ML20136H381
| ML20136H381 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/01/1985 |
| From: | Dubois Q TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20136H310 | List: |
| References | |
| PROC-851001, NUDOCS 8511250094 | |
| Download: ML20136H381 (30) | |
Text
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DESIGN ADEQUACY PROGRAM QUALITY ASSURANCE PROGRAM' Rev Recommended Q A Concurrence Approval I I . >
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0 9KP Mpnager /
R'eview Team'Ledder Albaken>
CSM-TRT issue Monoger osak DAP QA Manager uhler
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TN-85-6262 i
TABLE OF CONTENTS Section P3 I
- C ove r Shee t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Tab le of C ont en ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il I
1.0 OR G ANI ZATI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
QUALITY ASSUR ANCE PROGR AM . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.0 DES I G N C ONTR O L . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3.0 4.0 PROCUREMENT DOCUMENT CONTROL . . . . . . . . . . . . . . . . . . . . . . . 8 5.0 INSTRUCTIONS, PROCEDURES, AND D R AW I NG S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 DOCUMENT C ONTROL . . . . . . .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 6.0 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 8.0 NON-CONFORMING MATERIAL, PARTS, OR C O M P O TENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 9.0 CORR ECTIVE ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Ii 10.0 Q A RE C ORDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II I l .0 A U D I T S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II 4
i i TN-85-6262 il f
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I COMANCif PEAK RESPONSE TEAM - DESIGN ADEQUACY PROGRAM QUALITY ASSURANCE PROGRAM l.0 ORGANIZATION l.1 Comanche Peak Response Team (CPRT)
The CPRT organization and its functional responsibiiities are described in Section VI of the CPRT Program Plan. The CPRT is led by a Senior Review Team which formulates policy and provides overall direction of CPRT octivities.
The Design Adequacy Review Team Leader, along with the Review Team Leaders for QA/QC; Civil, Structurol, Mechanical; Electrical / instrumentation; and Testing Programs report to the Senior Review Team. A CPRT Program Director, who also report to the Senior Review Team, is responsible for rnonitoring the Review Team octivities on day-to-day basis.
l.2 Design Adequacy Review Team The Design Adequacy Review Team has been ossigned the responsibility of implementing the Design Adequacy Program Plon, Appendix A of the CPRT Program Plon, and the associated issue or Discipline Specific Action Plans.
TERA Corporation, under the direction of its Design Adequacy Review Team Leader, has been assigned the responsibility for monoging and performing the Design Adequacy Program activities.
Assisting the Design Adequocy Review Team Leader is the Design Adequacy Program Monoger, Project Management Coordinator, and the Construction Quality Interface Monoger. Reporting to the Design Adequacy Program Manager are the Project Quality Engineer and the Discipline Coordinators in the following disciplines:
o Civil / Structural o Piping / Supports o Mechanical Systems and Components o Electrical, I&C Systems and Components o Programmatic /Generie implications.
TN-RS A?a? Page I of 12
COMANCE PEAK RESPONSE TEAM - DESIGN ADEGUACY PROGRAM l QUALITY ASSURANCE PROGRAM The Design Adequacy Review Team organization is shown in Figure 1.
The Design Adequacy organization also includes a Design Adequacy Program Guality Assurance Monoger. This position is responsible for ensuring the effective implementation of the Design Adequacy Program Ouolity Assurance I Program. The Quality Assurance Manager will verify effective implementation of the progrom by conducting audits of Design Adequacy Review Team i
activities. The Quality Assurance Manager will report the results of his 1
L octivities to the Design Adequacy Review Team Leader. This structure provides access to a level of management sufficient to ensure that the quality assurance function con be performed.
The responsibilities of the Design Adequacy Review Team Leader are delineated ,
in Section Vill of the CPRT Program Plan. Design Adequacy Review Team Managers and Coordinators are responsible for assisting the Review Team Leader as directed by the Review Team Leader and as specified in Section ll.E of Appendix A to the CPRT Program Plan and tne Design Adequocy Procedures.
The Design Adequacy Review Team may use subcontractors to implement its Quality Assurance Program; however, the Design Adequacy Review Team retains responsibility for implementation of the program.
2.0 QUALITY ASSURANCE PROGRAM 2.1 Desian Adequocy Review Team Guolity Assurance Program Description The CPRT Progrom Plan, which was developed under the direction of the Senior 4 Review Team, provides overall direction for all CPRT octivities. Appendix A of the CPRT Progrom Plan is the Design Adequacy Program Plan which details the scope of work for Design Adequocy Review Team activities. Appendix C of the CPRT Program Plan contains Discipline Specific Action Plans (DSAPs) which TN-85-6262 Page 2 of 12
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CPRT DESIGN ADEQUACY PROGRAM ORGAMZATION l r
1
! CPRT E * - DWECT N em
! ___ -TERrAas l
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', DE58CH ADEOUACY
' DAP GUALITY PROGRAM, ASSURANCE -- REVIEW TE AM .. GA10C REVIEW LEADER TEAM LEADER Q. rhm.ss H. Levin i I t
!. I MANAGEMENT OuAL Y N COORDINATOR ME - E -
HTERFACE MGR. t D. Tinonins J. Hanshevy
- IF I I I i MECHAtVAL ELECTRICAL. l&C PROGRAMMATIC /
j Cf4Lf5TRUCIURAL PIPNG/5UPPORTS SYSTEMS SYSTEM 5 G M RIC COORDeNATOR COORDINATOR ADO COMPONENTS ADO COMPOtENTS IMPLICATIODS T.5nyder COORDINATOR COORDINATOR COORONATOR
- c. MorseM F. 5chefer W. Rice E.IIIsrenseed l m :
5* l l l l l I w l l l l l Q TUCCOMPPORT 5 TOM A wrHSTER TUCCO SUPPORT TUCCO SUPPORT TUCCO MPPORT
! COORDINATOR PIPING /St FPORT5 COORDINATOR COORD0HATOR COORDINATOR 4
- PROGRAM MGR.
N l R.Hessen E.Siehin F. m W. %W J. W
COMANCtf PEAK RESPONSE TEAM - DESIGN ADEQUACY PROGRAM QUALITY ASSURANCE PROCRAM specify how external source issues and self-initiated programs are to be investigated, evoluoted, and/or performed by the CPRT Review Teams. This Quality Assurance Program details the quality assurance requirements which will be opplied to the work conducted by the Design Adequacy Review Team, in order to implement the requirements of the CPRT Program Plan and its appendices and this Quality Assurance Program, Design Adequacy Procedures (DAPs) have been established. Table I lists the Design Adequacy Procedures.
The Quality Assurance Program elements applicable to Design Adequacy Review Team activities, as defined in this Quality Assurance Program, are Organization, QA Program, Design Control, Procurement Document Control, instructions, Procedures and Drawings, Document Control, Control of Purchased Material, Equipment and Services, Nonconforming Materials, Ports or Components, Corrective Action, QA Records, and Audits.
Should activities be necessary in the areas of Inspection, Testing or Measuring, and Test Equipment, oppropriate quality assurance' will be provided through performance of those activities by CPRT Review Teams or subcontractors with applicable quality assurance programs. Design Adequacy Review Team interfaces with other CPRT Review Teams and subcontractors are defined in Design Adequacy Procedures.
Table 2 is a matrix which cross references each of the applicable OA Program elements to sections of this OA Program os well as to the Design Adequacy Procedures that implement the QA Program.
2.2 Indoctrination and Training of Design Adequory Personnel Overall requirements for CPRT personnel qualifications are contained in Section I
Vil of the CPRT Program Plan. Detailed requirements for the indoctrination and
- 1 1
TN-85-6262 Page 4 of 12
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TABLE I CPRT DESIGN ADEOUACY PROGRAM PROCEDURES Procedure Wmber Title D AP-l Preparation and Review of Criteria Lists DAP-2 Documentation and Trackign of issues and Discrepancies DAP-3 Development and Validation of Self-Initiated Review Scope DAP-4 Preparation of Checklists DAP-5 Review of Calculations, Evoluotions, and Other Implementing Docurnents DAP-6 Review of Drawings, Specifications, and Other Design Output Documents DAP-7 Trending and Generic Implications Evoluotions DAP-8 Preparation of Engineering Evoluotions DAP-9 Preparation of Discipline Specific Results Reports and DAP Collective Evoluotion Report DAP-10 Development and Use of DAP Procedures and Discipline Instructions DAP-11 Document Control D AP-12 DAP interface and Comrnunications DAP-13 Preparation of Calculations DAP-14 DAP Records DAP-15 Training and Qualifications DAP-16 Audits DAP-17 Corrective Action D AP-18' Control of Subcontractor D AP-19 Processing and Review of Information between the Construction Ovality, OA/OC and DAP Program
- To be issued if necessary TN-85-6262 Page 5 of 12 t
T ABLE 2 DESIGN ADEGUACY REVIEW TEAM OUALITY ASSURANCE MATRIX GA Program QA Program Design Adequacy Elements Seetion Procedures (DAPs)
Organization 1.0 DAP-12,19 OA Program 2.0 D AP-15,19 Design Control 3.0 D AP- 1, 2, 3, 4, 5 6,7,8,9,13 Procurement Document Cotnrol 4.0 D AP-18 Instructions, Procedure and Drawings 5.0 D AP-4,10 Document Control 6.0 D AP-l l Control of Purchased Material, Equipment and Services 7.0 DAP-18 Non-Conforming Material, Ports 8.0 DAP-17 or Corrponents Corrective Action 9.0 DAP-17 OA Records 10.0 D AP-14 Audits I l .0 D AP-16 TN-85-6262 Page 6 of 12
COMANCE PEAK RESPONSE TEAM - DESlCN ADEOUACY PROGRAM QUALITY ASSURANCE PROGRAM training of Design Adequacy Review Team Personnel are contained in DAP-IS, Training and Qualifications. Audit personnel are discussed in Section ll of this OA Plan. Qualifications of personnel other than auditors (excluding clerical and administrative personnel) are reviewed by the Design Adequacy Review Team Leader to verify that education, experience, and qualifications are adequate to perform the assigned tasks.
2.3 Review of Adequocy of the Design Adequacy Review Team Quality Assurance Program As discussed in Section lI of this OA Program, periodic cudits of Design Adequacy Review Team activities will be con &cted to verify proper implementation of the OA Program. Additional reviews of the OA Program may be con &cted by Design Adequocy Review Team Management or other CPRT organizations. The res>lts of such reviews shall be considered with respect to their assessment of GA Program status and odequacy.
2.4 NRC Regulations and Industry Standards This OA Program was develcped considering the Quality Assurance Criteria specified in Appendix B to 10CFR50. In addition the following industry standards are considered applicable to this OA Program os discussed in the associated QA Progrom seetion:
Standard QA Plan Section ANSI N45.2.11, Design Control 3 ANSI N45.2.23, Ovalifications of II Audit Personnel Other standards, referenced in the standards listed obcne, are not endorsed unless stated otherwise in this OA Program.
TN-85-6262 Page 7 of 12 ;
COMANCtf PEAK RESPONSE TEAM - DESIGN ADEQUACY PROGRAM QUALITY ASSURANCE PROGRAM 3.0 DESIGN CONTROL The scope of Design Adequacy Review Team activities includes verifying the adequacy of specified elements of the CPSES design. These elements are specified by Discipline Specific Action Plans (DSAPs) developed to address design concems identified by, or through CPRT evaluation of, External Sources as well as by CPRT Self-initiated design evaluations.
The Design Adequacy Review Teams design verification activities closely parallel the Design Verification requirements specified in Section 6 of ANSI N45.2.11, 1974. Design verification activities include the preparation of criteria lists and checklists, review of calculations, evaluations and inputs, confirination of appropriate quality and quality oswrance requirements where specified, and attemate calculations. The design verification activities shall be cond>cted in accordance with written pruedures and by personnel other than those who performed the original design or design verification. Currently, the Review Team does not intend to use qualification testing as a design verification method. Therefore, no DAP has been developed to control qualification testing.
The results of the design verification activities shall be clearly documented in accordance with procedures. The res>lts will be reviewed by personnel other than those performing the design verification prior to final approval.
4.0 PROCUREMENT DOCUMENT CONTROL The Design Adequocy Review Team will ensure that appropriate quality assurance requirements are included in procurement documents for services relating to Design Adequacy Review Team activities or that those services are provided m>bject to the requirements of this OA Program.
TN-85-6262 Page 8 of 12 L
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROGRAM QUALITY ASSURANCE PROGRAM Procurement documents prepared shall be reviewed by the Design Adequacy Program Quality Assurance Manager. They are also reviewed for proper
- technical content by the Design Adequacy Review Team Leader or his designated respresentative. The reviews condseted by the Quality Aswronce Manager and the Design Mequacy Review Team Leader are appropriately documented.
Currently, any contracted services will be performed under the total require-ments of this GA Program. Should it become necessary to contract services controlled under other QA requirements, DAP-18 will be iswed to entre that appropriate QA requirements are specified in procurement documents.
5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Meowres have been established to ensare that Design Adequacy Review Team Activities are conducted in accordonce with written procedures or instructions.
These proced;res are dweloped as needed and, where appropriate, include acceptance criterio. The specific procedures controlling the preparation, revision, review, and gprwol of Design Adequacy proced>res, checklists, and instructions orer o DAP Preparation of Checklists o DAP Development and Use of DAP Procedures and Discipline Instructions.
6.0 DOCUMENT CONTROL The Design Adequacy Review Team hos established controls for the issuance, distribution, and use of Design Adequacy Procedsres and instructions. Written procedures specify controls to enwre that the latest revisions of these documents are used by Design Adequacy Review Team personnel in the cond>ct TN-85 6262 Page 9 of 12
COMANCPE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROGRAM QUALITY ASSURANCE PROGRAM of the work. In addition, procedures controlling revisions to procedures and instructions (Section 5.0 abwe) require that such revisions receive the same level of review as the originals.
1 i 7.0 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES Subcontracted services employed by the Design Adequacy Review Team will either be performed subject to the total requirements of this OA Program or subject to quality assurance program requirements specified in the procurement documents. Currently, any contracted services will be performed under the total requirements of this OA Program. Should it become necessary to contract services controlled under o ther QA requirements, DAP-18, Control of Subcontractors, will be issued with appropriate measures to ensure that contracted services are provided in accordance with procurement requirements.
8.0 NON-CONFORMING MATERI AL, PARTS, OR COMPONENTS Non-conforming design practices or documentation identified by the Design Adequacy Review Team during its design verification activities are documented on Discrepancy Reports as specified in DAP-2, Documentation and Tracking of issues and Discrepancies Reports. These Discrepancy Reports are used by the Design Adequacy Review Team only for evaluation purposes. Copies of all Discreponey Reports will be submitted to TUCCO for evoluotion and processing .
under its non-conformance control system.
l TN-85-6262 Page 10 of 12 l
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROGRAM i GUALITY ASSURANCE PROGRAM 9.0 CORRECTIVE ACTION The Design Adequacy Review Team has developed a written procedure, DAP-17, Corractive Action, to control the disposition of identified nonconformances associated with the Review Team's activities. DAP-17 includes requirements for the resolution of such nonconformances and the notification of offected organi-zotions. Iden'tified nonconformances as well as corrective action taken are documented and reported to appropriate levels of Design Adequacy Review Team monogement.
10.0 OA RECORDS
{
DAP-14, DAP Records, hos been established to control the collection, storage ;
and retention of records developed as a rewlt of Design Adequacy Review Team activities. At the completion of the work, Design Adequacy Review Team records shall be turned over the CPRT Program Director. Records are f identifiable and retrievable and include the following: ;
o Discrepancy Reports ;
o Discipline Specific Remits Reports [
t o DAP Collective Evaluation Report ;
o GA Audit Reports i
o Personnel Training and Qualification Records !
o Checklists, Calculotions and Engineering Evoluotions. l l1.0 AUDITS !
l The Design Adequacy Program Ouolity Assurance Monoger schedules and ;
covects planned and periodic medits of Design Adequocy Review Team i
TN-85-6262 Page lI of 12 l
' COMANCif PEAK RESPONSE TEAM - DESIGN ADEQUACY PROGRAM QUALITY ASSURANCE PROGRAM octivities. Auditable requirements include those requirements defined in the CPRT Progrcm Plan and Appendices, this OA Plon, and applicable DAPs. The audits ,shall be conducted in accordance with DAP-16, Audits, by the DAP Ovality Assurance Manager or personnel reporting to him. The person performing the audit, or leading the audit, if more than one person is on the mdit team, shall be qualified to the requirements of ANSI N45.2.23, Sections 2.3.1 through 2.3.4 for Lead Auditors. The results of audits shall be documented and provided to the Design Adequacy Review Team Leader for his review.
TN-85-6262 Page 12 of 12
Rsvision: O Page 8 of 14 APPENDIX G (Cont'd)
ATTACHMENT 4 VERIFICATION OF ISSUE-SPECIFIC ACTION PLAN WORKING FILES 1.0 PURPOSE This procedure defines the process for the CPRT internal review and verification of TRT Issue-Specific Action Plan (ISAP) Working Files.
The internal review and verification of the Working File for each TRT ISAP must be completed and a report submitted to the SRT at the same time that the Results Report for that ISAP is submitted to the SRT.
2.0 INTRODUCTION
As indicated in the CPRT Program Plan, the Senior Review Team (SRT) has assigned primary responsibility for the proper implementation and documentation of the results of the TRT ISAPs to the responsible Review Team Leaders (RTLs). The SRT is responsible for reviewing and approving the ISAPs and their associated Action Plan Results Reports. As an additional measure to ensure the quality of the documentation supporting the implementation of the Action Plans and the results and cenclusions presented in the associated Results Reports, the SRT has established the CPRT Results Report and Working Files Review Committee.
3.0 OBJECTIVES The Chairman of the CPRT Results Report and Working Files Review Committee reports directly to the SRT and is responsible for conducting a review and verification of the Working Files for each TRT ISAP. The objectives of this review and verification activity are to:
Ensure that the approved ISAP was implemented as defined.
- Determine that the content of the Working File is complete and organized in a manner consistent with the requirements of the CPRT Program.
- Determine that the work reported in and conclusions reached in the Results Report for the ISAP are substantiated by the idformation contained in the Working File.
Ravision: 0-Pagn 9 of 14 APPENDIX G ,
(Cont'd)
ATTACHMENT 4 (Cont'd) i 4.0 RESPONSIBILITIES The responsibilities and associated interfaces for the conduct of the CPRT verification of TRT ISAP Working Files are described below.
4.1 Review Team Leaders The assigned Review Team Leader (RTL) has the following responsibilities in the review and verification of the Working File for each ISAP for which he is responsible.
Assure that the Working File is complete and organized in a manner consistent with requirements of the CPRT Program Plan and the CPRT Guide on Assembly of Project Central and Working Files prior to submitting the Working File for review and verification.
Notify the Chairman of the Results Report and Working File Review Committee that the Working File is ready for review and verification.
Resolve comments generated by the review and verification team during the Working File review and verification process.
Discuss any unresolved review comments with the SAT when SRT meets to review and approve the Results Report [
for that ISAP.
Complete the requirements for resolution of these comments as directed by the SRT before releasing the Working File for transfer to the Central File.
- Report to the SRT that such requirements have been completed.
4.2 Results Report and Working File Review Committee Chairman The Chairman of the Results Report and Working Files Review Committee has the following responsibilities in the review and verification of the Working File for each TRT ISAP.
- Assign a review and verification team, constituted of members of the third-party CPRT Support Staff, to conduct the review and verification of the contents of the Working File.
Rsvision: O Pags 10 of 14 APPENDIX G (Cont'd)
- ATTACHMENT 4 (Cont'd) 4.0 RESPONSIBILITIES (cont'd) l Lead team review and verification effort.
Communicate the comments generated by the review and verification team to the responsible RTL.
Determine that comments have been adequately resolved.
l If, after consultation with the responsible RTL, any comments remain unresolved, document such open items in the Working File Verification Report to the SRT.
Ensure that the Working File Verification Report is submitted to the SRT at the same time that the Results Report for that ISAP is submitted to the SRT for review and approval.
4.3 Review and Verification Team The assigned review and verification team has the following responsibilities for the review and verification of each TRT ISAP.
Perform the review and verification of the Working File utilizing the review criteria described in Section 5.0 of this procedure.
Assist the Review Committee Chairman in communicating the comments generated during the review to the responsible RTL and in obtaining resolution of such comments.
5.0 REVIEW CRITERIA In performing TRT ISAP Working File verification reviews, the review and verification team shall utilize the following review criteria.
- Project documents used to support statements in Results Report in file are clearly referenced.
- Summaries of document reviews, inspection, and other related activities are provided to support statistical and numerical statements.
- Rsvision: 0 Page. 11 of 14 APPENDIX G (Cont'd)
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ATTACHMENT 4 (Cont'd) 5 '. 0 REVIEW' CRITERIA (cont'd)
Checklists for document reviews, inspection, and other
.related activities are included.
Documented criteria for evaluations, review, sample selection, and other related activities are included.
Reonfred training records and personnel
_ qualifications are included or clearly. referenced.
Documents are included which close out any related concerns identified during performance of the action plan.
.Each file or sub-file has a file content log.
The following items required by the'CPRT Program Plan are present:
^ o. -Copies of approved Action Plan and all revisions
, o - Documents of results of analysis performed L
1 including evaluations of root cause, generic h - implications and' safety significance. o : Documents of'results of. testing. o Copies of procedures or checklists used in testing. j\g o Documents of results of inspections. o Copies of procedures or checklists used in i inspections. o Documents of results of record reviews. L' o- Copies of procedures or checklists used in record reviews. o Copy of Action Plan Results Report including interim or approved preliminary reports.
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Revision: O Page 12 of 14
-APPENDIX G (Cont'd)
ATTACHMENT 4 (Cont'd) 6.0 -REPORTS. The conclusions resulting from the review and verification of the Working File for each TRT~ISAP shall be documented in a Working File Verification Report (Attachment 4.1). Such reports shall be developed and submitted to the SRT by the Chairman of the Results Report and' Working File Review Committee at the same time that the Results Report for that-ISAP is submitted to the SRT. The Working File Verification Reports shall be signed by both the Chairman of the Results Report and Working File Review Committee and the responsible RTL. I t I i
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r Rtvision: 0 Page 13 of 14 APPENDIX G (Cont'd) ATTACHMENT 4 (Cont'd) ATTACHMENT 4.1 TO: CPRT SENIOR REVIEW TEAM FROM: Chairman, Results Report and Working File Review Committee DATE:
SUBJECT:
Working File Verification Report fo* ISAP No. The Working File review and verification team has completed its review of the Working File for ISAP No. . Our conclusions and (if applicable) any remaining unresolved comments are presented below. NO YES The ISAP was implemented as defined and approved by the SRT. The content of the Working File is complete and organized in a manner consistent with the requirements of the CPRT Program. The work reported in and conclusions reached in the Results Report for the ISAP are substantiated by the information contained in the Working File. Addition Review Committee Comments:
r" R vision: 0 Pags 14 of 14 APPENDIX G (Cont'd) ATTACllMENT 4 (Cont'd) ATTACHMENT 4.1 (Cont'd) Working File Verification Report for ISAP No. Unresolved Comments: RTL, ISAP No. Chairman, Results Report and Working File Review Committee m
ATTACHMENT 6.0 APPENDIX II - CPRT PROGRAM PLAN
7 ..
'R vision 0 Paga 1 of 8 APPENDIX H CPRT PROCEDURE AND POLICY FOR THE DEVELOPMENT, APPROVAL, AND CONFIRMATION OF IMPLEMENTATION OF CORRECTIVE ACTIONS
'A. -INTRODUCTION / PURPOSE The CPRT Program Plan requires the definition of appropriate corrective actions for all deviations or deficiencies (both specific and programmatic) identified during the CPRT's investigatory activities. Corrective actions developed for each specific deviation or deficiency _ generally will be remedial in
-nature; i.e., defined to correct the specific non-conforming condition. Corrective actions developed for each programmatic deviation or deficiency generally will be prospective in nature; i.e., defined to preclude the recurrence of similar non-conforming
. conditions in the future.
The CPRT may recommend proposed corrective actions to the CPSES
. Project; however, the CPSES Project is responsible for the definition of corrective actions.
The CPRT Program Plan also establishes, as a prerequisite for the completion of the CPRT third-party's investigatory activities, that the. corrective actions defined by the CPSES Project for all deficiencies and for certain categories of deviations must be acceptable to the CPRT; i.e., the CPRT is satisfied that, when implemented as defined, the corrective actions defined by .the CPSES Project will correct the specific non-conforming condition (s) and, if applicable, will preclude the recurrence of similar
.non-conforming conditions in the future.
As stated in the CPRT Program Plan, corrective actions will be implemented by the CPSES Project. The nature and extent of third-party overview of the actual implementation of the CtaES Project's corrective action plans will vary depending upon the nature of the corrective actions'and the third-party's confidence that such actions are being implemented properly. The purposes of this document are to:
-- Describe the process through which corrective actions will be defined for deviations or deficiencies identified by the CPRT.
- Describe the process through which the CPRT third-party will review and approve the definition of corrective actions for all deficiencies and for certain categories of deviations identified by the CPRT.
- Describe the nature and extent of CPRT third-party confirmatory overviews of the implementation of defined corrective actions.
L Rsvision: 0 Pega 2 of 8 APPENDIX H j (Cont'd) B. DEVELOPMENT, APPROVAL, AND DOCUMENTATION OF CORRECTIVE ACTIONS FOR DEVIATIONS AND DEFICIENCIES IDENTIFIED BY THE CPRT Each CPRT Review Team Leader (RTL) is responsible for ensuring that all discrepancies identified during the conduct of their respective investigatory activities are: documented by the CPRT evaluated and classified by the CPRT trended by the CPRT transmitted to the CPSES Project for evaluation and disposition in accordance with CPSES Project procedures for processing non-conformances. For each deviation or deficiency identified by the CPRT, the CPSES Project is responsible for performing 10CFR50.55(e) reportability evaluations and for defining appropriate corrective actions. The CPSES Project is also responsible for obtaining CPRT RTL concurrence in the defined corrective actions for:
- Each safety-significant deficiency identified by the CPRT Each programmatic deviation or programmatic deficiency identified by the CPRT Each design deviation identified by the CPRT that involves a failure to meet FSAR criteria or commitments, other licensing commitments, or the regulations
- Each deviation identified by the CPRT that has been determined by the CPSES Project to meet the reportability criteria set forth in 10CFR50.55(e)
The CPRT RTLs are responsible, within their respective areas of review, for determining the adequacy of the corrective actions defined by the CPSES Project to resolve each CPRT-identified deficiency or deviation that is included in the above-mentioned categories. The results of these determinations (i.e., concurrence or non-concurrence) will be documented, retained in the CPRT Project files, and summarized in Action Plan Results Reports. The CPRT RTLs may recommend proposed corrective actions to the CPSES Project. However, any RTL recommendations for corrective actions in the following categories must be approved by the Senior Review Team (SRT):
Rsvision: O P;g2 3 of 8 APPENDIX H (Cont'd) B. DEVELOPMENT, APPROVAL AND DOCUMENTATION OF CORRECTIVE ACTIONS FOR DEVIATIONS AND DEFICIENCIES IDENTIFIED BY THE CPRT (Cont'd) recommendations for corrective actions that are programmatic in nature recommendations for corrective actions to resolve specific safety-significant deficiencies recommendations for corrective actions to resolve specific design deviations that could involve a change to existing licensing or FSAR commitments. The decisions of the SRT related to the approval of such recommendations will be documented and retained in the CPRT Project files. The CPSES Project may accept such recommendations or define alternative corrective actions that are acceptable to the CPRT RTL. In either event, the CPRT RTL's determinction of the adequacy of the corrective actions defined by the CPSES Project will be documented, retained in the CPRT Project files, and summarized in Action Plan Results Reports. SRT approval of CPRT RTL determinations of the adequacy of corrective actions defined by the CPSES Project will either be accomplished on an ongoing basis as such corrective actions are developed or as part of the Action Plan Results Report approval process. In either case, the decisions of the SRT related to the approval of such determinations will be documented and retained in the CPRT Project files. In the event that a corrective action defined by the CPSES Project is determined by the responsible CPRT RTL to be inadequate and cannot be resolved with the CPSES Project to the satisfaction of the CPRT RTL, the matter will be brought to the SRT for resolution. The SRT will reach a conclusion with respect to the corrective actions required. The SRT's conclusions in this regard, including the bases for such conclusions, will be documented and retained in the CPRT Project files; will constitute the CPRT's position on the matter in questioni and will be transmitted to the responsible CPRT RTL and to the Executive Vice President of TUGCO. The Executive Vice President of TUCCO is responsible for establishing TUGCO's position on any corrective actions for which agreement has not been reached between the CPRT and the CPSES Project and for advising the SRT of TUCCO's intentions.
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{ , Rsvisicn 0 Pags 4 of 8 f.' 1 APPENDIX H
'(Cont'd)
C. CPRT CONFIRMATORY OVERVIEW OF IMPLEMENTATION OF DEFINED CORRECTIVE ACTIONS . As described ~in Section B. above, the CPRT will ensure that the CPSES Project has defined corrective actions that are acceptable to the CPRT. That is, the CPRT must be satisfied that, when implemented as defined, the CPSES Project's corrective actions will correct the specific non-conforming conditions identified by the
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CPRT and, if applicable, will preclude the recurrence of similar non-conforming conditions in the future. In order to verify that the CPSES Project's program for
. implementing defined corrective actions is being effectively.
implemented, the CPRT lleview Team Leaders will be responsible for performing confirmatory overviews of the the implementation of certain corrective actions within their respective areas of review. These confirmatory overviews are intended to accomplish the following objectives: To ensure that the corrective actions for each programmatic deviation and programmatic deficiency have been effectively implemented. To ensure that the corrective actions for each specific safety-significant deficiency have been' effectively implemented. To ensure that the corrective actions for each specific design
. deviation that' involves a failure to meet FSAR and licensing commitments have been effectively implemented.
- To ensure that the corrective actions for each specific deviation that meets the reportability criteria of 10CFR50.55(e) have.been effectively implemented.
CPRT Review Team Leaders are responsible for documenting the results of'such confirmatory overviews. These results will be reported to the SRT either as'part of the Action Plan Results Report or in a supplement to the Action Plan Results Reports. Additional details related to this confirmatory overview are presented below.
- 1. OVERVIEW OF CORRECTIVE ACTIONS RELATED TO CPSES DESIGN ADEQUACY l
In order to obtain additional confidence that the CPSES Project is satisfactorily implementing the defined corrective actions for CPRT-identified deviations or deficiencies in the [. area of CPSES Design Adequacy, the CPRT will perform the following confirmatory activitiest
V~ R; vision: 0 Pega 5 of 8 APPENDIX H (Cont'd) ! C. CPRT CONFIRMATORY OVERVIEW OF IMPLEMENTATION OF DEFINED CORRECTIVE l ACTIONS (Cont'd)
-(a) The CPRT will confirm the adequacy of the CPSES Project's implementation of corrective actions for each CPRT-identified design deficiency. Such confirmation will be accomplished by CPRT review of (a) the design documentation that reflects the implementation of the corrective action, and, if applicable, (b) the documentacion that demonstrates that the as-constructed condition of the plant is in conformance with the revised design documentation.
(b) The CPRT will confirm the adequacy of the CPSES Project's implementation of corrective actions for each specific CPRT-identified design deviation that involves a failure to meet FSAR criteria or commitments, other licensing commitments, or the regulations (i.e., 10CFR). The nature and extent of the CPRT's confirmatory activities will vary depending upon the nature of the corrective action defined for each design deviation. In this regard, the following considerations will apply: The extent to which the defined corrective action is specific (i.e., not subject to interpretation with respect to implementation). The extent to which the defined corrective action is complex (i.e., involving a set of related activities where interface considerations are of importance). The extent to which the defined corrective action is, of itself, dispositive of the underlying design deviation (i.e., not dependent upon additional analyses or evaluations). The CPRT's confirmatory activities will include, at a minimum, review of (a) the design documentation that reflects the implementation of the corrective action, and, if applicable, (b) the documentation that demonstrates that the as-constructed condition of the plant is in conformance with the revised design documentation.
E Rsvision: O Pags 6 of 8 APPENDIX H (Cont'd) C.- CPRT CONFIRMATORY- OVERVIEW OF IMPLEMENTATION OF DEFINED CORRECTIVE
' ACTIONS (Cont'd)
If the CPRT-has concurred in a defined corrective action that resolves a deviation through a justifiable change to existing FSAR or licensing commitments and if such change does not involve a redesign or reanalysis, CPRT confirmatory overview will not apply. (c) The CPRT will confirm the adequacy of.the CPSES s- Project's implementation of corrective actions ' for any other design deviations that meet the reportability criteria set forth in 10CFR50.55(e). For such cases,
- the CPRT's confirmatory activities will be governed by the considerations and criteria described in Item (b) above.
(d) The CPRT will confirm the adequacy of the CPSES Project's implementation of corrective actions for each CPRT-identified programmatic deviation or deficiency. Such corrective actions are expected-to be defined in the. form of recommended revisions to CPSES Project policies, programs, and implementing procedures or instructions related to design activities, including but not limited to design control. CPRT confirmatory activities will be accomplished through reviews of the revised documents that reflect such changes.
- 2. OVERVIEW OF CORRECTIVE ACTIONS RELATED TO QUALITY OF CONSTRUCTION-AND QA/QC PROGRAM ADEQUACY In order to obtain additional confidence that the CPSES l Project is satisfactorily implementing the defined corrective actions for CPRT-identified deviations or deficiencies in the area of CPSES Quality of Construction'and QA/QC Program I Adequacy, the CPRT will perform the following confirmatory activities:
- (a) -The CPRT will confirm.the adequacy of the CPSES Project's implementation of corrective actions for each CPRT-identified construction deficiency. Such t confirmation will either be accomplished by an i independent CPRT reinspection after the corrective L action has been implemented or by CPRT personnel witnessing the reinspection performed by the CPSES Project after the corrective action has been implemented.
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I Rsvicion: 0 Pagn 7 of 8 APPENDIX H , (Cont'd) C. CFRT CONFIRMATORY OVERVIEW OF IMPLEMENTATION OF DEFINED CORRECTIVE ACTIONS (Cont'd) (b) The CPRT will confirm the adequacy of the CPSES Project's implementation of corrective actions for construction deviations that meet the reportability criteria set forth in 10CFR50.55(e). For such cases, the CPRT's confirmatory activities will be as described in (a) above. (c) The CPRT will confirm the adequacy of the CPSES Project's implementation of corrective actions for each CPRT-identified programmatic deviation or deficiency. Such corrective actions are expected to be defined in the form of recommended revisions to CPSES Project policies, programs, and implementing procedures or instructions related to QA/QC or construction processes. CPRT confirmatory activities will be accomplished through reviews of the revised documents ' that reflect such changes.
- 3. OVERVIEW OF CORRECTIVE ACTIONS RELATED TO PREOPERATIONAL AND STARTUP TESTING PROGRAMS In order to obtain additional confidence that the CPSES Project is satisfactorily implementing the defined corrective actions for CPRT-identified deviations and deficiencies in the area of CPSES preoperational and startup testing programs, the CPRT will perform the following confirmatory activities:
(a) The CPRI will confirm the adequacy of the CPRT Project's implementation of corrective actions for each specific CPRT-identified deficiency in the area of testing programs. Such confirmation will be accomplished by CPRT review of testing program documentation (e.g. , test result report) that re flects the implementation of the corrective action. (b) The CPRT will confirm the adequacy of the CPSES Project's implementation of corrective actions for specific CPRT-identified deviations in the area of testing programs that meet the reportability criteria set forth in 10CFR50.55(e). For such cases, the CPRT's confirmatory activities will be as described in (a) above.
I e R:visiont 0 Pzga 8 of 8 APPENDIX H (Cont'd) C. CPRT CONFIRMATORY OVERVIEW OF IMPLEMENTATION OF DEFINED CORRECTIVE ACTIONS (Cont'd) (c) The CPRT will confirm the adequacy of the CPRT Project's implementation of corrective actions for each CPRT-identified programmatic deviation or deficiency. Such corrective actions are expected to be defined in the form of recommended revisions to CPSES Project policies, programs, and implementing procedures or instructions related to testing programs. CPRT confirmatory activities will be accomplished through reviews of the revised documents that reflect such changes. i r 1 I l}}