ML20151U606
| ML20151U606 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/07/1986 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20151U581 | List: |
| References | |
| PROC-860207, NUDOCS 8602110065 | |
| Download: ML20151U606 (13) | |
Text
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APPENDIX E h
CPRT PROCEDURE FOR THE CLASSIFICATION AND EVALUATION OF SPECIFIC DESIGN OR CONSTRUCTION DISCREPANCIES IDENTIFIED BY THE CPRT A.
PURPOSE The purposes of this procedure are to:
Provide criteria for classifying discrepancies, and Establish a process and criteria for evalueting discrepancies.
The classification and evaluation processes described in this Appendix were primarily developed and designed to address design and construction discrepancies identified by the CPRT during the implementation of the ISAPs and DSAPs developed for the CPRT' self-initiated _ investigatory efforts.
In order to ensure consistency throughout the CPRT program, similar processes will also be applied in the reporting of the results of the CPRT investigatory efforts for ISAPs and portions of DSAPs that were developed to respond to concerns specifically identified by External Sources.
%.A Additional information related to the development, approval and documentation of corrective actions for all deviations or deficiencies (both specific and programmatic) identified by the CPRT is provided in Appendix H to the CPRT Program Plan.
B.
CLASSIFICATION The following definitions have been established for use in classifying and evaluating identified discrepancies.
1.
DESIGN ADEQUACY All design discrepancies are classified as observations, deviations or deficiencies, depending upon whether the design error resulted in a failure to meet design criteria and depending on the safety significance of any failures to meet design criteria. The definitions employed in this area by the CPRT are as follows:
(a)
Design Discrepancy Any identified error related to design inputs, p
implementing documents and outputs for safety-related C/
structures, systems or components that could have an adverse impact on the adequacy of their design.
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1 Page 2 of 13
~(T APPENDIX E
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(Cont'd)
B.
CLASSIFICATION (Cont'd)
(b)
Design Observation Any identified design discrepancy that has been determined to not constitute a design deviation.
l (c)
Design Deviation Any identified design discrepancy that has been determined to constitute a verified failure to meet a design commitment or specification. In this regard, design commitments include regulatory requirements, FSAR commitments, other licensiez commitments, code commitments or other project-specific design criteria or commitments.
(d)
Design Deficiency Any identified design deviation that has been determined to be safety-significant.
(3)
(e)
Safety-Significant-f
" Safety 7significant", for purposes of the CPRT Program, is defined to mean that the identified discrepancy, if uncorrected, would result in the loss of capability of the affected system, structure or component to perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redundancy at the component, system, train or structure level.
(f)
Programmatic Design Deficiency A set of related design discrepancies that have been determined to constitute an adverse trend that is programmatic in nature.
This definition, which is employed in the CPRT Program for purposes of sample expansion, is more restrictive than that usually applied to the term " safety-significant" for regulatory purposes or in common parlance, in that it ignores redundancies that do exist in real life.
[ Compare 10CFR50,- Appendix A (Introduction, " Single Failure"); 10CFR50.55(e)(1).]
Identification of a deficiency as O
" safety-significant" for purposes of the CPRT Program, therefore, is not equivalent to a statement that, in fact, the deficiency, if uncorrected, would have resulted in unsat'e operation.
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APPENDIX E
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B.
CLASSIFICATION (Cont'd) 2.
CONSTRUCTION ADEQUACY All construction discrepancies are classified either as deviations or deficiencies, depending upon the safety significance of the discrepancy. The definitions employed by the CPRT in this area are as follows:
(a)
Construction Deviation Any identified error related to construction or installation of safety-related hardware that has been determined to constitute a verified failure to construct or install a safety-related structure, system or component in accordance with safety-significant attributes and criteria contained in design drawings and specifications or installation procedures /
requirements.
(b)
Construction Deficiency
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Any identified construction deviation that has been determined to be safety-significant.
(c)
Safety-Significant See B.1.(e) and associated footnote for definition.
l (d)
Programmatic Construction Deficiency A set of related construction deviations that has been determined to constitute an adverse trend that is programmatic in nature.
3.
TESTING PROGRAM ADEQUACY All testing discrepancies are classified either as deviations or deficiencies, depending upon the significance of the discrepancy. The definitions employed by the CPRT in this area are as follows:
(a)
Testing D6viation Any verified failure to meet a testing program commitment, regulatory requirement or a project
./T specific testing commitment.
In this regard,
\\ssl-commitments include VSAR commitments and other licensing commitments,
6 Rsvision 1
Page 4 of 13 f)
AF?ENDIX E
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(Cont'd)
B.
CLASSIFICATION (Cont'd)
(b)
Testing Deficiency Any identified testing deviation that is determined to have resulted in a failure to meet a testing program objective such that retesting is required to demonstrate that the affected structure, system or component is capable of performing its intended safety functica.
(c)
Programmatic Testing Deficiency A set of related testing deviations that has been determined to constitute an adverse trend that is programmatic in nature.
4.
QA/QC PROGRAM ADEQUACY All QA/QC Program discrepancies are classif4' sither as deviations or deficiencies, depending upon the significance of
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the discrepancy. The definitions employed by the CPRT in this
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area are as follows:
(a)
QA/QC Program Deviation Any verified failure of the QA/QC Program to meet regulatory requirements (i.e., 10CFR50 Appendix B),
FSAR commitments or other licensing. commitments.
(b)
QA/QC Program Deficiency Any identified QA/QC Program deviation that is determined to have resulted in a failure that is reportable in accordance with 10CFR50.55(e).
(c)
Programmatic QA/QC Program Deficiency A set of related QA/QC deviations that has been determined to constitute an adverse trend that is programmatic in nature.
C.
EVALUATION PROCESS 1.
DESIGN ADEQUACY f
The decision logic used in the evaluation of identified design N-discrepancies is as follows:
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1 Page 5 of 13
/T APPENDIX E (s,f/
(Cont'd)
C.
EVALUATION PROCESS (Cont'd)
(a)
Design Observations Each design discrepancy that is determined not to constitute a verified failure to meet a design commitment or specification will be classified as a design observation.
The evaluation of each design obaervation will be considered to be complete when the basis for the above-mentioned determination is documented.
Design observations and design deviations will be collectively evaluated for the purpose of identifying adverse trends.
(See Section 5 below.)
(b)
Design Deviat' ions l
Each design discrepancy that is determined to constitute a verified failure to meet a design 3
commitment or specification will be evaluated further
)
for safety significance.
If it is determined that such
.a discrepancy is not safety-significant, it will be classified as a design deviation.
The evaluation of each design deviation will be considered to be complete when:
The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the design deviation (i.e., hardware changes, approval for an exemption or deviation from the couaitment or requirement from the governing body, or both); and The bases for the above-mentioned determinations have been documented.
Design observations and design deviations will be collectively evaluated for the purpose of identifying adverse trends. (See Section 5 below.)
(c)
Design Deficiencies
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Each design deviation that is determined to constitute
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a safety-signf.ficant failure to meet,a design commitment or specification will be classified as a design deficiency.
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APPENDIX E
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(Cont'd)
C.
EVALUATION PROCESS (Cont'd)
The evaluation of each design deficiency will be considered to be complete when:
The root cause and/or contributing causes for the deficiency have been identified; The generic. implications of the deficiency have been evaluated. This evaluation must be' of sufficient scope to provide reasonable assurance that there are no remaining undetected deficiencies within the affected area, population, or stratum; The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action'has been accomplished for the nonconformance associated with the design deficiency; and The bases for the above-mentioned i
f determinations have been documented.
q Any additional discrepancies that may be identified as a result of the above-mentioned generic implications evaluation will each be classified and dispositioned in-accordance with this Appendix.
In addition, the associated set of such discrepancies will be further evaluated for commonalities that may be indicative of an adverse trend.
(See Section 5 below.)
(d)
Programmatic Design Deficiency The evaluation of each programmatic design deficiency will be considered to be complete when the required actions set forth in Section 5 for identified adverse trends have been completed.
L 2.
CONSTRUCTION. ADEQUACY (a)
Construction Deviations Each verified failure ~to meet a design or installation specification will be evaluated further for safety significance.
If it is determined that such a O
deviation is not safety-significant, it will be classified as a construction deviation.
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/~'s APPENDIX E
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(Cont'd)
C.
EVALUATION PROCESS (Cont'd)
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The evaluation of each construction deviation will be l
considered to be complete when:
I The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the construction deviation (i.e., hardware changes); and the bases for the above-mentioned determinations have been documented.
Construction deviations will be collectively evaluated for the purpose of. identifying adverse trends. (See Section 5 below.)
(b)
Construction Deficiencies Each safety-significant failure to meet a design or
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installation specification will be classified as a construction deficiency and will be evaluated further for root cause and generic implications.
4 The evaluation of.each construction deficiency will be considered to be complete when:
The root cause and/or contributing causes for the deficiency have been identified; The generic implication of the deficiency have been evaluated. This evaluation must be of sufficient scope to provide reasonable assurance that there are no remaining undetected deficiencies within the affected area, population, or stratum; The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the construction deficiency: and The bases for the above-mentioned deterninations are documented.
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(Cont'd)
C.
. EVALUATION PROCESS (Cont'd)
Any additional deviations that may be identified as a result of the above-mentioned generic implications evaluation will each be classified and dispositioned in accordance with this Appendix.
In addition, the associated set of such deviations will be further evaluated for commonalities that may be indicative of an adverse trend. (See Section 5 below.)
(c)
Programmatic Construction Deficiency The evaluation of each programmatic construction deficiency will be considered to be complete when the required actions set forth in Section 5 for identified
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adverse trends have been complete.
3.
TESTING PROGRAM ADEQUACY (a)
Testing Deviation l'\\ '
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Each verified failure to meet a testing program commitment, regulatory requirement or a project specific commitment will be classified as a testing deviation. The deviation will be evaluated to determine whether it resulted in a failure to meet a testing program objective'such that retesting is required to demonstrate that the affected structure, system or component is capable of performing its intended safety function.
The evaluation of each testing deviation will be considered to be complete when:
The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the testing deviation (i.e., retesting, approval for an exemption or deviation from the commitment or requirement from the governing body, or both); and The bases for the'above-mentioned determinations have be.en do:umented.
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APPENDIX E
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(Cont'd) 1 s-l l
C.
EVALUATION PROCESS (Cont'd)
Testing deviations will be collectively evaluated for the purpose of identifying adverse trends.
(See Section 5 below.)
(b)
Testing Deficiency Each testing deviation that is determined to have resulted in a failure to meet a testing program objective such that retesting is required to demonstrate that the affected structure, system or component is capable of performing its intended safety function will be classified as a testing deficiency.
The evaluation of each testing deficiency will be considered to complete when:
The root cause and/or contributing causes for the deficiency have been identified; g-'S The generic implications of the deficiency
-( )
have been evaluated. This evaluation must be of sufficient scope to provide reasonable assurance that there are no remaining undetected deficiencies within the affected area, population, or stratum; The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the testing deficiency; and The bases for the above-mentioned determinations are documented.
Any additional deviations that may be identified as a results of the above-mentioned generic implications evaluation will each be classified and dispositioned in accordance with this Appendix.
In addition, the associated set of such deviations will be further evaluated for commonalities that'may be indicative of an adverse trend.
(See Section 5 below.)
(c)
Programmatic Testing Deficiency I
The evaluation of each programmatic testing deficiency will be considered to be complete when the required actions set forth in Section 5 for identified adverse trenos have been completed.
Rsvision:
1 Page 10 of 13
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APPENDIX E N/
(Cont'd) s C.
EVALUATION PROCESS (Cont'd) 4.
QA/QC PROGRAM ADEQUACY (a)
QA/QC Program Deviation Any verified failure of the QA/QC Program to meet regulatory requirements, FSAR commitments or other licensing commitments will be evaluated for reportability in accordance with 10CFR50.55(e).
If it is determined that such a failure is not reportable, it will classified as a QA/QC Program deviation.
The evaluation of each QA/QC Program deviation will be considered to be complete when:
The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for,
the nonconformance associated with the QA/QC Program deviation (i.e., program changes, f-s approval for an exemption or deviation from
( j the commitment or requirement from the
' governing body, or both); and The bases for the above-mentioned determinations have been documented.
QA/QC Program deviations will be collectively evaluated for the purpose of identifying adverse trends.
(See Section 5 below.)
(b)
QA/QC Program Deficiency Each QA/QC Program discrepancy that determined to be reportable in accordance with 10CFR50.55(e) 'will be classified as a QA/QC Program deficiency.
The evaluation of each QA/QC Program deficiency will be considered to complete when:
The root cause and/or contributing causes for the deficiency have been identified; The generic implications-of the deficiency have been evaluated. This evaluation must be of sufficient scope to provide roasenable
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assurance that there are no remaining s) undetected deficiencies within the affected area, population, or stratum;
Rhvision:
1 Page 11 of 13
/N APPENDIX E
(,,)
(Cont'd)
C.
EVALUATION PROCESS (Cont'd)
The CPRT has determined (to the extent
' required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the QA/QC Program deficiency; and The bases for the above-mentioned determinations are documented.
Any additional deviations that may be identified as a result of the above-mentioned generic implications evaluation will each be classified and dispositioned in accordance with this Appendix.
In addition, the associated set of such deviations will be further evaluated for commonalities that may be-indicative of an adverse trend.
(See Section 5 below.)
(c)
Programmatic QA/QC Program Deficiency 7-~s The evaluation of each programmatic QA/QC Program
-( )
deficiency will be considered to be complete when the required actions set forth in Section 5 for identified adverse trends have been completed.
5.
ADVERSE TRENDS A trend is a set of related discrepancies (observations and/or deviations) having attributes that reflect a discernible commonality.
Examples of possible commonalities include:
The individual, group of individuals or organization performing the safety-related activity; and The program requirements, procedures or controls governing the performance of the safety-related activity.
A trend is considered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected safety-significant deficiency in the affected area, population or stratum.
Adverse trends are also referred to as pregracratic deficiencies.
(N Each trend identified by the CFRT will be evaluated to s
determine whether it is adverse. CPRT Review Team Leaders are responsible for performing such evaluations and for making such determinations within their areas of responsibility, i
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1 Page 12 of 13
[
APPENDIX E (Cont'd)
C.
EVALUATION PROCESS (Cont'd)
The nature and extent of these evaluations will vary depending upon the nature'of the identified trend and the information already available regarding the implications of the trend.
Considerations in this regard include the extent to which:
The boundaries of the trend have been identified; The underlying cause and/or contributing causes of the trend have been identified; The area, population or stratum affected by the trend
.has been investigated; The potential safety significance of the trend has been identified; and Corrective action has already been taken to address the trend.
The results of these evaluations will be documented and retained in the CPRT working files.
If an adverse trend is determined to exist, the following actions are required:
The root cause and/or contributing causes must be assessed; The generic implications of the trend must be evaluated. This evaluation must be of sufficient scope.
to provide reasonable assurance'that there are no remaining undetected-deficiencies within the affected area, population or stratum; Appropriate corrective actions for any additional deviations or deficiencies identified during the evaluation of generic implications must be defined; and Appropriate corrective action to preclude recurrence in the future must be defined.
The results of these activities will be documented and retained in the CPRT working files.
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1 Pags 13 of 13
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APPENDIX E V)
(Cont'd)
C.
EVALUATION PROCESS (Cont'd) 6.
SPECIAL CASES As indicated above, unless an adverse trend is identified, root cause and generic implications evaluations will not be performed for individual design deviations or construction deviations.
It is recognized, however, that special cases may be identified where a root cause and generic implications assessment are warranted for certain individual construction or design deviations.
Review Team Leaders are responsible for identifying any such potential special cases to the Senior Review Team. The Senior Review Team in conjunction with the Review Team Leader will determine what additional action is required in such cases.
Such determinations, including the associated bases, will be documented and retained in the CPRT working files.
7.
UNCLASSIFIED DEVIATIONS g-s As noted in the Program Plan (e.g., Program Plan, Section g
)
IV(A), p.14), it may be determined that it is more practical or expeditio'us, with respect to a given deviation or set of deviations, to proceed directly to analysis of root cause and generic implications and to specification of corrective actions. Where such a determination has been made, performing a safety significance evaluation in respect of the unclassified deviation (s) would serve no purpose and will not be.done.
Such unclassified deviations will be tracked as deficiencies for purposes of root cause and generic implications analysis and for the purpose of corrective actions.
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