ML20147H035

Independent Corrective Action Program for Millstone, Unit 1, Project Manual

ML20147H035
Person / Time
Site:	Millstone
Issue date:	03/25/1997
From:	SARGENT & LUNDY, INC.
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ML20147H030	List: ML20147H025 ML20147H035 ML20147H704
References
PROC-970325, NUDOCS 9704020107
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l INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM FOR o

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AUDIT PLAN FOR INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM (ICAVP) 2 NORTHEAST UTILITIES MILLSTONE UNIT 1 PROJECT NO. 9583-110 Prepared by:

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D' ate Accident Mitigation Review Group Lead

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MC R. Querio Dite Operations & Maintenance & Testing Review Group Lead A.

Neri Date System Review Group Lead 3l7b'7 T.J.gfan Dito/

Programma[ tic Review Group Lead Approved by:

AQ 3/i,ls 7 A. K. Singh Date IRC Chairman

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n 3-17-T'l D. K. SclVpfer F '!

Date Verification Team Manager (1)

Northest Utilities ICAVP Audit Plan Millstone Unit 1 1.0 OBJECTIVE The objective of this project is to implement an Independent Corrective Action Veri 6 cation Program (ICAVP) at Nonheast Utilities Millstone - Unit 1 in accordance with the Nuclear Regulatory Commission's (NRC) August 14,1996 confuustory order. The ICAVP will be an independent verification of the adequacy of results of the Configuration Management Plan (CMP) currently being implemented by Northeast Utilities which is directed at resolving existing design and configuration management de6ciencies. The ICAVP will provide independent verification that, for selected systems, Nonheast Utilities' CMP has identified and resolved existing problems, documented and utilized licensing and design bases, and established programs, processes and procedures for effective configuration management in the future. The ICAVP will be comprehensive, incorporating all of the appropriate engineering disciplines, such that the NRC can be confident that Northeast Utilities has been thorough in identification and resolution of problems.

The ICAVP review will be conducted independently ofNonheast Utilities and its design contractors.

2.0 SCOPE OF WORK 1

The scope ofwork for the ICAVP as described in the NRC's August 14,1996 confirmatory order to Nonheast Utilities includes:

A review ofengineering and design control processes, a.

b.

verification of current as modified plant conditions against design bases and licensirg bases documentation.

veri 6 cation that design and licensing bases requirements are translated into c.

operating procedures and maintenance and testing procedures.

d.

verification of system performance through review of specific test records and/or observation of selected testing of panicular systems, and review of proposed and implemented corrective actions for design e.

deficiencies identified by Northeast Utilities.

The NRC's December 19,19% oversight inspection plan provides further direction on the scope of the ICAVP. In addition to the above items, the oversight inspection funher requires a review of accident mitigation systems that assesses the (2)

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i critical design characteristics to ensure that these systems and components can perform their specified safety functions.

S&L will implement the above scope of work as follows:

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a.

The review of engineering and design control processes will consist of an assessment ofNortheast Utilities change process procedures as well as a review of all plant modifications to the systems selected for a vertical slice review by the ICAVP that were prepared after issuance of the operating license. The review of the modifications will include:

A technical review of the changes contained in the modification packages to system specific analysis and output documents and to topical engineering programs.

l Verification that current design output documents have incorporated e

S the changes identified in the modification packages.

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v Verification that current system operating, maintenance, testing and e

training procedures adequately reflect the modiScations.

Verification that the physical installation conforms with the modification package.

Verification that the post modification test procedure and test results demonstrate the system is capable of performing its function.

Verification that no unreviewed safety question exists for the modification as documented inthe 50.59 safety evaluation.

b.

The verification of current as modified plant conditions against the design bases and licensing bases will include:

A review of position papers prepared by NU which doucment the Millstone Unit I commitments to regulatory guidance documents and l

to various topical areas.

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U Review of calculations, analysis, specifications and design output e

documents for consistency and for conformance with the design and licensing bases.

A physical walkdown of the system to verify conformance with the design output documents.

The verification that the design and licensing bases are translated into c.

operating, maintenance and testing procedures will include a cross-check of functional and performance requirements identified in the licensing and design bases versus those identified in the operating, maintenance, testing and training procedures.

d.

The verification of system performance will be accomplished through a review of specific test records for recently completed surveillance and post modification functional tests, o

e.

The review of proposed and implemented correctivnetions for

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deficiencies identified by Northeast Utilities during the CMP will include a review of all corrective actions for systems selected for a vertical slice review by the ICAVP and a review ofrandomly selected corrective actions l

for systems outside the scope of the vertical slice review.

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The review of the accident mitigation systems will include an assessment of the critical design characteristics to ensure that the systems and components can perfonn their specified safety functions.

1 3.0 PROJECT ORGANIZATION l

The organizational structure will facilitate both the internal and external interfaces of the Project Team. Exhibit I shows the project organization. This section describes how the organization will function and the expected interfaces. The roles and responsibilities of the different parts of the organization are provided.

3.1 Management Team The Sargent & Lundy management team for this project is comprised of the Project Director, Bryan Erler, the Verification Team (VT) Manager, O

Don Schopfer; and the Chairman of the Internal Review Committee, A. K.

b Singh. They are co!!ectively responsible for ensuring that the project is I

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i properly planned and implemented, that it meets the requirements of the 4

NRC Confirmatory Order, and that the process and the results are open and credible to the NRC and the public.

i The Project Director will have the overall responsibility for Sargent &

Lundy's performance for the woi. He will be responsible for facilitating l

the resolution of any differences between the VT Manager and the Internal l

Review Committee. The Project Director will be the primary external spokesman for the ICAVP Team and will meet with and report to the ICAVP Oversight Team (IOT), NRC, and Northeast Utilities as required and as allowed by the approved protocol. He will be available to the press, the media, and the public when requested by the NRC and NU. The l

Project Director will also be signatory to the final report produced by the ICAVP Team.

The VT Manager will be responsible for directing the development of and approving the plans and procedures for implementing the review, including recommended system selection critesia and the protocol covering O

communications between Sargent & Lundy project personnel and the other organizations. He will manage the work through the technical leads on the VT. He will be responsible for reviewing the findings produced by the VT, and, upon scrap *=ca, submitting them to the Internal Review Committee.

He may also return them to the VT Leads for additional information or further review. The VT Manager will be responsible for distributing the findings, including posting them on the electronic bulletin board as established in the approved protocol after acceptance of the findings by IRC. Similarly, the VT Manager will review, accept arxi distribute / post the VT's evaluation of the NU responses to the findings. He will be responsible for preparing the final report documenting the work of the VT.

The VT Manager will also serve as the backup for the Project Director with respect to communication with the IOT, NRC, and NU when necessary.

The Chairman of the Internal Review Committee will be responsible for -

coordinating the activities of that group. The roles and responsibilities of

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the Internal Review Committee is provided later in this section of the audit j

plan. The IRC Chairman will also make himself available to the IOT, NRC, i

and NU when requested.

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l 3.2 Veri 6 cation Team The VT is the core of the organization and is the group that does the actual review of the design and licensing bases and the effectiveness of the NU j

corrective actions. The VT is organized into four functional subgroups.

l Each subgroup will be headed by a Lead engineer and will be responsible 4

for a portion of the overall verification program. There will be a System Review Group (SRG), a Programmatic Review Group (PRG), an Operations and Mrintenance and Testing Review Group (ORG), and an Accident Miti atin Systems Group (ARG).

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The SRG will perform the in-depth review of the selected systems. This l

group will review the current system output documents and analysis to verify conformance with the design and licensing bases. The SRG will also review design modifications to the selected systems made since receipt of I

the OL, focusing on the validity of the design process, identi6 cation of i

system interface requirements, potential synergistic effects of the i

modifications, and appropriate design document controls.

q The SRG will also be responsible for verifying that the current, as-built i

condition of the pitat matches the current design output documents. This task includes physical and functional walkdowns of the selected systems and will be performed by the Physical Configuration Review subgroup l

(CRG)of the SRG.

The ORG will be responsible for reviewing system operating procedures, '

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surveillance procedures, maintenance procedures, and training documents to confirm that the design bases and any changes made to the decign bases have been translated correctly into these documents. This group will also j

confirm that cunent testing requirements and post modification testing requirements are adequate to verify system performance.

The ARG group will be responsible for reviewing the accident analysis contained in the FSAR to determine the accident mitigation systems and their critical design characteristics. The ARG will then review the accident mitigation systems and their critical characteristics to ensure the systems j'

can perform their safety functions specified to mitigate the FSAR accident i

scenarios.

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The PRG group will be responsible for the review of select NU processes for changing the facility design and for changing characteristics, procedures, or practices for maintairdng, operating, testing, and training to

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ensure the adequacy of the change process. The PRG will also be responsible for the review of NU's corrective actions resulting from their configuration management plan review. This review will determine the

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adequacy of the corrective actions.

3.3 Role of the Internal Review Committee The Intemal Review Committee will provide a Sargent & Lundy management technical oversight role. It will also help to provide consistency in the review results. It will be comprised of four very senior personnel within the organization that have specialized expertise in the areas being reviewed. The IRC Chairman will be responsible for obtaining the IRC's review of the planning documents and procedures for performing the verification program. This includes the audit plan, the protocol, and the O

individna> > rec anres 2 ir a fer ts -er*. Th Iac -iii r view's-findmgs of the VT for extent and for significance. They will also review the responses by NU after they have been accepted by the VT. The IRC may also make specific recommendations regarding the scope or methodology of the verification process as the work progresses. The IRC will also review the final report of the ICAVP.

3.4 ICAVP Oversight Team The establishment of an executive oversight team for the ICAVP will add i

to the NRC's and the public's confidence that the process and the results of the verification program were in accordance with NRC's Confirmatory Order. The ICAVP Oversight Team (IOT) will oversee and monitor the project team's activities. The IOT will be provided with the key process documents such as the confirmatory order, oversight inspection plan, audit j

plan, the protocol, the key procedures, and the recommended system '

selection criteria. The members of the IOT will include a person from the local public sector with a strong technical background, a person with former experience in nuclear power reactor regulation, a current or fonner I

executive (s) from a utility with an acknowledged excellent nuclear i

program, and one or more executives from Sargent & Lundy who are not j

directlyinvolved with theICAVP.

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~ Millstone Unit 1 The ICAVP Management Team will provide periodic technical briefings to the IOT on a monthly or more frequent bases, depending on the activities of the ICAVP project team. The purpose of these briefings will be to allow the IOT observe the process and examine the types of technical decision making by ICAVP project team. Input and guidance from the IOT will be accepted, considered, and factored into the program, as applicable. The IOT members will be pennitted to attend all meetings between the ICAVP Project Team, NU, and the NRC.

The IOT will document their evaluation of the ICAVP process and results by preparing a brief report which summarizes their conclusions. This repon will be included in the final overall ICAVP report. If requested, the IOT will brief the NRC onits efforts.

4.0 METHODOLOGY This section of the audit plan describes the methodology S&L will use to implement the ICAVP. Exhibit 2 depicts the review process In general, the ICAVP will consist of the following tasks:

Document Gathering I

System Review PhysicalWalkdowns e

Operation, Maintenance and Testing Procedure Review o

Accident Mitigation System Review e

Prugr.o eticReviews e

Processing VT Fmdings e Review ofNU Resolutions Issuing FinalReport e

4.1.

Document Gathering The first step in the ICAVP review process will be to gather the licensing and design bases documents, procedures, design process documents and design output documents needed to perform the review. The following top level controlled documents have been obtained and are stored in both the S&L Chicago office and the local offsite office:

Configuration Management Program e

Design ControlProcess Procedures e

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. _. _. _ _ _ _ _ ~. _... _. _. _ _ _ _. _ _ _ _ _

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Northest Utilities ICAVP Audit Plan Millstone Unit 1 e Current FSAR i

e FSAR at O/L e SER and all revisions i

e 10 CFR 50.59 Safety Evaluation Procedure I

Procedures for and System Specific A=**=mants e

I Corrective Action Procedures

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e List or database oflicensing commitments i

Description ofdocument system and hierarchy system e

List of all modi 6 cations designed since receipt of O/L for Maintenance e

Rule Category I and 2 system, sorted by primary affected system, including the organization responsible for the design Complete index of the Unit I controlled documents, including e

calculations and drawings Complete index of the procedure system for Unit 1, including e

corporate / administrative procedures, engineering procedures, maintenance procedures, and operating procedures including A

emergency operating procedures Complete listing of Adverse Condition Reports, sorted by system e

Documents describing specific engineering programs that may not be e

included in the above listing, such as MOV program, ISI/IST program etc.

.l NRC inspection reports, QA audit reports and the NU responses to

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e Millstone Unit 1 Position Papers on Regulatory Guidance and Topical Areas.

The following system specific documents for the systems chosen for review will be requested in accordance with the protocol outlined in PI-MPI-01.

Engineering Calculations (Mech, Elect, Struct, I&C and Piping j

e Analysis)

Equipment Procurement Specifications 1

e Modification Packages e

System Descriptions e

Equipment List e

Environmental and Seismic Qualification Reports e

• P& ids Logic Drawings e

• Electrical Schematics (9)

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Piping Drawings Electrical Single Line Drawings Panel Wiring Drawings Cable Routing Drawings and Databases o

Pipe Support Drawings Structural Equipment Mounting Details General Arrangement / Equipment Location Drawings Instrument Location Drawings e

Zoae Maps (Environment / Fire Protection, etc).

Operating Procedures including Emergency Operating Procedures Maintenance Procedures e

Surveillance Test Procedures e Vendor Manuals System Training Procedures 4.2 System Reviews O(d The vertical slice system reviews will be performed by the SRG in accordance with PI-MPI-02 and 03. System reviews will focus on two objectives,1) to verify the system design elements being reviewed are technically adequate and consistent with the licensing and design bases (PI-MPI-02) and 2) to verify the modifications implemented after receipt of the operating license are technically adequate and that configuration control of design documents was maintained (PI-MPI-03).

The first step of the process is to review the licensing and design bases documentation to identify the functional, design, performance, operational and testing requirements of the system. This step willinclude a review of the FSAR, SER, Technical Specifications, position papers on regulatory guidance, and the licensing committment tracking system. Requirements identified during the review will be individually tabulated on a system requirements checklist. This checklist will be used by the SRG and ORG as the bases for verifying design conformance to the design and licensing bases. This step will also review the position papers prepared by NU which document the Unit I committments to regulatory guidance documents and various topical areas. The review of the position papers will evaluate the positions taken by NU to ensure they are technically adequate and complete. This evaluation will include a comparison of the fm position papers to the licensing committments identified by NU as part of

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their CMP. This evaluation will not include an independent review ofNU (10)

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correspondence files to verify that all committments made by NU to the NRC have beenidentified by the CMP.

Following the development of the system requirements checklists, the SRG will perform the three reviews described below. The purpose of these reviews is to determine how the design meets the functional and performance requirements of the system and to ensure consistency between the various design output documents and design process documents.

These three reviews include:

A review of design process documents to verify the technical a.

adequacy of each document and its conformance to the design and licensing bases. This review will include mechanical, electrical, I&C, and structural calculations, piping analysis and equipment EQ/SQ reports.

b.

An upper tier drawing review including P& ids, electrical schematics and logic diagrams to verify the system design is capable c()

of performing the functional requirements described in the design and licensing bases and to verify the drawings are consistent with the design process documents.

c.

A component review to verify consistency between the licensing and design bases documents and the design output documents such as, component speciScations, system calculations, and vendor component drawings.

Once the reviews are completed, the SRG will enter on the systems requirements checklist how each of the design, functional and performance requirements is satisfied. The ORG will complete the portion of the checklist relative to operating and testing requirements. This will include identification ofeach document reviewed against the requirement and whether the documents that were reviewed are consistent with the requirement and/or substantiate the requirement.

The next step will be to review the plant modifications issued after receipt of the operating license. Each modification will first be screened to identify the lead discipline (mechanical, electrical or I&C). A lead verifier from the l

affected design discipline will then perform a modification screening

,G process to identify which design elements are affected by the modification.

V The lead verik will complete a checklist consisting of general questions (11)

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ICAVP Audit Plan Millstone Unit 1 to facilitate the determination of which design elements are affected by the modification. The design elements that will be screened include:

a.

MechanicalDesign b.

ElectricalDesign c.

I&C Design d.

Structural Design e.

ALARA Design f.

Security g.

Appendix R Compliance h.

Electrical Equipment Qualification i.

Seismic Qualification j.

RadiologicalEnvironment k.

Non-RadiologicalEnvironment 1.

Station Blackout m.

Control PanelDesign n.

Piping Design o.

Setpoint Database p.

Hazards /HELB Program

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Fire Protection r.

Licensing Review s.

PRA t.

Training Procedures Plant Procedures (OPS, Maintenance, Surveillance) u.

v.

Configuration Change Review w.

Quality Software Design Review For each design element that is affected, a VT member with the appropriate techaW background will perform a detailed review to verify that the design element was adequately addressed in the modification. This review will verify the technical adequacy of calculations, specifications and design documents impacted by the modifications. All reviews will be performed by the SRG with the exception ofItems t and u which will be performed by the ORG.

The SRG will then perform a detailed review of the changes to licens'mg documents that were generated for each modification to ensure the changes are adequately incorporated into the FSAR, Technical Speci6 cations, etc. The SRG will also review the 10 CFR 50.59 safety evaluation prepared for each modification to ensure the unreviewed safety

's question determination was thorough and well documented.

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O Millstone Unit 1 Finally, the SRG will review the installation and testing requirements including acceptance test criteria to determine that appropriate installation and testing requirements were specified. The ORG will be responsible for verifying that satisfactory post-modification testing was implemented.

4.3 Physical Confiniration Review The physical configuration review will be performed by the CRG in accordance with PI-MPI-05. This review will focus on verifying the current as built condition of the plant matches the current design documents. This group will perform a physical and functional walkdown of the systems in the scope vertical slice review. This group will also review plant modifications implemented after issuance of the OL to verify i

the as built condition conforms to the modification documents and to verify the modi 6 cation documents have been accurately incorporated into ae I

affected design drawings or are posted against the affected design drawings. The walkdown of system modifications will be a more in-depth 3

(O walkdown than the system functional walkdown described above. Key critical dimensions such as analysis / calculation bases and/or dimensional restrictions identified on drawings will be verified during the modification walkdowns.

After retrieving the system design drawings and outstanding changes, the CRO will create a set of walkdown documents by redlining the open amendments onto the physical drawings. The CRG will then perform a review of the lower tier drawings such as piping drawings, wiring diagrams, etc., to verify conformance to the upper tier P&lDs and schematics. This review is required to ensure the lower tier documents being used for configuration walkdowns are functionally in agreement with the upper tier documents that are checked for technical accuracy by the SRG. The SRG as part of their calculation reviews will also verify calculations such as stress reports and lower tier drawings such as piping isometrics are in conformance. Discrepancies identified by the SRG in this area will be communicated to the CRG. This review is not intended to be a line by line review of the lower tier documents, but only a functional check.

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ICAVP Audit Plan Millstone Unit 1 Prior to performing the walkdowns, the CRG will identify system boundaries on the walkdown drawings. These boundaries will be reviewed with the SRG for consistency in the scope for the two groups.

The next step will be to perform physical plant walkdowns of the systems.

The walkdown will check the following attributes:

a.

System component location and identification are as indicated on the P& ids and other schematic type documents.

b.

Component nameplate data is consistent with component specifications and drawings.

c.

System components are not physically damaged.

d.

System configuration is functionally consistent with design output documents byverifying.

e L.me sizu Configuration ofpiping including number and location of bends, location ofvalves, supports and other in-hne components Valve orientation and flow direction e

1 Pipe support type and configuration Equipment and instrumentation mounting details e

Configuration ofconduit and tray routing e

Cable"To and From" routings Conduit and cable size Conduit and tray support type and configuration Tubing / electrical configuration to instruments e

HVAC ductwork size and routing e.

Divisional trains of the system are physically separated by barriers and or distance. Electrical separation will be checked by verifying cable is routed through applicable divisional raceway, f.

Portions of the system which are not safety related have been designed to II/I seismic requirements.

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, v As stated previously, this walkdown is not intended to check all dimensions, but is merely intended to be a functional verification.

The CRG will also perform a review of the modifications identified by the SRG as impacting system configuration drawings. The SRG will provide / identify drawing changes resulting from system modifications.

Upon receipt of this data, the CRG shall first review the drawing changes i

to ensure they are either incorporated into the current drawings or are identified as open amendments against the drawings. The CRG will then l

perform a detailed walkdown of the modified area. This walkdown will include a check of critical dimensions in addition to the other walkdown attributes described above for the functional walkdown.

1 4.4 Operation & Maintenance and Testing Review The operating & maintenance and testing review will be performed by the 1

ORG in accordance with PI-MPl-06. This review will focus on verifying that the system operating procedures, maintenance procedures, surveillance

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procedures and training documents conform to the systems design and licensing bases. This group will also review the post modification tests performed following the installation of plant modifications to the system to verify the testing was adequate to maintain the design and licensing bases.

Upon receipt of the system requirements checklists from the SRG, the ORG will perform a review to verify the following:

I The operating procedures are in conformance with the systems a.

functional requirements described in the Licensing and Design i

Bases. This review willinclude all modes ofsystem operation including normal, abnormal and emergency system operations. This review willinclude:

a.1 Review of the operating procedures against the system P& ids.

a.2 Verification that instrumentation and controls described in the procedure are consistent with the installed condition.

c a.3 Verification that procedures for support systems are p

adequate to support the operation of the system.

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a.4 Verification that manual operator actions can be performed under accident conditions.

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The maintenance procedures are in conformance with the 3

maintenance requirements desenhd in the Licensing and Design Bases. The review will:

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b.1 Verify that maintenance procedures and vendor manuals i

exist for key system components.

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b.2 Check the maintenance procedures for technical adequacy.

b.3 Review a sampling of vendor manuals, generic communications (i.e., Bulletin, Information Notices, i

Generic Letters, NSSS Techincal Bulledns) and verify applicable items have been implemented into the l

maintenance program.

b.4 Review component history files to identify recurring equipment problems and determine if any trends exist.

b.5 Review past maintenance activities and verify technical adequacy, performance of the appropriate post maintenance testing, and satisfactory demonstration of equipment operability.

c.

The review will verify that test procedures and surveillance procedures are in conformance with the Design and Licensing Bases. The review will focus on the following:

c.1 Review the technical adequacy of Technical Specification Surveillance Test Procedures and verification of the adequacy of a sampling of test results completed within the last two years.

c.2 Verify the system tests adequately ensure the system will operate as intended under postulated conditions.

c.3 Determine if surveillance test procedures comprehensively address system responses addressed in the licensing bases.

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Upon completion of the above reviews, the ORG will compite the system 4

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requirements checklist to document how the Licensing and Desiga Bases --

requirements related to Operation & Maintenance and Testing are rtidied.

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The ORG will also review plant irsiihdons implemented after issuance 1

j of the Operating Licensing As stated in Section 4.2 of this audit plan, the i

SRG screening process will determine if plant modi 6 cations affect the l

operation, maintenance or inspection requirements of a system. When affected, the ORG will evaluate the moddication to identify the required j

changes. The ORG will then review the operating, maintenance and testing

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j procedures to verify the changes due to the modification have been i

j reflected in the procedures. Additionally, the ORG will review the post modification test results for each modification to verify the adequacy of the l

test results.

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1 4.5 Accident Mitiaation S_v ama Review e

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j The process discussed in this section will be used by the ARG to develop i

the critical parameters for the accident mitigation systems. This process l

shall be implemented in accordance with PI-MPI-07.

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The ARG Lead and Verifiers will review the iniiJMents in the FSAR, f

as they apply to Millstone Unit I and identify the x4.c.t mitigating j

systems and components within the system. The reload analysis and the FSAR shall be used to identify the specific critical parameters which are required to mitigate the event. As a result of this review, the ARG Lead will create a database consisting of the following items: a) Analyzed Accidents, b) Mitigating Systems, c) Components, d) Critical Parameters

- and e) References to the accidents and associated documents contained in j

the SAR.

t The portion of the database consisting of the accident mitigation systems in the the scope of the vertical slice system reviews (Subsection 4.2) will be j

given to the ORG and SRG for their review of the Critical Parameters.

The ARG Verifiers will verify the Critical Parameters using a documented 7

System / Component test, and or Surveillance test from the Millstone Unit 1 p

Technical Specification or Post Maintenance Tests.

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In addition, the Critical Parameters will be verified using the design calculations, specifications, and vendor documents for acceptability.

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I 4.6 Programmatic Reviews The programmatic reviews will be conducted by the PRG on a horizontal bases (across systems) for the purpose of determining if the actions taken by Northeast Utilities (NU) to con'ect previously identified problems have been effective and if the NU change processes are effective. The programmatic reviews will be performed in accordance with PI-MPI-04.

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Licensee Initiated Corrective Actinna As part ofits Configuration Management Program (CMP), NU has f

performed a vertical slice review of safety-significant systems and has j

identified degraded or non-conforming conditions. For each of these j

degraded or non-conforming conditions NU is initiating corrective actions.

l The programmatic review will assess the adequacy of these corrective j

actions. This review will be conducted for all corrective actions associated l

with the systems included in the scope of the ICAVP vertical slice system reviews, and for a representative sample ofcorrective actions associated l

with the other NU completed CMP vertical slice systems.

i The NU CMP findings / corrective action documents will be obtained both for the systems in the scope of the ICAVF m@,3! dica system review and i

for systems outside the ICAVP vertical slice system review.

A checklist will be prepared for the review of corrective actions. Using the checklist, the PRG Verifier will assess the corrective actions for adequacy of the following:

a.

Root cause determination - the extent to which plant processes and procedures are affected.

b.

Extent ofcondition determination - the extent to which other systems, structures or components are affected, Plant restart -is the corrective action required prior to restart?

c.

d.

Content - is the corrective action adequate in resolving the issue?

O (18)

Northest Utgities ICAVP Audit Plan Minstone Unit 1 I

l Channe Prm;;

NU's current plant change processes will be reviewed for both their j

adequacy with respect to industry standards and for the effectiveness by which they are being implemented. Both design change processes and procedure change processes will be included in this review.

As part of the ICAVP system reviews, the SRG and the ORG will assess the plant modifications made on the sample systems. This review will evaluate the effectiveness of the change processes involved in these modifications (i.e. if the resulting modification is found to be acceptable, it can be inferred that the process used in performing the modification is acceptable). In addition to this system review, specific process related reviews will also be performed by the PRG. The various change processes reviewed will include the following:

fatHIt Correspondine MP1 Procedure drawings NUC DCM Chapter 7 specifications NUC DCM Chapter 6 calculations NUC DCM Chapter 5 procedures DCl, DC2, DC3, DC4 i

temporary alterations WC 10 minor modifications NUC DCM Chapter 3 modifications NUC DCM Chapter 3 l

licensing documents NGP-4.03 vendor manuals NUC DCM Chapter 8 like forlike replacements NUC DCM Chapter 1 The current MP1 procedure for the processes listed above will be evaluated for its content and completeness. This evaluation will determine if the O

procedure exercises adequate controls on the change process and invokes appropriate interface reviews to assure the plant design bases and (19) i

1 Northest Utilities ICAVP Audit Plan i

Millstone Unit 1 l

4 i

i con 6guration is maintained consistent with the licensing bases The evaluation will be based on guidance provided in the following:

l i

Reg Guide 1.33, Quality Assurance Program Requirements (Operation) j NRCInspection Manual INPO guidelines

l INPO 87-006, Repon on Con 6guration Management in the Nuclear

[

Industry NEIguidelines i

The adequacy of NU's implementation of the change process procedure 1

will also be evaluated. Since the system review will usess the technical adequacy of the change, the prog..i..atic review is intended to evaluate l-only the procedural adequacy of the change. The evaluation will determine j

if the procedure is being followed, that the required checklists are being i

accurately and completely fdled in, and that all other documentation is complete and accurate. This evaluation shall be performed for the changes

?

captured in the ICAVP system reviews. If any of the processes noted O

a6ev arenetincino ainth r t r vie.an aa,ic ent id the ICAVP willbe selected for review.

4.7 Prnce==laa Verifirmion Team Findia==

When a member of the VT identines a discrepant condition which does not appear to meet the requirements, he shall initiate a discrepancy repon (DR) per PI-MPI-11. Exhibit 3 of this Audit Plan depicts the DR process.

Examples ofdiscrepant conditions are a disagreement between the, system design bases and the FSAR, the as-built configuration of a piping system and the piping analysis, or a change to maintenance procedures, which should have been made due to a plant modi 6 cation, but was not. The DR will document the discrepant condition and the documents or walkdown reports that were reviewed to arrive at that conclusion. Other technical and administrative items will be included on the DR fonn to help track, trend and analyze the results of the veri 6 cation program. The DR will be signed by the VT member and forwarded to the VT Group Lead.

The VT Group Lead will review each DR with the VT member for technical adequacy, completeness, and whether that speci6c issue has already been addressed by another DR or by an existing NU corrective action document. The DR could be returned to the VT member for

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additional information or investigation; or it could be accepted and signed (20)

I Northest Utilities ICAVP Audit Plan Millstone Unit 1 s

by the VT Group Lead; or it could be determined to be not valid. For any I

DRs determined to be not valid, thejusti6 cation for this decision will be i

documented on the DR and the DR will be signed by the VT member and j

the VT Group Lead. Ifvalid the VT Group Lead will assign a DR number l

and forward the DR to the VT Manager.

l The VT Manager will review each DR with the Group Leads for technical j

adequacy, completeness, and whether that specific issue has already been j

addressed by another DR or by an existing NU corrective action document.

l The DR could be returned to the VT member for additional information or i

investigation; or it could be accepted and signed by the VT Manager, or it could be determined to be not valid. For any DRs determined to be not valid, the justification for this decision will be documented on the DR and the DR will be signed by the VT member, VT Group Lead and VT Manager.

i The VT Manager will submit accepted DRs to the IRC for their review.

They will review the DRs for extent of the condition to confirm that the O

VT looked deep enough into the issue to ensure that the problem is fully scoped; they may make recommendations to the VT to look for similar conditions in other areas or systems. The IRC may request that the VT member obtain additional information; tig could accept the DR as written, whereupon the IRC Chairman would sign the DR and return it to the VT Manager, or the IRC may conclude the DR is not valid. If the VT member, VT Group Lead, and the VT Manager agree with the conclusion that the DR is not valid based on additional information, those justifications shall be documented on the DR and signed by the VT member, VT Group Lead, and the VT Manager.

All valid and accepted DRs will be transmitted to both NRC and NU when the above process is completd. The DRs will be transmitted in accordance with the approved protocol. Since an important part of this project is to keep the public informed of the status and results, in addition to expected monthly meetings with the public, all DRs which are sent to NU and the NRC will be posted on the Internet World Wide Web.

4.8 Review NU Resolution to Verification Team Findings As shown in Exhibit 3 the handling of NU's proposed resolution of the VT O

findings will follow a similar process as the generation of the findings. The resolution will be submitted to the VT member who initiated the DR the (21)

Nortbest Utilities ICAVP Audit Plan (V]

Millstone Unit 1 VT Group Lead and the VT Manager. If the proposed resolution is determined acceptable, it is forwarded to the IRC for their review. Ifboth the VT Team and the IRC find the NU resolution of the DR to be adequate, NU and the NRC will be notified by the method established in the protocol. At this point we will post the accepted resolutions to the findings on the Internet bulletin board established for public access. If NU's resolution to the finding is not considered adequate by the VT member, VT management, or the IRC, it will be returned to NU and sent in parallel to the NRC with a written explanation and bases for why the team did not consider it to be adequate. It is expected that NU would reconsider the information and resubmit it to the VT. Meetings between NU and the VT may be required to reach an understanding and resolution of particular 1

issues. These meetings would be requested and held in accordance with the established protocol.

5.0 SYSTEM SELECTION CRITERIA cs (j

At the public meetings on September 24,1996, the NRC indicated that they would select the systems for review rather than S&L. They also stated at those meetings that the NRC would decide on the number of systems to be selected for review.

As input to the NRC staff, S&L recommendations on the number and selection of the systems for review are provided below.

Sargent & Lundy's system selection criteria are based on NRC Inspection Manual Chapter 2535, Design Verification Program, modified to be appropriate to this situation of an operating unit. These criteria would be applied to the list of approximately 20 systems for which the NU line organization and the NU oversight organization will have completed their review also.

I l

1)

The systems should be in the top quartile ofrisk significant or safety related

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systems.

j l

2)

The systems should involve a full cross section of engineering disciplines with internal and external organizational interfaces, such as NSSS supplier, component vendor, and engineering service organization.

i 3)

The concept and implementation of the design should not be limited to the NSSS supplier or another single component supplier.

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Northest Utilities v

ICAVP Audit Plan G

Millstone Unit 1 t

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4)

The systems should be generally representative of the safety related features ofother systems.

5)

The systems should be reasonably complex, requiring multiple operating modes.

6)

The systems should have multiple, non-trivial modifications performed on it since initial licensing, preferable by different desi n organizations.

F 1

l With the likely selection of four systems, it is not necessary that every system meet i

all of the above criteria. However, each system should meet as many of the criteria as possible and each of the criteria should be met by at least two of the selected systems. The system selection may of course also be weighed more heavily to e

concentrate on specific known problem issues at Millstone Unit 1.

6.0 PROJECT DELIVERABLES Deliverables for this project will include a final repon which describes the scope of O

the ICAVP, the methodology used, the results of the review and the conclusions U

regarding the adequacy of the configuration management program and the corrective action program at Millstone Unit 1. Exhibit 4 of this audit plan presents an outline of the final report.

7.0 PROJECT TEAM The project team members are identified on the project roster included herein as l

Exhibit 5. The project organization chart is included herein as Exhibit 1.

The selection of personnel for the ICAVP was based on their qualifications to perform the assigned reviews, their financial and technical independence from the Unit being reviewed, and NRC acceptance of the personnel. Substitution of existing personnel on the team may be required to add expertise or manpower to fully investigate issues which are identified during the course of the program. A specific procedure (PI-MPI-08) has been written to govern the substitution and addition ofpersonnel to the project team. NRC notification and approvalis required.

O (23)

Nortbest Utilities ICAVP Audit Plan 3

Millstone Unit 1 i

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8.0 GOVERNING PROCEDURES i

j The work for this project is classi6ed as Nuclear Safety Related and shall be performed in accordance with this audit plan, S&L's Quality Assurance Program j

and the followmg project instructions:

l Proiect Instruction No.

Iigt i

PI-MPI-01 ICAVP Communications Protocol l

PI-MP1-02 Review of System Design for Compliance j_

with Design and Licensing Bases j

PI-MPl.03 Review ofPlant Modi 6 cations Prepared l

After Receipt of Operating License for l

l Technical Adequacy and for Configuration l_

Control j

PI-MPl-04 Programmatic Reviews PI-MPl-05 Physical Plant Configuration Walkdowns PI-MPI-06 Operations and Maintenance and Testing i

Procedures and Training Dewdon j

Reviews PI-MPI-07 Review of Accident Mitigation Systems PI-MPl-08 ICAVP Team Personnel Substitution and/or Addition f

PI-MPl-09 Preparation and Approval ofChecklists l

PI-MPI-10 Differing Professional Opinions i

i PI-MPI-11 Discrepancy Report Submittal and Closure PI-MPI-12 Project FileIndex The project team members will be trained to the applicable project instructions.

Training records will be maintained in accordance with S&L QA procedures. The Manager of the S&L Quality Assurance Division will select an audit team to monitor the activities of the project as it progresses. Their review will be to l

ensure that the process used by the project team is in accordance with the NRC i

Confirmatory Order and the procedures developed to implement those

{

requirements. The QA auditors will review selected DRs identified by the VT and will pay particular attention to any DRs that are determined to be not valid. A

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summary of the QA activities related to the ICAVP and their conclusions will be j

included as part of the ICAVP final report.

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ICAVP Audit Plan Millstone Unit 1

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9.0 PROJECTINTERFACES The purpose of this project is to obtain an unbiased assessment of the Millstone -

Unit I configuration management and corrective action programs. Therefore, i

every reasonable effort must be made to assure that the observations and i

conclusions made are the result of our Project Team's own independent l

assessment and not influenced or biased by outside organizations. To maintain this assurance ofindependence, communications with outside organizations will be in accordance with PI-MPI-01, "ICAVP Communication Protocol".

i 10.0 LOCATION OF WORK The S&L VT with the exception of the CRG subgroup of the SRG will be i

stationed in S&L's Chicago offices. The CRG will be stationed at vi offsite office located near the Millstone station.

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The project team members stationed in the Chicago offices may make periodic i

i trips to the S&L offsite office and to the station as needed to gather documentation, interview NU personnel, or to attend meetings ta discuss NU i

proposed resolutions to S&L discrepancy reports.

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4 j

11.0 PROJECT SCIIEDULE i

The project schedule is illustrated in the bar chart included herein as Exhibit 6.

)

12.0 BUDGET DATA l

Applicable project number and task codes for this project are listed in Exhibit 7.

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Exhibit 1

!O ICAVP Project Organization Chart l

l Northeast Utilities hRC j

System AL AL UAk i

f ICAVP 4

B. A. Erler Oversight Project Director Team Quality Assurance 1

A. K. Singh D. K. Schopfer IR Committee Verification

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j Chairman Team Manager i

IR CommlMee System O&M and Accident Programmatic K. J. Green Review Lead Testing Mitigation Review Lead Review Lead Review Lead ue D. Ran' eja A. A. Neri T.J.Ryan Physical Configuration i

i Review Lead P'

R. E. Kropp i

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initiete Discrepency

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PROCESSING FINDINGS Report (DR)

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& Post on Electronic BB VT Mgmt i

Provide DR Response to VT Menegement NU i'

h Review NU Response forAdequecy Document Reasons for Rejection / Submit to d

~ NU/NRC Review NU Response VT Mgmt

& VT Acceptance /

h Reection RC i

DocumentAcceptance NU Response

& Submit to NRC/NU &

4b Ne leDR Yee---> Post on Electronic BB Adequele?

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Exhibit 4 i

OutlineICAVP Final Report Executive Summary i

ICAVP Oversight Team Report Sargest & Lundy Quality Assurance Division Report I.

Introduction A.

Background

B.

Objective i

C.

Scope D.

Methodology E.

Project Organization II.

Conclusions A.

Overall Conclusion 1

B.

Design ControlProcess C.

Design Basis /Lic>aning Bssis Consistency D.

Design Adequacy E.

As-built Plant Con 6guration F.

Translation of design into plant maintenance and operation G.

Adequacy ofTesting Programs H.

Applicability of selected sample to all Millstone 3 systems I.

Corrective Action Program I

III.

Review Results A.

System 1 B.

System 2 C.

System 3 D.

System 4 E.

Accident Migitation Systems F.

Corrective Action Program G.

Change Processes Appendices 1.

Project Team 2.

Objectivity Questionnaires 3.

ReviewRecords 4.

DiscrepancyReports O-5.

NU Resolutions 6.

Project Manual 7.

List ofChecklists i

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ICAVP Project Team Unit 1 Project DirectorfProject Manaser B. A. Erler X

PSD I

4 D. K. Schopfer X

PSD internal Review Committee

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i A. K. Singh X

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D. P. Galle X

2790 MSS K. J. Green X

MDM W. G. Schwartz X

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J. L Tenwinkel X

PSM K. R. Novatny MPED J. DeMarco X

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1. Wamer X

EPED T. L Sarver X

ERIN R. Hindia X

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C. M. Launi X

NT&R J. M. Rich X

NT&R N.Klaic X

NPD J. W. Johnson X

CMED P. R. Olson X

NPD j

i M. D. Stout X

HVAC CMED EQ Spedalist X

ERR # 351 NPD Piping specialist X

ERR # 352 NPD C/S Engineer X

ERR # 353 PSED ME 3 X

ERR # 354 i

PSED ME 3 X

ERR # 355 EPED Sr. En0r X

ERR # 358 EPED Sr. Engr X

ERR # 357 1

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CRG R. E. Kropp X

279/MPED i

CMED Sr. Ener X

ERR # 358

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G. E. Bitar X

ERIN Mechanical Designer A X

ERR # 387 Mechanical Designer B X

ERR # 388 Electncal Designer A X

ERR # 389 Electrical Designer B X

ERR # 390 1

ARG R. D. Raheja X

PSM

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T.J.Kane X

PSED L A. Bennett X

ERIN W. R. Peebles X

PSED i

W. J. Johnson X

NTRD 3

l&C En0r-Offer to TU X

ERR #325 EPED Project Engr X

ERR #326 i

Nitin Patel X

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Mill:tona ICAVP Pcrssnn:1 EN5 Page 2 of 2 ga ICAVP Project Team Unit 1 PRG T.J.Ryan X

SCD D. A. Schroeder

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QAD S.P.Wrona X

ERIN t&CPED Sr. Proj. Engr X

ERR # 359 ORG R. E. Querio X

279/OMSS i

B. A. Childers 279/OMSS J. A. Kleam 279/OMSS R. L Marsh 279/OMSS J. P. O'Brien 279/OMSS R.Bax X

289 T. Tamlyn X

279/OMSS R. Spear X

279/OMSS J. E. RushWck ERIN O

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Northeast Utilities - Millstone Units 1 & J sargent ag ICAVP Implementation Schedule Nc.....ber December l

January l

Fetr ID Task Name Start Finleh 11/10111A7111/24 12ft l 122 l12n5 l12/22l12/29l 16 l 1/12 l 1/19 l 1/28 l 2/2 l 24 1

NU mset wth NEAC =2-_-,.

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evaluate resp. & report to NEAC @ public meeting 11/2160 12/12/98 4

NU hold public meeting wf NRC re: Restart Plans 52'*7198 12/17ss 5

NU docket letter to NRC for Cortractor Selection 12/18/96 12/18 s 6 h12118 8

NU issue letter of intert to S&L fcr Unt 3 12t1000 12/1EW96

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7 NRC svaluate selection of S&L Team 12n9/96 2f4/97 8

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NEAC prowde input to NRC on ICAVP Contractor 12/13/96 12J3Lv95

'g 10 NRC hold public meebng to discuss selechon 2/5/97 2/6G7

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g 15 Ottain Current Non-system NU Documents for Unt 3 12/2096 1(14/97 l

16 C7 4 Unt 3 Prof. Manual / Pts & AP 1/1097 2f27s7 17 Cr.Q Unt 3 reviewchecidests 2I28/97 3I24/97 18 Hold KO. moeung w/ NRC & Submt Audt Plan for approval 3/1207 3/12/97 19 NRC review Unt 3 Audt Plan & Pts 3/13G7 4r2s7 20 Muuius and Train Project Team 4/3G7 4/9s7 21 NU notifies NRC that Unt 3 wis be reedy for ICAVP on SEG7 4/1407 4/1497

• d 22 NRC Select Unt 3 systems 4f1507 4t E/97

" tY 23 Obtain Unt 3 system specino documents 4/3W97 6/7s7 l

24 Perform Rewows for Unt 3 5/847 7/2S7 25 riws and Report Unt 3 Findings 5/2907 7/18 s 7 Pann 1

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Northeast Utilities - Millstone Units 1 & 3 swunit ag ICAVP Implementation Schedule November December l

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Fetr ID Task Novie Start Finleh 11/10 l 11/17 l 11/24 12/1 l 12s 112/1Sl12/22l12/291 15 l 1/12 l 1h9 l 1GB l 2/2 l 2s 26 NU Provide Pr------J ResokAkm et12s7 700s7 27 Review NU Proposed Resolutkm 6/2S!97 7/30G7 28 Prepare Unt 3 Final Report 7/24/97 8t13s7 29 NU request S&L propoe=1for Una 1 12/2000 12f2 DSS 30 S&L submt rW supplement for Una 1 1n97 trtas7 31 NUlesue Letter ofIrtert for Unt 1 1/1497 1/17s 7 32 Obtain Currert Non-system NU Documerts for Unt 1 1/27s 7 2/167 33 Cr.4 Una 1 Pts / AP & Submt to NRC 212 8 S 7 3/17s7 34 Dowlop Una 1 re-Aewchecidlets 3/18s 7 3/24hE 35 NRC rm4ew Unt 1 Audt Plan & Pas 3n8s7 4f7s7 36 NU notdies NRC that Unt 1 is ready for ICAVP 3/17s7 3/17s 7 37 NRC Seied Una 1 systems 3/25/97 4/7s7 38 Ottain Unt 1 system specific documerts 4/8S7 4/14/97 39 P-Lm Reviews for Unt 1 4/15s 7 C/9s7 40 Pivwas and Report Unt 1 Findings 5ss7 6/23/97 41 NU Provide Proposed Resokson 5/20 s 7 7/7s7 42 ReviewNU Proposed Resoktion 6397 717 s 7 43 Prepare Unt 1 Final Report 7/1/97 7/2127 N

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Exhibit 7 ICAVP Budget Data Project No.: 9583-110 Task Codes: As follows:

Task Code Descriotion A00311 Development ofProject Manual A30020 Project Administration A30022 IRC Review ofDRs and Disposition A30027 Development of Communications Protocol A30028 Development ofWeb Site A30055 Training & Mobilization g

A30056ARG ARG - Perform Reviews / Report Findings A30056CRG CRG - Perform Reviews / Report Findings A300560RG ORG - Perform Reviews / Report Findings A30056PRG PRG - Perform Reviews / Report Findings A30056SRG SRG - Perform Reviews / Report Findings A30057 Evaluate Resoir. tion ofFindings A30058 Final Rep' art A30090 Independent Oversight Team 4

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• gs PROJECT INSTRUCTION PI-MP1-01 j

INSTRUCTION REV.O l

Client: Northeast Utilities Station: Millstone Unit 1 i

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Title:

INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM l

COMMUNICATIONS FROTOCOL 4

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[ Safety-Related Non Safety-Related l

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Reviewed By:

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System Lead Programmatic O&M Lead Accident QA Engineer Intemal Review Verification Team j

Lead Mitigation Committee Manager 1

Lead Chairman

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INSTRUCTION PI-MP1-01 INSTRUCTION REV.0 a

l 1.0 PURPOSE j

The purpose of employing an independent reviewer for the Independent C' rrective Action Program (ICAVP)is to obtain an unbiased assessment of o

}

the Millstone Unit 1 configuration management and corrective action l

programs. Therefore, every reasonable effort will be made to assure that the j

observations and conclusions made are the result of the Project Team's own j

independent assessment and not influenced or biased by representations of l

other parties such as the NU line organization or their contractors responsible for subjects under review. To maintain this assurance of independence, this formal protocol has been established and will be implemented to control the i

communications between S&L, NU, and the NRC. This protocol has been written so that the Project Team reviewers remain objective and unbiased, yet 9

will permit the legitimate need for the Project Team to communicate with the NU organization to obtain information including any necessary verbal i

clarification to maintain an efficient process. It is, however, the responsibility j

of the independent reviewers to assure that these guidelines are implemented in a manner which assures the objectivity and independence of the review.

tO 1

Sargent & Lundy Project Team intemal communications are unaffected by the l

requirements of this protocol, including those between or among the j

Verification Team, the Internal Review Committee and the Independent i

Oversight Team (IOT).

}

2.0 ORGANIZATIONAL-POINTS OF CONTACT Each of the organizations involved in the ICAVP (NRC, NU, and S&L) has provided a primary and backup point of contact. These points of contact are the personnel through which inter-organizational communications will occur or be arranged. This includes both verbal and written communications, including electronic mail.

i l

N Page 2 of 8

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PROJECT INSTRUCTION PI-MP1-01 INSTRUCTION REV. O i

i 2.1 Northeast Utilities i

Primary

Contact:

Bob Grazio, ICAVP Project Manager li Phone - 860-440-0459 Fax - 860-444-5520 l

e-mail-grazire@gwsmtp.nu.com l

Ovemight mail-Northeast Utilities i

j Millstone Nuclear Power Station i

Rope Ferry Road l

Waterford, CT 06385 l

Backup

Contact:

Richard Laudenat Phone - 860-440-5248 Fax - 860-440-2091 j

Ovemight mail-Northeast Utilities 4

Millstone Nuclear Power Station l

Rope Ferry Road 1

i Waterford, CT 06385 iO l

2.2 Nuclear Regulatory Commission i

Primary

Contact:

Gene Imbro, ICAVP Manager l

Phone - 301-415-1490 l

j Fax - 301-415-2260 i

e-mail - evi@nrc. gov

{i Ovemight mail - Nuclear Regulatory Commission 11555 Rockville Pike j

Roc 2ville, MD 20852-2738 Backup

Contact:

i.oren Plisko, ICAVP Team Leader Phone - 301-415-123' Fax - 301-415-2260 e-mail -Irp@nrc. gov Ovemight mail - Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 m

Page 3 of 8

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

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PROJECT INSTRUCTION PI-MP1-01 INSTRUCTION REV.0 1'

2.3 Sargent & Lundy

)

Primary

Contact:

Don Schopfer, Verification Team Manager l

Phone - 312-269-6078 Fax - 312-269-2049 j

e-mail - don.k.schopfer@sichicago.infonet.com i

Ovemight mail-Sargent & Lundy l

55 E. Monroe Street l

Chicago,IL 60603 4

I Backup

Contact:

Bryan Erler, ICAVP Project Director Phone - 312-269-7132 Fax - 312-269-2049 l

e-mail - bryan.a.erler@sichicago.infonet.com j

Ovemight mail-Sargent & Lundy i

55 E. Monroe Street l

Chicago,IL 60603 '

i 3.0 RULES FOR VARIOUS TYPES OF COMMUNICATIONS

!O There are a variety of types c e i ommunications necessary to effectively j.

implement the ICAVP. The ft 7 wing identifies the various types of inter-i organizational communications required and defines the rules goveming those l

types of communicatier.s. These rules address aspects such as who initiates the communication, whether notification of other parties is given, who may l

participate in the communication, whether public access is to be given, and j

the documentation requirements for the communication and to whom it is i

l provided. Other communication between personnel in these project j

organizations or their contractors should be avoided during the performance of the ICAVP.

3.1 Request for information - S&L will need significant amounts of j

documents and drawings from NU to commence and proceed with the i

review. The information request process from S&L to the NU organization will be a frequent occurrence during the ICAVP.

4 The S&L Verification Team Manager, or one of the Review Leads, will submit all requests for information to the NU primary contact or his designee in writing. This may be via fax, e-mail or ovemight mail.

i Page 4 of 8 4

i PROJECT INSTRUCTION PI-MP1-01 INSTRUCTION REV. O l

Each request shall be on a standard form developed for this purpose and shall be provided with a sequential number for tracking (See l.1). A copy of each request for information shall be provided to the NRC's primary contact. NU's response to the requests shall be submitted in duplicate to the S&L primary contact, one copy to l

Chicago and one copy the office space provided by NU to S&L near the Millstone station. NU shall provide an index of all documents submitted, including a revision number or identifying date.

In order to ascertain the availability of information or to identify the appropriate documents containing required information, the S&L j

Verification Team Manager or one of the Review Leads may contact i

the NU primary contact or a designated Document Control personnel

)

via phone. This type of informal contact shall only be made in the i

process of preparing and submitting a request for information.

i 3.2 Request for informal conference - S&L may on occasion request a conference with NU lire organization personnel to obtain clarification or 3

i further understanding of particular issues. Altemately, NU may request a (O

i coorere"ce to eisc" orcierir riaeioo is vee a sa' T"i comreremce v

v can be by telephone, by videoconference, or in person 1

The primary contact for the organization initiating the informal conference shall contact the primary contact of the other organization (via phone, fax, or e-mail) and identify the reason for the conference and the participants needed. The NRC primary contact will be notified i

of the conference and given the opportunity to participate. A minimum of a half day advanced notice shall be provided to the participating organization and to the NRC. Notes of the conference shall be written by the initiating organization and distributed to the primary contacts of the participating organizations and the NRC.

3.3 issuance of Findings - The findings identified by S&L will be distributed to NU and the NRC, including their posting on an Internet Web Site.

The S&L primary contact, or designee, will distribute the findings (discrepancy reports) from the ICAVP to the NU and the NRC primary contacts by fax and ovemight mail. In addition, S&L will post the findings on a uniquely identified Intemet page. This will allow public Page 5 of 8

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PROJECT INSTRUCTION PI-MP1-01 INSTRUCTION s

REV.O access to this information. More information about accessing the ICAVP information on the Intemet is included in Section 4.0 of this protocol. The S&L instructions for the processing of the discrepancy reports and their proposed resolutions is provided in project instruction PI-MP1-11.

3.4 Submittal of proposed resolutions - NU will evaluate the findings submitted by the S&L Project Team and develop proposed resolutions and submit these proposed resolutions to S&L for review.

The NU primary contact will submit the proposed resolutions to the ICAVP findings to both the S&L and the NRC primary contacts.

j Following acceptance of the resolution in accordance with PI-MP1-11 S&L will post the NU resolution on the ICAVP Web Site.

3.5 Formal Meetings or Briefings - It is expected that there will be formal meetings with the various participants and the public to discuss the results of the program.

Formal meetings to discuss the results of the ICAVP and periodic briefings for the public will normally be scheduled in advance or initia.ted by the NRC. The NRC will notify the NU and S&L primary contacts at least one week in advance of the meetings. For meetings open to the public, the NRC normally provides a two week notification.

S&L will also post meeting notification on the Web Site for meetings open to the public after the NRC has issued notification. S&L participation at this type of meeting will normally be the Project Director, the Verification Team Manager, and others as may be determined by S&L. Participation other than S&L will be determined by the NRC. If the NRC has the meeting transcribed, no other notes of meeting are required. Otherwise, S&L will publish notes from the meeting and distribute them to the participants. Copies of all presentation material will be available at the public meetings and will be posted to the Web Site.

3.6 Meetings between S&L and IOT - The S&L Project Team will have periodic meetings to brief the Independent Oversight Team on the progress of the ICAVP. The IOT is considered part of the S&L review process.

Muuuummers r

Page 6 of 8 3

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INSTRUCTION PI-MP1-01

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INSTRUCTION REV.O i

l Periodic meetings between S&L and the IOT will normally be scheduled well in advance. A minimum two week advanced notice will be provided for non-routine meetings. S&L will contact each member of the IOT by fax, e-mail, or ovemight mail, as appropriate, with the i

meeting logistics and an agenda for the meeting. This meeting will not I

be open to the public, but the NRC will be given an opportunity to

)

attend. Notes of the meeting will be prepared by S&L and distributed to all 10T members and the NRC primary contact.

1 3.7 Press and/or Media Communications - Based on the current level of public interest in the ICAVP and Millstone in general, there is expected to be press and media interest in the work of the ICAVP Contractor.

}

Communications with the press and media and notification of the NRC and NU of such interest are included in this protocol.

l Requests for interviews with the press or media shall be referred to i

the Project Director or the Verification Team Manager. One of them shall notify the NU and the NRC primary contact of the request. The j

Director or Manager shall respond appropriately to the press or media i.

requests.

}

3.8 Communications related to NRC oversight of S&L - S&L's activities in the ICAVP are considered an extension of the NRC. As such, j

communication between S&L and the NRC will be required, both related to the execution of the review and to the NRC's oversight of S&L's l

performance.

.l From time to time S&L may have specific questions or need direction i

from the NRC. When necessary the S&L primary contact may call or meet with the NRC primary contact, or his designee, to discuss these issues. Notes of conference shall be prepared by S&L to reflect j

specific decisions, actions or direction provided, and these notes shall be distributed to the NRC primary contact. No other participants are j

required for a conference of this type between S&L and the NRC nor

]

will the notes be distributed to any other party.

I Pm i

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INSTRUCTION PI-MP1-01 INSTRUCTION REV.0 l

3.9 Financial / Contractual issues between S&L and NU - As with any i

contractual relationship between two organizations, periodic discussions i

and / or written communications will be required between S&L and NU.

1 These discussions will be outside the scope of this protocol. This type of communication will be primarily between the S&L Verification Team Manager and the NU Director - Contracts & Purchasing and/or the NU i

ICAVP Project Manager, and will be limited to purchasing and contract related issues.

4.0 PUBLIC ACCESS TO ICVAP INFORMATION ON THE INTERNET l

As discussed in earlier sections of this protocol, discrepancy reports identified f

during the course of the ICAVP and their accepted resolution will be posted on i

the Intemet Web Site to allow public access. In addition, certain other documents will be posted on the Web Site, including portions of the Project i

Manual, periodic status report information, and the final report. The address for the Web Site is http:/hvww.mp_icavp.com.

O i

Sargent & Lundy will add a hyperlink on its Internet home page entitled j

Millstone ICAVP that will send the viewer to that page with a menu showing i

the available documents posted. The S&L home page may be accessed on 4

the Intemet World Wide Web at http://www.s/ chicago.com.

5.0 ATTACHMENTS 5.1 ICAVP Request for information (1 page) m Page 8 of 8

i PI-MPI-01 M=A-* 5.1

~

Northeast Utilities RFI No.

afillstone Unit 1 REQUEST FORINFORMATION INDEPENDENT CORRECTIVE ACTION VERIFICATION PROGRAM i

To:

Mr. Bob Grazio, ICAVP Project Manager s

1 From:

Date ofRequest:

/DateNeeded by:

t 1

a Document Title or Descrintion Document Title or Descrintion 3

3

{

i, e

l t

)

cc: Mr. D. K. Schopfer i

2

1 l

t I

)$'"*"

PROJECT INSTRUCTION PI-MP1-02 REV.O i

INSTRUCTION Client: Northeast Utilities Station: Millstone Unit 1

Title:

REVIEW OF SYSTEM DESIGN FOR COMPLIANCE WITH THE DESIGN AND LICENSING BASIS S Safety-Related Non-Safety-Related l

Reviewed By:

Approved By:

i System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team Lead Mitigation Committee Manager l

Lead Chairman

/

Date: 3'/7-97 l

Sf/W' Wl & $cWSerk ($lhduhiPYmb kW Description IngalIdue d ' ))

Gl 1

1 l

PROJECT INSTRUCTION PI-MP1-02 INSTRUCTION REV.0 l

)

1.0 PURPOSE j

Thls instruction establishes the requirements for the design review of systems included in the scope of the Independent Corrective Action Verification l

Program (ICAVP). The purpose of the design review is to verify the system design as reflected on design output documents and design process j

documents is consistent with the plant's Design and Licensing Basis.

l Additionally, the design review will verify technical adequacy of design j

process documents.

i j

2.0 REFERENCE i

I 2.1 NRC Inspection Manual Procedure 93801, Safety System Functional j

inspection

}

2.2 NRC Inspection Manual, Chapter 2535, Design Verification Programs 2.3 10CFR50.2, Definitions 2.4 NRC Confirmatory Order Establishing Independent Correction Action Verification Program - Millstone Nuclear Power Station, Units 1, 2, and 3 2.5 NUMARC 90-12, Design Basis Program Guidelines 2.6 PI-MP1-06, Operations and Maintenance and Testing Procedures and

{

Training Documentation Reviews i

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2.7 PI-MP1-07, Review of System Design for Compliance with the Design and Licensing Basis 2.8 PI-MP1-09, Preparation and Approval of Checklists 2.9 PI-MP1-11, Discrepancy Report Submittal and Closure 2.10 Pl-MP1-12, Project File Index 4

j 2.11 Northeast Utilities Configuration Management Plan N

4 Page 2 of 15

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INSTRUCTION PI-MP1-02

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INSTRUCTION REV.O i

1 2.12 CK-MP1-02 Series Checklists as follows:

i CK-MP1-02-01 System Reference List CK-MP1-02-02 System Requirements List l

CK-MP1-02-03 Design Process Document Review Checklist CK-MP1-02-04.1 P&lD Review Checklist

}

CK-MP1-02-04.2 Logic Diagram Review Checklist i

CK-MP1-02-04.3 Electrical Schematic Review Checklist i

CK-MP1-02-05.1 MechanicalComponent Review CK-MP1-02-05.2 Electrical Component Review i

CK-MP1-02-05.3 l&C Component Review CK-MP1-02-06 Position Paper Review Npote:

j Checklists used in the performance of this P1 are not included as attachments to the Pl. Checklists are prepared and controlled as I

separate documents per PI-MP1-09.

i l

3.0 DEFINITIONS i

3.1 Accident Mitigation Systems Review Group (ARG)- The subgroup of the ICAVP Verification Team responsible for review of critical characteristics of accident mitigation systems to ensure those systems can perform their required safety functions.

3.2 Operations & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification Team responsible for the review of the j

operating, maintenance and testing procedures, and training materials for j

the systems within the scope of the ICAVP.

i i

3.3 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

3.4 Configuration Review Group (CRG)- The subgroup of the SRG Verification Team responsible for walkdowns to verify the current as-built conditions are in conformance with the design output documents.

Pm Page 3 of 15

PROJECT INSTRUCTION PI-MP1-02 INSTRUCTION REV.O i

j 3.5 Design Bases - The information which identifies the specific functions to j

be performed by a structure, system or component of a facility, and the specific values or ranges of values chosen for controlling parameters as i

reference bounds for design. These values may be (1) restraints derived from generally accepted ' state of the art" practices for achieving functional goals or (2) requirements derived from analysis of the effects of 4

i a postulated accident for which a structure, system or component must meet its functional goals (Reference 2.3).

i 3.6 Design Output Documents - Controlled plant documents such as specifications, drawings, vendor drawings, datasheets, lists and

{

databases (Reference 2.5).

4 3.7 j

Design Process Documents - Documents such as calculations, analysis, evaluations or other documented engineering activities that substantiate j

the final design (Reference 2.5).

j 3.8 Current Licensing Basis (CLB)- The set of NRC requirements applicable to a specific plant, and a licensee's written commitments for j

assuring compliance with and operation within applicable NRC i

i requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19, 20, 21, 30, 40, 50, 51, 55, 72, 73,100 and appendices thereto; orders; license conditions; exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented in the most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports. (Reference 2.6)

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3.9 Verifier - The individual assigned to review engineering attributes within his area of responsibility.

3.10 Millstone 1 Position Papers - The documents prepared by NU as part of the Unit 1 Configuration Management Plan which describe the Unit 1 m

Page 4 of 15

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INSTRUCTION PI-MP1-02 INSTRUCTION REV.0 1

i committments to regulatory guidance, such as the general design critieria, i

and to topical subjects, such as heavy loads, HELB/MELB, single failure, etc. (Reference 2.11) i 4.0 RESPONSIBILITIES 4.1 The Verification Team Manager shall be responsible for overall j

management of the Verification Team.

4.2 The SRG Lead shall be responsible fer assigning the L0ad Verifier for 3

each system in the ICAVP scope and for overall coordination of the SRG i

effort.

4.3 The Lead Verifier shall be responsible for performing system reviews for i

the attributes within his area of expertise and for assigning verifiers with appropriate background for review of remaining attributes.

I 4.4 The Verifiers shall be responsible for performing reviews of engineerirg

!O attributes within their area of expertise in accordance with this instruction.

I 5.0 PROCEDURE i

5.1 General The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in Section 2.0 of this PI requires Northeast Utilities (NU) to i

implement the ICAVP. The confirmatory order also defines the scope of j.

the ICAVP. Item 2 of the scope of the ICAVP described on page 13 of the confirmatory order requires the Licensee to verify the current as-modified j

plant conditions against design basis and licensing basis documentation.

This procedure describes one aspect of the process needed to perform the verification described above. Specifically, this procedure will determine if the current system design as reflected on design output i

documents and design process documents is consistent with the system design basis and licensing basis documentation. Changes to the plant made after receipt of the units operating license will be reviewed per PI-

{

MP1-03 as part of the modification review process.

i, i

l 4

Page 5 of 15 4

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PROJECT INSTRUCTION PI-MP1-02

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INSTRUCTION REV.O i

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The systems to be included in the scope of the ICAVP program will be defined by the Nuclear Regulatory Commission. Once the systems have d

been identified, the following tasks shall be performed in order to determine if the system's design is consistent with the plant's design and licensing basis:

I l

a. Document Retrieval & Review i

b. Identification of System Requirements

c. Technical Review of Design Process Documents

d. Upper Tier Drawing Review l

e. Component Review l

f. Reconciliation of Design vs. Design & Licensing Basis

g. Discrepancy Report Preparation and Closure l

h. Final Report Preparation j

The detailed instructions for performing these tasks are provided in the i

subsections 5.2 through 5.9 below. References 2.1,2.2 and 2.4 were used to develop these instructions. Attachment 6.1 is a flow chart

{

illustrating the system review process.

O 5.2 Document Retrieval & Review i

5.2.1 Since there may be duplication between documents required by the l

various review groups, the following division of responsibility has been j

established:

l 5.2.1.1 The SRG shall gather, as a minimum, the following licensing and design bases documents and system specific documents:

1 a.

Design & Licensing Basis Documents (Applicable Sections i

Only) i a.1 NRC Regulations i

a.2 Technical Specifications i

a.3 Updated Safety Analysis Report a.4 NRC Safety Evaluation Report j

a.5 MP1 Commitments to NRC

(

a.6 Design Basis Documentation Package (DBDP) j b.

System Specific Documents m

Page 6 of 15

PROJECT INSTRUCTION Pl-MP1-02 INSTRUCTION REV.0 b.1 Engineering Calculations (Mech, Elect, Struct, I&C and Piping Analysis) l b.2 Equipment Procurement Specifications i

b.3 Modification Packages b.4 System Descriptions b.5 Equipment List b.6 Environmental and Seismic Qualification Reports \\

)

b.7 Findings and corrective actions identified by NU during the j

implementation of their Configuration Management Plan j

(CMP) l 5.2.1.2 The ORG Shall gather, as a minimum, the documents listed below-a.

Operating Procedures including Emergency Operating Procedures b.

Maintenance Procedures c.

Surveillance Test Procedures l

d.

Vendor Manuals j

e.

System Training Procedures

{

f.

Necessary Support and/or Related Procedures i

i 5.2.1.3 The CRG shall gather, as a minimum, the following system specific drawings:

)

a.

P&lDs b.

Logic Drawings j

c.

Electrical Schematics d.

Piping Drawings e.

Electrical Single Line Drawings f.

Panel Wiring Drawings g.

Cable Routing Drawings and Databases h.

Pipe Support Drawings 1.

Structural Equipment Mounting Details i

J.

General Arrangement / Equipment Location Drawings k.

Instrument Location Drawings j

l.

Zone Maps (Environment / Fire Protection, etc).

t 5.2.2 Design and Licensing Basis documents are available in the S&L ICAVP Library. System specific documents shall be obtained from 4

l 6

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INSTRUCTION PI-MP1-02 INSTRUCTION REV.0 NU. Requests for documentation from NU shall be submitted in 4

j accordance with subsection 3.1 of PI-MP1-01.

i 5.2.3 Once the documents hcve been gathered, each group shall complete the applicable section of the System Reference List (SRL) and forward the completed SRL to the SRG Lead. Checklist CK-MP1-02-01 shall l

be used for the SRL.

j i

5.2.4 The SRG Lead shall combine the SRL input from each review group, and issue the combined list for use to the ORG, SRG and CRG.

i 5.2.5 Each member of the ORG, SRG and CRG assigned to review the system shall study the documentation to become as familiar as 1

possible and achieve an in-depth understanding of the system as it relates to their area of expertise. Each member shall also review the findings and corrective actions that resulted from NU's CMP. S&L shall not duplicate findings identified by the NU CMP.

[

1 5.2.6 If the need for additional documents is identified during the review O

Process. ihese decemeets s8eii ee renvested ia accoreence wit 8 subsection 5.2.2 cf this Pl.

i 5.2.7 Requests for updates to the SRL shall be forwarded to the SRG Lead.

j The SRG Lead shall issue formal revisions to the SRL as needed.

l l

5.2.8 The SRG Lead shall file the SRL in accordance with PI-MP1-12.

l l

5.3 Identification of System Reauirements l

l 5.3.1 The SRG shall review the licensing and design basis documents to identify the functional, performance, and other design requirements for l

the system being reviewed. Identification of operating, testing and maintenance requirements shall be performed by the ORG in accordance with PI-MP1-06. The licensing and design basis documents reviewed shall, as a minimum, include the FSAR, SER, i

Technical Specifications, licensing committments, and the Unit 1 j

position papers.

)

l Page 8 of 15

i PROJECT INSTRUCTION PI-MP1-02 j

INSTRUCTION REV. O i

l Note: The review of Unit 1 Licensing committments will include those l

committments identified by NU during the CMP. S&L will net j

perform'an independent document search to verify that NU has j

identified all applicable committments.

5.3.2 The SRG Lead shall assign a Lead Verifier for each of the systems being reviewed. The Lead Verifier shall be from the related discipline (Mechanical for Mechanical System, Electrical for Electrical System, i

etc). The SRG Lead shall also assign verifiers from other disciplines as needed to support the system review pro::ess.

5.3.3 The Verifier (s) shall review the Licensing and Design Basis i

Documents for the system being reviewed to identify design, j

performance and functional requirements. Each requirement shall be j

tabulated along with a reference on the Systems Requirements Checklist (Checklist CK-MP1-02-02).

i 5.3.4 The system requirements review for functional, performance and 4

design requirements shall be limited to the following design aspects:

!O l

a.

Mechanical Design l

b.

Electrical Design c.

l&C Design d.

Structural Design e.

Piping Design f.

Equipment Qualification (environmental and seismic) 5.3.5 The Lead Verifier shall incorporate input received from the ORG (per PI-MP1-06)into the System Requirements Checklist. The Lead Verifier shall also incorporate the characteristics identified by the ARG j

(per PI-MP1-07) for the system if the ARG determines the system is an accident mitigation system. Upon completion, the Lead Verifier shall I

obtain signatures from the verifiers providing input and shall sign the

" Input Approval" block of the checklist.

5.3.6 The Lead Verifier and/or Verifiers shall also perform an independent review of the position papers prepared by NU as part of the CMP.

i This review shall be documented using Checklist MP1-02-06. The intent of this review shall be to verify the adequacy and completeness j

O Page 9 of 15

PROJECT INSTRUCTION PI-MP1-02 INSTRUCTION REV.O of the position paper and to verify the position papers agree with licensing committments identified by the NU CMP.

5.3.7 The SRG Lead will review the Systems Requirements Checklist and Position Paper Review Checklist for completeness and shall indicate his concurrence by signature and date in the appropriate block on Checklist CK-MP1-02-02.

5.3.8 The SRG Lead shall distribute the checklists to the ORG Lead and to applicable SRG verifiers for use and to the project file in accordance with PI-MP1-12.

5.4 Technical Review of Des:an Process Documents 5.4.1 The SRG shall perform a detailed review of applicable design process documents to verify technical adequacy.

5.4.2 Applicable design process documents shall include:

j Mechanical calculations (hydraulic calculations, component a.

O sizing calculations, design pressure and tem, 'nture calculations, NPSH calculations, etc.

b.

Electrical calculations (load calculations, voltage drop, etc.)

c.

180 calculations (setpoint calculations) i d.

Structural calculations (equipment mounting, pipe supports, cable tray supports, conduit supports, etc.)

e.

Piping Analysis i

f.

EQ/SQ Reports Note: The review process is not intended to include the entire population of repetitive component calculations such as pipe support calculations. The SRG shall review an adequate sample of repetitive type calculations.

5.4.3 Checklist CK-MP1-02-03 shall be used to document the design process document review. The applicable subject specific checklists from PI-MP1-03 shall also be used.

5.4.4 The Verifier (s) shall review the adequacy of the following attributes:

m Page 10 of 15 2

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PROJECT INSTRUCTION PI-MP1-02 1

INSTRUCTION REV.0 i

a.

Numerical Accuracy - The numerical aspects and mathematical operations shall be error free. The number of significant figures i

shall be consistent with the input data, assumptions and design l

methodology. Transposed or transferred numbers are correct.

l i

b.

Modeling Accuracy - Analytical models shall be consistent with the degree of accuracy of the input data, assumptions and design methodology.

c.

Assumptions and Engineering Judgment - Assumptions and i

engineering judgment shall be consistent with the design j

approach and methodology.

f d.

Design inputs - Design inputs shall be based on the latest controlled design documents.

i j

e.

Methodology - The method shall be appropriate for the purpose i

and scope of the calculation.

l 5.4.5 The Verifier (s) shall note any comments identified during the review on the Design Process Document Review Checklist (CK-MP102-03).

5.4.6 The Verifier (s) shall evaluate the comments to determine if they affect the conclusion of the Design Process Document. The evaluation shall l

be documented on the Design Process Document Review Checklist j

(CK-MP1-02-03).

l 5.4.7 The Verifier (s) shall indicate on the checklist coversheet (CK-MP102-i

03) whether the conclusions are acceptable with comments or unacceptable, and shall sign and date the coversheet.

l 5.4.8 For acceptable with comments or unacceptable dispositions, the 1

Verifier shall generate a Discrepancy Report per subsection 5.8 of this Pl. The Verifier (s) shall also evaluate the unacceptable disposition for impact on other documents that may use the conclusion as input. The

]

Verifier (s) shall consult other SRG members while evaluating the Impact.

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PROJECT INSTRUCTION PI-MP1-02 INSTRUCTION REV.O Note: Calculation results are typically used as input in other documents. If a Discrepancy is identified which affects the result of the calculation, it is important to define where those results were used and evaluate those documents for impact. The review should be done prior to generating a Discrepancy Report so that the Discrepancy Report describes the full extent of the condition.

5.4.9 The Lead Verifier shall verify the checklists have been properly completed, indicate his concurrence with signature and date, and shall compile and file the design process document review checklists prepared by the Verifier (s) to the project file in accordance with Pl-MP1-12.

5.5 Upper Tier Document Review 5.5.1 The SRG shall perform a functional review of the upper tier drawings to verify the system is capable of performing its functions as described in the design and licensing basis. The SRG shall also perform a technical review cf the drawings to verify conformance to design calculations and classification criteria.

5.5.2 The Verifier (s) shall utilize drawing review checklists CK-MP1-02-4.1, -

4.2, -4.3 for the review of the P&lDs, logic diagrams and electrical schematics, respectively. These checklists define the attributes to be reviewed. In general, review attributes will include flow paths, interlocks, automatic actuations, permissives, redundancy and separation, safety classification, component sizes, pressure class, overpressure protection, etc. The review is not intended to identify drafting or style errors.

5.5.3 The Verifier (s) shall note any comments on the applicable checklists (C K-MP1-02-4.1, -4.2, -4.3).

5.5.4 Upon completion of the review, the Verifier (s) shall sign and date the coversheet of the applicable checklists.

5.5.5 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.8 of this PI for any discrepancies not previously identified by the NU CMP.

m Page 12 of 15

PROJECT INSTRUCTION PI-MP1-02 INSTRUCTION REV.0 5.5.6 The Lead Verifier shall verify the checklists have been properly completed, indicate his concurrence with signature and date, and shall compile and file all drawing review checklists prepared by the Verifier (s) in the project file per PI-MP1-12.

5.6 Component Review 5.6.1 The SRG shall perform a detailed review of system components. This review shall verify the design data included in the design and licensing basis, the vendor drawings, the procurement specifications, equipment list and calculations are consistent.

5.6.2 The scope of this review shall include all major mechanical, electrical and l&C components.

5.6.3 Detailed component checklists are included in the CK-MP1-02-05 series checklists. These checklists verify attributes such as classification, design conditions, operating conditions, functional requirements, applicable codes and standards, performance requirements, and qualification requirements, etc.

5.6.4 The Verifier (s) shall complete individual Component Review Checklists (CK-MP1-02-05 series) for each component within the scope of review. Discrepancies noted shall be indicated in the appropriate blocks on the checklists.

5.6.5 Upon completion of the review, the Verifier (s) shall sign and date the checklists.

5.6.6 The Verifier (s) shall generate a Discrepancy Report in accordance with Subsection 5.8 of this PI for any discrepancies not previously identified by the NU CMP.

5.6.7 The Lead Verifier shall verify the checklists have been properly completed, indicate his concurrence with signature and date, and shall file all completed checklists in the project file per PI-MP1-12.

m Page 13 of 15

T I

PROJECT M[

INSTRUCTION PI-MP1-02 INSTRUCTION REV.O i

h 5.7 Reconciliation of Deslan vs. Desian and Licensina Basis i

I 5.7.1 The SRG will complete the verification of the system design versus the l

design and licensing basis documentation. The verification shall be l

completed by dispositioning each requirement on the System Requirements Checklist (Checklist CK-MP1-02-02).

)

5.7.2 Where applicable, the Verifier (s) shall identify on the System l

Requirements Checklist, the design process documents which verify the restraints imposed by the system requirement are not exceeded.

I The Verifier (s) shall either indicate the design process document is

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technically adequate or describe any deficiencies. The Verifier shall also identify missing design process documents, if applicable.

I 5.7.3 The Verifier (s) shall identify on the System Requirements Checklist, the design output documents related to the system requirement. The Verifier shall indicate whether the technical requirements contained in j

the design output documents are consistent with the system i

requirements or shall identify the discrepancy.

i 5.7.4 The Verifier (s) shall initial and date all entries in the System Requirements Checklist, and shall sign the System Requirements l

Checklist when completed.

5.7.5 The Verifier (s) shall generate a Discrepancy Report in accordance with Subsection 5.8 of this PI for any discrepancies not previously i

identified in Subsection 5.4,5.5, and 5.6 of this procedure, i

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i Page 14 of 15 i

j PROJECT INSTRUCTION PI-MP1-02 INSTRUCTION REV.O i

i 5.7.6 The SRG Lead shall review the disposition in the system requirements 4

Checklist (CK-MP1-02-02) for completeness and technical accuracy.

The SRG Lead shall indicate his concurrence with signature and date I

in the appropriate column. The SRG Lead shall notify the ARG Lead that either all critical characteristics for accident mitigation systems have been satisfied or he shall identify which have not been.

i 5.7.7 The Lead Verifier shall file the completed checklists in the project l

file per PI-MP1-12.

I 5.8 Discrepancy Report Preparation and Closure i

j 5.8.1 Discrepancy Reports for discrepant conditions identified during the system review process shall be prepared and processed in i

accordance with Pl-MP1-11. Discrepancy reports shall not be initiated

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for findings already identified by NU during implementation of the CMP.

i (O

5.8.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in accordance with PI-MP1-11.

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5.9 Final Report i

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5.9.1 The Lead Verifier shall draft a final report summarizing the results of j

the system review.

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5.9.2 The report format shall be determined by the Verification Team

Manager, i

i 5.9.3 The report shall be reviewed and approved by the VT Lead, VT Manager and IRC prior to external distribution.

6.0 ATTACHMENTS 6.1 ICAVP Process Flowchart, ' System Review'. ( 1 page) i i

)

'O Page 15 of 15

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Identify Systems in ICAVP PROCESS FLOWCHART -

lCAVP Scope ATTACHMENT 6.1 SYSTEM REVIEW b]

r NRC v

Gather Design &

Ucensing Basis Documents & Design Output Documents SRG,CRG,ORG 4

Prepare System Reference Ust SRG,CRG,ORG

+

v Distribute APP Define System Design &

System Reference Ucensing Basis / Review emkm:

Ust for Use Position Papers / Prepare System Requirement Ust

\\ mw1-o7 SRG SRG v

i f

f f

Perform Detailed Perform Compoqent i

Submit Des /Uc.

Perform Functional Calc Review Review for (O

Basis Ust to Review (M/E/1/Plping Analysis Consistency (Uc & Des

/

CRG for Use PalD/ Logics /Schm.

& EQ/SQ Rept.)

Basis /Dwg/Cales/

Specs SRG SRG SRG SRG

+

+

+

v Disposition System Requirements Ust

%.e cena.:

SRG

~ "Y Were discrepancies No+

dentified?

i Yes y

Process Discrepancy Reports (PI-MPi 11)

SRG u

u Prepare Review Report SRG

l INSTRUCTION

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I PROJECT INSTRUCTION PI-MPi-03 REV.O I

Client: Northeast Utilities I

i Station: Millstone Unit 1 l

l

Title:

REVIEW OF PLANT MODIFICATIONS PREPARED AFTER RECE!PT OF OPERATING LICENSE FOR

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TECHNICAL ADEQUACY AND FOR CONFIGURATION CONTROL l

l

[ Safety-Related Non-Safety-Related i

i Reviewed By:

Approved By:

System Lead Programmatic O&M Lead Accident QA Engines >r Internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman cate:3-17-17 4,

t*Y

$12h x

l Description Ir(rtialidue d' y s

i Page 1 of 14

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

i PROJECT INSTRUCTION PI-MP1-03 INSTRUCTION REV.0 1.0 PURPOSE This instruction establishes the requirements for the review of modifications to systems included in the scope of the Independent Corrective Action j

Verification Program (ICAVP). The purpose of the modification review is to l

verify the adequacy of the engineering design and configuration control processes.

I

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2.0 REFERENCES

r l

2.1 NRC Inspection Manual Procedure 93801, Safety System Functional i

inspection 2.2 10CFR50.2, Definitions 2.3 NRC Confirmatory Order Establishing independent Correction Action Verification Program - Millstone Nuclear Power Station, Units 1,2, and 3 O

2.4 NUMARC 90-12, Design Basis Program Guidelines 2.5 PI-MP1-02, Review of System Design for Compliance with Design &

Licensing Basis 2.6 PI-MP1-04, Programmatic Reviews 2.7 PI-MP1-05, Physical Plant Configuration Walkdowns 2.8 PI-MP1-06, Operations and Maintenance and Testing Procedures and Training Documentation Reviews 2.9 i';-iviP1-09, Preparation und Approval of Checklists 2.10 PI-MPi-11, Discrepancy Report Submittal and Closure 2.11 Pl-MP1-12, Project File Index Page 2 of 14

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l PROJECT INSTRUCTION PI-MP1-03 INSTRUCTION REV,0 j

2.12 CK-MP1-03, Series Checklists as follows:

i j

CK-MP1-03-01 Modification Review Administrative Checklist CK-MP1-03-02 Modification Screening Checklist CK-MP1-03-03 Mechanical Systems Design Review l

CK-MP1-03-04 Electrical Design Review l

CK-MP1-03-05 l&C Design Review l

CK-MP1-03-06 Structural Design Review i

CK-MP1-03-07 ALARA Design Review CK-MP1-03-08 Security Review CK-MP1-03-09 Appendix R Compliance Review CK-MP1-03-10 Electrical Equipment Qualification Review CK-MP1-03-11 Seismic Qualification Review CK-MP1-03-12 Radiological Environmental Review CK-MP1-03-13 Non-Radiological Environmental Review CK-MP1-03-14 Station Blackout Review CK-MP1-03-15 Control Panel Design Review CK-MP1-03-16 Piping Design Review l

CK-MP1-03-17 Setpoint Database Design Review O

CK-MP1-03-18 Hazards /HELB Program Review CK-MP1-03-19 Fire Protection Review CK-MP1-03-20 Licensing Review CK-MP1-03-21 PRA Review CK-MP1-03-22 Quality Software Design Review CK-MP1-03-23 Installation Plan Review CK-MP1-03-24 Test Plan Review CK-MP1-03-25 Project Closeout Review Note:

Checklists used in the performance of this Pi are not included as attachments to the Pl. Checklists are prepared and controlled as separate documents per PI-MP1-09.

3.0 DEFINITIONS 3.1 Operations & Maintenance and Testing Revtew Group (ORG) -The subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training materials for the systems within the scope of the ICAVP.

Page 3 of 14

PROJECT w-INSTRUCTION PI-MP1-03 O

INSTRUCTION REv. 0 3.2 System Review Group (SRG)-The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

3.3 Configuration Review Group (CRG)-The subgroup of the SRG responsible for walkdowns to verify the current as built conditions are in conformance with the design output documents.

3.4 Design Bases - The information which 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 vslues may be (1) restraints derived from generally accepted " state of the art" practices for achieving functional goals or (2) requirements derived from analysis of the effects of a postulated accident for which a structure, system or component must meet its functional goals (Reference 2.2).

3.5 Design Output Documents - Controlled plant documents such as O

specifications, drawings, vendor drawings, datasheets, lists and databases (Reference 2.4).

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3.6 Design Process Documents - Documents such as calculations, analysis, j

evaluations or other documented engineering activities that substantiate j

the final design (Reference 2.4).

3.7 Current Licensing Basis (CLB)-The set of NRC requirements applicable to a specific plant, and a licensee's written commitments for assuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19, 20, 21, 30, 40, 50, 51, 55, 72, 73,100 and appendices thereto; orders; license conditions; exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented in the most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses l

to NRC bulletins, generic letters, and enforcement actions, as well as i

Page 4 of 14

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PROJECT INSTRUCTION PI-MP1-03

. INSTRUCTION REV.O licensee commitments documented in NRC safety evaluations or licensee event reports. (Reference 2.7) 3.8 Verifier - The individual assigned to review engineering attributes within his area of responsibility.

4.0 RESPONSIBILITIES 4.1 The Verification Team Manager shall be responsible for defining final report format and for overall management of the Verification Team.

4.2 The SRG Lead shall be responsible for assigning the Lead Verifier for each system in the ICAVP scope and for overall coordination of the SRG effort.

4.3 The Lead Verifier shall be responsible for reviewing modification elements within his area of expertise and for assigning verifiers with appropriate background for review of remaining elements.

4.4 The Verifiers shall be responsible for performing reviews of modification j

elements within their area of expertise in accordance with this instruction.

5.0 PROCEDURE 5.1 General The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in Section 2.0 of this PI requires Northeast Utilities (NU) to implement the ICAVP. The confirmatory order also defines the scope of the ICAVP. Item 1 of the scope of the ICAVP described on page 13 of the confirmatory order requires the Licensee to perform a review of the engineering design and configuration control processes. The scope of the review encompasses the modifications to the selected systems since initiallicensing.

This procedure provides the instructions for performing an orderly review of the modifications to the selected systems in order to comply with the confirmatory order and applies to both major modifications and minor modifications. Like for like replacements are not included in the scope of m

Page 5 of 14

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PROJECT M

INSTRUCTION PI-MP1-03

{

INSTRUCTION REV.0 1

this review. Adequacy of the engineering design proce.ss will be determined by performing detailed technical reviews of the modification I

design elements including changes to design process documents and i

design output documents. Adequacy of the configuration control proces.s will be determined by verifying that changes resulting from the modification have been reflected in design output documents, licensing i

documents such as the Technical Specifications and FSAR, plant procedures such as operating procedures, maintenance procedures and i

surveillance procedures, physical configuration and engineering programs. This project instruction only verifies the adequacy of the configuration control process as it relates to design output documents,

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engineering programs and licensing documents. Configuration control as j

it relates to plant physical configuration and plant procedures is covered j

by PI-MP1-05 and -06, respectively. Review of NU's design change l

process procedures is covered by PI-MP1-04.

The review of the system modifications shall be performed in chronological order because of the impact subsequent modifications can have on previous modifications. The SRG shall also be responsible for clearly identifying prior to the CRG and ORG review of the system modification, which portions of modification packages were subsequently revised by later modification. The SRG shall also clearly identify which modifications have not yet been installed. These measures are needed to prevent generation of erroneous discrepancy reports during the CRG system walkdowns and the ORG review of plant procedures.

l The systems included in the scope of this review and the applicable modification packages were identified and retrieved as part of the system review process described in PI-MP1-02. The specific tasks associated with the review of modifications include:

a. Screening of affected modification elements.

b. Review of affected modification design elements.

c. Review of Installation and Test Plans.

d. Review of Changes to Licensing Documents.

e. Review of Modification Close-out.

f. Discrepancy Report Preparation and Closure.

g. Final Report Preparation.

m Page 6 of 14

4 1

1 l

I PROJECT INSTRUCTION PI-MP1-03 INSTRUCTION REV.O i

The detailed instructions for performing these tasks are described in l

Subsection 5.2 through 5.8 below. Attachment 6.1 is a flow chart illustrating the modification review process.

f 5.2 Screenina for Affected Modification Elements i

5.2.1 The SRG Lead shall screen the system modifications to identify i

whether the modification is a Mechanical, Electrical, l&C or Structural 4

modification. The SRG Lead shall then assign a Lead Verifier from the applicable discipline to perform the modification review. The SRG Lead shall document this assignment on the Modification Review i

)

Administrative Checklist (Checklist CK-MP1-03-01).

1 l

5.2.2 The Lead Verifier shall screen the modifications for impact on i

modification elements by completing the Modification Screening

)

Checklists (CK-MP1-0342 Checklists). This task involves responding

}

to a series of questions intended to minimize unnecessary discipline / program personnel review. The Lead Verifier may seek i

assistance as needed from other members within the SRG to respond to questions outside his area of expertise.

5.2.3 The Lead Verifier and Verifier (s) shall respond "yes" or "no" to each question on the checklists and shall initial each response. The topics addressed in the screening checklist include:

MODIFICATION SCREENING

SUMMARY

MECHANICAL SYSTEMS DESIGN REVIEW ELECTRICAL DESIGN REVIEW I&C DESIGN REVIEW STRUCTURAL DESIGN REVIEW ALARA DESIGN REVIEW SECURITY REVIEW APPENDIX R COMPLIANCE REVIEW e

ELECTRICAL EQUIPMENT QUALIFICATION REVIEW SEISMIC QUALIFICATION REVIEW RADIOLOGICAL ENVIRONMENTAL REVIEW e

NON-RADIOLOGICAL ENVIRONMENTAL REVIEW e

STATION BLACKOUT REVIEW CONTROL PANEL DESIGN REVIEW m

Page 7 of 14

PROJECT "fi INSTRUCTION PI-MP1-03 INSTRUCTION REV.O j

i PIPING DESIGN REVIEW SETPOINT DATABASE DESIGN REVIEW l

HAZARDS /HELB PROGRAM REVIEW RRE PROTECTION REVIEW LICENSING REVIEW PRA REVIEW i

TRAINING PROCEDURES REVIEW EMERGENCY PREPAREDNESS PROGRAM REVIEW PLANT PROCEDURES REVIEW (OPS, MAINTENANCE, SURVElLLANCE, TESTING) l CONFIGURATION CHANGE REVIEW QUALITY SOFTWARE DESIGN REVIEW i

5.2.4 When the screening process has been completed, the Lead Verifier 4

shall indicate on the Modification Screening Checklist Summary Sheet (CK-MP1-03-02) which modification elements are affected.

5.2.5 The Lead Verifier shall then assign Verifiers from the applicable O

discipline to perform a detailed review of the affected modification elements in accordance with Subsection 5.3 of the project instruction.

If the screening process identifies that physical plant configuration or plant procedures may be affected by the modification, the Lead Verifier shall forward the completed Modification Screening Checklist (CK-MP1-03-02) and a copy of the modification package to the CRG and ORG for their review. This step shall not be performed until after all modifications to the system have been screened, the impact of subsequent modifications to previous modifications has been assessed, and the identification of modifications not yet installed has been completed. Note: CRG and ORG modification reviews are covered by PI-MP1-05 and 06, respectively.

5.2.6 The Lead Verifier shall document on the Modification Review Administrative Checklist (CK-MP1-03-01) that the affected modification element screening process has been completed and shall file the Modification Screening Checklist in the project file per PI-MP1-12.

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Page 8 of 14

_ _ ~ _ _ _ _. _ _

4 PROJECT INSTRUCTION PI-MP1-03 i

O INSTRUCTION Rev. 0 I

,5.3 Review of Affected Modification Elements

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5.3.1 The Verifier (s) assigned by the Lead Verifier shall perform a detailed review of the affected modification design elements within his area of l

j responsibility. The detailed review shallinclude a verification of the technical adequacy of changes to, or new, design process documents l

and design output dccuments prepared for the modification.

4 l

5.3.2 The Verifier (s) shall review the modifications utilizing the applicable j

element review checklist. The element review checklists include:

Checklist No.

Description l

CK-MP1-03-03 MECHANICAL SYSTEMS DESIGN REVIEW CK-MP1-03-04 ELECTRICAL DESIGN REVIEW I

CK-MP1-03-05 I&C DESIGN REVIEW CK-MP1-03-06 STRUCTURAL DESIGN REVIEW CK-MP1-03-07 ALARA DESIGN REVIEW l

CK-MP1-03-08 SECURITY REVIEW CK-MP1-03-09 APPENDIX R COMPLIANCE REVIEW jO j

CK-MP1-03-10 ELECTRICAL EQUIPMENT QUALIFICATION l

REVIEW i

CK-MP1-03-11 SEISMIC QUALIFICATION REVIE'N l

CK-MP1-03-12 RADIOLOGICAL ENVIRONMENTAL REVIEW l

CK-MP1-03-13 NON-RADIDLOGICAL ENVIRONMENTAL l

REVIEW CK-MP1-03-14 STATION BLACKOUT REVIEW CK-MP1-03-15 CONTROL PANEL DESIGN REVIEW CK-MP1-03-16 PlPING DESIGN REVIEW CK-MP1-03-17 SETPOINT DATABASE DESIGN REVIEW CK-MP1-03-18 HAZARDS /HELB PROGRAM REVIEW CK-MP1-03-19 FIRE PROTECTION REVIEW i

CK MP1-03-21 PRA REVIEW CK-MP1-03-22 QUALITY SOFTWARE DESIGN REVIEW These checklists are intended to identify topics which should be reviewed for each element. The Verifier shall indicate on the checklist whether the topic has been addressed satisfactorily, was not addressed satisfactorily or is not applicable to the modification.

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6 4

i Page 9 of 14

PROJECT INSTRUCTION Pl-MP1-03 INSTRUCTION REV.0 1

4 1

comments needed to substantiate the Verifier (s) response shall be

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entered on the comment sheets included with each checklist.

i 5.3.3 The Verifier (s) shall perform a technical review of the new or revised i

design process documents in accordance with Section 5.4 of PI-MP1-j 02.

5.3.4 The Verifiers shall perform a technical review of new or revised design 1

output documents including drawings, specifications and or lists. The j

review is a line by line review to verify the changes made to the design j

output documents are technically correct and consistent with the level j

of detail previously shown on the drawings.

i

)

5.3.5 When the review is completed, the Verifier shall sign and date the i

applicable element review checklist and forward the completed j

checklist to the Lead Verifier.

i j

5.3.6 The Verifier shall generate a discrepancy report for any discrepancies identified during the review in accordance with Subsection 5.7 of this l

project instruction.

j 5.3.7 The Lead Verifier shall indicate on the Modification Screening j

Summary Checklist (CK-MP143-02) that the affected element has been reviewed and shall indicate whether any discrepancies were identified. When all affected elements have been reviewed, the Lead Verifier shall sign and date the Modification Screening Summary l!

Checklist (CK-MP1-03-02), assemble and file the CK-MP103-03 series detailed element review checklists in the project file per PI-MP1-12.

5.3.8 The Lead Verifier shall indicate on the Modification Review Administration Checklist (CK-MP1-03-01) that the affected modification element detailed review process has been completed.

1 5.4 Be%w of Installation & Test Plans

^

5.4.1 The Lead Verifier shall review the modification scope and confer with other modification verifiers to determine installation and test (s) requirements. The Installation Plan Checklist (CK-MP1-03-23) and Page 10 of 14

PROJECT

1. ~

INSTRUCTION PI-MP1-03 INSTRUCTION REV.0 I

the Test Plan Checklist (CK-MP1-03-24) shall be used as the basis for identifying these requirements.

5.4.2 Once installation and testing requirements have been identified, the Lead Verifier shall assign verifiers to review the installation plan and test plans contained in the modific,ation package.

i 5.4.3 The Verifier (s) shall review the installation plans utilizing Checklist CK-MP1-03-23. This review is intended to verify that appropriate j

installation requirements including welding procedures, ASME Section l

XI, NDE requirements, etc., are specified. Upon completion of their reviews, the Verifiers shall sign and date the checklists. Justification for responses entered on the checklists may be entered on the l

checklists comment sheet.

i 5.4.4 The Verifier (s) shall review the test plans utilizing Checklist CK-MP1-03-24. The review is intended to verify that adequate test requirements including code required preservice tests and j

inspections, component level tests, system level tests and integrated

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tests are specified. Upon completion of the reviews, the Verifier (s) shall sign and date the checklists. Justification for responses entered on the checklists may be entered on the checklist summary sheet. If j

post modification tests are required, the SRG Lead Verifier shall submit the test requirements and acceptance criteria and Checklist i

CK-MP1-03-24 to the ORG for review.

i 1

5.4.5 Discrepancies identified during the installation and test plan review shall be processed in accordance with Subsection 5.7 of this project i

instruction. DRs regarding post-modification tests shall be reviewed i

with the ORG to determine whether the test that ws performed was I

inadequate.

5.4.6 The Verifier (s) shall forward the completed checklists to the i.ead Verifier.

5.4.7 The Lead Verifier shall indicate on the Modification Review Administrative Checklist (CK-MP1-03-01) that the installation and test plan review process has been completed and shall file the applicable checklists in the project file in accordance with PI-MP1-12.

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I PROJECT INSTRUCTION PI-MP1-03 INSTRUCTION REV.0 l

5.5 Review of Chanaes to Licensino Documents i

5.5.1 The Lead Verifier shall perform a review of changes to licensing documentation including FSAR changes and Technical Specification changes to ensure accuracy and completeness. The Lead Verifier j

shall perform a review of the 10CFR50.59 safety evaluation or safety evaluation screening to verify completeness and accuracy.

5.5.2 The Lead Verifier shall review the Licensing Document changes using j

j Checklists CK-MP1-03-20. The intent of this review is to verify that j

changes due to modifications have been reviewed for impact on the FSAR and Technical Specifications. If it is determined that a change is required, the Lead Verifier shall verify changes were processed and j

shall review these changes for consistency with the modification.

i Upon completion of the review, the Lead Verifier shall complete j

l Checklist CK-MP1-03-20, enter any comments on the checklist

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l comment sheet and sign and date the completed checklist.

i 5.5.3 The Lead Verifier shall review the safety evaluation prepared for the O

meeiricetioa # ie9 checkiist cx-me4-03-20. The intent of this review is to verify the modification is safe and satisfies the requirements of l

10CFR50.59. Upon the completion of the review, the Lead Verifier j

shall complete Checklist CK-MP1-03-20, enter any comments on the checklist comment sheet and sign and date the completed checklist.

j 5.5.4 The Lead Verifier shall generate a Discrepancy Report in accordance l

with Subsection 5.7 of this PI for any discrepancy identified while performing Subsection 5.5.2 and 5.5.3.

i l

5.5.5 The Lead Verifier shall indicate on the Modification Neview j

Administrative Checklist (CK-MP1-03-01) that review of licensing l

document changes and the safety evaluation has been completed and i

shall file the applicable checklists in the project file per PI-MP1-12.

l 5.6 Review of Modification Close-out Activities 5.6.1 The Lead Verifier shall perform a review to verify adequate modification close-out. The intent of this review is to verify that changes identified in the modification package have been processed N

Page 12 of 14

l PROJECT "f

INSTRUCTION PI-MP1-03 INSTRUCTION REV.O i

l to incorporation or are identified as open changes. The scope of this review includes those design output documents, design process documents and licensing documents within the SRG scope. These i

documents as a minimum include:

I a.

Calculations b.

Specifications I

c.

Drawings l

d.

Lists and Databases e.

Engineering Program Documents f.

FSAR g.

Technical Specifications I

5.6.2 The Lead Verifier shall review modification close-out activities using

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Checklist CK-MP1-03-25.

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5.6.3 The Lead Verifier shall complete Checklist CK-MP1-03-25, note any comments on the checklist comment form, and sign and date the l

checklist.

O se4 Tae 'eee veritiere8 iiseaerete e oiscregemcv senor 4ia ecceroemce i

with Subsection 5.7 of this project instruction for any discrepancies identified during the review.

i

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5.6.5 The Lead Verifier shall indicate on the Modification Review Administrative Checklist (CK-MP1-03-01) that the review of modification close-out activities has been completed and shall file the l

applicable checklists in the project file per PI-MP1-12.

5.7 Discrepancy Report Preparation and Closure j

5.7.1 Discrepancy Reports for discrepancies identified during the system j

modification review process shall be prepared and processed in accordance with PI-MP1-11.

5.7.2 Review of NU dispositions for the Discrepancy Reports generated i

during the review cycle shall be in accordance with PI-MP1-11.

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Page 13 of 14

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PROJECT INSTRUCTION PI-MP1-03 INSTRUCTION REV.0 5.8 Final Report

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i 5.8.1 The Lead Verifier shall draft a final report summarizing the results of l

the system modification review. The results of the review tasks described above shall be used to determine that adequacy of both j

design and configuration control processes for the development of j

modifications after receipt of the operating license.

I 5.8.2 The report format shall be determined by the Verification Team l

Manager.

5.8.3 The report shall be reviewed and approved by the VT Leads, VT Manager and IRC prior to external distribution.

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6.0 ATTACHMENTS f

(

6.1 ICAVP Process Flowchart, " Review of Modifications". ( 1 page) i I

I i

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i i

i l m t

j Page 14 of 14

Pl-MP143, REV. O ICAVP PROCESS FLOWCHART-A

""N 8 5 REVIEW OF MODIFICATIONS Screen Mod Pkgs. to identify Lead Discipline SRG v

Screen Mod Packages toidentify Affeded Elements Submit to CRG for Review

% pg SRG Submit to ORG for e-Yon

%w per PI-MP1-05 change Physk:al

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asset OPS /Mainst Yes-o, Review config?

U surveu. Test?

per PI-MP106 SRG f.eview Affected Engr.

SRG Elements No SRG No

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4 CRG ORG Rh Review RW Not Licensing Changes Not Required /

& Safety Eval.

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Perform instal. & Test Requirement &

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Were AllCriteria to ORG

- Yes Discrepancies

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Yeo-e forReview identified?

Required?

per PI-MP106 v

SRG Process Discrepancy No No Reports

+

4 (PI-MP1 11)

ALL lE lE Prepare O

SRG

1 j

PROJECT INSTRUCTION PI-MP1-04 INSTRUCTION REV.O t

4 Client: Northeast Utilities i

j Station: Millstone Unit 1 i

Title:

PROGRAMMATIC REVIEWS j

i i

l l

l 2 Safety-Related Non Safety-Related i

4 Reviewed By:

Approved By:

1 i

l System Lead Programmatic OnM Lead Accident GA Engineer Internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman i

y cate: 3-/7-17

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Page 1 of 7 l

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PROJECT INSTRUCTION PI-MP1-04 INSTRUCTION REV.0 1.0 Purpose This project instruction (PI) establishes the Sargent & Lundy procedure for performing programmatic reviews as a part of the ICAVP. These programr.aiic reviews are performed in addition to the ICAVP system design and licensing basis, O&M and testing, accident mitigation system reviews, and physical configuration reviews. The programmatic reviews are conducted on a horizontal basis (ac.oss systems) for the purpose of determining if the actions taken by Northeast Utilites (NU) to correct previously identified problems have been effective and if the NU change processes are effective.

The scope of the programmatic reviews willinclude:

Licensee initiated Corrective Actions As part of its Configuration Managemer i Program (CMP), NU has performed a vertical slice review of safety-significant and rish significant systems and has identified i

l degraded or non-conforming conditions. For the degraded or non-conforming conditions NU is initiating corrective actions. The programmatic review will assess the adequacy of these corrective actions. This review will be conducted for all corrective l

actions associated with the ICAVP sample systems, and for a representative sample of i

corrective actions associated with the other NU completed CMP vertical slice systems.

y Chance Processes NU's current plant change processes will be reviewed for both their adequacy with respect to industry standards and for the effectiveness by which they are being implemented. Both design change processes and procedure change processes will be included in this review, 2.0 References 2.1 NRC Confirmatory Order Establishing Independent Corrective Action Verification Program - Millstone Nuclear Power Station, Units 1,2 and 3 2.2 Millstone ICAVP Oversight inspection Plan, approved 12/19/96 2.3 PI-MP1-09, Preparation and Approval of Checklists l

2.4 PI-MP1-11, Discrepancy Report Submittal and Closure 2.5 j

NUMARC 90-12, Design Basis Program Guidelines N

Pago 2 of 7 1

J

^

PROJECT INSTRUCTION PI-MPi-04 INSTRUCTION REV.O i

l 2.6 PI-MP1-12, Project Fiie Index

}

2.7 CK-MP1-04, Series checklists as follows:

CK-MP1-04-01 Corrective Actions CK-MP1-04-02 Change Process Review CK-MP1-04-03 Change Procedure implementation Note: Checklists used in the performance of this Pl are not included as j

attachmens to the PL Checklists are prepared and controlled as separate documents per PI-MP1-09.

j 3.0 Definitions 3.1 Programmatic Review Group (PRG)- The subgroup of the ICAVP Verification Team responsible for performing the reviews of corrective actions and change j

processes.

l 3.2 Current Licensing Basis (CLB)- The set of NRC requirements applicable to a i

specific plant, and a licensee's written commitments for assuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments j

over the life of the license) that are docketed and are in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,30,40, 50, 51,55,72,73,100 and appendices thereto; orders; license conditions; l

exemptions, and Technical Specifications (TS). It also includes the plant-specific design basis information defined in 10 CFR 50.2 as documented in the l

most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71

]

and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic j

letters, and enforcement actions, as well as licensee commitments documented j

in NRC safety evaluations or licensee event reports.

l 3.3 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

l 3.4 Operations & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training manuals for the systems within the scope of the ICAVP.

1 i

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l Page 3 of 7

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PROJECT

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INSTRUCTION PI-MP1-04 INSTRUCTION REV.0 i

3.5 Design Bases - The information which identifies the specific functions to be i

performed by a structure, system or component of a facility, and the specific j

values or ranges of values chosen for controlling parameters as reference i

bounds for design. These values may be (1) restraints derived from generally i

accepted " state of the art" practices for achieving functional goals or (2) requirements derived from analysis of the effects of a postulated accident for which a structure, system or component must meet its functional goals.

1 l

3.6 Verifier - The individual assigned to review engineering attributes within his area of l

responsibility.

1 3.7 Discrepancy Report (DR)- The mechanism for documenting the discrepant l

conditions identified by the ICAVP and reporting an apparent error, inconsistency, or procedural violation with regard to licensing commitments, specifications, j

procedures, codes or regulations.

I 4.0 Responsibilities j

l 4.1 The Programmatic Review Group Lead shall be responsible for assigning the

}

verifier for each programmatic review and for overall coordination of the j'

Programmatic Review effort. He shall also approve checklists that are prepared i

for each program review, and he shall provide concurrence after the review is l

performed that the checklist is complete.

4.2 The Verifier shall be responsible for performing the programmatic review and completing the appropriate checklist. The Verifier or any other appropriate l

PRG Member shall prepare checklists prior to a program review.

i' 5.0 Procedure i

j 5.1 Corrective Actions 5.1.1 General All NU identified corrective actions for the ICAVP sample systems shall be included in the prograrnmatic review. For the remaining systems in the CMP vertical slice which have been completed by NU, a statistically significant (95/95 confidence / reliability) random sample of NU corrective actions shall be reviewed. It is not the intent of the ICAVP to verify completion of the corrective i

action, but only to assess the acceptability of the proposed corrective action.

!l Therefore, it is only necessary that the corrective action determination be completed by NU to be included in this sample.

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Page 4 of 7

I 1

PROJECT INSTRUCTION PI-MP1-04 INSTRUCTION REV.O l

5.1.2 Review Process The NU CMP findings / corrective action documents shall be obtained from the SRG for the ICAVP sampled systems. The other CMP completed j

findings / corrective action documents (for systems outside the ICAVP) shall be l

obtained from NU.

l Checidist CK-MP1-04-01, " Corrective Actions" shall be prepared by an l

appropriate team member for the review of corrective actions. Using the l

checklist, the PRG Verifier shall assess the corrective actions for adequacy of l

the following:

i i

a.

Root cause determination - what is the fundamental cause, which, if corrected, will prevent recurrence of the condition? Are plant processes l

or procedures affected?

b.

Extent of condition determination - the extent to which other j

systems, structures, components, or activities are affected.

j c.

Plant restart - is the corrective action required prior to restart?

d.

Content -is the corrective action adequate in resolving the issue?

i After reviewing the checklist for completeness, the PRG Lead shall file the checklist in accordance with PI-MP1-12.

5.1.3 Discrepancies The Verif3r shall prepare a Discrepancy Report in accordance with PI-MP1-11 j

for any discrepancies identified during the corrective action review.

i 5.2 Chance Processes l

5.2.1 General As part of the ICAVP system reviews, the SRG and the ORG will assess the i

plant modifications made on the systems sampled inthe ICAVP. This review will evaluate the effectiveness of the change processes involved in these modifications (i.e. if the resulting modification is found to be acceptable, it can be inferred that the process used in performing the modification is acceptable).

j in addition to this system review, specific process related reviews wiu also be

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performed as controlled by this Pl. The various change processe.5 reviewed shallinclude the following:

Page 5 of 7 i

j PROJECT W

INSTRUCTION PI-MP1-04 O

'usrauCrios Rev. 0 d

i Process Correspondina MP1 Procedure

]

j drawings NUC DCM Chapter 7 specifications NUC DCM Chapter 6 calculations NUC DCM Chapter 5 l

procedures DC1, DC2, DC3, DC4 I

l temporary alterations WC 10 I

minor modifications NUC DCM Chapter 3 i

1 modifications NUC DCM Chapter 3 1

N l

l licensing documents NGP-4.03 4

l l

vendor manuals NUC DCM Chapter 8 like forlike replacements NUC DCM Chapter 1 j

5.2.2 Review Process l

A.

Assess Adequacy of Process The current MP1 procedure for the process listed in Section 5.2.1 will be

)

evaluated forits content and completeness. This evaluation will determine if the procedure exercises adequate controls on the change i

process and invokes appropriate interface reviews to assure the plant I

design basis and configuration is maintained consistent with the licensing basis. The evaluation will be based on guidance provided in j

the following:

i Reg. Guide 1.33 Quality Assurance Program Requirements (Operation)

NRC Inspection Manual INPO guidelines i

INPO 87-006 Report on Configuration Management in the Nuclear

}

Industry j

NEl guidelines

}Pm Page 6 of 7

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i l

PROJECT INSTRUCTION PI-MP1-04 j

INSTRUCTION REV.O 1

Checklist CK-MP1-02,

• Change Process Review" shall be prepared by i

an appropriate team member for the evaluation of the current MP3 procedures according to the above. Using the checklist, the PRG Verifier j

shall assess the adequacy of each procedure. After reviewing the

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checklist for completeness, the PRG Lead shall file the checklist in j

accordance with PI-MP1-12.

B.

Assess implementation of Procedures The adequacy of NU's implementation of the change process procedure j

will be evaluated by reviewing actual plant change documentation. The j

evaluation will determine if the procedure is being followed, that the i

required checklists are being accurately and completely filled in, and that all other documentation is complete and procedurally adequate. This i

evaluation shall be performed for the plant changes captured in the l

ICAVP system reviews. If any of the processes noted in Section 5.2.1 l

are not included in the system reviews, an example outside the ICAVP will be selected for review. Since the system review will assess the j

technical adequacy of the change, the programmatic review will evaluate j

only the procedural adequacy of the change.

Checklist CK-MP1-04-03, " Change Procedure implementation" shall be

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preparad by a qualified team member for the evaluation of the j

implementation of MP1 procedures on current changes according to the above. Using the checklist, the PRG Verifier shall assess the adequacy j

of each change. After reviewing the checklist for completeness, the

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PRG Lead shall file the checklist in accordance with PI-MP1-12.

l 5.2.3 Discrepancies 1

The Verifier shall prepare a Discrepancy Report in accordance with PI-MP1-11 for any discrepancies identified during the change process reviews 6.0 Attachments i

j 6.1 ICAVP Process Flowchart, " Programmatic Reviews" (1 page)

I t

1 i

M i

Page 7 of 7

PI MP1-04.1 i

Gather Programmatic Documents-AITTS Listing PRG v

Prepare Checklists PRG M

i v

v v

Obtain Change Perform Change Documentation from 1

Select Corrective Process Procedure SRG,NU

• p Action Samples Review PRG PRG A

Perform Process implementation y

Review i

Perform Corrective PRG Action Review PRG

\\

Were Discrepancies Ne identified?

Yes E

v Process Discrepancy File Checidist per Report per PI-MP1-11 PI-MP1-12 O

y PRG PRG O

ICAVP PROCESS FLOWCHART Programmatic Reviews

i PROJECT INSTRUCTION PI-MP1-05 INSTRUCTION REV.O t

Client: Northeast Utilities Station: Millstone Unit 1 I

i 1

Title:

PHYSICAL PLANT CONFIGURATION WALKDOWNS l

l i

1 h Safety-Related Non Safety-Related Reviewed By:

Approved By:

l l

=

]

System Lead Programmatic O&M Lead Accident QA Engineer Intemal Review Verification Team Lead Mitigation Committee Manager 4

Lead Chairman

/

Date:3'l7-k'f cMO (bl/G

?

Description Irkalisstie d' g

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1 l

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,i Page 1 of 12 f

I

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PROJECT INSTRUCTION PI-MP1-05

]

INSTRUCTION REV.0 1.0 PURPOSE l

This instruction establishes the requirements for conducting physical walkdowns of the systems included in the scope of the Independent Corrective Action Verification Program. The scope ir,cludes Phase 1 - System Functional Walkdowns and Phase 2 - Detailed Walkdowns of Modification Implemented After Receipt of Operating License.

l 2.0 REFERENCE l

2.1 NRC Inspection Manual Procedure 93801, Safety System Functional l

Inspection l

2.2 NRC Oversight inspection P!an for the Millstone Independent Corrective Action Verification Program dated 12/19/96.

2.3 NRC Confirmatory Order Establishing Independent Correction Action Verification Program - Millstone Nuclear Power Station, Units 1,2, O

me a 2.4 PI-MP1-01, ICAVP Communications Protocol 2.5 PI-MP1-02, Review of System Design for Compliance with the Design and Licensing Basis 2.6 PI-MP1-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control 2.7 PI-MP1-09, Preparation and Approval of Checklists 2.8 PI-MP1-11, Discrepancy Report Submittal and Closure 2.9 PI-MP1-12, Project File Index i

l 6

Page 2 of 12 z

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PROJECT 1NSTRUCTION PI-MP1-05 INf :RUCTION REV.0 j

c l

2.10 CK-MP1-05, Series Checklists as follows:

CK-MP1-05-01 Walkdown Control Checklist CK-MP1-05-02 Physical Drawing Review Attributes Checklist CK-MP1-05-03 Functional Walkdown Checklist CK-MP1-05-04 Modification Walkdown Checklist l

Note:

Checklists used in the performance of this Pl are not j

included as attachments to the Pl. Checklists are l

prepared and controlled as separate documents per Pl-j MP1-09.

3.0 DEFINITIONS l

3.1 System Review Group (SRG)-The subgroup of the ICAVP Verification i

Team responsible for performing an in-depth review of the design of the systems in the scope of the ICAVP.

l 3.2 Configuration Review Group (CRG)-The subgroup of the SRG l

Verification Team responsible for walkdowns to verify the current as-built conditions are in conformance with the design output documents.

l 3.3 Design Output Documents - Controlled plant documents such as specifications, drawings, vendor drawings, datasheets lists and databases (Reference 2.4).

3.4 Walkdown Team -The team from within the CRG responsible for performing walkdowns in accordance with the instructions. The team shall consist of, as a minimum, an engineer (Lead Verifier) and one 2

mechanical and one electrical designer (Verifier).

j 4.0 RESPONSIBILITIES 1

4 4.1 The SRG Lead shall have overall responsibility for the implementation of j

the physical configuration walkdowns.

i j

4.2. The CRG Lead shall be responsible for providing overall direction to the

{

CRG at S&L's offsite office and rhall be responsible for interfacing with j

me SRG lead.

N 4

Page 3 of 12 1

I

i PROJECT INSTRUCTION PI-MP1-05 INSTRUCTION REV.0 4.3 The Lead Verifier shall be responsible for l

Coordination of system walkdowns Reviewing checklists, system boundary drawings and redline t

drawings prepared by the walkdown team verifiers j

4.4 The Verifier (s) shall be responsible for:

Performing system and modification walkdowns & completing j

applicable checklists Preparing redline drawings Preparing system boundary drawings l

Verifying that modification packages agree with current design drawings 5.0 PROCEDURE 5.1 General 1

The Nuclear Regulatory Commission (NRC) Confirmatory Order

}

(Reference 2.3) requires Northeast Utilities (NU) to implement the l

lCAVP. The confirmatory order also defines the scope of the ICAVP. Item 2 of the scope of the ICAVP described on page 13 of l

the confirmatory order requires the Licensee to verify the current j

l as-modified plant conditions against design basis and licensing basis documentation for the specific systems selected by the NRC.

l This procedure describes one aspect of the process needed to l

perform the verification described above. Specifically, this l

procedure shall determine if the current system design as reflected l

on design output documents is consistent with the physical installed condition of the plant. This determination shall be made i

by performing physical walkdowns of the plant systems. The walkdowns shall be performed in two phases. Phase i shall j

perform functional walkdowns of the entire system to verify the i

current configuration is consistent with the current design output i

documents. Phase 2 shall perform a detailed walkdown of the l

portions of the system modified after receipt of operating license to j

verify the modified installation is consistent with the modification j

package. The Phase 2 walkdown shall include more exter,sive l

m i

4 Page 4 of 12 i

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PROJECT INSTRUCTION PI-MP1-05 INSTRUCTION REV.0 l

l dimensional checks, such as spool end to end dimensions, hanger j

locations, etc., which are not required for the Phase 1 walkdown.

l The decision to exclude dimensional checks for the Phase 1 I

walkdown was based on the guidance provided in References 2.1 and 2.2 and the fact that various inspection programs were typically implemented during initial plant construction and startup l

prior to receipt of an operating license, i

i The systems to be included in the scope of the ICAVP will be l

defined by the Nuclear Regulatory Commission. Once the systems j

have been identified, the first step is to gather the applicable 4

system documents. This activity shall be performed in conjunction with the SRG as outlined in PI-MP1-02. Once the documents have l

been gathered, the following tasks shall be implemented per this procedure:

l I

a.

General Walkdown Preparation i

b.

Phase 1 Walkdown and Plart 'ng j

c.

Phase 2 Walkdown and Planning i

d.

Walkdown Documentation Package Assembly e.

Discrepancy Report Preparation and Closure 4

f.

Final Report Preparation l

.1 is a process flowchart illustrating the Physical Configuration Walkdown process.

i.

1 l

5.2 General Walkdown Precaration Recuirements i

5.2.1 The CRG Lead shall be responsible for assigning a walkdown team for i

each system in the scope of the ICAVP. The CRG Lead shall

)

document the walkdown team assignment in the appropriate blocks of l

the Walkdown Control Checklist (CK-MP1-05-01). The Walkdown i

Team shall consist as a minimum of an engineer (Lead Verifier), and j

one electrical and one mechanical designer (Verifier (s)).

i l

Note: The assigned walkdown team is responsible for implementing i

both phases of the walkdown for that system.

t

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Page 5 of 12

l l

f"~

INSTRUCTION PI-MP1-05 PROJECT l

INSTRUCTION REV.O i

5.2.2 The Lead Verifier shall obtain a copy of all applicable design output documents for the system and all plant modification packages for that j

system (Refer to Section 5.2 of PI-MP1-02).

5.2.3 The Lead Verifier shall identify the plant areas which contain the system from general arrangement drawings. The Lead Verifier shall i

schedule the walkdown, notify the appropriate plant personnel and obtain all necessary clearances. Discussions and/or contacts with NU personnel shall be in accordance with the protocol outlined in PI-MP1-01.

i 5.3 Phase 1 Walkdown & Plannina 5.3.1 The Walkdown Team shall highlight the system boundaries on the j

following drawings, as applicable:

I a.

P&lDs j

b.

Piping Isometrics c.

Electrical Schematics and Single Line Drawings d.

Electrical Physical Conduit and Tray Routing Drawings

]

e.

Vendor Skid Drawings i

l 5.3.2 The Walkdown Team shall identify all support drawings (pipe and j

electrical), equipment mounting details, component vendor j

drawings and instrument details for components to be verified in the walkdown.

5.3.3 The Lead Verifier shall review the boundary drawings and commodity drawings with the applicable Lead Verifier from the SRG. The respective Lead Verifiers shall resolve any comments and denote their concurrence by signing and dating the applicable blocks on the Walkdown Control Checklists. The CRG Lead Verifier shall list all applicable documents including revision number or date on the Walkdown Control Checklist (CK-MP1-05-01).

5.3.4 The Walkdown Team shall incorporate all open change documents (redline) into the parent document. Redlining shall be limited to incorporation of only those details which will be verified during the walkdown (i e., since Phase 1 walkdowns do not verify dimensions, 6

Page 6 of 12

PROJECT INSTRUCTION PI-MP1-05 Q

INSTRUCTION REV.0 l

dimensional data need not be shown). The Lead Verifier shall list i

all the incorporated change documents on the redlined documents.

i i

Note: Only those change documents which have been completely l

installed shall be included in the redline scope. These will be identified by the SRG.

5.3.5 The Lead Verifier shall note completion of the redline step on the Walkdown Control Checklist (CK-MP1-05-01) and shall initial and l

date the entry.

I 5.3.6 The Walkdown Team shall perform a review of the lower tier i

drawings versus the upper tier drawings as follows:

i Note: Upper tier drawings will be reviewed against calculations, j

specifications and design and licensing bases by the SRG per PI-MP1-02. The intent of this review is to verify the consistency of the piping isometrics and electrical physical drawings and electrical single lines to the upper tier

O documents.

i 5.3.S.1 The Walkdown Team shall review the following drawings:

I a.

P&lDs versus Piping Isometrics j

b.

Electrical schematics versus electrical single lines and electrical physical drawings.

l The review attributes shall be in accordance with the Physical j

Drawing Review Attributes Checklist (CK-MP1-05-02).

5.3.6.2 The Walkdown Team shall prepare an individual CK-MP1-05-02 Checklist for each type of drawing reviewed and shall sign and date each checklist.

5.3.6.3 Discrepant conditions identified during this review shall be processed in accordance with Subsection 5.6 of this project instruction.

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Page 7 of 12

l PROJECT

[ #~

l INSTRUCTION PI-MP105 l

INSTRUCTION REV.O i

i 5.3.6.4 The Lead Verifier shall indicate completion of the physical drawing review step on the Walkdown Control Checklist (CK-MP1-05-01)

)

{

and shallinitial and date the entry.

l 5.3.7 The Walkdown Team shall perform the Phase 1 system functional walkdowns as follows:

j 5.3.7.1 Phase i system functional walkdowns shall be performed using the l

Functional Walkdown Checklist (CK-MP1-05-03). Each attribute i

verified during the walkdown shall be verified by two walkdown l

team members.

}

5.3.7.2 The Phase 1 functional walkdown shall in general verify the nameplate data of the system components, check for physical damage and functionally check system installation by checking the following items for proper configuration (not dimensions):

a.

Equipment Nos. and Equipment Location b.

Piping Line Size (Diameter)

O c.

Pipe configuration functional location of bends, valves, supports, and other in line components d.

Valve orientation and flow direction e.

Insulation and/or heat tracing f.

Support type g.

Equipment and support mounting type and anchorage details (No. of bolts, weld pattern, etc.)

h.

Cables are functionally routed to appropriate "To" and i

"From" equipment.

l.

Conduit size, cable size where practical J.

Conduit support and cable tray support type k.

Configuration of tubing and electrical for instrumentation Note: If pipelines are insulated, verification shall be accomplished by adding insulation thickness to line size and measuring outside diameter of insulation.

Refer to checklists CK-MP1-05-03 for further details and attributes.

s m

Page 8 of 12

PROJECT INSTRUCTION PI-MP1-05

O iNSTRuCrioN Rev. 0 l

The walkdown shall also review divisional separation and seismic l

11/1 attributes. Specifics are provided on the functional walkdown l

checklist (CK-MP1-05-03) 4 5.3.7.3 The Walkdown Team shall enter the nameplate data found on the i

components in the applicable section of the Functional Walkdown j

Checklist (CK-MP1-05-03).

l 5.3.7.4 The Walkdown Team shall note visible physical damage, such as separated supports, in the applicable section of the Functional Walkdown Checklists (CK-MP1-05-03).

l 5.3.7.5 The Walkdown Team shall mark any configuration discrepancies identified during the walkdown directly on the redline drawings i

developed in step 5.3.4.

5.3.7.6 The Walkdown Team shall initial and date any entries made on the l

Functional Walkdown Checklists (CK-MP1-05-03) or Redline i

drawings.

lO l

5.3.7.7 Following completion of the walkdown, the Walkdown Team will l

verify nameplate date recorded in the field with the vendor i

drawings and indicate any discrepancies on the Functional l

Walkdown Checklist (CK-MP1-05-03).

j 5.3.7.8 The Lead Verifier shall review the completed Functional Walkdown l

Checklist (CK-MP1-05-03) to ensure it has been properly j

completed and shall note his concurrence by signature and date.

5.3.7.9 Discrepant conditions identified during this review shall be l

processed in accordance with Subsection 5.6 of the project j

instruction.

j 5.3.7.10The Lead Verifier shall indicate comploiion of the functional walkdown step on the Walkdown Ceni ul Checklist (CK-MP1 '

j

01) and shall initial and date the entry.

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Page 9 of 12

l PROJECT INSTRUCTION PI-MP1-05 INSTRUCTlON REV.O i

j 5.4 Phase 2 Walkdown & Plannino i

5.4.1 During the system modification review, the SRG shall per PI-MP1-03, identify any modifications to the system being reviewed which j

resulted in plant configuration changes. The SRG will also identify j

which portions of a previous modification were revised by a j

subsequent modification.

l 5.4.2 Upon receipt of the modification data from the SRG, the Lead l

Verifier shall initiate a physical walkdown of the modified portion of l

the system by initiating a Modification Walkdown Checklist (CK-1 4

MP1-05-04). A separate modification walkdown checklist shall be l

prepared for each system modification being reviewed. The Lead Verifier will enter the modification number and description on the l

checklist (CK-MP1-05-04).

i 5.4.3 The Walkdown Team shall review the document changes contained in the modification package versus the redline drawings prepared as part of the system walkdown (Subsection 5.3 of this

)

project instruction). Discrepancies shall be noted on the Modification Walkdown Checklist (CK-MP1-05-04).

l

{

5.4.4 The Lead Verifier shall identify key critical dimensions that will be l

checked by the Walkdown Team. The Lead Verifier shall note these key critical dimensions on the Modification Walkdown i

Checklist (CK-MP1-05-04). Key critical dimensions may include analytical / calculation bases, specific dimensional limits and requirements stated on the drawings which deviate from the standard installation tolerances, etc.

5.4.5 The Walkdown Team shall perform a walkdown of the modified area to verify installation is in accordance with the modification package. This step includes checking critical dimensional data included in the modification package. Any discrepancies shall be noted on the Modification Walkdown Checklist (CK-MP1-05-04).

N Page 10 of 12

d I

PROJECT INSTRUCTION PI-MP1-05 i

INSTRUCTION REV.0 i

l I

5.4.6 Upon completion of the walkdown, the Walkdown Team shall sign and date the completed Modification Walkdown Checklists (CK-MP1-05-04) and shall generate a Discrepancy Report per t

l Subsection 5.6 for any discrepant conditions identified during the j

walkdown.

I I

5.4.7 The Lead Verifier shall review the completed Modification t

Walkdown Checklists (CK-MP1-05-04) for completeness and shall signify his concurrence by signing and dating the checklist.

l 5.4.8 The Lead Verifier shall indicate completion of the modification j

walkdown on the Walkdown Control Checklist (CK-MP1-05-01) and j

shallinitial and date the entry.

i l

5.5 Walkdown Documentation Packaoe Assembly 5.5.1 The Lead Verifier shall assemble a documentation package l

consisting of the following:

j Reference Drawings l

Redline Drawings CK-MP1-05 Series Checklists 5.5.2 The Lead Verifier shall distribute the package to the project file in accordance with PI-MP1-12.

5.5.3 The Lead Verifier shall indicate completion of this step by signing and dating the Walkdown Control Checklist (CK-MP1-05-01).

5.6 Discrepancy Report Preparation and Closure 5.6.1 Discrepancy Reports for discrepant items identified during the system and modification walkdowns shall be prepared and processed in accordance with PI-MP1-11. Discrepancy reports shall not be initiated for findings already identified by NU during implementation of the CMP.

5.6.2 Review of NU dispositions for the Discrepancy Reports generated during the review cycle shall be in accordance with PI-MP1-11.

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INSTRUCTION REV.O 5.7 Finel Report i

5.7.1 The Lead Verifier shall draft a 'inal report summarizing the results of the system and modification walkdowns.

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l 5.7.2 The report format shall be determined by the Verification Team Manager.

6.0 ATTACHMENTS l

6.1 ICAVP Process Flowchart, " Physical Plant Configuration Walkdowns". (1 page)

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Page 12 of 12

Pl-MP146, REY. O ICAVP PROCESS FLOWCHART ATTACHMENT 6A PLANT PHYSICAL Assign Walkdown CONFIGURATION WALKDOWNS T**

• CRG Lead v

Gather Documents per PI-MP1-02 Lead Verifier v

Obtain Clearance /

ScheduleWalkdowns Obtain Installed Mod Lead Verifier Packages from SRG 4

nor PI-MP1-03 Lead Verifier v

Define System Boundries/Reviewwith v

v SRG Review Mod Package Lead Verifier /SRG vs. Redune Drawings Walkdown Team V

Redline Walkdown

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y Define Key Critical Walkdown Team Dimensions Lead Verifier v

Review Lower Tier Docs vs. Upper Tier i

y Perform Modification Walkdown Team Walkdown Walkdown Team v

Perform Functional Walkdowns Walkdown Team x

Are i

Discrepancies \\

No identified?

Yes Q

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Prepars & Process Prepare input for DRs per PI-MP1-11 Report SRG CRG

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INSTRUCTION PI-MP1-06 INSTRUCTION REV.O I

Client: Northeast Utilities Station: Millstone Unit 1

Title:

OPEPATIONS AND MAINTENANCE AND TESTING PROCEDURES AND TRAINING DOCUMENTATION REVIEWS l

l h Safety-Related Non-Safe.ty-Related l

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Reviewed By:

Approved By:

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System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team l

Lead Mitigation Committee Manager 4

Lead Chairman j

l Date: S#$l-??

$$ & Nhlus W44fcx :A W k

.l' Description initialiss6e

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i PROJECT INSTRUCTION PI-MP1-06 INSTRUCTION REV.0 1

PURPOSE l

The purpose of the Operations, Maintenance and Testing (O&M&T) portion of the

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independent Corrective Action Verification Program (ICAVP) is to determine whether l

the design and licensing bases for Millstone, Unit 1 including the Position Papers, have been adequately translated into operating, maintenance and test procedures for the selected systems. The O& M&T portion of the ICAVP will also verify that changes made to Unit 1 since issuance of the operating license were implemented by appropriate procedure changes and testing. Training program procedures and other i

Significant Support / Interacting Systems and Related Activities required for pn)per l

implementation of these procedcres and testing will also be evaluated. The O&M&T j

will also confirm that current testing requirements, maintenance, and post modification j

testing are adequate to verify system performance.

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REFERENCES j

2.1 NRC Inspection Manual Procedure 93801, Safety System Functional inspection.

I 2.2 10 CFR 50.2, Definitions.

s 2.3 NRC Confirmatory Order Establishing independent Corrective Action Verification Program - Millstone Nuclear Power Station, Units 1,2, and 3.

2.4 NRC ICAVP Oversight and inspection Plan, dated December 19,1996.

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2.5 Regulatory Guide 1.33, Revision 2, Quality Assurance Program Requirements j

(Operations) j 2.6 NUMARC 90-12 Design Basis Program Guidelines.

j 2.7 NRC Generic Letter 90-03, Relaxation of Staff Position in Generic Letter 83-28, 1

Item 2.2, Part 2, Vendor Interface for Safety-Related Components.

l 2.8 NRC Generic Letter 91-18, Information to Ucensees Regarding Two NRC

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inspection Manual Sections on Resolution of Degraded and Nonconfonning Conditions and on Operability.

j-2.9 Northeast Utilities Configuration Management Plan i

j 2.10 PI-MP1-01, independent Corrective Action Verification Program j

Communications Protocol.

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l PROJECT INSTRUCTION PI-MP1-06 INSTRUCTION REV.0 i

2.11 PI-MP1-02, Review of System Design for Compliance with the Design and 1.

Licensing Basis.

l 2.12 PI-MP1-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control.

l 2.13 PI-MP1-04 Programmatic Reviews l

2.14 PI-MP1-05, Physical Plant Configuration Wa:kdowns.

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2.15 PI-MP1-07 Review of Accident Mitigation Systems l

l 2.16 PI-MP1-09, Preparation and Approval of Checklists.

2.17 PI-MP1-11, Discrepancy Report Submittal and Closure.

2.18 Pl-MP1-12, Project File Index.

j 2.19 CK-MP1-06 Series Checklists as follows:

4 CK-MP1-06-01 Accident Mitigating Systems-Critical Parameters Checklist CK-MP1-06-02 Bases / Change Features Checklist CK-MP1-06-03 System Modes / Phases Checklist CK-MP1-06-04 P&lD Checklist I

CK-MP1-06-05 Significant Support / Interacting Systems and Related Activities j

Checklist.

l CK-MP1-06-06 Supplemental Documents Checklist CK-MP1-06-07 Process Indications Checklist i

CK-MP1-06-08 Vendor Manuals / Files Checklist l

CK-MP1-06-09 Perfonnance History Files Checklist j

CK-MP1-06-11 Mod Procedures Checklist CK-MP1-06-12 PRG Change Process Procedures Checklist i

CK-MP1-06-13 Training Materials Checklist i

CK-MP1-06-14 Testing Requirements Checidist i

CK-MP1-06-15 Testing Requirements Review Checklist j

CK-MP1-06-16 Test Procedure Adequacy Checklist

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CK-MP1-06-17 Testing Records Review Checklist j

CK-MP1-06-18 Procedures Observed in The Field Checklist 4

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Note: Checklists used in the performance of this Pl are not included as attachments to the Pl. Checklists are prepared and controlled as separate i

documents per PI-MP1-09.

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INSTRUCTION PI-MP1-06 INSTRUCTION REV.0 l

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3 DEFINITIONS 1

j 3.1 Operations & Maintenance and Testing Review Group (ORG)- The subgroup l

of the ICAVP Verification Team responsible for review of the operating, i

maintenance and testing procedures, and training materials for the systems l

within the scope of the ICAVP.

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3.2 System Review Group (SRG)- The subgroup of the ICAVP Verification Team i

responsible for performing an in-depth review of the design of the systems in l

the scope of the ICAVP.

3.3 Configuration Review Group (CRG)- The subgroup of the SRG Verification l

Team responsible for walkdowns te verify that the current as-built conditions are j

in conformance with the design output documents.

3.4 Accident Mitigation Review Group (ARG)- The subgroup of the ICAVP i

Verification Team responsible for the review of the critical system attributes of l

the systems used to mitigate the consequences of an accident.

i 3.5 Programmatic Review Group (PRG)- The subgroup of the ICAVP Verification l

Team responsible for performing a review of the design control and corrective action processes in the scope of the ICAVP.

3.6 Current Ucensing Basis (CLB)- The set of NRC requirements applicable to a 3

specific plant, and a licensee's written commitments for assuring compliance j

with and operation within applicable NRC requirements and the plant-specific j

design basis (including all modifications and additions to such commitments j

over the life of the license) that are docketed and are in effect. The CLB I

includes the NRC regulations contained in 10 CFR Parts 2,19,20,21,30,40, j

50, 51, 55,72, 73,100 and appendices thereto; orders; license conditions; exemptions, and Technical Specifications (TS). It also includes the plant-l specific design basis information defined in 10 CFR 50.2 as documented in the i

most recent Final Safety Analysis Report (FSAR) as required by 10 CFR 50.71 and the licensec's commitments remaining in effect that were made in docketed j

licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports. (Reference 2.7) 1 l-3.7 Design Bases - The information which identifies the specific functions to be i

performed by a structure, system or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference l

bounds for design. These values may be (1) restraints derived from generally j

accepted m' state of the art" practices i

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PROJECT INSTRUCTION PI-MP1-06 INSTRUCTION REV.O requirements derived from analysis of the effects of a postulated accident for l

which a structure, system or component must meet its function goals.

(Reference 2.2) l 3.8 Design Output Documents - Controlled plant documents such as specifications, drawings, vendor drawings, datasheets, lists and databases.

I (Reference 2.5) l l

3.9 Design Process Documents - Documents such as calculations, analyses, j

evaluations or other dowmented engineering activities that substantiate the l

final design. (Reference 2.5) i j

3.10 Verifier - The individual assigned to review engineering attributes within his area of responsibility.

3.11 Significant Support / Interacting Systems and Related Activities - As used in this Pi Significant Support / Interacting Systems and Related Activities refers to l

those process systems, activities, or procedures that are considered essential and significant by the ORG Verifiers, in accomplishing the Design or Ucense l

Basis, or Unit 1 Position Paper item that is being evaluated. It is not intended l

that this consideration of Significant Support / Interacting Systems and Related j

Activities be viewed as an all encompassing chain of all possible support and related activities. As an example, if an operatcr or maintenance worker must be trained with specific skills to perform particular procedures, then the existence of i

approved training procedures will be verified to accomplish that specific skill training. Neither the entire training program nor the skills nor qualifications of l

the trainers will be evaluated as part of meeting the subject design basis item

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being evaluated.

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3.12 Millstone Unit 1 Position Papers - The documents prepared by NU as part of i

the Unit 1 Configuration McMgement Plan which describe the Unit 1

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committments to regulatory guidance, such as the General Design Criteria, and l

to topical subjects such as Heavy Loads,HELB/MELB, single failure, etc.,(Reference 2.9).

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i 4

RESPONSIBILITIES b

j 4.1 The Verification Team Manager shall be responsible for overall management of the Verification Team.

4.2 The ORG Lead shall be responsible for assigning a Lead Verifier for each system in the ICAVP scope, for assigning other verifiers as necessary to support the Lead Verifier, and for overall coordination of the ORG effort.

Page 5 of 20 i

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PROJECT INSTRUCTION PI-MP1-06

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INSTRUCTION REV.0 i

4.3 The ORG Lead Verifier shall be responsible for performing a review of procedures, vendor manuals, training materials and plant simulator configuration as described in this instruction.

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4.4 The ORG Verifiers shall be responsible for performing reviews within their area j

of expertise in accordance with this instruction.

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INSTRUCTIONS 5.1 General The Nuclear Regulatory Commission (NRC) Confirmatory Order referenced in Section 2.0 of this Pl requires Northeast Utilities (NU) to implement the ICAVP.

The Confirmatory Order also defines the scope of the ICAVP. This scope includes verification that design and licensing bases requirements are translated into operating, maintenance and testing procedures. The ORG includes as part of this verification a check that functional and performance requirements, identified by the SRG in the licensing and design bases of the selected systems, and in the Unit 1 Position Papers, are implemented in the operating, O

maintenance and testing procedures and training material. The ORG will also review modifications to the system to verify that the appropriate procedures correctly reflect the changes made. The ORG will also verify system performance through review of test records, maintenance history, and 3

observation of selected testing. Walkdowns will be used as appropriate to verify adequate control of operational, maintenance, test and surveillance procedures, operator training, and control of the plant simulator configuration.

i 5.1.1 Additional Significant Support / Interacting Systems and Related Activ: ties may be identified during reviews in order that procedures goveming such activities can be evaluated for adequate implementation of Design Bases and Licensing Basis items, including the Unit 1 Position Papers. Refer to Definition 3.11 of this PI for clear understanding of this action.

5.2 Document Retrieval and Review 5.2.1 Refer to Project instruction PI-MP1-02 for a detailed breakdown in the division of responsibility within the ICAVP Verification Team for gathering documents. The ORG shall gather, for the selected system, the following minimum list of documents:

a. Operating Procedures including Emergency Operating Procedures

b. Maintenance Procedures Page 6 of 20

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INSTRUCTION PI-MP1-06 INSTRUCTION REV.O I

c. Surveillance Test procedures 2

d. VendorManuais

e. System Training Procedures

f. Other Significant Support and/or Related Procedures t

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5.2.2 The ORG shall use the station document index to determine the types of documents or records to be gathered and to identify specific procedures and tests applicable to the system being reviewed.

5.2.3 The ORG shall request relevant documents which are not in the ICAVP Library, from NU in accordar.ce with subsection 3.1 of PI-MP1-01.

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5.2.4 The ORG shall complete the applicable section of the System Reference i

List (SRL) with the documents identified in 5.2.2 and forward the completed checklist to the SRG Lead. Checklist CK-MP1-02-01 shall be used for the SRL 5.2.5 Once the ORG Lead has received the combined SRL hom the SRG Lead, the ORG Lead Verifier and the other ORG Verifiers assigned to i

review the system shall review the appropriate documentation in order to achieve an in-depth understanding of the system as it relates to their j

area of expertise.

i 5.2.6 Prior to the ORG review of system modifications which have occurred since the issuance of the operating license, the SRG shall provide the ORG a clear description of portions of modification packages which were subsequently revised by later modifications. The SRG shall also clearly j

describe for the ORG the modifications which are complete and j

implemented, and those that have not yet been installed. These i

measures are required, in part, to prevent generation of erroneous discrepancy reports during the ORG review of procedures and other j

supporting material.

5.2.7 The SRG screens the modifications using a Modification Screening 1

Checklist, CK-MP1-03-02. Among the topics addressed by the checklist i

is a screening of the modification forimpact on training procedures and i

plant procedures (operations, maintenance and surveillanco). If the screening process determines that plant procedures may be affected by

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the modification, the SRG Lead Verifier shall forward a copy of the i

checklist and the modification package to the ORG for review. This step

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shall not be performed until all modifications to the system have been j

screened.

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INSTRUCTION PI-MPi-06 INSTRUCTION REV.0 1

i 5.2.8 If the system being reviewed is an Accident Mitigating System, critical i

parameters will be provided by the ARG to the ORG. The ORO Verifier i

shalllist the critical parameters on Checkfist CK-MP1-06-01. The ORG verifier shall verify that the procedures to be reviewed for implementation of these parameters are listed on the checklist. The ORG Verifier shall i

verify that the appropriate surveillance test procedures adequately implement these critical parameters and document the results on Checklist CK-MP1-06-01.

5.3 Identification of System Recuirements i

j 5.3.1 As described in PI-MP1-02, the SRG shall use a Systems Requirements Checklist (SRC), Checklist CK-MP1-02-02, to identify the functional, performance and other design requirements for the system being l

reviewed.

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5.3.2 The ORG shall use the Systems Requirements Checklist (SRC),

Checkfist CK-MP1-02-02, to review the licensing and design bases i

documents, including the Unit 1 Position Papers, to identify operating, i

maintenance, and testing requirements.

5.3.3 The ORG Lead will assign a Lead Verifier for each of the systems being i

reviewed.

i 5.3.4 The Lead Verifier shall tabulate the requirements along with a reference i

on the System Requirements Checklist, CK-MP1-02-02.

5.3.5 The ORG Lead shall approve the ORG input on the System l

Requirements Checklist and forward it to the SRG Lead for combination

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with the other ICAVP inputs.

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5.3.6 The SRG Lead shall provide the ORG Lead a signed copy of the l

combined System Requirements Checklist for use.

i 5.3.7 The ORG Verifier shall plan and schedule plant walkdowns for the I

purpose of verifying system performance and to verify adequate control j

of procedures through observation of selected activities and testing,as i

described in Section 5.6.11 of this Pl. The ORG Verifier shall refer to PI-MP1-05 for guidance in planning wakdowns, and coordinate the j

walkdown plan with the CRG Lead.

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5.4 Bases Recuirements Review N

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INSTRUCTION REV.0 i

5.4.1 The ORG Verifier shall perform a detailed review of the appropriate i

procedures listed on the SRL to evaluate them for implementation of the bases requirements, including the Unit 1 Position Papers, as listed on the System Requirements Checklist. During the detailed review, the ORG Verifier should consider the need to identify specife S!gnificant

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Support / Interacting Systems and Related Activitiec to be reviewed for j

implementation of the bases requirement being evaluated based on

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initial reviews or results of questions considered as described in Section 5.4.3.d of this Pl. The Verifier shall refer to Definition 3.11 of this P1 for i

clarification.

i 5.4.2 The ORG Verifier shall list each System Requirements Checklist l

requirement to be evaluated, or each modification or process change j

item, on each checklist used below or in Section 5.5 of this Pl. The ORG l

Verifier shall list the procedures to be reviewed for each requirement on this same checklist. The ORG Verifier shall list the specific section of

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each procedure as a reference for each requirement being evaluated on i

this same checklist.

I 5.4.3 The ORG Verifier shall review relevant procedures to:

a. Verify that the design bases features and the current licensing basis l

j features, including the Unit 1 Position Papers, are adequately f

translated into the referenced procedures. The Verifier shalllist the t

features and document the results of his review on Checklist CK-j MP1-06-02.

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b. Verify by reviewing the procedures that all modes and phases of the j

selected system are adequately operated, maintained, and tested.

Where appropriate, the review shall verify that any required manual operator actions can be performed under accident conditions. The Verifier shall list the appropriate modes and phases and any required accident conditions and document the results of his review on Checklist CK-MP1-06-03.

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c. Verify that the various system configurations described in the procedures will perform their intended functions by reviewing the appropriate P&lD's. The ORG Verifier shall list the appropriate i

P&lD's and document the results of his review on Checklist CK-MP1-06-04.

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d. Verify that any required Significant Support / Interacting Systems and j

Related Activities (refer to definition 3.11 of this PI for clarification) l 6

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i PROJECT INSTRUCTION PI-MP1-06 INSTRUCTION REV.0

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adequately provide for proper performance of the system being reviewed to accomplish its bases requirements, including the Unit 1 Position Papers. The ORG Verifier shall complete Checklist CK-I l

MP1-06-05 to evaluate the need for further items to be reviewed.

The Verifier shall add any requirements to the System Requirements Checklist in accordance with Section 5.3 of this Pl. The Verifier shall add any necessary references to the SRL in accordance with Section 5.2.4 of this Pl. The Verifier shall document the results of his review on Checklist CK-MP1-06-05 j

i NOTE: This step is not intended to verify the adequacy of supporting systems and functions, but is merely intended to verify that l

procedures for supporting systems and functions reflect the ICAVP j

systems' requirements.

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e. Verify that sections of vendor manuals, equipment operating instructions, drawings, or other supplementa documents that are j

referenced, or used directly as operating or maintenance procedures receive the same level of MP1 review and approval as the initial procedures. This is not a review of the technical adequacy of the l

documents. The Verifier shall I!st any such documents and document the results of his review on Checklist CK-MP1-06-06.

l f.

Verify that the instruments and controls identified in the procedures to be used for remote and local operation are consistent with the installed configuration. The Verifier shall list any such instruments and controls, identify whether they are local or remote. and j

document the results of his review on Checklist CK-MP1-06-07.

g. Verify that vendor manuals / files adequately support the bases 3

requirements for the system being reviewed. The Verifier shalllist the appropriate vendor manuals and files, and document the results 1

of his review on Checklist CK-MP1-06-08.

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h. Verify that performance history files adequately support the bases i

requirements, including the Unit 1 Position Papers, for the system j

being reviewed.This verification shall include reviews to identify recurring equipment problems, and determination of any trends.

l Additionally, the verification shall include review of the technical i

adequacy of maintenance activities, performance of appropriate 1

post-maintenance tests, and satisfactory demonstration of equipment operability. The verifier shall list the files and specific items reviewed. Specific references shall be indicated on the checklist.

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The Verifier shall document the results of his review on Checklist CK-MP1-06-09.

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1.

It may be appropriate to walkdown some samples of procedure usage in the field to observe for procedure control, and to witness samples of the review items from the above sections. Refer to l

Section 5.6.11 of this PI for a description of the walkdown arrangements. The Verifier shall clearly identify any items verified by walkdown on the appropriate Checklist, and document the results of his review with comments on the appropriate checklist.

5.4.4 The verifier shall note any comments identified during the review on the i

comment section of each checklist used in the above reviews. Additional l

copies of the checklists and comment sections shall be used as required j

to thoroughly document the results of the reviews.

l 5.4.5 The ORG Lead Verifier and the other Verifiers shall also review the findings and corrective actions that resulted from NU's Configuration i

Management Plan (CMP). S&L shall not duplicate findings identified by i

the NU CMP.

5.4.6 The ORG Verifier will complete the verification of the procedures versus the i

system requirements by dispositioning each requirement on the System l

Requirements Checklist, Checklist CK-MP1-02-02.

j 5.4.7 The Verifier (s) shallidentify on the System Requirements Checklist, the procedures that verify the system requirements are satisfied. The Verifier (s) shall indicate that the procedure is technically adequate or describe any j

deficiencies. The Verifier shall also identify missing procedures, if

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applicable.

5.4.8 The Verifier (s) shall initial and date all entries in the System Requirements l

Checklist, and shall sign the System Requirements Checklist when completed.

1 5.4.9 The ORG Lead shall review the disposition in the system requirements i

Checklist, CK-MP1-02-02, for completeness and technical accuracy. The ORG Lead shall indicate his concurrence with signature and date in the j

appropriate column. The ORG Lead shall notify the ARG Lead that either all j

critical characteristics for accident mitigation systems have been satisfied or he shall identify which have not been.

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5.4.10 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.7 l

of this PI for any discrepancies not previously identified by the NU CMP.

5.4.11 The ORG Lead shall verify the checklists have been properly completed and shalli indicate concurrence by signing and dating the checklists. The l

ORG Lead will file the checklists in the project file in accordance with j

PI-MP1-12.

j 5.5 Review of Chanaes i

t 5.5.1 The ORG Verifier shall independently review the Modification Packages i

and appropriate Modification Screening Checklists, CK-MP1-03-02, that have been forwarded from the SRG. The intent of this reviewis to j

identify the specific procedures to be reviewed by the SRG for those modifications that were determined to either have procedure impact, or may have procedure impact, by the SRG.

4 1

5.5.2 The ORG Verifier shalllist the Modification Package Identification and the appropriate Modification Screening Checklist identification on any j

checklists used in the steps of this section of tile Pl. The ORG Verifier i

shall also list the appropriate procedures for the modification being evaluated on each checklist used in this Pl, i

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5.5.3 Based on a technical review of the modification packages forwarded to the ORG from the SRG, the ORG Veri %r shall confirm that the appropriate procedures for the modification being evaluated are listed on the SRL obtained from the SRG lead as described in Pl Section 5.2.5.

Any additional procedures that are identified during the modification i

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review that are not on the SRL should be listed on a copy of the SRL, and forwarded to the SRG Lead for updating the SRL The ORG Verifier shall use Checklist CK-MP1-06-11 to list all procedures for the modification being evaluated.

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5.5.4 The ORG Verifier shall list the change processes that the PRG is i

reviewing according to PI-MP1-04 on Checklist CK-MP1-06-12. The j

ORG Verifier shall select 1 or 2 procedure change items for each of the i

change processes that the PRG is reviewing and list these procedures also on Checklist CK-MP1-06-12, and provide a detailed review of those changes to verify the technical adequacy of the changed procedures to reflect the initiating change. These procedures shall be reviewed as described below in Section 5.5.8 of this Pl. The results of the review of these PRG Change Process procedures shall be evaluated for discrepancies and reported as described in Section 5.5.15 of this Pl.

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5.5.5 Any newly identified procedures that are not in the ICAVP Library should be requested from MP1 in accordance with section 3.1 of PI-MP1-01.

i 5.5.6 The ORG Verifier shall perform a detailed review of the appropriate procedures for each modification or change process to evaluate them for implementation of the changes identified. During the detailed review, the f

ORG Verifier should consider the need to identify specific Significant j

j Support / Interacting Systems and Related Activities to also be reviewed I

j for implementation of the above identified changes, based on initial I

reviews or results of questions considered as described in Section l

5.5.8.d of this Pl. The Verifier shall refer to Definition 3.11 of this PI for I

clarification l

I 5.5.7 The ORG Verifier shall verify that the design and operation changes identified by the SRG in Section 5.2.7 above, or identified by the reviews of this section of the Pl, or the changes identified by the PRG as

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described in Section 5.5.4 above, are adequately reflected in operating, i

l maintenance, and testing procedures, in training materials, and in the simulator configuration as appropriate. The ORG Verifier shalllist each i

modification or change process to be evaluated on each checklist used in Section 5.5.8 below. The Verifier shalllist each procedure that is d

being evaluated for implementation of the changes also on each j

i checklist used in Section 5.5.8. The ORG Verifier shall also list the j

j specific procedure section as a reference for each item that is being j

evaluated.

5.5.8 The ORG Verifier will review the relevant procedures to:

i 1

a. Verify that operation and maintenance of the system is consistent i

with any modifications to the design bases and current licensing basis features, including the Unit 1 Position Papers, for the system 1

being reviewed. The Verifier shall list the features and document the results of his review on Checklist CK-MP1-06-02.

b. Vei1fy by reviewing the procedures that all modes and phases of the selected system are adequately operated, maintained, and tested to i

reflect the changes. The Verifier shalllist the appropriate modes and phases and document the results of his review on Checklist CK-MP1-06-03.

c. Verify that the various system configurations described in the procedures will perform their intended functions to reflect the i

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changes by reviewing the appropriate P&lD's. The ORG Verifier shalllist the appropriate P&lD's and document the results of his review on Checklist CK-MP1-06-04.

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d. Verify that any required Significant Support / Interacting Systems and Related Activities (refer to definition 3.11 of this PI for clarification) adequately provide for proper performance of the system being j

reviewed to accomplish the changes. The ORG Verifier shall i

complete Checklist CK-MP1-06-05 to evaluate the need for further l

items to De reviewed. The Verifier shall add any requirements to the i

System Requirements Checklist in accordance with Section 5.3 of l

this Pl. The Verifier shall add any necessary references to the SRL in accordance with Section 5.2.4 of this Pl. The Verifier shall i

document the results of his review on Checklist CK-MP1-06-05 I

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j NOTE: This step is not intended to verify the adequacy of supporting systems and functions, but is merely intended to verify that i

procedures for supporting systems and functions reflect the ICAVP j

systems' requirements.

e. Verify that sections of vendor manuals, equipment operating instructions, drawings, or other supplemental documents that are I

referenced, or used directly as operating or maintenance procedures receive the same level of MP1 review and approval as the initial j

procedures. This is not a review of the technical adequacy of the documents. The Verifier shall list any such documents and i

document the results of his review on Checklist CK-MP1-06-06.

i

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f.

Verify that the instruments and controls identified in the procedures i

to be used for remote and local operation are consistent with the installed configuration. The Verifier shall list any such instruments and controls, identify whether they are local or remote. and i

document the results of his review on Checklist CK-MP1-06-07.

i i

g. Verify that vendor manuals / files adequately support the requirements f

for the change. The Verifier shalllist the manuals / files reviewed, and document the results of his review on Checklist CK-MP1-06-08.

I 2

h. Verify thd performance history files adequately support the change requirements for the system being reviewed.This verification shall

}

include reviews to identify recurring equipment problems, and determination of any trends. Additionally, the verification shall

}

include review of the technical adequacy of maintenance activities, i

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Page 14 of 20

j I

l PROJECT INSTRUCTION PI-MP1-06 INSTRUCTION REV.O i

performance of appropriate post-maintenance tests, and satisfactory demonstration of equipment operability. The verifier shalllist the files and specific items reviewed. Specific references shall be indicated on the checklist. The Verifier shall document the results of his review on Checklist CK-MP1-06-09.

l

i. Verify that training materials, especially operator training materials, have been appropriately updated to reflect the change. The Verifier shall also identify any required simulator configuration changes to evaluate.The Verifier shall list the training materials reviewed, and any simulator changes evaluated, and document the results of his review on Checklist CK-MP1-06-13.

j. It may be appropriate to walkdown some of the changes in the field to observe for procedure control, and to witness samples of the i

review items from the above sections. Referto Section 5.6.11 of j

this PI for a description of the walkdown arrangements. The Verifier shall cleady identify any items verified by walkdown on the j

appropriate Checklist, and document the results of his review with comments on the appropriate checklist.

l 5.5.9 The verifier shall note any comments identified during the review on the comment section of each checklist used in the above reviews. Additional 8

copies of the checklists and comment sections shall be used as required to thoroughly document the results of the reviews i

5.5.10 The ORG Lead Verifier and the other Verifiers shall also review the findings and corrective actions that resulted from NU's Configuration l

Management Plan (CMP). S&L shall not duplicate findings identified by j

the NU CMP.

i j

5.5.11 The ORG Verifier will complete the verification of the procedures versus the i

change requirements by dispositioning each requirement on the System Requirements Checklist (Checklist CK-MP1-02-02).

5.5.12 The Verifier (r) shallidentify on the System Requirements Checklist, the i

procedures that verify the change requirements are satisfied. The Verifier (s) i shall indicate that the procedure is technically adequate or describe any i

deficiencies. The Verifier shall also identify missing procedures, if l

applicable.

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Page 15 of 20

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PROJECT INSTRUCTION PI-MP1-06 inSTauCrion Rev.0

(

i 5.5.13 The Verifier (s) shall initial and date all entries in the System Requirements l

Checklist, and shall sign the System Requirements Checklist when i

completed.

i 5.5.14 The ORG Lead shall review the disposition in the system requirements Checklist, CK-MP1-02-02, for completeness and technical accuracy. The l

ORG Lead shallindicate his concurrence with signature and date in the l

appropriate column. The ORG Lead shall notify the ARG Lead that either all critical characteristics for accident mitigation systems have been satisfied or j

he shall identify which have not been.

i l

5.5.15 The Verifier (s) shall generate a Discrepancy Report per Subsection 5.7 l

of this P1 for any discrepancies not previously identified by the NU CMP.

1 i

5.5.16 The ORG Lead will verify the checklists have been properly completed j

and willindicate concurrence by signing and dating the checklists. The i

ORG Lead will file the checklists to the project file in accordance with l

PI-MP1 12.

5.6 Review of Testino 5.6.1 The ORG shall use input from the SRG to assist in the identification of l

required testing for the system. Modification functional test requirements

}

and acceptance criteria are contained in the modifiration packages and l

are being reviewed by the SRG per PI-MP1-03. The, ORG Verifier shall list the test requirements from the System Requirements Checklist,and l

the modification tests forwarded by the SRG, on Testing Requirements i

+

Review Checklist CK-MP1-06-15.

5.6.2 The ORG Verifier shall also identify other testing requirements for the system being reviewed by using Testing Requirements Checklist Ck-MP1-06-14, as guidance The Verifier shall review the resource material, including the Unit 1 Position Papers, for each category on CK-MP1 14 to ldentify any additional required testing for the system being

{

reviewed. The ORG Verifier shall list the specific test requirements for each category on Checklist CK-MP1-06-14 and the specific procedures that implement each required test as a reference on CK-MP1-06-14.

i The procedures identified on CK-MP1-06-14 shall be listed on CK-MP1-l 06-15 along with the procedures listed as described in Section 5.6.1, j

above, of this Pl.

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Page 16 of 20 i

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l PROJECT INSTRUCTION PI-MP1-06 INSTRUCTION REV.0 1

5.6.3 The ORG Verifier shall also list the Surveillance tests required to verify 1

the critical parameters for the Accident Mitigation Systems, forwarded by i

the ARG, on Checklist CK-MP1-06-15.

l j

5.6.4 The ORG verifier shall use the station document index to identify the i

specific testing procedures and the data / calculation / review sheets for each category on the list.

5.6.5 The ORG Verifier shall request relevant documents, which are not in the

{

ICAVP Library, from NU in accordance with subsection 3.1 of PI-MP1-01.

5.6.6 The ORG Verifier shall provide a list of required procedures that were i

not on the SRL to the SRG Lead so that an update to the SRL can be j

prepared and issued. Additionally, any requirements that were identified in Sections 5.6.1, and 5.6.2, above, that were not on the System j

Requirements Checklist, CK-MP1-02-02, shall be listed on a copy of CK-MP1-02-02, and forwarded to the SRG Lead for updating the System l

Requirements Checklist.

f l

5.6.7 The ORG Verifier shalllist each test requirement item from Section 5.6.1, 5.6.2, and 5.6.3, above, on a copy of Checklist CK-MP1-06-15, along with the specific procedure or procedure sections as references.

l The Verifier shall use CK-MP1-0615 to complete the reviews described in Section 5.6.9 of this Pl.

I l

5.6.8 The ORG Verifier shall select a sample of the on-going periodic tests to review based on the required frequency of the specific test item. For test items with a frequency of regular intervals within each refuel cycle, the sample shallinclude the most current three performances of the specific test. For test frequencies that are once per refuel cycle, the sample shall be the last time the test was performed. The verifier shall identify the test frequency on the appropriate checklist for each item. For tests that are one-time performance, such as post maintenance tests or special i

tests, the Verifier shall select a sample of three items to review for each j

test category as described in Section 5.6.2 above of this Pl.

j 5.6.9 The ORG Verifier will review each test item to:

j

a. Verify that test data and results have been appropriately reviewed 1

and approved Specific data and results identifications shall be listed for each item on CK-MP1-06-15. The Verifier shall document the i

results of his review on the Checklist. It may be appropriate to

}

conduct field walkdowns to verify the results for some of the tests to

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Page 17 of 20

_~..___ _ __ _._ _ _ _ _____ _ _ _

i, PROJECT INSTRUCTION PI-MP1-06

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INSTRUCTION REV.0 2

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be reviewed. The process for the walkdowns is described in Section 5.6.11 of this Pl below.

1 4

j

b. Verify that acceptance criteria have been met. The Verifier shalllist j

the specific acceptance criteria, and document the resuits of his i

review on Checklist CK-MP1-06-15.

c. Verify that each test appropriately tests for the requirements identified in Section 5.6.1, 5.6.2, and 5.6.3 and listed on CK-MP1 15 The Verifier shall list the bases requirements, and document the results of his review on Checklist CK-MP1-06-15 I

d. Assess the adequacy of the test procedure and of the actions taken

)

as a result of the tests, ( e.g., test " trend"information and root cause analyses for test failures; where appropriate, retesting; compliance with Limiting Conditions for Operations; condition reports). The Verifier shall list the items to be reviewed on Checklist CK-MP1 l 16, and document the results on the Checklist.

1 j

e. Verify that testing records are appropriately maintained, and are j

retrievable. The verifier shall identify the specific records 1

1 reviewed,and document the results on Checklist CK-MP1-06-17.

5.6.10 The verifier shall note any comments identified during the review on the comment section of each checklist used in the above reviews. Additional copies of the checklists and comment sections shall be used as required to thoroughly document the results of the reviews 5.6.11 The ORG Verifier may identify a sample of activities to walkdown and observe for actual performance in the field. The walkdown may be used to aid in verifing system performance, and to aid in verifing adequate control of the appropriate procedures,and to observe for proper conduct of the activity according to the approved procedures. This walkdown can be used for witnessing conduct of any of the procedures subject to review by this Pl. This includes; operating pmcedures, maintenance procedures, surveillance procedures, and simulator training performance. The verifier shall identify any activities to be observed on Checklist CK-MP1-0618. The ORG Verifier shall refer to PI-MP1-05 for guidance in walkdown planning, or discuss the walkdown plan with the CRG Lead.

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i PROJECT

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INSTRUCTION PI-MP1-06 i

INSTRUCTION REV.O 5.6.12 The ORG Verifiers shall also review the findings and corrective actions that resulted from NU's Configuration Management Plan (CMP). S&L shall not duplicate findings identified by the NU CMP.

1 5.6 93 The ORG Verifier will complete the verification of the testing procedures versus the system testing requirements by dispositioning each requirement j

on the System Requirements Checklist, CK-MP1-02-02.

5.6.14 The Verifier (s) shallidentify on the System Requirements Checklist, the i

testing procedures that verify the system testing requirements are satis ~9d.

The Verifier (s) shallindicate that the procedure is technically adequate or j

describe any deficiencies. The Verifier shall also identify missing procedures,if applicable.

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5.6.15 The Verifier (s) shall initial and date all entries in the System Requirements

]

Checklist, and shall sign the System Requirements Checklist when l

completed.

5.6.16 The ORG Lead shall review the disposition in the system requirements I

Checklist, CK-MP1-02-02, for completeness and technical accuracy. The l

ORG Lead shallindicate his concurrence with signature and date in the

{

appropriate column.

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Additionally, the ORG Lead shall notify the ARG Lead that either all critical characteristics for accident mitigation systems have been satisfied or he shallidentify which have not been.

5.6.17 The Verifier (s) shall generate a Discrepancy Report per Suosection 5.7 i

of this PI for any discrepancies not previously identified by the NU CMP.

j 5.6.18 The ORG Lead shall verify the checklists have been properly completed j

and shallindicate concurrence by signing and dating the checklists. The i

j ORG Lead shall file the checklists to the project file in accordance with l

PI-MP1-12.

5.7 Discrepancy Report Preparation and Closure I

i 5.7.1 Discrepancy Reports for discrepancies identified during the review j

process shall be prepared and processed in accordance with PI-MP1-11.

Discrepancy Reports shall not be initiated for findings already identified

)

by NU during implementation of the CMP.

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1 PROJECT INSTRUCTION PI-MP1-06 l

INSTRUCTION REV.O 5.7.2 Review of NU dispositions for the Discrepancy Reports generated during j

the review cycle shall be in accordance with PI-MP1-11.

5.8 Final Reoort l

5.8.1 The ORG Lead Verifier shall draft the section of the final report summarizing the results of the ORG system reviews.

5.8.2 The report format shall be determined by the Verification Team Manager.

6 ATTACHMENTS I

8.1 O&M&T Process Flow Chart page(1 page) i t

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Domment Retnval and 8teview SRGCRGrCRG Pro e eye.m Reisence Ust GRGIORGICRG L

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PROJECT

• • [*"

INSTRUCTION PI-MP1-07 INSTRUCTION REV.0 i

Client: Northeast UtHities j

Station: Millstone Unit 1

Title:

REVIEW OF ACCIDENT MITIGATION SYSTEMS l

I f

8 Safety-Related Non-Safety-Related l

Reviewed By:

Approved By:

l i

System Lead Programmatic O&M Lead Accident QA Engineer intamal Review Verification Team l

Lead Mitigation Committee Manager i

Lead Chairman 3'I747

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Date:

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1. 8 ~ ff// M (/W//thyt&d,J/M ATAW WAN Description Inftlal is'ue

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PROJECT INSTRUCTION PI-MP1-07 i

INSTRUCTION REV.O i

l 1.0 PURPOSE i

This procedure establishes the requirements for the ICAVP Verification Team to I

identify and review the critical design characteristics for the accident mitigating systems tc provide reasonable assurance that these system parameters meet their design and licensing requirements as discussed in References 2.1 and 2.2.

i I

2.0 REFERENCE i

j 2.1 NRC Confirmatory Order establishing Independent Corrective Action i

Verification Program Millstone Power Station Units 1,2 and 3.

J 2.2 Millstone Independent Corrective Action Verification Program - Oversight Inspection Plan dated 12/19/96.

I i

2.3 S&L Project Instruction PI-MP1-01, ICAVP Communications Protocol d

j 2.4 S&L Project Instruction PI-MP1-02, Review of System Design for j

Compliance with Design and Licensing Basis i

2.5 S&L Project instruction PI-MP1-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration Control 1

l 2.6 S&L Project instruction PI-MP1-06, Operations and Maintenance and l

Testing Procedures and Training Documentation Reviews 2.7 S&L Project instruction PI-MP1-09, Preparation and Approval of Checklists i

j 2.8 S&L Project instruction PI-MP1-11, Discrepancy Report Submittal and Closure 1

2.9 S&L Project Instruction PI-MP1-12, Project File Index 2.10 CK-MP1-07 Series Checklists as follows:

CK-MP1-07-01 FSAR Ch 15 Accidents, Systems & Components (Not included in this PI)

N Page 2 of 5

I 1

PROJECT INSTRUCTION PI-MP1-07 INSTRUCTION REV.O i

l 3.0 DEFINITIONS l

j 3.1 Accident Mitigation Systems Review Group (ARG)- The subgroup of the i

ICAVP Verification Team responsible for the identification and review of the f

critical design characteristics for the accident mitigating systems to ensure j

that they can perform their required safety functions, i

3.2 System Review Group (SRG)- The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the j

system in the scope of the ICAVP.

j 3.3 Operations & Maintenance and Testing Review Group (ORG)- The j

subgroup of the ICAVP Verification team responsible for the review of the l

operating, maintenance and testing procedures, and training manuals for the j

j systems within the scope of the ICAVP.

j 3.4 Independent Corrective Action Verification Program (ICAVP) - The program required by NRC Confirmatory order, Reference 2.1 to verify the i

adequacy of the corrective actions taken by NU for their configuration i

management of design and licensing basis of the unit.

l 3.5 Discrepancy Report (DR) - The mechanism for documenting the discrepant l

conditions identified by the ICAVP and reporting an apparent error, j

inconsistency, or procedural vlotation with regard to licensing commitments, j

specifications, procedures, codes or regulations.

4 i

l 3.6 Verifier-The individual assigned to review engineering attributes within his area of responsibility.

i 3.7 System Critical Parameters - The variables that are relied upon for j

p6 ming the safety related functions of an accident mitigating system.

s 1

4.0 RESPONSIBILITIES 4.1 The Verification Team Manager shall be responsible for providing overa'!

guidance and management to the teams.

4.2 The ARG Lead shall be responsible for assigning the discipline verifiers for j

identifying the accident mitigating systems and a review of their critical j

design characteristics necessary to perform their safety function (s).

N Page 3 of 5

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PROJECT INSTRUCTION PI-MP1-07

+

INSTRUCTION REV.O i

4.3 The Discipline Verifiers (Mechanical, Electrical, l&C, Nuclear) shall be responsible for identifying the critical system parameters from the FSAR l

accident parameters and verifying that these attributes meet the plant l

current design basis in accordance with this instruction.

5.0 PROCEDURE j

The process discussed below shall be used by the ARG to develop the critical j

parameters for the accident mitigating systems. Sections 5.1,5.2 and 5.3 l

discussed below shall be the responsibility of the ARG for all the accident mitigation systems. ARG shall be responsible for the remainder of the Sections 5.4 through 5.7 for only those accident mitigation systems which are not j

included in the detailed Vertical Slice Review (VSR) which shall be done by l

ORG and SRG. These reviews are addressed in the Project Instructions j

References 2.4 through 2.6.

I 5.1 The ARG Lead and Discipline Verifiers shall review the accidents

)

analyzed in the FSAR, for Millstone Unit 1 and identify the accident j

mitigating systems, components within the system and specific critica!

l parameters which are required to mitigate the event. As a result of this is review the ARG Lead or his designee shall create a database consisting i

j of the following items: a) Analyzed Accidents, b) Mitigating Systems, c)

Components, d) Critical Parameters and e) References to the accidents and associated documents contained in the SAR, where the parameters

' were used by the NSSS supplier or AE during the original analysis at the j

time of receipt of the Operating License or a revised analysis due to j

changes or modifications.

i

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5.2 The ARG Lead or his designee shall sort the database in Section 5.1 to facilitate the verification of the critical parameters in the following order:

l a) Mitigating Systems, b) Components, c) Critical Parameters, d)

References and e) Analyzed Accidents.

5.3 The portion of the database consisting of the accident mitigatbn systems in the VSR shall be given to the ORG and SRG for their review of the Critical Parameters.

6 Page 4 of 5

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PROJECT

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INSTRUCTION PI-MP1-07 lNSTRUCTION REV.0 l

5.4 The ARG Verifiers shall verify the Critical Parameters listed in Section 5.2 using a documented System / Component test, and or Surveillance t

i test from the Millstone Unit 1 Technical Specification or Post 1

Maintenance Tests. The verification shall be documented on the appropriate ORG Checklist (s) from Reference 2.7 which shall be signed l

and dated.

i 5.5 In addition to the verification of the Critical Parameters by test reviews i

i discussed in Section 5.4, the design calculations, specifications, vendor documents and drawings shall be obtained and reviewed for

)

i conformance with the design requirements of the accident analysis.

j Request for documentation shall be processed in accordance with Reference 2.3.

l i

5.6 Verification of the Critical Parameters using design calculations, 1

specifications, vendor drawings or documents shall be documented on the appropriate SRG Checklist (s) (Ref. 2.4 and 2.5) which shall be signed and dated. lf the Critical Parameters cannot be verified the review conclusions shall be documented on the appropriate Checklist (s) and a Discrepancy Report shall be processed in accordance with Reference 2.8.

5.7. The ARG Lead or his designee shall verify that the checklists have i

been properly completed and indicate concurrence with his signature and date. He shall file the documents per Reference 2.9.

i 5.8 The ARG Lead shall draft a final report summarizing the results of the j

review. The report format shall be determined by the Verification Team Manager.

J t'

6.0 ATTACHMENTS 6.1 lCAVP Review of Critical Parameters for Accident Mitigation Systems

-(1 page)

N Page 5 of 5

l Floure 1

!(

ICAVP Review of Critical Parameters i

for Accident Mitigating Systems Review Plant Accident Initiating Events I

ARG

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Create a Database Accidents, Systems, Components, Critical Parameters, Provide Critical References Parameters for VSR Systems to ORG/SRG ARG

+

for Review per 4

PI-MP1-02 & 06 Verify Critical Parameters Using

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Tech. Spec.,

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Design Cales, Specifications, vendor docurnents/ drawings ARG Were o

Discrepancie[s identified?

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,Yes Process DRs PI-MP1-11 ARG

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ARG

PI-MP1-07, Rav. 0 AttachmInt 6.1 1

Floure 1 O

i ICAVP Review of Critical Parameters for j

Accident Mitigating Systems Review Plant Accident initiating Events ARG i

e Create a Database 2

Accidents, Systems, Components, Critical Parameters, Provide Critical s

References Parameters for VSR Systems to ORG/SRG for Review per ARG

+

3 PI-MP1-02 & 06 v

Verify Critical 3

Parameters Using Tech. Spec.,

Design Cales, Specifications, vendor t

documents / drawings 4

ARG s

Were Discrepancies No identified? /

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Yes 1

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Process DRs i

PI-MP1-11 4

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ARG l

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1 l

PROJECT INSTRUCTION PI-MP1-08 INSTRUCTION REV.0 4

i Client: Northeast Utilities i

i Station: Millstone Unit 1 i

Title:

ICAVP TEAM PERSONNEL SUBSTITUTION AND/OR ADDITION a

i i

i i

2 Safety-Related Non-Safety-Related i

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Reviewed By:

Approved By:

System Lead Programmatic O&M Lead Accidant QA Engineer Internal Review Verification Team

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Lead Mitigation Committee Manager Lead Chairman l

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Date:3"IN7 2,,

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Page 1 of 4

PROJECT INSTRUCTION PI-MP1-08 INSTRUCTION REV.O j

1.0 PURPOSE l

This instruction establishes the requirements for the substitution and addition of personnel to the ICAVP Project Team. The selection of personnel for the l

lCAVP was based on their qualifications to perform the assigned reviews, i

their financial and technical independence from the Unit being reviewed, and j

NRC acceptance of the personnel. Substitution of existing personnel on the team may be required as a result of unavoidable circumstances. Addition of j

personnel may be required to add expertise or manpower to fully investigate issues which are identified during the course of the program.

I i

2.0 REFERENCE i

i 2.1 NRC Confirmatory Order Establishing Independent Correction Action Verification Program - Millstone Nuclear Power Station, Units 1,2, and j

3 i

2.2 PI-MP1-01, ICAVP Communications Protocol iO

)

3.0 DEFINITIONS I

3.1 Substitution - Replacing existing personnel on the ICAVP Project i

Team which were included in the original proposal for that Unit and l

which the NRC interviewed and accepted.

I I

3.2 Addition - Adding personnel to the ICAVP Project Team.

t i

3.3 System Review Group (SRG)- The subgroup of the ICAVP l

Verification Team responsible for performing an in-depth review of the i

design of the systems in the scope of the ICAVP.

l 3.4 Operations & Maintenance and Testing Review Group (ORG)-The j

subgroup of the ICAVP Verification Team responsible for the review of j

the operating, maintenance and testing procedures, and training j

manuals for the systems within the scope of the ICAVP.

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Page 2 of 4

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PROJECT INSTRUCTION PI-MP1-08 Rev.0 iNSTRUCrioN 1

i 3.5 Accident Mitigation Review Group (ARG)- The subgroup of the ICAVP Verification Team responsible for the review of the critical system attributes of the systems used to mitigate the consequences of j

an accident.

3.6 Programmatic Review Group (PRG)- The subgroup of the ICAVP j

Verification Team responsible for performing a review of the design control and corrective action processes in the scope of the ICAVP.

l l

4.0 RESPONSIBILITIES 4.1 The Verification Team Manager shall be responsible for the selection of substitute or additional personnel for the ICAVP Project Team.

i 4.2 The individual personnel shall be responsible for completing the l

Objectivity 0uestionnaire.

5.0 PROCEDURE 5.1 Substitution j

j I

The Nuclear Regulatory Commission (NRC) Confirmatory Order

)

referenced in Section 2.0 of this PI requires that the selection of the members of the ICAVP Project Team be subject to NRC staff approval.

Prior to the start of the program the original team will have been j

approved by the NRC. If for some reason team members cannot fulfill l

their obligation to the Project Team, the Verification Team Manager

-hall select replacements for them. The substitute personnel shall j

have the technical background, education and experience necessary i

to perform the functions that are required of them by their position on i

the ICAVP Project Team. They shall also be required to meet the I

independence criteria established for the original team members. The substitute personnel shall satisfactorily complete the ICAVP Objectivity Questionnaire (Attachment 6.1). The Verification Team Manager shall notify the NRC and NU in writing in accordance with the Communications Protocol (PI-MP1-01) that substitutions were made.

j The Verification Team Manager shall provide the NRC and NU with a

i d

l PROJECT

";f/""

INSTRUCTION PI-MP1-08 i O

'NS1RuCTiON REv. 0 i

)

copy of the substitute personnels' resumes and a copy of their j

completed Objectivity Questionnaires (Attachment 6.1), if the NRC notifies S&L that it has unresolvable objections to the qualifications or the independence of the substitute personnel, they shall be suspended from any further work on the ICAVP and all work performed by them shall be reperformed by acceptable individuals.

5.2 Addition j

l Since the specific systems selected for the ICAVP are not known at this time, it is difficult to know exactly the number of engineers in each discipline and the number of specialists that will be needed to j

implement the ICAVP, in addition, as the program proceeds, specific j

issues may be identified which need specialized expertise to fully i

investigate. Or, the size and complexity of the systems chosen for j

review may be greater than estimated. If any of these situations j

occur, additional staff may be needed for the Verification Team. In i

this case the Verification Manager will select additional personnel for the ICAVP Project Team. Similar to section 5.1 above, the additional q

personnel shall have the technical background, education and j

experience necessary to perform the functions that are required of g

them by their position on the ICAVP Project Team. They shall also be required to meet the independence criteria established for the original team members. The additional personnel shall satisfactorily complete the ICAVP Objectivity Questionnaire (Attachment 6.1). The Verification Team Manager shall notify the NRC and NU in writing in accordance with the Communications Protocol (PI-MP1-01) that additional personnel are being added to the Project Team. The Verification Team Manager shall provide the NRC and NU with a copy of the additional personnels' resume and a copy of their completed Objectivity Questionnaires. If the NRC notifies S&L that it has unresolvable objections to the qualifications or the independence of the additional personnel, they shr.Il be suspended from any further work on the ICAVP and all work performed by them shall be reperformed by acceptable individuals.

6.0 ATTACHMENTS 6.1 ICAVP Objectivity Questionnaire (1 page) m Page 4 of 4

._.__.m Attachm::nt 6.1 Millstone Unit 1 ICAVP Objectivity Questionnarie 1.

Name:

2.

Current Employer:

3.

Project Title / Function:

4.

Have you ever been ernployed by any of the folowing companies:

Northeast Utisties Yes No _,,,

Raytheon/E8ASCo Yes __.

No General Electric Yes No _,

5.

Have you been involved in ary Millstone 1 actMty in your previous or current position?

Yes __,

No _,

6.

Have any of your immediate family (father, mother, spouse, son, or daughter) been involved in any Millstone 1 activity in their previous or current position?

Yes _

No _

7.

Do you own/ control stock in any of the following companies?

Northeast Utilties Yes No __

Raytheon/EBASco Yes_

No _

General Electric Yes _

No _._,

i 8.

Have you been promised any additional compensation, reward of anything of any value, contingent upon the position you take on any issue being considered by you in connection with the Millstone 1 ICAVP?

Yes _,,.

No _,

9.

Do you know of any reason, whether or not inquired about in this questionnaire, which would affect your obilty to be completely objective in performing any of the tasks assigned to you with the Millstone 1 ICAVP?

Yes _,._

No,_._

10.

Are you aware of any reason which might create a perception that you would not act with objectivity in performing any of the tasks assigned to you in connection with the MiNatone 1 ICAVF7 Yes No 11.

If the answer to any one or more of the questions was "yes', please explain each such reply futy, referenced by the question number, on the reverse side of this l

questionnaire. Attach additional sheets as needed.

Signature of Appicant Date Reviewed and Accepted by:

Date i

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i PROJECT INSTRUCTION PI-MP1-09 INSTRUCTION REV.O Client: Northeast Utilities i

Station: Millstone Unit 1 i

Title:

PREPARATION AND APPROVAL OF CHECKLISTS i

i

{

h Safety-Related

[ Non Safety-Related I

i j

Reviewed By:

Approved By:

i System Lead Programmatic C&M Lead Accident QA Engineer intemal Review Verification Team Lead Mitigation Committee Manager Lead Chairman Date:3-17-Y7

/ >

hb Ib

[N"M /k[?/Wobgbs kN h ~f M Desedption gMallsfue

(/ '

Page 1 of 5 l

"~

PROJECT INSTRUCTION PI-MP1-09 O

iNSrauCriON Rev. 0 1

1.0 PURPQSE

}

This project instruction (PI) establishes the Sargent & Lundy procedure for preparing checklists to be used in the Independent Corrective Action Verification Program (ICAVP) reviews. These checklists shall be used by the ICAVP l

reviewers to document and verify key attributes and areas covered in the ICAVP. These checklists will provide the team with the basis for determining if i

i discrepancies exist in the design, configuration, and operation, maintenance l

and testing of the Millstone Unit 1 plant (MP1).

All areas of the ICAVP shall utilize checklists to control the review activities.

l These areas include:

i l

System Reviews Operation, Maintenance and Testing Reviews Physical Configuration Reviews 1

Programmatic Reviews l

Accident Mitigation Systems Review As many checklists as is required to adequately cover the particular review area j

shall be utilized.

i j

2.0 REFERENCES

2.1 MP1 Final Safety Analysis Report 2.2 MP1 Safety Evaluation Report 2.3 MP1 Technical Specifications 2.4 MP1 Design Criteria 2.5 10CFR50 Appendix A General Design Criteria 2.6 NRC Inspection Manual, Chapter 2535, Appendix A 3.0 DEFINITIONS 3.1 System Review-In depth review of the design of the systems in the scope of the ICAVP m

Page 2 of 5

PROJECT

"[p/*~

INSTRUCTION PI-MP1-09 O

insTauCTiOs aev. 0 l

1 3.2 Operation, Maintenance and Testing Review-Review of the t

operating, maintenance and testing procedures, and training manuals for the systems within the scope of the ICAVP l

3.3 Physical Configuration Review - Walkdowns to verify that the current I

as-built conditions are in conformance with the design and licensing j

basis for the systems within the scope of the ICAVP j

3.4 Programmatic Review - Review of programs and processes addressing j

" generic" (non-system specific) issues i

3.5 Accident Mitigation System Review - Review of the critical design characteristics for the accident mitigating systems to ensure that they j

can perform their required safety functions.

i j

4.0 ftESPONSIBILITIES i

i 4.1 A Verification Team (VT) Member shall be responsible for preparation of a checklist and for performing a review associated with a checklist.

4.2 The VT Lead or his designee shall be responsible for approving the l

checklists in his area and for providing concurrence for the reviews l

l conducted within his area.

l 4.3 The VT Manager shall be responsible for resolving comments which l

cannot be resolved between a team member (reviewer) and the Team Lead. The Verification Team Manager may also approve checklists.

5.0 PROCEDURE 5.1 General I

The checklists are intended to assure that key issues associated with a j

particular area or element are adequately and consistently evaluated during the review process. Some checklists may be system specific, but i

many of the checklists will apply to elements that are common to many or all systems.

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i PROJECT

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INSTRUCTION PI-MP1-09 isSTRuCTioN Rev. o 1

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5.2 Checklist Preparation 5.2.1 Checklists shall be prepared prior to performing the affected review 1

activities.

5.2.2 The checklist shall be prepared by an individual knowledgeable in the i

area or element under review. The preparer may be the individual who will perform the review.

5.2.3 The first page of the checklist shall use a form similar to that shown in i.2. The checklist shall contain questions related to key Issues applicable to the area or element under review. Applicable i

checklists developed for previous project reviews may be utilized as a source for checklist preparation. Input for checkiisi pieparation mov ba obtained from the following:

i j

MP1 Final Safety Analysis Report i

MP1 Safety Evaluation Report j

MP1 Technical Specifications MP1 Design Criteria 10CFR50 Appendix A General Design Criteria i

USNRC Regulatory Guides applicable to MP1 l

Industry Codes and Standards applicable to MP1 1

In addition to the above MP1 source documents, S&L design experience

{

and practices, as well as industry experience, shall provide a basis for j

checklist preparation. Chapter 2535, " Design Verification Programs",

i Appendix A, of the NRC Inspection Manual also provides guidance for checklist preparation, (Ref. 2.6).

i

}

Checklists shall address system design adequacy, component design i

adequacy, design process adequacy, and plant procedure adequacy, i

Specific accept / reject criteria shall be provided for configuration reviews.

5.2.4 Checklists shall be numbered by each ICAVP group according to the following scheme:

CK-MP1-M-M l

Project instruction -

L SequentialNumber Applicable to the l

Checklist l

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PROJECT "f

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INSTRUCTION PI-MP1-09

O INSTRUCTION aev. 0 l

i 5.2.5 The Team Member designated as preparer of the checklist shall sign and dato the checklist. The checklist shall be approved by the respective VT Lead or by the VT Manager.

j 5.2.6 The VT Lead shall file checklists in the project file in accordance with PI-l MP1-12.

i 5.3 Checklist Completion 1

l l

The ICAVP Verifier assigned to perform the evaluation of a particular 1

area / element shall complete the appropriate checklist according to the requirements of the applicable project instruction and sign and date the l

checklist. It is recommended that the checklist be used to document the j

basis for accepting questionable items which might otherwise be considered discrepant by another reviewer. As a minimum, the appropriate VT Lead or his designee will indicate his concurrence with I

the review work performed by the ICAVP Verifier by also signing and j

dating the checklist. This concurrence will confirm that the checklist is j

complete and that there is adequate explanation describing the results.

i Concurrence shall not be given unless there is documentation of those records and/or documents used in filling out the checklist.

Any unresolved comments between the ICAVP reviewer and the VT Lead will be resolved by the VT Manager. Any differing professional coinions shall be handled in accordance with PI-MP1-10.

i

)

Discrepancies identified as a result of the checklist review shall be processed in accordance with PI-MP1-11.

i.

l 6.0 REVISIONS

)

Any revisions to a checklist shall be prepared and approved in the same manner j

as the originalissue. The revision level of the checklist shall be indicated on the j

checklist. If a checklist revision is made subsequent to the completion of any i

reviews, the affected review shall also be updated, as applicable, to account for i

the revisions to the checklist.

I j

7.0 ATTACHMENTS 7.1 ICAVP Process Flowchart," Checklist Preparation, Approval and Use" 3

(1 page) j 7.2 Sample Checklist Form (1 page) l 6

i Page 5 of 5

PI-MP1-09

'.1 Gather MP3 Data &

i l

Questions Related to Checklist i

Team Mem Prepare Checklist l

Team Member l

ma m mmenummemmuens l

Approve Checklist Review Te Lo v

Perform Review per 5

applicable Checklist Requirements Verifier g.

Review Concurrence Review Team Lead m

v File Checklist per PI-MP1-12 ICAVP PROCESS FLOWCHART Checklist Preparation, Approval and Use l

4 PI-MPI 09 Meh-' 7.2 j

j Q Samnie Checklist Cover Pane C/

J Northeast Utilities Millstone-Unit 1 l

j I

4 Independent Corrective Action Verification Program (ICAVP)

System Review Checklist CK-MPI-02 -4.3, Rev. O Electrical Schematic Review ChWitt O

Prepared by:

Name Signature Date i

Approved by:

Name Signature Date IMPLEMENTATION System Document No/Rev.

Verified by:

Date:

Concurrence by:

Date:

l O

4 i

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l PROJECT INSTRUCTION PI-MP1-10 INSTRUCTION REV.0 l

Client: Northeast Utilities Station: Millstone Unit 1 3

l

Title:

DIFFERING PROFESSIONAL OPINIONS l

l i

l l

h Safety-Related Non-Safety-Related d

l Reviewed By:

Approved By:

System Lead Programmatic O&M Lead Accident QA Engineer internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman

/

Date:3

• l*l"T7 O

m

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$$f-YY-

'$hau) !$hlJA0a& 2 AW AW

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j Description innfal tdue 0 ' ~g I

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l Page 1 of 4 I

1 i

l PROJECT INSTRUCTION PI-MP1-10

O INS 1RuCTioN REv. 0 1.0 PURPOSE i

This instruction establishes the requirements for the handling and resolution of i

differing professional opinions (DPO) related to technical safety significant concems raised during the implementation of the Independent Corrective Action Program (ICAVP) for Millstone Uniti.

i i

2.0 REFERENCE l

i 2.1 NRC Confirmatory Order Establishing independent Correction Action l

Verification Program - Millstone Nuclear Power Station, Units 1,2 and 3 4

l 2.2 PI-MP1-01, Communications Protocol 2.3 PI-MP1-12, Project File Index l

2.4 10CFR50.7, Employee Protection i

3.0 DEFINITIONS j

3.1 Differing Professional Opinion - a written statement expressing an individual's professional judgment on a technical issue that is different than j

a decision made or a position taken by the management of the project.

3.2 DPO Resolution - a written statement providing the technical basis for the j

disposition of the DPO.

i 3.3 initiator - The individual Project Team member that initiates a DPO.

l l

i 4.0 RESPONSIBILITIES 4.1 The initiator shall be responsible for preparing the DPO when he believes it i

necessary to raise a technical safety concem.

4.2 The ICAVP Management Team (Project Director, Verification Team i

Manager, or Intemal Review Committee Chairman, as appropriate) shall be j

responsible for providing the technical basis in writing for a decision made or i

a position taken on a techr.icalissue for which a DPO has been generated.

m Page 2 of 4 i

ll

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PROJECT INSTRUCTION PI-MP1-10 INSTRUCTION REV.0 l

4.3 The Quality Assurance Manager shall be responsible for establishing a l

board to provide a disposition for the DPO using the resources of the firm as required.

4.4 The Verification Team Manager is responsible for maintaining a log of all l

DPOs initiated during the project and for submitting a copy of the DPOs and j

their resolution to the NRC.

i i

5.0 PROCEDURE i

i 5.1 General 1

Differences of opinion on technical issues occur from time to time during the conduct of professional activities. These differences are normally resolved by the individuals within the chain of command of a project. In the case of the ICAVP, it is expeded that the Verification Team Manager will facilitate the resolution of issues within the Verification Team, and that the Project Director will facilitate the resolution of issues between the Verification Team and the intemal Review Committee, when required. However, if any O

member of the ICAVP Project l earn disagrees with a decision or position taken on a technical issue that he believes has potential safety significance, he may initiate a formal Differing Professional Opinion in accordance with the following procedural steps.

5.2 The Initiator shall prepare the DPO on Attachment 6.1.

The DPO shall contain the following information related to the technical issue, along with any supporting information:

a summary of the Management decision or position on the technical e

issue, a description of the Initiator's view and how they differ from the e

management position, the rationale for the initiator's opinion on the issue, including an e

assessment of the potential consequences, based on risk and safety, if the Initiator's position is not adopted.

5.3 The initiator shall sign and date the DPO form and forward the original of the form along with any attachments to the S&L Quality Assurance Manager. A copy of the DPO form shall be submitted to the Verification Team Manager and he shall maintain a log of all DPOs on the project.

m Page 3 of 4

i l

PROJECT INSTRUCTION PI-MP1-10 INSTRUCTION REV.0 5.4 The QA Manager shall, within three working days of receipt of the DPO, acknowledge its receipt to the Initiator. The QA Manager shall j

notify the S&L Power Services Business Group Executive Vice President of the receipt of the DPO and shall convene a board consisting of himself, the PSBG Lead Nuclear Project Director and a mutually acceptable subject matter expert to disposition the DPO.

l 5.5 The DPO Board shall provide a disposition to the DPO based on the l

technical merits of the issue within 10 working days from receipt of the l

DPO. They may request to interview the Initiator and /or the management of the project or others as required to anive at their decision. The QA Manager shall submit the DPO Resolution to the

{

Initiator, the Verification Team Manager, the Project Director, and the j

PSBG Executive VP.

5.6 The Verification Team Manager shall log the resolution and submit a j

copy of the complete DPO and DPO Resolution along with all supporting i

documentation to the NRC primary contact listed in the Communications i

Protocol PI-MP1-01 (Reference 2.2).

5.7 The Verification Team Manager shall review the disposition and take any

)

corrective action required by the disposition, including any "re-work" of the ICAVP review process, if required.

i

{

5.8 The Verification Team Manager shall file the DPO and the resolution in j

accordance with PI-MP1-12.

I i

5.9 The Initiator and any other employee also has the right to contact the j

NRC directly with a safety concem without fear of reprisalin accordance j

with S&L policy and 10CFR50.7 (Reference 2.4).

1 i

j 6.0 ATTACHMENTS 6.1 Differing Professional Opinion Form (1 page)

]

6.2 Flow Chart, DPO Process (1 page) i I

i l

m a

l Page 4 of 4

i PI-MPI-10 l.1

' (O DPO-MP1-

/

i Independent Corrective Action Verification Program Millstone Nuclear Power Station - Unit 1 Differing Professional Opinion 4

Description of Technical Issue and S&L Management Position:

(Add pages as required)

Description ofInitiator's View, Rationale, and Assessment of Consequences, if not adopti Initiator Date (Add psges as ruguired)

Disposition:

1 QA Manager Date (Add pages as required) 9 I

l PI-MP110.2 DIFFERING PROFESSONAL OPINON i

PROCESS FLOW CHART tO Normal Resolution of Technicalissues l

VT Mgr/PD l

1r l

Initiates DPO on Safety Concem Notification of Receipt initiator ir Log DPO Receive. DPO e

Notifies PowerServices VT Manager QA Manager Business Group ExecVP a

f 1V

(

Convenes Board to Disposition DPO QA Mena0er ir Disposition DPO and Distribute to:

Distribute initiator DPO Board Project Director PSN ExecVP

,r Submit DPO and Disposition to NRC VT Manager l

3r Corrective Action, if Required VT Manager i

i

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

a j

j i

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• ["#"

PROJECT INSTRUCTION PI-MP1-11 INSTRUCTION REV.O i

Cilent: Northeast Utilities I

i Station: Millstone Unit 1

Title:

DISCREPANCY REPORT SUBMITTAL AND CLOSURE 1

l i

[ Safety-Related I

Non-Safety-Related 1

Reviewed By:

Approved By:

t l

System Lead Programmatic O&M Lead Accident QA Engineer Intemal Review Verification Team Lead Mitigation Committee Manager i

Lead Chairman h

f Date:3*ll*Y W ! t/bhh bSL Ar N? $

Description IrfalIsliliue

/g ' g7 l'

i i

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i 1

l e

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Page 1 of10 j

i

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l PROJECT INSTRUCTION PI-MP1-11 INSTRUCTION REV.O l

1 i

1.0 PURPOSE This instruction establishes the requirements for the preparation, submittal and closure of Discrepancy Reports for descrepant conditions identified by the Independent Corrective Action Verification Program (ICAVP) Team. This instruction addresses the preparation of DRs by the ICAVP team, the review l

of proposed resolutions developed by Northeast Utilities and the trending of j

DRs generated by the Verification Team.

i 2.0 REFERENCE 1

l 2.1 NRC Confirmatory Order Establishing Independent Correction Action Verification Program - Millstone Nuclear Power Station, Units 1,2, l

and 3 l

2.2 PI-MP1-01, ICAVP Communication Protocol 2.3 PI-MP1-02, Review of System Design for Compliance with Design &

)O Licensing Basis 2.4 PI-MP1-03, Review of Plant Modifications Prepared After Receipt of Operating License for Technical Adequacy and for Configuration i

Control.

i l

2.5 Pl-MP1-04, Programmatic Reviews 2.6 PI-MP1-05, Physical Plant Configuration Walkdowns 2.7 PI-MP1-06, Operations and Maintenance and Testing Procedures and Training Documentation Reviews 2.8 PI-MP1-07, Review of Accident Mitigation Systems 2.9 PI-MP1-10, Differing Professional Opinions 2.10 PI-MP1-12, Project File Index m

1 l

Page 2 of 10

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PROJECT f""

INSTRUCTION PI-MP1-11

!O aev. 0

'NSTRuCriON

)

i I

3.0 DEFINITIONS I

l 3.1 Accider.t Mitigation Review Group (ARG)-The subgroup of the ICAVP i

Verification Team responsible for review of critical ci;aracteristics of I

accident mitigation systems to ensure those systems can perform their j

required safety functions.

3.2 Internal Review Committee (IRC)- A committee comprised of senior l

S&L management personnel responsible for overall technical oversight of the ICAVP.

i 3.3 Operations & Maintenance and Testing Review Group (ORG)- The subgroup of the ICAVP Verification Team responsible for the review of the operating, maintenance and testing procedures, and training materials for l

the systems within the scope of the ICAVP.

l l

3.4 System Review Group (SRG)-The subgroup of the ICAVP Verification Team responsible for performing an in-depth review of the design of the j

systems in the scope of the ICAVP.

3.5 Configuration Review Group (CRG)-The subgroup of the SRG Verification Team responsible for walkdowns to verify the current as built conditions are in conformance with the design output documents.

3.6 Programmatic Review Group (PRG)- The subgroup of the ICAVP Verification Team responsible for review of the processes used to change the facility design or the operation, maintenance and testing of the facility.

The PRG is also responsible for verifying the adequscy of NU's corrective actions.

3.7 Discrepancy Report (DR) - The mechanism for documenting the discrepant conditions ident; fad by the ICAVP and reporting the condition to NU for resolution.

N Page 3 of 10

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PROJECT P "'

INSTRUCTION PI-MP1-11

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!O

'NSTRUCTiON Rev. 0 i

4.0 RESPONSIBILITIES i

j 4.1 initiator Responsible for preparation of DR in accordance with l

the instructions contained in this project instruction.

l l

Responsible for review of proposed NU resolutions in accordance with the instructions contained in this project instruction.

l 4.2 Verification Group Lead Responsible for first level review of DRs

{

prepared by initie*

Responsible for assigning DR number.

i i

Responsible for review of S&L's l

dispositions to proposed NU resolutions.

i i

Responsible for resolving comments with i

the Initiator.

e 4.3 Verification Team Manager Responsible for reviewing initial DRs i

j t;nd S&L dispositions to proposed NU resolutions.

Responsible for resolving comments i

with the Verification Grc:;p Lead and the initiator.

Responsible for overall control of DR l

process including maintenance of DR i

log, trending data and external distributions.

i 4.4 IRC Members / Chairman Responsible for reviewing DRs and l

dispositions of proposed NU i

resolutions prepared by the Verification Team and for resolving j

any comments with the Verification Team.

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Page 4 of 10

i

1. ~

PROJECT INSTRUCTION PI-MP1-11

'O INSTRUCTION Rev. 0 1

5.0 PROCEDURE i

The Nuclear Regulatory Commission (NRC) Confirmatory Order (Reference 2.1) requires Northeast Utilities (NU) to implement the. lCAVP. References 2.3 i

through 2.8 provide the instructions for implementing the reviews included in the scope of the ICAVP. Discrepant conditions identified by the Verification

)

l Team members during the performance of these reviews will require the initiation of a DR. This project instruction provides the requirements for

{

initiating, processing and closure of DRs. DRs shall not be generated for i

findings already identified by NU during implementation of their Configuration j

Management Plan.

Note: DRs shall be generated as soon as practical after the condition has been identified. Those DRs which may be potential operability concerns shall be expedited through the review and approval process and NU shall be notified per l

Subsection 5.5.1 of this instruction.

The DR process involves the following tasks:

a.

DR initiation I

b.

DR resolution and closure l

c.

DR log and trending data i

d.

DR distribution i

DRs shall be generated in an electronic format using a DR Access Database.

Attachments 6.2 through 6.5 of this project instructions illustrate sample database input screens. Hardcopies of the DRs, a DR Log, DR status reports and DR trend reports can be generated from the database.

4 1

l The detailed instructions for each of the above task are described in sub-i sections 5.2 through 5.5. Attachment 6.1 is a flow chart illustrating the DR i

process.

5.2 DR Initiation i

5.2.1 Members of the ARG, CRG, ORG, PRG and SRG Verification Teams j

shall initiate a DR for any discrepant condition identified during their respective reviews. The individual initiating the DR shall be referred i

to as the Initiator.

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PROJECT INSTRUCTION PI-MP1-11 i

'"STRuCTiDN REv. 0 i

j Note: Before initiating a DR, the initiator shall ensure the condition 1

has been thoroughly investigated and the total scope of the condition has been identified. Any additional information needed

]

from NU shall be requested per PI-MP1-01.

1 5.2.2 The initiator shall prepare the Discrepancy Report by entering the j

following data into the database's " Discrepancy Screen", Attachment j

6.2:

)

Note The fields listed below which are indicated with an asterisk have pulldown menus. Applicable entries in these menus are listed in.6.

i

{

Field Instruction 1

j Review Group

• Enter Applicable Review Group 1

1 l

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Review Element

• Enter Applicable Review Element Discipline

• Enter Applicable Organization i

Discrepancy Type

• Enter Applicable Discrepancy Type l

l Potential Operability

• Enter whether the Discrepancy is a j

issue Potential Operability issue using the j

guidance in Attachment 6.7 4

System / Process Enter by Full Name the system or process

)

being reviewed.

Discrepancy Enter brief title Description Enter detailed description of condition including specific references and basis for potential operability determination, if DR is determined to be potential operability issue.

Page 6 of 10

PROJECT INSTRUCTION PI-MP1-11 INSTRUCTION REV.0 l

Initiator Enter your name; Last name first followed by first and middle initials (i.e. Doe, J. A.)

i Date Enter preparation date i

i j

The database will automatically assign DR Nos., revision level and j

status.

i l

5.2.3 The VT Lead shall review the initial DR draft.

5.2.3.1 If the VT Lead has comments on the DR or determines that additional information is needed, the VT Lead shall resolve the comments with i

j the Initiator.

I l

5.2.3.2 If the VT Lead does not concur with the DR, the VT Lead shall complete the " Invalid Screen", Attachment 6.3, by entering his name, date and justification for the invalid disposition. The VT Lead shall review the invalid disposition with the Initiator.

O 5.2.3.3 If the Initiator agrees with the VT Lead's invalid disposition, the i

Initiator shall indicate his concurrence on the " Invalid Screen",

).3. The initiator shall then file the invalid DR with the j

applicable element review file.

5.2.3.4 If the VT Lead and initiator do not reach agreement, the VT Manager shall resolve the issue. If either of the parties has a safety concern related to the DR, the provisions of PI-MP1-10 for Differing Professional Opinions may be invoked.

5.2.3.5 If the VT Lead concurs with the DR, the VT Lead shall enter his name, and date on the Discrepancy Screen, Attachment 6.2.

5.2.4 The VT Manager shall review the DR. The review process shall be consistent with the instructions contained in Subsections 5.2.3.1 through 5.2.3.5 above, except that any comments or invalid dispositions shall be reviewed with both the initiator and the VT Lead.

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PROJECT INSTRUCTION PI-MP1-11 INSTRUCTION REV.0 l

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Note: The reviews associated with Subsections 5.2.3 and 5.2.4 can be concurrent in a group session.

j 5.2.5 The IRC shall review the DR. The review process shall be consistent with the instruction contained in Subsections 5.2.3.1 through 5.2.3.5 i

above, except that any comments or invalid dispositions shall be j

reviewed with the Initiator, VT Lead and VT Manager.

1 l

5.2.6 The VT Manager shall distribute approved DRs to the NRC, NU and j

the Public in accordance with Subsection 5.5 of this project instruction.

j 5.3 DR Resolution and Closure I

5.3.1 Proposed resolutions submitted by NU shall be reviewed in a manner similar to the DR initiation process described in Subsection 5.2 of this j

project instruction. The DR proposed resolution shall first be reviewed j

by the Verification Team and then the IRC. Concurrent review by VT members, Leads, and Manager are permitted.

1 5.3.2 The Initiator shall summarizes the NU resolution on the 'NU Resolution Screen', Attachment 6.4. Concurrence by the VT members shall be indicated on the screen, Attachment 6.4. The DR shall be distributed to the NRC, NU and the Public per Section 5.5 of this j

project instruction.

4 l

5.3.3 If the Initiator, VT Lead, VT Manager or IRC do not concur with the j

proposed resolution, the non-concurring party shall document their j

justification for rejecting the resolution on the " Rejection Screen",

).5 and obtain concurrence from all other members on l.5. Rejected Dispositions shall be distributed to the NRC and NU in accordance with Subsection 5.5 of this project instruction.

5.3.4 Revised proposed resolutions submitted by NU in response to S&L j

comments shall be reprocessed in accordance with Subsection 5.3.1 l

through 5.3.3. Only one additional resolution cycle per discrepancy is j

anticipated.

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h PROJECT INSTRUCTION PI-MP1-11 O

'"s'auc'io" aev. o l

5 5.3.5 If all groups, (the VT members and the IRC) cannot reach agreement

}

on acceptance of the proposed NU resolutions and anyone has a

{

safety concem, then the provisions of PI-MP1-10 for differing

{

professional opinions DPO may be invoked.

5.4 DR Loa and Trendina Data 5.4.1 DR Log i

I 5.4.1.1 The DR database shall automatically assign DR Nos, status and l

revision. Hardcopy logs can be generated from the database.

1 l

5.4.2 Trending Data I

5.4.2.1 The DR database can be sorted by the entries on Attachment 6.6 to

}

generate trend reports.

5.5 DR Distribution 5.5.1 initialissues l

5.5.1.1 The VT Manager shall distribute valid DRs to the NRC, NU and the Public per Subsection 3.3 of PI-MP1-01. Distribution to the NRC and NU shall be in the form of hardcopies. Since generation of DRs will be l

by electronic media with database security provisions, signatures shall j

not be required.

5.5.1.2 DRs determined invalid during review shall not be distributed j

externally. Hardcopies shall be maintained in the project file in j

accordance with PI-MP1-12.

5.5.1.3 The VT Manager will fax DRs which may pose potential operability concern to the NU Point Of Contact identified in PI-MP1-01. The date sent shall be entered on the Discrepancy Screen.

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• h INSTRUCTION PI-MP1-11

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'NS1RUCTiON O

aEv. 0 i

i l

5.5.2 Proposed Resolutions l

l 5.5.2.1 The VT Manager shall distribute accepted (closed) DRs to the NRC, j

NU and the Public in accordance with Subsection 3.4 of PI-MP1-01.

l Hardcopies shall be sent to the NRC and NU.

i 5.5.2.2 The W Manager shall distribute S&L comments on proposed resolutions to the NRC and NU only, in accordance with Subsection i

3.4 of PI-MP1-01.

i i

{

6.0 ATTACHMENTS 1

1 6.1 Process Flowchart, Processing Findings & Resolutions (1 page).

)

6.2 Sample Discrepancy Screen (1 page).

llO e.a Semnie inveile Screen (19eoe).

i l

6.4 Sample Resolution Screen (1 page).

i 1

l 6.5 Sample Rejection Sheet (1 page) 1 j

6.6 Summary of Available Entries for Pulldown Menus (1 page) i l

6.7 Criteria for Operability Determination (1 page).

/

l Note: Attachments 6.2 through 6.4 are sample illustrations of the DR Access j

Database data entry screens. This instruction will be revised if the data fields j

are revised. Revision to this instruction is not required for format changes to l

the data entry screens.

i 4

l i

j m

i j

Page 10 of 10 i

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Initiate Discrepancy pg.gpt.11 PROCESSING FINDINGS Rep HDR)

ATTACHMm.1 p

AND RESOLUTIONS vr d

3.

Review DR VT Mgmt u

Document Basis for is DR Vaid &

DR ns Not Discrepant Adequale?

Vand Y VT Yes 4

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Review DR i

info Rechat IRC r

is DR Valid &

DR not Adequate?

Valid ~~

Submit DR to NRC/NU O

& Post on Electronic BB VT Mgmt 4

Provide DR Response to VT Management NU A

Review NU Response forAdequacy Document Reesons for VTNT Mgmt Rejection /Submitto E

NU/NRC Review NU Response VT Mgmt

& VT Acceptance /

Rejection o

LRG DocumentAcceptance NU Response

& Submit to NRC/NU &

He toDR Yes--+ Post on Electronic BB p

Adequale?

V VT Mgmt

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PI-MPI-011, Rev. O Mtehwnt 6.6

SUMMARY

OF AVAILABLE ENTRES FOR PUT1DOWN MENUS E

ENTRIES Review Group CRG i

ORG PRG SRG ARG Review Element

System Design

Modification Design SystemInstallation Modification Installation Operating Procedures Test Procedure Maintenance Procedure Training Procedure Change Process Corrective Action Process Discipline MechanicalDesign ElectricalDesign I&C Design Structural Design Piping Design Equipment Qualification Operations Maintenance Training Other Discrepancy Type Drawing Component Data Calculation Licensing Document Test Requirements Installation Requirements Installation Implementation O&M&TProcedure O&M&TImplementation Corrective Action ProcedureImplementation Change Process Potential Operability Issue Yes No

Q PI-MP1-11, Rev. O b.7 CRITERIA FOR POTENTIAL OPERABILITY ISSUE The following criteria shall be used to determine if a DR poses potential operability issue:

1.

Any departure from the conditions of the operating license, Technical Specifications.

2.

Any occurrence or plant condition that requires notification to the NRC or other regulatory agency in accordance with the Configuration Management Plan.

3.

Failure to meet the provisions of the Technical Requirements Manual.

4.

Conditions resulting in a Maintenance Rule Functional Failure (MRFF)

(10CFR50.65).

5.

Any occurrence that appears to jeopardize radiological protection, or may be a violation of a program, procedure or regulation with radiological implications.

O

_ - - ~.

I PROJECT INSTRUCTION PI-MP1-12 INSTRUCTION REV.O i'

l Client: Northeast Utilities I

l Station: Millstone Unit 1 i

j Title.

PROJECT FILE INDEX l

t

(

i i

l

[ Safety-Related Non-Safety Related 1

Reviewed By:

Approved By:

System Lead Programmatic O&M Lead Accident QA Engineer Internal Review Verification Team Lead Mitigation Committee Manager Lead Chairman Date:3~II'1l l

DOS' WL.fff6b 49dibl1u24,ld WE

• C~LkL Description init(alldue (f '

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Page 1 of 5

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PROJECT INSTRUCTION PI-MP1-12

"~

l lNSTRUCTION REV.O i

i 1.0 PURPOSE This project instruction supplements S&L Procedure GQ-6.01 for the implementation of the Project File Index for the Northeast Utilities Millstone Unit l

1 Independent Corrective Action Verification Program (ICAVP).

l l

2.0 REFERENCE l

2.1 GQ-6.01, " Project Distribution List and Project File Indexes."

2.2 GOP 17.02, " Quality Assurance Records Control System' 3.0 DEFINITIONS 3.1 Project Flie Index - A project file index is a listing of document categories with location references for the central consolidated project file.

3.2 Central Consolldated Project Files - Central consolidated project files include documents pertaining to a project or group of projects for a single l

client and are maintained by a project team, usually under the direction of the Project Manager or his designee. Central consolidated project files are interdepartmental and are the source from which the Records Center receives documents for long-term storage.

)

l 3.3 Project Documents - Project documents are defined in the applicable l

project instructions. Examples of these documents are listed on l.1.

3.4 Internal Project Correspondence - Internal project correspondence j

includes documents generated within S&L which are not distributed j

outside of S&L. Internal project correspondence includes, but is not i

limited to, the documents listed in Attachment 7.1.

I i

l m

i Page 2 of 5

"f"'

PROJECT INSTRUCTION PI-MP1-12 j

INSTRUCTION REV.O l}

External Project Correspon&#nce - External project correspondence 3.5 includes documents generated within S&L and distributed outside of S&L, i

as well as documents generated outside of S&L. External project correspondence includes, but is not limited to, the documents listed in l.1.

3.6 Special Project Documents - Some project documents, such as i

purchase orders and contracts are normally filed with the Project Manager i

rather than the central consolidated project file. Files containing these documents are considered part of the central consolidated project file and l

shall be referenced in the project file index.

I j

4.0 RESPONSIBILITIES i

4 l

4.1 The Verification Team (VT) Manager shall be responsible for establishing the central consolidated project file, and ensuring the transmittal to file of l

documents per Subsection 5.2.1.

2 l

4.2. Verification Team (VT) Group Leads shell be responsible for ensuring the I

transmittal to file of documents per Subsection 5.3.

i 5.0 PROCEDURE 5.1 The VT Manager shall establish a central consolidated project file for j

the filing of documents.

1 5.2 Project documents shall be filed in the central consolidated project file in accordance with the project file index (Attachment 7.2). There are two general categories of project documents - generic project documents and task-specific documents.

l 5.2.1 The project file index contains the subcategories of the files for the generic project documents. It also indicates the person responsible for sending each subcategory of document to the central consolidated l

project File.

i l

Pm j

Page 3 of 5 i

b PROJECT N ""

INSTRUCTION PI-MP1-12 INSTRUCTION REV.O j

i 5.2.2 Task-specific documents shall be filed by Verification Team identity, i

Verification element (system or program) and applicable review checklist. The project file index lists the subcategories and j

responsibilities.

I 5.3 All project personnel shall clearly indicate the appropriate project file l

number from the index when submitting documents to the central i

consolidated project file. The DPD personnel assigned to maintain the l

central consolidated project file shall file the documents chronologically in appropriate subcategory of the file system. If there j

are questions about the file number or no file number is shown, the l

DPD personnel shall resolve this with the person submitting the j

document or their supervisor.

I 5.4 Project documents shall be submitted to the project file as soon as possible after receipt / issue to keep the files current. Project personnel j

may keep working files in their own work areas as necessary in the j

performance of their work. The use and number of working files should be minimized. The individual is responsible for ensuring that the documents in the working file are current before relying upon them j

for qua'ity related decisions.

l l

5.5 External project correspondence shall be filed in two places. [ Note:

This is the only instance of permanent duplicate files on the project.j A copy of the correspondence should be filed under generic project files, and a copy should also be filed under the task-specific file when l

related to a task. The recipient, or addressee, is responsible for directing incoming external correspondence to the generic file and the j

task-specific file. The person signing the external correspondence is l

l responsible for submitting outgoing correspondence to the generic i

project file and to the task-specific files.

l 5.6 A submittal schedule for QA records which shall be retained by S&L i

shall be developed in accordance with procedure GQ-17.01. These records shall be transmitted to storage in accordance with procedure i

GQ-17.02. Project-related documents which are not QA records shall l

not be sent to storage until the project has been completed and the transmittal has been authorized by the VT Manager."

)

i Page 4 of 5

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

i l

PROJECT INSTRUCTION PI-MP1-12 INSTRUCTION REV.O i

i l

6.0 REVISIONS l

The project file index (Attachment 7.2) may be revised by the VT Manager. The issue of a new or revised project file index shall not require retraining in this Pl j

unless the VT Manager determines that, in a particular case, retraining is i

necessarv.

l 7.0 ATTACHMENTS 7.1 Types of project-related documents (1 page) l 7.2 Project File index (2 pages)

O i

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1 i

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Page 5 cf 5 2

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i n PI-MPI-12 V

Rev.0 i.1 4

TYPES OF PROJECT-RET.fTED DOCUMENTS INTERNAL PROJECT CORRESPONDENCE Interoffice Memoranda e

Meeting Notes e

Internal Status Reports Internal Schedules, Lists, Estimates, and Budgets Internal hand-written or PC-generated Documents e

Telephone Memoranda Issued Internally e

EXTERNAL PROJECT CORRESPONDENCE Correspondence sent to S&L by Northeast Utilities, NRC and Others Correspondence sent by S&L to Northeast Utilities, NRC and Others s

e Notes ofmeetings between S&L and Northeast Utilities, NRC and Others Schedules or Status Reports e

Telephone memoranda issued externally PROJECT DOCUMENTS Discrepancy Reports System Review Checklists e

Modification Review Checklists O&M&T Review Checklists e

Programmatic Review Checklists e

Accident Mitigation Review Checklists e

Walkdown Checklists Project Instructions e

Final Report e

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l PI-MPI-12 Rev.0

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MILLSTONE UNIT 1ICAVP 4

i PROJECT FILE INDEX 1

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GENERIC PROJECT FILES File No.

Titig Position Title Responsible

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l for Submittina - Praiac+ Files ll i

MP1-1.0 Contract and Supplements VT Manager l

l MP1-1.1 Commercial Correspondence VT Manager

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MPl.1.2 ICAVP Requirements VT Manager i

j MPI-2.0 Project Manual QA Coordinator i

MPI-2.1 Training Records QA Coordinator i

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MPI-3.0 Status Reports VT Manager j

MPl-4.0 General Quality Assurance QA Coordinator i

MPI-4.1 Internal Audits QA Coordinator MPI-4.2 External Audits

- QA Coordinator MPI-5.0 Project Team Meeting Notes VT Manager MPI-5.1 OtherInternalMeeting Notes VT Group Lead MPI-5.2 ExternalProject Meeting Notes VTManager (Not Specific to a Task)

MP1-6.0 Manpower Planning and Overall VT Manager Project Schedules MPI-7.0 External Correspondence to NU orNRC VT Manager MP1-8.0 -

Correspondence from NU orNRC VT Manager MP1-9.0 DiscrepancyReports VTManager i

MPI-10.0 Differing Professional Opinions VT Manager Page 1 of 2

PI-MPI-12 Rev.0

.2 MILLSTONE UNIT 1 ICAVP PROJECT FILE INDEX i

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II.

TASK-SPECIFIC PROJECT FILES l

1 File No Ii113 Position Title Responsible for Submitting-Project Files SRG-XXX-YY-ZZ System ReviewFiles SRG Lead i

CRG-XXX-YY ZZ Configuration Review Files SRG Lead i

i ORG-XXX-YY-ZZ O&M&T ReviewFiles ORG Lead i

ARG-XXX-YY-ZZ Accident Mitigation Review Files ARG Lead PRG-AAA-YY-ZZ Programmatic Review Files PRG Lead Where:

XXX =

3 Letter System Designator Assigned by ARG or SRG Lead.

YY-ZZ =

Last 4 Digits ofChecklist Number (Example Use 02-01 for CK-MP3-02-01)

AAA =

3 Letter Program Designator Assigned by PRG l

Page 2 of 2

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Q, (CHECKLISTS UNDER DEVELOPMENT)

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Serge

& Lundy " c

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l Don K. Schopfer Vice President l.

March 25,1997 i

312 m s Project No. 9583-110 l-9583-100

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l Docket Nos. 50-245 50-423 I

Northeast Nuclear Energy Company j

Millstone Nuclear Power Station, Unit Nos.1 and 3 Independent Corrective Action Verification Program Audit Plan and Associated Project Instructions 4

Mr. E. V. Imbro Deputy Director, ICAVP Oversight United States Nuclear Regulatory Commission 11555 Rockville Pike y

Rockville, MD 20852-2738

Dear Mr. Imbro:

in response to a request by Mr. Grazio of Northeast Nuclear Energy Company, I am confirming in writing that Sargent & Lundy is waiving the normal proprietary status of its project instructions for the ICAVP for Millstone Units 1 and 3. NRC may reproduce these documents as necessary and place them in the appropriate Public Document Rooms as required for the program.

i Yours very truly, I

}nY Don K. Schop er i

Vice President and ICAVP Manager Copies:

R. E. Grazio F8e MP3 7.0 MP17.0 s

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55 East Montce Street a Chicago, IL 60603-5780 USA + 312-269-2000

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