ML20202J073
| ML20202J073 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/19/1986 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20202J051 | List:
|
| References | |
| DAP-2, NUDOCS 8607170020 | |
| Download: ML20202J073 (46) | |
Text
i TITLE '
DOCUMENTATION APO TRACKING OF ISSUES APO DISCREPANCIES s
NUMBER DAP-2 Revision Prepared Date kviewed Date Approved Date 0
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i TABLE OF CONTENTS Seetion Cove r Shee t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .I . . . .
Table of Con ten t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11. . . .
1.0 P URP OS E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I. . .
2.0 SCOPE..................................................... I f 3.0 DEFINITIONS AND RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . I 4.0 INSTR UCT IO N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13 ..
5.0 DO CUME NTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 ATTACHMENTS A
i ISSUE RECORD COVER SEET . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1 B
CONSTRUCTON QA/QC ISSUES LOG . . . . . . . . . . . . . . . . . . . . . . . . . B-1 C ISSUE RECORD ............................................ C-1 D
DISCREPANCY /ISS UE RESOLUTION RECORD . . . . . . . . . . . . . . . . . D-l E INTERPRETATION OF DAP TRACKING SYSTEM
" TYPE" BLOCKS ......................................... E-l F USE AND INTERPRETATION OF DESIGN ACTIVITY ......................................... F-l l
TN-85-6262/2 li
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUME'.4TATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES 1.0 PURPOSE This procedure defines the requirements for documentation, trocking and resolu-tion of external source issues and of discrepencies identified during the conduct of the Design Adequacy Program (DAP).
2.0 SCOPE This procedure applies to issues identified by external sources and to discrepon-cies identified during implementation of the DAP.
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions 3.1.1 Externo! Source issue (Issue)
An error or concern related to design or design processes identified by on organization other + hon the Comanche Peak Response Team (CPRT) and con-toined in public documents on the NRC dockets for the Comanche Peak Steam Electric Station (CPSES).
3.1.2 Status The designation, as determined under the DAP, of an issue or discrepancy as l open or closed, and whether it has been transferred to o primary issue.
l O TN-85-6262/2 Page I of 32 i
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE s Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 4
ISSUES AND DISCREPANCIES i
3.l.3 Open 3.1.3.1 Open issues Issues are considered to be open until there is reasonable assurance that the following conditions, os determined under the DAP, have been met:
i o it has been determined that: !
a) the issue is unsubstantiated, or, 2
b) the issue
- 1) has been resolved by on external source and requires no odditional investigation by the CPRT except as on input to trend evoluotion, and li) hos been oppropriately classified by the CPRT as .
on observation, deviation or deficiency; or, c) the issue is a discreponey determined by the CPRT to have been resolved and meets the conditions for closure of a discreponey listed in paragraph 3.I.3.2 of this procedure; ond, o The bases for any one of the obove-mentioned determino-1 tions have been documented.
- 3.1.3.2 Open Discrepancies Discrepancies are considered to be open until there is reasonable assurance that the following conditions, as determined under the DAP, have been met
o The DAP has determined that the discrepancy has been oppropriately classified (as on observation, deviation or deficiency).
o The DAP has determined that oppropriate resolutions and correct ,e actions, as required by the CPRT Program Plan, have been established.
l TN-85-6262/2 Page 2 of 32 I
COMANCHE PEAK RESPONSE TEAM - DESIGN ADENJACY PROCEDURE
- O' Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 3 o it has been determined that the root cause and the ,
generic implications have been investigated as required by the CPRT Progrom Plan. -
]
l l l
o The basis for the above-mentioned determinations have '
been documented.
3.1.4 Closed ,
Issues and discrepancies are considered closed when the opplicable conditions outlined in 3.I.3 have been met.
3.1.5 Transferred to The designation used to describe the result of combining duplicate issues that I
appear in one or more of external source documents. The issue into which duplicates are transferred to is referred to os the primary issue.
3.1.6 Classification i
The designation used to indicate the chorocteristics of an Issue or discrepancy regarding its validity, consistency with design commitments and nuclear safety-significance. The classifications are: unsubstantiated, obsevation, deviation, unclassified deviation, deficiency and programmatic deficiency. Figure I depicts i the relationship among the classifications.
3.1.7 Unsubstantiated An external source issue or DAP-identified discrepancy that has been deter-
- mined, by the DAP, to be not valid.
O TN-85-6262/2 Page 3 of 32 i
9 o-ACTION PLAN RESULTS
$ EXTERNAL NOT EXPLICITLY DEFINED E ADVERSE SOURCE BY AN EXTERNAL g TREND ISSUE SOURCE ISSUE
/
UNSUBSTANTIATED w .
9 h
$ DISCREPANCY d
OBSERVATION DEVIATION I
o i r PROGRAMMATIC UNCLASSIFIED DEFICIENCY DEFICIENCY DEVIATION FIGURE I RELATIONSHIP AMONG CLASSIFICATIONS TN-85-6262/2 Page 4 of 32
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE )
- \ Number
- DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3
. ISSUES AND DISCREPANCIES 3.1.8 Discreponey Any identified error related to design inputs, implementing documents and outputs, i.e., assumptions, procedures, calculations, analyses, drawings or specifications for safety-related structures, systenu or components that could ;
have on adverse impact on the odequocy of their design. All dise:repancies are ultimately either classified as observations, deviations, unclassified deviations, i l
deficiencies or programmatic deficiencies, or are found upon additional investigation by the DAP to be unsubstantiated. Substantiated issues become discrepancies within the DAP.
3.I.9 Observation Any identified design discrepancy that has been determined, under the DAP, not O to constitute o design deviation. An observation may be technical (related to a technical aspect of design) or programmatic.
3.1.10 Deviation Any identified design that has been determined, under the DAP, to constitute a verified failure to meet o design criterio commitment or specification. In this regard, design criterio commitments include regulatory requirements, FSAR commitments, other licensing commitments, applicable code and stondord requirements or other project-specific design criterio or commitments.
3.1.1 I Unclassified Deviation A deviation or set of deviations for which it has been determined that it is more proctical to proceed directly to analyzing root cause and generic implications and specifying corrective actions. A safety-significance evoluotion will not be done for unclassified deviations because it would serve no useful purpose.
TN-85-6262/2 Page 5 of 32 t
~_, - - - - -. ._ _ _
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE t Number: DAP-2
Title:
DOCUMENTATION ANDTRACKING OF Revision: 3 ISSUES AND DISCREPANCIES Unclassified deviations are those related to areas in which total reverification or redesign is being conducted. Unclassified deviations will be trocked as deficiencies in that root cause and generic implications evaluations will be done and corrective action will be evaluated. in areas where 100% verification is being performed, the ossessment of root cause and generic implications is only for the purpose of identifying potential problems in other design areas.
3.1.12 Deficiency l Any identified design deviation that has been determined, under the DAP, to be a safety-significant deviation.
3.1.13 Programmatic Deficiency A set of related design discrepancies that have been determined to constitute on adverse trend that is programmatic in nature. An adverse trend is referred to os a programmatic deficiency. 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 offected design area. Programmatic deficiencies (like design deficiencies) are subject to evaluations of safety-significance, root cause, generic implications, and ode-quacy of corrective action.
3.1.14 Safety Significant A deviation that, if uncorrected, would result in the loss of copobility of the offected system, structure or component to perform its Intended safety function.
Credit is not allowed for redondon:y at the component, system, train or structure level. Refer to Appendix E, CPRT Program Plan for additional information regarding the CPRT definition of safety significant.
O TN-85-6262/2 Page 6 of 32
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
- I . Number
- DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 L
ISSUES AND DISCREPANCIES 3.1.15 Root Cause The cause or causal factors that contributed to o programmatic deficiency, unclassified deviation, or design deficiency, (i.e., why it occurred). A root cause may be determined during on evoluotion by testing a hypothesis or by making a preliminary judgement subject to confirmation. Root causes ond causal factors and the extent of their applicobility in design are based on objective evidence.
They are confirmed and bounded by the findings of evaluations (what does exist) rather than by general statements of what could exist.
3.1.16 Generic Implication A reasonable likelihood that on issue or discreponey (DlR) offects some aspect of design other than the specific instance in which the finding was identified.
b O 3.1.17 Generic implications Evoluotion The process of reviewing programmatic deficiencies, unclassified deviations, or design deficiencies identified or confirmed by the DAP to:
o Determine whether related design deficiencies exist, o investigate the root cause or cousal foctors, o Determine limiting boundaries of applicability of the deficiency under review.
3.1.18 issue Record A form (DAP-2-3) prepared by the Design Adequocy Review Teon. during the review of external source documents which contains o description of the issue and a record of its disposition by the DAP (See Attochment C).
TN-8S-6262/2 Page 7 of 32
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 i
ISSUES AND DISCREPANCIES 3.1.19 issue Record Cover Sheet Q
A form (DAP-2-1) prepared by the Design Adequacy Review Team that identifies the source document for on ottoched set of Issue Records (See Attochment A).
3.1.20 Construction /QA/QC (QOC) Issues Log ld A form (DAP-2-2) prepared by the Design Adequocy Review Team during the review of external source documents that lists issues that are within the scope of the OOC Program (See Attachment B). Use of this form is optional.
3.1.21 Discreponey/ Issue Resolution Report (DIR) ld i
A form (DAP-2-4) prepared by the Design Adequacy Review Team to track the .
status, classification and resolution of o!! open luues and of all diser poncles identified during conduct of the DAP (See Attochment D).
1 3.2 Responsibilities l
3.2.1 Review Team Leader
, The Review Team Leader is responsible for I
l o Approving the classification of discreponeles as defi-l ciencies, programmatic deficiencies or unclassified devio-tions; o Approving the closure of deficiencies, programmatic defi-ciencies and unclassified deviations; o Transmitting deficiencies, programmatic deficiencies and unclassified deviations to the CPRT Senior Review Team and to the Project Manager-Unit 1.
i TN-85-6262/2 Page 8 of 32 1
1
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i -
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION ANDTRACKING OF Revision: 3 ISSUES AND DISCREPANCIES These responsibilities may be delegated to the DAP Monoger.
The Review Team Leoder may perform any of the functions of the Reviewers,
! Discipline Coordinators, the Generic implications Coordinator or the DAP I Manager.
3.2.2 Design Adequacy Program Manager (DAP Monoger)
The DAP Manager is responsible for:
o Approving the classification of discrepancies as devio-tions; o Concurring in (or approving, if authorized by the Review
, Team Leader) the classification of discreponcles as defi-
! ciencies, programmatic deficiencies or unclassified devio-tions; o Approving the closure of deviations :
i o Recommendin Team Leoder)g (or approving, closure of deficiencies, if authorized programmaticby deft-the Review ciencies and unclassified deviations; l o Transmitting to the Project Manager-Unit I on a weekly
, . basis copies of new and revised DIRs that are:
- "D" DIRs T" DIRs classified as a deviation, unclassified devi-l ation, deficiency, or programatic deficiency j -
DIRs that were closed.
The DAP Monoger may perform any of the functions of the Reviewers, Discipline Coordinators or the Programmatic / Generic Implications Coordinator.
l l
lO l TN-85-6262/2 Page 9 of 32
. , _ _ , _ _ - -- - - - ~ -
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDI'RE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3
- (v9 ISSUES AND DISCREPANCIES 3.2.3 Progrommotic/ Generic Implications (PGI) Coordinator The Programmatic / Generic implication:: Coordinator (or his designee) is responsible for:
o Assigning numbers to approved issue Records and DIRs; o Ensuring data entry to the Design Adequacy Program Trocking System; o Manging the DAP Trocking System (DAPTS);
o Issuing periodic status reports to oddressees os deter-mined by the DAP Monoger; o Ensuring that a DIR is created for each open issue Record; o Returning unsigned hard copies of DIRs to Discipline Coordinators for potential ravisions; o Maintaining on auditable record of all Issue Records, DIRs, and revisions to DIRs.
3.2.4 Discipline Coordinator l
The Discipline Coordinator is responsible for:
o Approving issue Record Cover Sheets, GOC issues Lc,gs, and issue Records; o Concurring with the identification of external source documents which discuss QOC issues; ,
o Approving the status of external source issues; o Approving the classification of closed external source issues; o identifying duplicate issues and approving the transfer of duplicate issues to the primary issue; 1
i o Approving the classification of open issues as ur.mbstanti-ated issues or as discrepancies; TN-85-6262/2 Pcge 10 of 32 1
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES o Concurring with or approving DIRs (depending upon classi '
fication as detailed below);
o Approving the identification of discrepancies that are not explicitly defined by on external source issue; o Approving the classification of discrepancies as observo-tiAs; o Approving the closure of observations; o Concurring in the classification of discrepancies os deviations, deficiencies, programmatic deficiencies, or unclassified deviations; o Recommending the closure of deviations; o Forwarding copies of issue Record Cover Sheets for documents that discuss QOC inves, and specifically iden-tified issues requiring clarification as to DAP versus GOC coverage, to the DAP Construction Quality Interface Monoger for transmittal to the QOC Interface Coordi-notor (QOC issued Logs or issue Records may be included at the discretion of the Discipline Coordinator);
o Forwarding signed issue Record Cover Sheets and issue Records to the Generic Implications Coordinator; o Forwarding DIRs with the recommended classifications of deviation or deficiency to the DAP Monoger; o Forwarding DIRs and revisions to DIRs to the Generic implications Coordinator offer oppropriate approvals have been obtained; o Determining whether scope expansion is re. quired, as directed in DAP-3; g o Approving the reassignment of issues or discrepancies to '
the OOC Program; o Ensuring that, within his discipline, all open issues, and all j
discrepancies not explicitly defined by external source issues, are closed prior to the completion of the DAP.
3.2.5 Reviewer
! The technical reviewer is responsible for:
o Reviewing external source documents; TN-85-6262/2 Page il of 32 i
l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP 2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES o identifying external source issues; o Preparing issue Record Cover Sheets; o Preparing QOC transmittals including issue Record Cover Sheets, issue Records or QOC issue Logs os appropriate; o Preparing issue Records; o
Recommending the status of external source issues; o
Recommending the classification of closed external source issues; o Recommending the classification of open issues os unsub-stantiated issues or os discreponcies; o
identifying discrepancies that are not explicitly defined by external source issues; o Preparing DIRs and revisions to DIRs; o
Recommending the classification of discrepancies; O' o Reviewing information provided by others to close issues or discrepancies; o
Forwarding issue Record Cover Sheets, fr. sue Records, OOC issues Logs, DIRs and revisions to DIRs to the Discipline Coordinator.
1 3.2.6 Construction Quality Interface Monoger The Construction Quality interfoce Monoger is responsible for forwarding information received from the Discipline Coordinators on QOC issues to the appropriate QOC program interface person, and for maintaining a record or copy of information transmitted to the QOC Program. ,
3.2.7 TRT issues Monoger The TRT issues Monoger's responsibilities for signing DIR forms are the some os the DAP Monoger's responsibilities to the extent that DIRs are generated in the O TN.85-6262/2 Page 12 of 32
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES course of TRT reviews. In these cases, this procedure applies to the TRT issues Manager wherever the term "DAP Manager"oppears.
4.0 INSTRUCTION 4.1 Identification of issues 4.1.1 General The identification of issues is accomplished by the systematic review of documents which describe concerns related to the design or design process (external source documents). Identification of external source issues is an on-going activity throughout the DAP.
The reviewer shall complete on issue Record (using attoched Form DAP-2-3) for each issue related to the design or design process, regardless of the indicated status of the issue. This shall include issues identified by the QA/QC Review Team and transferred to the Design Adequacy Review Team for evoluotion. b If, during the initial source document review, it is apparent that on inue has both technical and programmatic components, these components will be docu-i mented on two separate issue Records. One issue Record will document the technical aspect of the concern and the other will document the programmatic aspect of the concern.
4.1.2 QOC issues i
Where on issue is noted by the DAP reviewer to be potentially relevant to the Quality of Construction (OOC) program, it shall be documented in one of the
, following forms:
By noting on the issue Record Cover Sheet (Form DAP-2-1) that construction issues are discussed within l the document.
TN-85-6262/2 Page 13 of 32 i
t
4 O' COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES By noting on the QOC lssues Log (Form DAP 2-2) or issue '
Record (Form DAP-2-3) specific issues that .equire GOC confirmation that they are or are not covered within the scope of the GOC Program. This will typically be done for issues that are not included in the scope of the DAP and where it is uncertain that they are covered in the scope of the GOC Program.
By any combination of the above.
4.1.3 Determination of issue Status For exh issue, the reviewer will make a determination as to whether the issue is open or closed using the criteria specified in paragraph 3.1.3.1. Any issue considered unresolved by the external source will be designated open under the DAP.
If the issue is determined to be open, Part i of the issue Record will be completed to the extent oppropriate in occordance with parograph S.4.l.
If the issue is determined to be closed, the issue will be classified and Parts I and 2 of the issue Record will be filled out as completely as possible.
4.1.4 Disposition of Issue Records When the review of a source document is complete, the reviewer shall attach an Issue Record Cover Sheet (using attached Form DAP-2-1) to the complete set of issue Records. The package will then be submitted by the reviewer to the Discipline Coordinator for review and opproval. After approval, the Discipline Coordinator will forward the package (including issue Records with original signatures) to the Generic implications Coordinator for entry into the DAPTS.
Issue Records and issue Record Cover Sheets shall be retained in ouditable files by the Generic implications Coordinator. As use of QOC issues Logs is optional, there is no requirement that files of QOC issues Logs be auditable.
d O
TN-8S 4262/2 Page 14 of 32
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
- O.
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 3 If any QOC issues are identified, the Discipline Coordinator responsible for initial source document review will send a copy of the relevant documentation described in Section 4.1.2 to the QOC Interface Coordinator via the DAP Construction Quality interface Monoger.
For each open issue, the Generic Implications Coordinator (or his designee) will transfer the information from the issue Record to on unsigned DIR and forward two copies of the DIR to the appropriate Discipline Coordinator. The Discipline Coordinator shall distribute one of these copies to the reviewer who originated the issue Record.
The Discipline Coordinators will review the initial set of DIRs for duplicate issues and will, by revision of the DIRs, designate (in the status field) duplicate '
issues as " transferred to " and indicate the issue number to which the duplicate was transferred (the primary issue). There are different methods by which a j
primary issue may be created. The easiest method to describe o primary issue should be used without creating odditional, unnecessary paperwork. Regardless of the method used, all fields that are filled in on the primary issue should be checked for occurocy and revised as necessary.
o An existing E-XXXX DlR that encompasses the duplicate Issue records may be designated as the primary issue without revising the content of the primary DIR; o An existing E-XXXX DIR that does not completely en-compass all aspects of duplicate issues may be revised to reflect all aspects of duplicate issues and to state in the
" Description" block that this DIR is the primary issue and reflects duplicate issues, or; o A new E-XXXX DIR may be written as the primary issue l
l with the issue description stating that this DIR is o compilation of duplicate issues and encompasses all aspects of duplicate issues. If a new DIR is created, o new E-XXXX number for the primary issue shall be obtained from the Generic implications Coordinator (or his designee) for entry in the " transferred to" block of duplicate issues.
TN 85-6262/2 Page 15 of 32
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O Number: DAP-2
Title:
DOCUMENTATION AND TRACKING DF Revision: 3 1
ISSUES AND DISCREPANCIES l
During the first and subsequent revisions to the DIR, each open issue shall be classified as either on unsubstantiated issue or os a discreponey, and the DIR shall be revised to reflect that classification and any odditional or revised information developed during the review process. The revised DIR cannot be accepted if the issue is not classified. To be classified as on observation, the issue must be designated as closed, and a description of resolution (why the DIR is closed) must be included on the DIR.
1 The Discipline Coordinators will send the revised (signed) DIRs (both duplicate and primary issues) to the Generic Implications Coordinator for entry into the DAPTS and retention in on auditable file.
4.2 Identification of Olscreponcles O If an open issue is determined to be o discreponey, the reviewer shall revise and J
sign the DIR, and ironsmit the DlR to the Discipline Coordinator for opproval.
The reviewer shall prepare o new DIR for each discreponey that is not explicitly defined by on open issue. Revision 2 of form DAP-2-4 shall be used for DIRs originated by reviewers offer March 31,1986. DIRs originated before April I, 1986 may be done using Rev. O of DAP-2-4 and need not be rewritten on a Rev. 2 form. There is no Rev. I of DAP-2-4. Do not use Rev. O of DAP-2-4
- offer March 31,1986.
l I
The DIR, including any supplementary sketches, notes and explanatory informo-tion, shall be prepored with the objective of allowing a person not familiar with the work, but technically quollfled, to understond it without extensive additional inquiry and research. Supplementory sketches, notes and explanatory informo-
- tion shall be o port of discipline files. The DIR shall describe the content of this odditional information relative to the discreponcy so that by itself the DIR describes the discreponey.
- O TN-85-6262/2 Page 16 of 32
--,---,------.-------,n__---
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES The Discipline Coordinator shall review, approve, and sign the DIR and forward the DIR to the Generic implications Coordinator for entry to the DAPTS and retention in on auditable file, if, during the implementation of on Action Plon, it is determined that the issue /discreponey under review should be reassigned to the QOC Program for resolution, the issue / discrepancy will be designated as closed and a copy of the DIR will be forwarded to the QOC Interface Coordinator by the DAP Construc-tion Quality interfoce Monoger of ter approval by the Discipline Coordinator.
4.3 Classification of Discrepancies When sufficient information is available, the reviewer shall classify each 3 discrepancy as either on observation or a deviation. The classification will be -
documented by the reviewer through revision of the DIR. If classified as on observation, the DIR must otso be marked closed and the description of resolution included, as no further action other than trending will be taken by the DAP regarding the observation.
Issues classified as unsubstantiated or os discrepancies, and discreponeles classi-i fled as observations, require the signature of the reviewer and the approval signature of the Discipline Coordinator on the DIR.
Classificotton of a discreponey as a deviation requires the signature of the reviewer, the concurrence signature of the Discipline Coordinator and the approval signature of the DAP Monoger on the DIR.
If the discrepancy is determined to be o deviation other than on unclassified deviation, it will be evaluated for safety significance, as required by DAP-22.
O TN-85-4262/2 Page 17 of 32 l
t
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
/O Number: DAP-2 V
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 3 If the deviation is determined to be o deficiency or on unclassified deviation, the DlR will be revised. All deficiencies and unclassified deviations will be evoluoted for root cause and generic implications, as required by DAP-7. The b revision requires the signature of the reviewer, the concurrence signature of the Discipline Coordinator and Design Adequocy Monoger, and the approval signature of the Review Team Leoder.
For o DIR to be classified as on unclassified deviation, the reviewer shall verify that a program undertaken by the CPSES Project does encompass a review of all aspects of the discreponey. The DIR shall contain in the reference block a reference to o procedure, document, plan, etc., that contains evidence that the discrepar.cy will be addressed. After this verification and documentation on the DIR is complete, the DlR may be opproved as on unclassified deviation in on g open status.
After evoluotions of root cause/ generic implications and any necessary corrective oction plan have been completed by the DAP, the unclassified deviation shall be closed provided it meets other conditions for closure per this procedure.
If the DlR documents on odverse trend, the DIR shall be classified as a programmatic deficiency and shall receive the some concurrence and approval signatures os o deficiency, described in the preceding parograph.
4.4 Revisions Revisions to DIRs shall be mode, verified and approved in the some manner os the original document. Revised DIRs shall be forwarded to the Generic Implications Coordinator for entry into the DAPTS (replacing the superseded revision) and retention of the signed revision in on auditable file. The active DAPTS will contain only the most current revision of DIRs.
g TN-8S-6262/2 Page 18 of 32
(3 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
() Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revisiom 3 ISSUES AND DISCREPANCIES Two hard copies of the revised DIR (with blank date blocks but with typed names of signators on the last revision) will then be returned to the Discipline Coordinator. The next revision will be made by mark-up and signatures on one copy. The Discipline Coordinator will distribute the second copy to the reviewer who signed the DIR.
4.5 Data Entry The Generic implications Coordinator (or his designee) will ensure that the Information from each approved issue Record, DIR, and DIR revision is entered
' into the DAPTS and verified. Codes and descriptions of codes currently in the DAPTS will be distributed periodically by the Generic implications Coordinator (or designee) the DAP discipline.
After verification that the information contained in the DAPTS is occurate, the signed originals will be transmitted to the controlled DAP files by the Generic l Implications Coordinator or his designee.
Externally resolved issue numbers (R-XXXX), open issue numbers (E-XXXX), and DAP identified discrepancy numbers (D-XXXX) will be sequentially aulgned by the Generic Implications Coordinator (or his designee) and will be noted on the l Issue Records and DIRs along with the date of entry into the DAPTS.
Issue / discrepancy numbers remain unchanged throughout the conduct of the DAP.
ld 4.6 Disposition of DIRs When the reviewer has completed the preparation or revision of the DIR, the i
reviewer will sign the DIR and submit it to the appropriate Discipline Coordi-notor for disposition.
O TN-85-6262/2 Page 19 of 32
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES The Discipline Coordinator will ensure that all required signatures and approvals are obtained as delineated in paragraph 3.2 of this procedure and depicted in Figure 2. When the DIR has been approved, the Discipline Coordinator will i
forwcrd it to the Generic implications Coordinator for entry into the DAPTS.
l Each week the Generic implications Coordinator (or his designee) will forward hard copies of new and revised DIRs (that meet one of the following conditions) received during that week to the DAP Monoger for forwarding to the Project Manager-Unit 1. The conditions for DIRs transmitted are:
d.
o All DIRs that were closed during that week regardless of classification; o All open D-XXXX DIRs that were opened or revised during that week; j o All E-XXXX DIRs that were classified during that week
' as a deviation, unclassified deviation, deficiency, or pro-4 grammatic deficiency
]
The DAP Monoger will request that TUCCO odvise him of the TDDR number l ossigned by TUCCO to each deviation, unclassified deviation, programmatic
) -
deficiency, or deficiency recorded on a DIR.
. i
) Upon receipt of a DIR that has been classified as o deficiency, programmatic deficiency or unclassified deviation, the Review Team Leader will, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of approval of the DIR, transmit a copy of the DIR to the CPRT Senior Review Team and to the Project Monoger Unit-l.
I l
l O TN-85-6262/2 Page 20 of 32
RESPONSIBILITY
- O F p
G N CLASSIFICATION AND CLOSURE EXTERNAL AP RESULTS SOURCE NOT EXPLICITLY DEFINED ISSUE BY EXTERNAL SOURCE ISSUE CLOSED OPEN DISCIPLINE COORDINATOR UNSUBSTANTIATED DISCREPANCY O
OBSERVATION DAP MANAGER DEVIATION REVIEW '
TEAM PROGRAMMATIC UNCLASSIFIED DEFICIENCY LEADER DEFICIENCY DEVIATlON FIGURE 2 RELATIONSHIP BETWEEN CLASSIFICATION APO APPROVAL AUTHORITY O TN45-4262/2 Page 21 of 32
I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES 5.0 DOCUMENTATION 5.1 Summary issue Record Cover Sheets, issue Records, OOC lasues Logs (if used) and DIRs shall be prepared using the attoched forms. All pertinent information shall be documented clearly and completely. A flow chart of the report generation process is contained in Figure 3.
5.2 lasue Record Cover Sheet The Source Document Title field will include the complete title of the document reviewed. For untitled documents (e.g., letters), the field will indicate that the document is untitled along with the subject, or contents, of the document. i The Originating / Investigating Organization field will contain the nome of the organization which issued the document being reviewed.
Eoch external source document reviewed will be assigned on identification number by the DAP. The Document I.D. field will contain this CPRT Identifica.
tion number.
l t The Description field will contain any odditional Information needed to describe the document, including any document ID number assigned by the issuing orgonization.
The Addressee Organization field will contain the nome of the organization to which the document is oddressed (if opplicable).
The Document Date field will contain either the date of issuonce of the document or, if the document is a meeting transcript, the date that the meeting was held.
TN 85-6262/2 Poge 22 of 32 i i
- OPEN EXTERNAL CCTION PL AN SOURCE 155UE5 IMPLEMENTATlON s.o I OPEN 1F EXTERNAL 155UE5 YES SUBSTANTIATED " DISCREPANCY /ISSLK RESOLUTION
? REPOR7: CLAJ5trY155UES AND I ACTION PLAN RESULT 5 NOT COVEREO IN 15$UE$ A5 No CC 7 DISCREPANCIES CLOSE 155UE YES j
ON DISCREPANCY / T 55W RESOLUTION OT4R REPORT m$CREPANCIES h EVALUATE PER ACTION PL AN REVISION OR EXPAN5 ION a -
4 + m DATA EPffRY pg T
F A.
NO UPCRADE CLAS$1r CATION DOCUMENT ISSUE CLOSURE IN DifC.
COORD* $* '$ * * "
M5 ULT 5 REPORT COORD. DAP McR. . C'ONCUR APPROVE YES RTL . APPROVE F SICN SRT . REVIEW CLOSE Di$CREP ANCy MVISE DISCREPANCY REPORT A5 OBSERVATION UPCRADE TO DEVIATION 55UE CLOSED MTM OR WITHOUT UP43$TANTIATED CORRECTIVE ACTION)
IN REVISED Di$CREPANCY/ ISSUE RE$0LUTION REPORT g g i
, COPY TO PROKCT i
DATA ENTRY W/ REQUEST FOR TDDR#
j DATA ENTRY q r DATA ENTRY F
TDOM #
FROM PROKCT 1 r DOCUMENT IN DISC.
RESUL75 REPOR7 COORD.
DIRECT NO CORRECTIVE A IS$UE/OSSERVAflON E CLOSED UNCLA$$1FIED O FIGURE 3 DEYlATK)N CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW TN 85-6262/2 Page 23 of 32
I EVALUATE PER ACTION PL AN REVl510N OR EXPANSION EVALUATE SAFETY q p SIGNIFICANCE C Dilgssp
, 7 1 V NO UPCRADE CLASSIFICATION E ANCY A5 ITH YES DISC.
ACTION COORD..
IN RE. CONCUR, O ANCY/ DAP MCR. D15C. COORD. . CONCUR E UTION APPROVE REVISE DISCREPANCY REPORT DAP MGR. - CONCUR UPCRADE TO DErlCIENCY RTL . APPROVE SRT . REVIEW I
O hY 4
COPY TO PROKCT
+
DATA ENTRY W/ REQUEST FOR TDDR #
T - DA NTRY
~
FROM PROKCT
_ g.
e
_[ - EVALUATE PER ACTIONPLAN REVl510N OR EXPANSION @ (PR G AMM C DEFICIENCY)
EVALUATE ROOT CAU5El CEPERIC IMPLICAT10N5 FIGURE 3 (continued)
O CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM D4SCREPANCY/ ISSUE RESOLUTION REPORT Fl.OW TN-85*% Page 24 of "J2 4
, . . - - - , , - . . . - , , . _ , - - - . , - . , . _ , . , . . . . , . _ , _ - _ . - . ~ . . _ . . .
G IDENTirYKVALUATE CORRECTIVE ACTION PLAN b DATA ENTRY $ -
1 r EVALUATE CORRECTfvE ACTION IMPLEMENTATION ORRECTIVE ACTI ACMPTABLE
?
YES S V CLO$E Dt$CREPANCY A$ CErlCENCY,
, O UNCLA$$1FIED DEVIATION OR PROCRAM-MATIC DEFICIENCY (WITH CORRECTIVE ACTION EVALUATION) IN REVISED OfSC. COORD.
DATA ENTRY DOCUMENT IN OflC. i RESULT $ REPOR7 COORD.
IS$UE/DEFICfENCY CLO$CD FIGURE 3 (Continued)
CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW TN-85 4262/2 Poge 25 of 32
I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 3 The Document Date field will contoin either the dote of lasuance of the document or, if the document is a meeting transcript, the date that the meeting was held.
The number of Issue Records that are ottoched to the issue Record Cover Sheet shall be recorded in the apoce provided.
Upon completion of the issue Record Cover Sheet, the review and the Discipline i
Coordinator shall sign this cover sheet to indicate their reviews are complete.
i 5.3 OOC lasue Loo if the reviewer elects to use the QOC lssue Log, under the guidance of Section 4.1.2, the log con be used to either summarize the issue or refer to specific issue Records which describe the issue in greater detall.
if the OOC lssue Log is used, it shall be signed by the reviewer and the Discipline Coordinator.
I 5.4 lasue Reeord lasue Records are divided into 2 ports. Only Port I will be completed for open Isens. Both Ports I ond 2 will be completed for closed issues and may be used 1
for open issues.
A The maximum number of chorocters allowed for each field is Indicated on the I
lasue Record. Continuations beyond these maximum numbers of chorocters are occeptable. Continuotions will be mode ovalloble with DIRs by placing them in o notebook at each tracking system terminal. They are identified by DlR number, luue nome, and revision number (if Rev. I or obove). Continuotions will not be entered in the DAP trocking system.
O TN-85-4262/2 Page 26 of 32 i
i i
l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3
- ISSUES AND DISCREPANCIES I .
The Date Entered DAPTS and issue # fields shall not be completed by the Reviewer except when on E-XXXX DIR number is received from the PGl Coordinator for a new primary issue. Otherwise, these fields shall be completed of the time of dato entry into the DAPTS.
i 5.4.I Port i This port of the form will be completed for each luue identified during review of each source document.
A brief title for the issue will be entered in the issue Title field. The title should
, summarize the Issue description (e.g., what is wrong and what is offected) so j that those famillor with the review con identify the issue by its title. Keywords may be used in the title. Potential cause of the issue should not be used as a title.
A complete description of the issue will be documented in the issue Description
] field. Failures to meet speelfic project criterio and procedures should be i
identified to the extent they are specified by the source document. Any included I
information not taken directly from the document will be so identified.
i Comments including resolution status os noted by the source document may be ,
odded at the Description of Resolution / Comments field of Port 2 whether or not the issue status Is closed.
j The page number of the source document on which the issue is discussed along j with the external source lasue identifier number (if applienble) will be entered in .
the fields provided.
I 1
i j The structure (s), system (s), or component (s) of fected will be identified if it con !
I' TN-85 4262/2 Poge 27 of 32
COMANCtT, PE AK RESPONSE TE AM - DESIGN ADEQUACY PROCEDURE O Number: DAP.2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 3 be roodily determined from the source document. This identifiedtion may include eknponents, comporent types, system names, locations, or structures.
The CPRT document identifier number will be entered in the DOC. ID field.
The si#w of the issue (as determined under the DAP) will be entered in the stotus % (Open issues must have aa Action Plan number and revision assigned belowl II th'b hos been determined to be closed, the classificotton of the issue will be la% sed in the field provided.
The%decipline will be Identified. For disciplines comprised of subdiscipline ofNesign In DAP-7, Attochment A, the subdiscipline will also be docu.
WMlitional subdisciplines may be designated. -
O For oM& des, and for closed issues that are not classified as unsubstantiated, it is no.% the issue Record whether the issue:
- Is on isolated error or hos potential generle implicottons; J May have potential cumulative of fects with other issues:
88 la considered to be o technical or programmatic concern.
II hilon connot be reodily determined, the field will be left blank.
A% contains guidance on Interpretations of these terms.
FaWhw closed substantiated issues, the design organization and design M'be documented if that Information con be readily determined from h nt. The design orgonization is the organization originolly l
M8MIbr the work offected by the issue. The Design Activity field refers Maupirements discussed in ANSI N45.2.ll.1974 ond Attochment F of O = e e 28 '"
. l lV COMANCHE PEAK RESPONSE TEAM - DESIGN Revision: 3 ADEQUACY Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES For open issues, the number of the Action Plan (including ld. the revisi under which the issue will 3be investl ated shall be provided in the indica 5.4.2 Port 2 This port of the form will be completed (to the extent required based upon classification of the issue) for all Issues determined to be closed during d
review.
The basis for determining that on issue is closed will be documented in t Description of Resolution field. This field also documents any correc identified by the originating / investigating organization to resolve the any additional clarifying comments that the reviewer determines are to complete the issue Record.
V The Safety Significance field documents the safety algnificonce of the originating / investigating organization described safety significa external source document.
The Root Couse field documents the root cause of the issue if dete originating / Investigating organization, if any generic implicatio they should be included in this field.
5.4.'3 Sign-Off Upon completion of the issue Record to the extent possible, th The Discipline Coordinator alw signs to of the bottom of the issue Record. Signatures (not initials) are required on the indicate his review is complete.
issue Record (and DIR) forms os of April 1,1986. Initials of the Q Discipline Coordinator are acceptoble on issue Record and DIR April 1,1986 (in lieu of signatures) based on post revisions of Poge 29 of 32 TN.85-6262/2
N 91 AK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE MD2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES Ilsereponey/ issue Resolution Report (DIR)
M 6entoins information that is simillor to information centained on hs 4 but the DIR information is active rather than historical. Differences the DIR fields and the issue Record fields are described below.
% number of the DIR shall be Ir.dicated in the field provided. The will designated as Revision 0.
From field is used only fo'r discreponcles that are not explicitly defined
% source issues. This field will contain the Action Plan number (ISAP under which the discreponey was identified. For external source field will contain H/A"(not opplicable).
field will indicate the hetiono PI' n number under which the issue or is being investigated. For example, o discrepancy identified during Nion of a TRT ISAP may be assigned to o DAP DSAP If it is hfo evoluote the discrepancy os port of the DSAP.
~
t On field will contain o Ilst df issue or discreponey numbers which h prior to closure of the issue or discrepancy described on the i
block of each duplicate issue shall be marked "Open" and "Trans-
- ! Number) of the primary lasue. This shall be the next revision of b Issue DIR. An "Opena transferred to DlR will contain the primary followed by "(O)", e.g. E-XXXX(0), in the status block. A (berred to DIR will contain the primary d DlR A
XXXX(C),in the status block of the mochine printed DIR. Af ter o i is marked "tronsferred to," no further revisions should be mcde to
,, the primary issue is closed. At this time, all "tronsferred to" Poqe 30 d .u 9
--_-,_--..,,,.,_,,-n,,, _ . , . . , , .--..c., -- __
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE A
V Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 3 Issues associated with that primary issue will be reviewed by the discipline to ensure that each "tronsferred to" issue has been resolved, and then designated
" Closed" in a final revision of each " transferred to" DIR. Because the E-XXXX cross-reference to the primary issue is the trock to evaluation and resolution of the issue, only the status block is to be revised from "Open" to " Closed," that is, from E-XXXX(0) to E-XXXX(C). The " Transferred to:" E-XXXX remains on these DIRs. All other Information that DAP-2 requires to be documented in the trocking system is entered only on the primary issue DIR. The primary issue DIR does not need to list E-XXXX DIRs that were transferred to it.
If, during implementation of on Art'on Plon, it is determined that the issue / discrepancy should be reassigned to the GOC Program for resolution, the issue /discreponcy will be designated as closed in the status field. The Descrip-tion of Resolution field will document that the issue /discrepency was reassigned to OOC, and the Reference field will reference the memo documenting that
\ reassignment.
If on issue is determined to be unsubstantiated, the issue will be assigned a status of closed, classificotton will be marked unsubstantiated and the basis for the determination will be documented in the Description of Resolution field.
If on issue meets the requirements of on unclassified deviation, the DIR must include o specific reference to the procedure, document, plan, etc., that encompasses all aspects of the discreponey. This reference must be on the DIR form prior to opproval as on unclassified deviation by the Review Team Leader.
I The Design Discipline and Subdiscipline, Type, Trend (if identifled), Design Organization, and Design Activity fields shall be entered during the course cf evoluoting and revising DIRs classified as on observation, deviation, deficiency, programmatic deficiency, or unclassified deviation. Attochment E contains guidance on interpretation of entries in the Type and Trend blocks. Attoch.
ment F contains guidance on use and Interpretation of the Design Activity blocks.
TN-85-(>262/2 Page 31 of 32
1 -
COMANCPE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP.2
Title:
DOCUMENTATION AND TRACKING OF Revision: 3 ISSUES AND DISCREPANCIES If the DIR resulted from implementation of a Discipline Specific Action Plan (DSAP), offected Homogeneous Design Activity number (s) and the Review Topic number shell be entered.
Tne Sofety Significance fleid will be completed only for deviations, deficiencies, and proyammatic deficiencies. The Safety Significance Evoluotion will be conducted in accordance with DAP 22. Tne Root Couse/ Generic Implications lg field wlN be completed for unclassified deviations, deficiencies, and j progronenstic deficiencies. This infermotion is not required on the DlR fnot initlollyslessifies the discreponey, but con be developed during evoluotion of the issue endsevision to the DIR.
l Prior tosInsure of any DIR (other than " Transferred to:" DIRs), oli entries on the l DlR thatse required by this procedure for the final classification of the DlR
{ shall besampleted (e.g., safety significance must be filled in for a deviation
! prior toAlesing the DIR).-
l
{ As of Aell I,1986, signatures (not initials) are required as speelfied in DAP-2 l for the wious classifications of discreponcles. Iniflots on IR/DIRs prior to April I, ik are occeptable (in lieu of signatures) based on post revisions of tnis proced4er l
The Saber Review Team may review ony DlR and identify the need for clorificaliss expansion of review or reassessment by DAP personnel, l,
I
)
f f
'O TN-85 424. Page 32 of 32 1
ATTACHENT A f
COMANCE PEAK DESIGN ADEQUACY PROGRAM Source Document
Title:
Originating / Investigating Organization:
Document ID:
Description:
~W Addressee Organization:
Document Date:
No. of issue Records Attoched:
, Signatures
)O 4 Reviewer Date Discipline Coordinator Date i
FORM DAP.21 l
I .
l l
I 1 i l
l a
l !
l l TN 05-6262/2 A.
i . _- , _,. - __ . . _ . - - . _ _ . . . . . _
l
. ATTACHMENT B COMANCtf PEAK DESIGN ADEQUACY PROGRAM CONSTRUCTK)N/QA/QC ISSWS LOG Brief issue Description identifier # Page #
O Signaturest Reviewer Octe Discipline Coordinotor Date romM DAP * ? sq l
ATTACHAENT C l l
CON DESIGN ADEQUACY PROGRAM Data Ent: rcd DAPTS:
ISSLE RECORD IN' #:
PARTl lasue
Title:
um Description ofDet um identifier # tie Poge #: . Doc. ID ,,,
. Structure (s), Syssn(s) or Component (s) Affected:
1 tem Stotus: Clou (Closed lasues Only): , , ,
, ,p,n ,c ,,,,
c Devietlen D Unmestantieted Discipline: ge gg Type: 1. a cenwie
- 2. O Cumulative o heisted O Net Cwmletive I
am * " I"' " '"
Subdiscipline uni Design Organizother crn Design Activity o Pro c o m m e. o intefece centres o chose Centrei o bout D veificetten O corr. Action D Presses O Deewnent Centrol O Audits D Investigate Fudher Through Action Plan #: tie Rev.
PART2 Description of ResMion/ Comments:
um Safety Significonce:
nw Root Couse:
1 N)
Signatures: ,.
Date Discipline Coordinator Date
) Reviewer
! FORM DAe.2 3 g,g
ATTACHMENT D DESIGN ADEQUACY PROGRAM Data Entsr:d DAPTS:
/ ISSUE RERUTION REPORT lasue/ Discrepancy #: -
Rev. #: -
- *
- Titie O
- Description og gh/Discroponey "
esac AP # Fg_ To: '< Dependent On:
Wem(s) or Component (s) Affected:
g,m - -
mn O cesse , Class: a osseropency a unese Devimien em a cheerveien a oeficioney
. __ O Progrevnetic Defielency 0 Devletlen O thoutstantiated j o C/s Type: 1. o ceneric o isoleted C D Gen. Ingl. ,,
' 2. O Cumuletlw 0 Not Cumuletive O Other: -
- 3. O Technical O Progrenmotie Ise Trend: 1. O Adverse D Nonedverse on HDA r= as Program Reg. O interfece Centrol D Che j hout O Verificetten O Cerr.ge Centrol Action g g ysyne , gg Process O Deewment Centrol O Audits tion (incl. Corrective Action) 882n I
y m_
M
%h
) Wimplications:
y-. am w
Discipline Coordinato TRT/DAP Monoger Review Team Leoder
',. Date Date Date
__ _;3re40:'
029 h- Date
, FORIA -
D-l
)
O ATTACHMENT E l
l INTERPRETATION OF DAP TRAClONG SYSTEM
" TYPE" BLOCKS Type: Generic or Isolated Cumulative or Not Cumulative Technical or Programmatic Trend - Adverse or Nonodverse All four of these choices should be interpreted within the confines of the 4
discipline. Clorification of terms follows:
i o Generic means that the discreponey applies or ,
i
' potentially opplies to other ospects of design within the discipline related to the DIR. For example, use of SRSS in combining dead weight and seismic loods is generic to the piping / pipe support discipline since this error appears to have occurred extensively (if not throughout) that discipline. Marking " Generic" in this example does not imply that the some error occurred outside the discipline Indicated in the DIR.
If the some error is found in other disciplines, whether it is generic to these other disciplines is determined on o discipline-bydiscipline basis.
l o isolated should be checked if the discreponey described in the DIR oppears to be on error whose chorocteristics make it unlikely to have spread to other ospects of design within the discipline. For ,
example, technical aspects of on error in a calculo- '
. tion of post-LOCA hydrogen generation would be j isolated by the narrow scope of this ospect of
! design, if a programmatic ospect of this error could opply inputs)to other in the octivitiesthis discipline, (such as control ospect progrcmmotic of design would be described in another DIR, and program.
I motic and generic blocks would be checked.
o Cumulative should be checked if the discreponey described in the DIR is believed to impoet the design in combination with other identified discre-poncles. For example, small unconservatisms may usually be neglected in design. If it were confirmed i
l O that most of the conduit supports are designed to maximum capacity, the cumulative effect of many l
l
_ _ .~.__ _ .- _ _ _
1 N-85-6262/2 E-l -- _
O: unconservatisms may be significant. All DIRs con-sidered to have o cumulative effect on the design should be checked cumulative.
< o Not Cumulative should be checked if the discre-poney described in the DlR is by its nature not likely 1
to impoet the design if considered in combination with other discreponcles. For example, if on error in o calculation hos no significant impoet on a design output, then this error connot have o cumulo-tive effect with any other discrepancy, and it should be marked not cumulative.
o Technical should be checked if the discrepancy described la the DIR relates to o technical concern.
l For example, DIR D-0019 states that "TUCCO Cole.
SRB-109C, SET 3, Rev. 6 contains o modeling error and two unjustified assumptions that are important to the results." This DIR is correctly described as
- technicol.
o Programmatic"should be checked if the discrepancy i
described in the DIR relates to o design process or design control process (e.g., program, process, procedure, work octivity, methodology, or similar programmatic ospect of design). For example, if j during review of a technical discreponey, It becomes apparent that o procedure for controlling the design work associated with the technical discroponey was inodequate, incomplete, not implemented, or non-existent (if a procedure was required or committed to), then this new discreponey should be documented in a new D-XXXX DlR ond marked programmatic.
Similar to the obove interpretation of the term Wric", o progrommotic discroponey should be interpreted within the confines of the disciallne in which it was found. This does not mean twt the ,
discreponey is programmatic to other disciplines i olthough it may be. If a discipline coordinator believes that the discreponey could likely offeet i other disciplines, than DAP-7 requires that the discipline coordinator identify the discreponey to the Progrommotic/ Generic Implications Coordinotor and other potentially offected discipline coordi.
notors. Checking the programmatic block olerts the PCI coordinator to the possibility of effects on other disciplines. Similar or related programmatic discreponcles will be identified or confirmed through trend evoluotions of discreponcles ocross :
disciplines.
TN-85-4262/2 E-2 _ . __ --
O. o Trend - Adverse should be checked if the DIR is the result of a trend evoluotion of design discrepon-cies and has been determined to constitute on odverse trend. A trend is considered to be adverse if it is determined that the identified pattern or commonolity is likely to have resulted in the occur-rence of on undetected safety-significant deficiency in the offected design area.
o Trend - Nonodverse should be checked if the DIR is the result of a trend evoluotion of design discre-paneles and hos been determined to consistute o trend, but the trend is not adverse (not likely to have resulted in the occurrence of on undetected safety-significant deficiengein the oreo offected).
o O
4
!O TN-85-6262/2 E-3
O ATTACHMENT F
~
USE ADO ltfTERPRETATION OF DESIGN ACTNITY The DIR form contains nine design activities (DESACT) that are brood categories of various aspects of design. These design activities are based on ANSI N.45.2.ll-1974. They are used in initial trending of discrepancies, and they are contained in Attachment A, Excmple Attributes Matrix, of DAP-7 as Level 11 ottributes.
The design activities that are associated with the discreponcy should be checked when the DIR is written, or when the DESACT is identified and the DlR is revised in the course of evoluoting the discreponey. If the discreponey relates to more than one DESACT, multiple DESACTs may be checked. The DAPTS trocking system is configured to capture combinations of DESACTs if more than one opplies.
DESACT is a key ottribute used in trending and generic implications evoluotions.
In trending, for example, counts of the DIRs that show each DESACT and combinations of DESACTs are used to determine the distribution of DIRs among DESACTs. When DESACTs are combined with other attributes, such as cuts by discipline, subdiscipline, design chization, type, and classification, the result. .
Ing distributions of numbers of DIRs in these combinations (subsets) con be identified, displayed, and analyzed. If these distributions are skewed so that some combinations have large numbers of discreponcies, then this pottern is indicative of a potential trend.
The next step in trending is to expand to Level 111 the attributes of those DIRs in the subsets that exhibit potential trends. This is done to locate and understond the porticular ospects of a potential trend, such as the kinds of problems related to design inputs. The process of subdividing further the subsets of DIRs enables ,
us to focus on specific problems with knowledge of where they occurred. With this information, we con Identify and chorocterize trends os to where they apply, how widespread is the problem, what orgonization ond discipline were involved,
_ m 2f2 o mi- --
and whether the DIRs that constitute the trend were observations, deviations, or deficiencies.
The end result of trend identification is o concise description of a problem. This description could have been originated based on judgment of DAP personnel and confirmed by analyzi1 the data. Alternatively, the description may have been originated as a result of analyzing the data. Problem description precedes decisions os to whether the trend is adverse and, if so, that a programmatic deficiency exists. Problem description also precedes determining why it occurred (root cause or cousal factors), ond whether it offects other oreos of
- design not yet identified (generic implications).
Interpretations of design octivity attributes follow. These interpretations supplement descriptions found in ANSI N45.2.11-1974:
o Program Requirements - Specifies organizational struc-ture, outhority, responsibility, interfaces, monogement, '
O requirements related to the other design octivities listed below, md procedures that implement the design process or design control process. For example, discrepancies that reveal inodequate progrorns because of deficient requirements for these programs would exhibit this ottri-bute.
I o input Requirements - Speelfies requirements to ensure that design inputs (those criterio, porometers, bases, or other design requirements, including regulatory require-ments, codes and standards, upon which detailed final design is based) are identified, documented, reviewed, approved, and controlled. Levellli of Attochment A to DAP-7 contains a listing of kinds design inputs that may apply. This list is not all inclusive, and not all items need apply to every situation in which design inputs are required. For example, design inputs regarding maximum operating temperatures for a safety-related cooling water system were specified of certain values, but other higher values were apparently used as inputs in some design work on this system. One aspect of this discrepancy is control of design inputs (or changes in these inputs) that were reflected in the final design.
o Design Process - Specifies the use of procedures suffi-cient to ossure that applicable design inputs are correctly translated into specifications, drowings, procedures, or O instructions, and to ensure that oppropriate quality ston-
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s dords and changes thereto are identified, documented, reviewed, opproved, and controlled. In a brood sense, oil design octivities may be considered part of the design process. For the purpose of marking design process os on offected DESACT on a DIR, however, o ncrrower Inter-pretation should be used. That is, design process relates i to controls Gob specifications, work instructions, planning i'
sheets, procedure manuals, test procedures, or any other '
type of written form) opplied to analyses, calculations, and other direct work octivities used to produce design output drawings, specifications, or other documents.
o Interfoce Control - Specifies requirements for external and internal interfaces. These interfaces are relation-ships between companies (external) and design groups or organizations within a company. Requirements relate to identifying interfaces in writing, defining, and document-ing responsibilities, establishing lines of communication, controlling the flow of design information, and document-ing design information (including changes) transmitted in drawings specifications, or other controlled documents.
For exam,ple, DIR D-0016 describes o failure of interface control in that Gibbs & Hill used a Westinghouse specifi-cation to design reactor vessel / biological shield wall gap cooling, whereos the reflective insulation fabricator (sub-O' contractor to Westinghouse) deviated from this specifico-tion by designing a support ring outside the boundary of the insulation. Gibbs & Hill either did not recognize that this change had occurred or was never informed. Another example is the DIR D-0008 in that uncontrolled memo-ronda were used os design inputs.
o Verification - The process of reviewing, confirming, or substantiating the design by one or more methods to provide assurance that the design meets the specified design inpuis. Verification methods include design review, alternate calculations, and qualification testing.
Attachment A to DAP-7 includes 15 ospects of design reviews that are based on ANSI N45.2.ll-IP74. The extent of design verification required is o function of importance to safety, complexity, degree of stondordiza-tion, state-of-the-ort, and similarity with previously proven designs. For example, errors in calculations or design outputs should have been identified as a result of design verification to the extent that verification was required.
o Document Control - Specifies requirements for proce-dures to control issvonce of design documents and changes thereto. Document control requirements relate to prepo-ration, approval, Issuonce, and revisions of design docu-ments. Procedures cover responsibilities for preparing, reviewing, approving, inuing, and revising documents, TN-85-6262/2 F-3
t O identifying documents, coordinating, and controlling interface documents, ascertaining that pro >er documents are used, and establishing distribution ,ists that are updated and current. For example, use of a superseded document (D-0002) or uncontrolled drawings (D-0010 flooding drawings) are related to failure to meet docu-d ment control requirements.
Document control should be checked if DIRs are written for discreponcies in licensing documents, such as the FSAR or revisions or updates te the FSAR, that are noted during a review. In such cases, the DIR description should Identify the licensing document and the discrepancy in it that was found.
o Change Control - Specifies requirements for controlling changes to approved design documents to assure that impoets of changes are carefully considered, required octions are documented, and change information is trans-mitted to all offected persons and organizations. Changes shall be justified and subjected to design control measures commensurate with those applied to the original design.
Reasons for changes and review of changes listed in Attochment A of DAP-7 ore valuable os attributes because they may indicate o pottern of why changes occurred (e.g., unsatisfactory test results, Interference, disposition of nonconformances, failure to meet func-tional requirements, etc.). For example, DIR D-0053 describes changes in piping insulation thickness, whose odditional weight was not occounted for in piping onalysis. '
o Corrective Action - Specifies requirements for .proce-dures for reporting deficiencies and determining corree-tive action of specific errors. in oddition, for sig11ficant or recurring deficiencies, determining the cause and insti-tuting changes in the design process or quality assurance progrom to prevent recurrence of similar types of defi-ciencies is also required. Attachment A of DAP-7 lists examples of objects of corrective action (e.g., design octivities, procedures, personnel, training, and monoge-ment). For example, if on error had been detected in the post and corrective oction was taken, but the some type of error continued to recur, then corrective action would be checked as on attribute on the DIR.
o Audits - Specifies requirements to plan, conduct, and document oudits to verify comptionce with all aspects of the QA program for design. If a discreponey relates to failure to conduct oudits, inodequocy of oudits, or failure to follow-up on correcting findings resulting from audits, O then this DESACT should be checked on the DIR.
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