit 2 ICAVP in accordance with this Audit Plan. After identification of a project start date, all schedules can be revised to show actual calendar commitments. Schedule durations have been based on the approach discussed in this Audit Plan. All task assumptions 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 e Contractor for Millstone Unit 2. The NRC has approved the Parsons Power's Audit Plan. The NRC will select SVSR systems. e G Nominal inspection periods have been assumed (no allowance for sample e expansion, special evaluation, or excessive finding processing). Nominal review and comment periods has been assumed. Allowances for public meetings and NNECo/NRC reviews will be determined on or before the Kick-off Meeting. i Iv Audit Plan Revison 0 7-1 April 3,1997

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MILIETONE UNIT 2 ICAVP ' PROJECT PROCEDURES PROJECT PROCEDURE TITLE REVISION PP-01 System Vertical Slice Review Procedure O PP-02 Accident Mitigation System Review 0 PP-03 Process Modeling, Analysis, and Review 0 4 PP-04 Regulatory Review Procedure 0 PP-05 Differing Professional Opinion 0 PP-06 Substitution or Addition of Personnel 0 4 PP-07 Evaluation of Findings 0 i J l .}}