ML20202J179
| ML20202J179 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/05/1986 |
| From: | Blackwood E TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20202J051 | List:
|
| References | |
| DAP-7, NUDOCS 8607170037 | |
| Download: ML20202J179 (70) | |
Text
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C's V TITLE TRENDING AND EERIC IMPLICATIONS EVALUATIONS NUMBER DAP-7 l
Revision Prepared Date Reviewed Date Approved Date o %Y":Ad th/n
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8607170037 e60711 PDR ADOCK 05000445 A PDR .
O i TN-85-6262/7
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V TABLE OF CONTENTS Section Pm C ov e r S hee t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i Tcb l e o f Con t en t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.0 PURPOSE................................................... 1 2.0 SCOPE..................................................... I 3.0 DEFINITIONS AND RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . I 4.0 I NS T R U CY l O N . .^ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 S.0 DO CU ME NT ATI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
- ATTACHMENTS A ATTRIBUTES INDEX ........................................ A-1 B EXAMPLE USE OF ENGINEERING EVALUATIONS IN GENERIC IMPLICATIONS EVALUATIONS ................... B-l C EXAMPLE LIST OF POTENTIAL ROOT CAUSES ................ C-1 D EXAMPLE QUESTIONS FOR EVALUATION OF P OTE NTI AL ROOT CA USES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-l I
i l
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COMANCFE PEAK RESPONSE TEAM - DESIGN ADEQUACY' PROCEDURE p, Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 IMPLICATIONS EVALUATIONS l
1.0 PURPOSE This procedure establishes acceptable methods for performing two separate types of evaluations. They are: (1) identifying trends in DAP findings and External Source issues (including resolved External Source issues), and evoluoting whether these trends are adverse, and (2) evaluating the generic implications of deficiencies, unclassified deviations, and identified adverse trends. The use of these methods or equivalent techniques will provide reosonable assurance ihot trends or generic implications have been identified and evoluoted.
. 2.0 SCOPE 3
This procedure applies to DAP technical disciplines oad the programmotic/
l generic implications discipline in trending and generic implications (including root cause) evaluations of External Source issues and discrepancies identified during the DAP review of the design of CPSES. Equivalent techniques may be used if they cre consistent with the requirements of Appendix E to the CPRT Program Plan. This procedure encompasses evoluotions of identified adverse trends, unclassified deviations, and deficiencies. This procedure does not encompass the overall program evoluotion of the quality of the design of CPSES (see DAP-9). Attachment I is on executive level summary of trending and 9eneric implications evaluations and their relationships with other DAP octivi-ties.
3.0 DEFINITIONS AND RESPONSIBILITIES l 3.1 Definitions v
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.-_ _ = _ _ _~ _ . _ . ._.
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 f]N
\ IMPLICATIONS EVALUATIONS 3.1.1 Trend As quoted from Appendix E of the CPRT Program Plon, "(o) trend is a set of related discrepancies (observations and/or deviations) having attributes that reflect a discernable commonality. Examples of possible commonolities include:
.o The individual, group of individuals, or organization performing the safety-related activity o The progrom requirements, procedures, or controls -
governing the performance of the safety-related activity.
In this procedure, a multidisciplinary trend is one that offects more than one i
discipline. This use of the term "multidisciplinary" is not limited to the l
k multidisciplinary review activities in the DSAPs that deal with equipment qualification, FMEA, flooding, fire protection, etc.
3.1.2 Adverse Trend i
j .
A trend is considered to be adverse if it is determined that the identified pattern or commonolity is likely to have resulted in the occurrence of an undetected safety-significant deficiency in the offected area of design. With respect to design, on adverse trend is programmatic in nature and is classified as o programmatic deficiency.
3.l.3 Programmatic Deficiency A set of related design discrepancies that have been determined to constitute on adverse trend that is prcgrammatic in nature. An odverse trend is referred to os a programmatic deficiency. Programmatic deficiencies (like design deficiencies) are subject to evaluations of safety-significance, root cause, generic implico-
)
tions, and adequacy of corrective action.
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l COMANCIE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE m
Title:
TRENDING AND GENERIC Revision: 0
') Number: DAP-7
=
IMPLICATIONS EVALUATIONS 3.1.4 Unclassified Deviation A deviation or set of deviations for which it has been determined that it is more practical to proceed directly to analyzing root cause and generic implications and specifying of corrective actions. A safety-significance evoluotion will not be done for unclassified deviations because it would serve no useful purpose.
Unclostified deviations are those related to areas in which total reverification or redesign is being conducted. Unclassified deviations will be trocked as deficien-cies in that root cause and generic imp'ications evaluations will be done and corrective action will be evaluated. In areas where 100% verification is being performed, the assessment of root cause and generic implications is only for the purpose of identifying potential problems in other design oreos.
3.1.5 Trend Evaluation A process of developing and reviewing information (e.g., attributes) re!ated to issues, discrepancies, observations, deviations, unclassified deviations, or defi-ciencies that is intended to identify any trend and to determine whether it <
constitutes on oJverse trend.
3.1.6 Attributes A set of characteristics that describes on issue, discreponey, observation, deviation, unclassified deviation, or deficiency and con be used to identify a trend.
3.l.7 Attributes Matrix A matrix that contains all or a subset of records (Discrepancy / Issue Resolution (DIR) Reports) in the DAP tracking system (deficiency, deviation, unclassified deviation, observation, discrepancy, issue, or combination of these) and selected, L
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COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE f^, Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0
\g IMPLICATIONS EVALUATIONS relevant attributes that opply to each of the records included. Matrices with different sets of attributes may be used depending on the nature of the evoluotions to be performed.
3.1.8 Common Attributes A collection of attributes that is found by evoluotion to be common chorocter-istics of a set of issues, discrepancies, observations, deviations, unclassified deviations, or deficiencies. A common attribute exists when there are multiple DIRs that exhibit a particular attribute. A set of common attributes that relate .
to several items is on indication of a trend or pattern that worronts further
. evoluotion, j 3.1.9 Generic Implication A reasonable likelihood that on issue or discrepancy (DIR) offects some aspect of design other than the specific instance in which the finding was identified.
3.1.10 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 causal factors, and o Determine limiting boundaries of applicability of the deficiency under review.
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COMANCK PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 Q IMPLICATIONS EVALUATIONS 3.1.11 Root Cause The cause or cousal 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 judgment subject to confirmation. Root causes and cousal factors and the extent of their opplicability in design are based on objective evidence.
They are confirmed and bounded by the findings of evoluotions (what does exist) rather than by general statements of what could exist.
3.1.12 Safety Significance As quoted from Appendix E of the CPRT Program Plon:
l "Sofety-significant," for purposes of the CPRT Program, j is defined to mean that the identified discrepancy, if l uncorrected, would result in the loss of copobility of the offected system, structure or component to perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redundancy of the l comporwnt, system, train or structure level.
l 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 10 CFR 50, Appendix A (introduction, " Single Foilure");
10 CFR 50.55(e)(l).) Identification of a deficiency as "sofety-significant" for purposes of the CPRT Program, therefore, is not equivalent to o statement that, in fact, the deficiency, if uncorrected, would have resulted in unsafe operation.
3.2 Responsibilities Responsibilities specific to this procedure are os follows:
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COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 IMPLICATIONS EVALUATIONS 3.2.1 Generic implications Coordinator o Establishes a program and methodology for (1) discipline-specific trend evoluotions of observations, deviations, unclassified deviations, or deficiencies (including External Source issues) that apply to a single DAP discipline, and (2) multidisciplinary trend evoluotions.
o Establishes a program and methodology for discipline-specific and multidisciplinary generic implications evoluotions of programmatic deficiencies, unclassified deviations, and design deficiencies. This includes investigation of root causes and limiting boundaries of applicability.
~ ~
~
o Reviews or manages reviews of results of trend and generic implications evoluotions for consistency and potential effects in other disciplines.
o Manages the generic implications evoluotion program and maintains DAP-7.
o Participates in determination of root cause of multidisciplinary programmatic deficiencies, unclassified deviations, and design deficiencies.
o Coordinates applicable programmatic considerations with the OA/QC Review Team through proper interfaces. ,
o Maintains auditable files and documentation for multidiscipline trending and generic implications evoluotions.
o Forwards evoluotion results to the Design Adequacy Program Monoger and Design Adequacy Program Review Team Leader for review, concurrence, or opproval as appropriate.
o Provides apparent cross-discipline concerns to other disciplines os applicable based upon review of discipline-specific evoluotions.
O O
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COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE D Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 0 3.2.2 Discipline Coordinators o Conduct or direct trend evoluotions and generic implications evoluotions within their discipline to assess whether trends exist, whether trends are adverse, whether generic implications exist and whether the bounds and root causes of generic implications appear to be localized within the disci-pline. Identify those implications which may be cross-discipline in nature to the Generic Implico-tions Coordinator and other potentially offected Discipline Coordinators.
Participate in the determination of root causes of o
programmatic design deficiencies within the disci-pline.
o Modify or create new action plans as necessary to y oddress generic implications identified by generic implications evoluotions.
o Maintain auditable files and documentation for discipline-specific trend and generic implications evoluotions.
o Review and concur in evoluotions done within their discipline.
o Forward results of trend and generic implications evoluotions done within the discipline to the Generic Implications Coordinator for review and to the DAP Manager and DAP Review Team Leader for review, concurrence, or opproval as appropriate.
3.2.3 Discipline Leaders / Reviewers o Perform, coordinate, and document trend evoluo-tions and generic implications evoluotions as assigned.
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COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
- p. Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 0 J
3.2.4 Design Adequacy Program Monoger o Approves work assignments for portions of generic implications evaluations that appear to offect more thon one discipline (including root-cause investiga-tions) to be done by the technical disciplines.
o Directs implementation of a generic implications evaluation of any special case described in Appendix E of the CPRT Program Plan.
o Participate in determination of root causes of DIRs that require root cause evaluation.
o Reviews and concurs in the results of trend evoluo-tions and generic implications evaluations. -
3.2.5 Design Adequacy Program Review Team Leader (RTL) o Participates in determination of root causes of DIRs that require root cause evaluation, o Approves the results of trend evoluotions and generic implications evaluations and submits results to the sat for review as required.
o Assist other non-QA/OC RTLs os requested in the condect of root cause and generic implications onalyses. -
4.0 INSTRUCTION These instructions provide requirements that shall be met in conducting trend evoluotions and generic implications evoluotions. Each of these types of evoluotions shall be conducted by a specific DAP discipline for concerns that apply to that discipline or by the Programmatic / Generic Implications (PGI) discipline for concerns that offect more than one discipline. Figure I shows the relationships of trend and generic implications evoluotions with discrepancy classification, safety significance evoluotion, corrective action evaluation, and closure. Attachment I is on overview ti.at summarizes these relationships and
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trending and generic implications evoluotions. This attachment is for TN-85-6262/7 Page 8 of 25 I
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T* "D" EXTERNAL DR , gjpg , DIR O
SELF. INITIATED SOW $ $ v IDENTFIED ' EVALUATION OAP.2 1
DUPLICATE IR/DIRs TRANSFERRED TO DAP.2 EVALUATION; ATTRIBUTES IDENTFIED DU.2/ ACTION PLA>6 4 4 t>627ANTIATED IR/DIRs ceKRVATION , ,
_ CLA55lFIED v -
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"*"0" EXPANSION TO SIC F CAN -
EVALUATION
" b III OAP.22 OAP 7 DFflCENCY ATTReUTES TREPO EVALUATION r D AP.7 1 P I ROOT CAUSE/EPERIO IMPLICAT'ON5
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. EVALUATION 5 l v DAP.7 UWTING SCMCARIES ROOT NONADWERE CORRECTIVE CAVE fnEm ACTION EVALUATION DAP.20 4
- CLO5URE 4 FIGURE I INTERRELATIONSHIP OF DAP ACTIVITIES AFO PROCEDURES DISCREPANCY CLASSIFICATION, SAFETY SIGNIFICANCE EVALUATION, TREPOING, EtERIC IMPLICATIONS, CORRECTIVE ACTION, AND CLOSURE DAP-7 REV.0 TN-85-6262/7 Page 9 of 24
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE 7 Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 (Q IMPLICATION 5 EVALUATIONS information only and should give those not directly involved in trending and generic implications sv.fficient understanding of these evoluotions to allow them !
to corry out interfacing activities without specific training in DAP-7. Figure 3 of DAP-2 is a more detailed chart that shows these activities in the context of the flow of Discreponey/ Issue Resolution (DIR) reports within the DAP.
4.1 Trend Evoluotions Each DAP technical discipline shall perform trend evoluotions described in this section on information and findings that are identified within the review
. octivities of that DAP discipline. The Discipline Coordinator shall determine _
when such evoluotions will be performed. Trend evoluotions of information and
, findings that may reasonably offect rr ce than one technical discipline shall be performed under the direction of the Programmatic / Generic Implications Coordinator, who shall determine when such evoluotions shall be performed.
Additionally, the Programmatic / Generic implications Coordinator may elect to initiate cost-discipline trending based on the recommendations of Discipline Coordinators who suspect a potential multi-disciplinary trend. The purpose of a trend evoluotion is to determine whether a trend exists and whether on identified trend is adverse. Attachment B provides step-by-step instructions for performing a trend evoluotion and documenting it on Attachment F (form DAP-7-1) in accordance with these instructions. Departures from this guide shall be justified and documented on form DAP-7-1 and approved by the Discipline Coordinator or Programmatic / Generic implications Coordinator, as appropriate. His signature on the form indicates his opproval of any such exceptions.
4.1.1 Input Information During the course of implementing the DAP within each discipline, design-related discrepancies may result from: (1) identification through the self-initiated DSAP reviews, (2) confirmation in evoluotions of open External Source O
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)
COMANCFE PEAK RESPONSE TE AM - DESIGN ADEQUACY PROCEDURE DAP-7
Title:
TRENDING AND GENERIC Revision: 0 h) Number: IMPLICATIONS EVALUATIONS v
Issues, or (3) classificatio., of External Source issues that had been closed by on )
external source. A Discreponey/ Issue Resolution report (DIR) per DAP-2 will be generated or revised to track these discrepancies. During reviews conducted within the discipline, the attributes of each discreponey shall be determined to the extent reasonable to describe relevant information such as what, where, when, why, who, and how regarding the discrepancy.
Information that indicates a possible multidisciplinary trend shall be referred to the PGl discipline. This information (1) could be contained in issue Records or DIRs, (2) could result from o discipline-specific trend evoluotion that identified
' ~
on adverse trend (programmatic deficiency) that could logically offect other disciplines, oi (3) could result from o discipline-specific generic implications evaluation that indicates that a problem is not limited to that discipline in that a problem could likely have resulted in safety-significant deficiencies in other N disciplines.
]
4.1.2 Trend Attributes The attributes for identifying and evaluating trends are:
o Design discipline o Design organization o Design activities o Design attributes (within design activities) o System, structure, or component o Classification, status and type of issue o Potential safety significance (if identified) o Root cause (if identified) i o Potential generic implication (if identified)
[ o Nature of the problem o Review topic (group of HDAs)
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COMANCif PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE ,
l Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 l lMPLICATIONS EVALUATIONS I
i o Homogeneous design activity (HDA).
Within these attributes, odditiono! tiers of entries that could be relevant to each issue or DIR evoluoted have been developed. Second-tier entries in each attribute are Level 11 subattributes. Third-tier entries within each subattribute are colled Level lli information. The Generic Implications Coordinator shall develop and maintain a list of attributes, subottributes, and Level 111 information. The list shall be distributed by the Generic implications Coordinator to o controlled distribution list that includes the Review Team Leoder, the DAP Manager, and the Discipline Coordinators os a minimum. -
. Revised lists shall be distributed as necessary. Attachment A is on example list.
. In situations where expansion of attributes into subtiers is colled for in Attachment B, form DAP-7-2 (Attachment G) should be used to input Level 11 subottribute and Level 111 information into the data system.
4.1.3 Trend Recognition i
Reviewers shall conduct trend evoluotions using information in the generic implications dato system, which contains data on Issue Records and DIRs 9enerated in the DAP. Information in the DAP Tracking System and DAP files may also be used. Reviewers may identify trends manually or may use the dato system copobilities to display and analyze the data to identify relationships among the dato. Duplicate issue Records of the some observation (such as those that report the some issue in different parts of one External Source document or in different External Source documents) are not multiple observations and shall be counted as a single observation for trending purposes. These duplicates will 4
be transferred to primary issues per DAP-2, and the primary issues will be used in trend evoluotions. Duplicate issue Records and duplicate DIRs are not entered in the generic implications dato system. Unsubstantiated issues will not be used in trend evoluotions or generic implications evoluotions.
O V
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COMANCtf PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 IMPLICATIONS EVALUATIONS A trend shall be identified if a common set of attributes is found among multiple issues, observations, deviations, unclassified deviations, and deficiencies, and the distribution of DIRs exhibiting these attributes indicates a possible causal relationship. Due to the comprehensive scope of the DAP, it is expected that a trend that is programmatic will be indicated by several DIRs that exhibit the attributes of the trend. Although final trends will be based on DIRs with final classifications, trending may be done also on issues and discrepancies offer entry in the DAP trocking system but before final classification.
Reviewers may conduct more focused trend reviews to gain information -
concerning their discipline, review topic, HDA, etc. For example, o reviewer
. may wish trend information on one or more checklist attributes. In the event that such trend reviews are conducted, they are beyond the minimum scope of this procedure. Trend reviews, if performed, should be documented as part of an i oppropriate engineering evoluotion. If a trend is identified throug' a trend review, the determination of whether it is adverse should also be documented in the engineering evoluotion. DIRs shall be written for any identified trends and shall be processed in accordance with DAP-2.
Af ter a trend is identified, the trend shall be evoluoted to determine whether it is adverse and programmatic in nature offer consideration of the requirements of 4.1.4 or 4.1.5 as oppropriate.
4.I.4 Trends in Discrepancies Classified Only as Observations For trends found in discrepancies and External Source issues classified only as observations, expansion of the DAP scope of review should not be performed to determine whether similar observations could be found. In this cose, the reviewer should proceed directly to the trend evoluotion described in 4.l.6.
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I COMANCif PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE x Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 IMPLICATIONS EVALUATIONS 4.l.5 Trends in Discrepancies Classified as Observations and Deviations For trends found in discreponcies that include deviations, on investigation for the existence of similar deviations shall be performed. The following action shall be token within the oppropriate disciplines to determine whether similar deviations exist elsewhere.
o Decide how to determine whether similar deviations exist elsewhere. The method to make this determination may be to reuse on existing checklist or part of a checklist that is sufficient to detect a deviation if it exists in the arco being reviewed. -
o Determine from the project whether similar deviations had been identified in the post. This could have been documented in 50.55(e) or Port 21 reports to the NRC or in project internal reports such as TDDRs, ECNs, TDRs, p NCRs, etc.
- o Based on the chorocteristics of the deviation, determine whether ond, if so, where else the deviation could logi-colly exist.
o Decide what aspect of design activities should be examined in looking for other deviations that could be part of the some trend. This may be o review within the
. Homogeneous Design Activity (HDA) in which the devio-tion being evoluoted was found, within a related HDA or review topic, or within on unrelated HDA but in which a deviation in the some trend could logically exist. For example, if a trend involving interface control is found, the review shall be tailored to examine design activities across potentially offected interfaces.
l 4.1.6 Trend Evoluotion For o trend to be programmatic, multiple instances of ooservations or deviations must relate to o design process or design control process. This con include o process, procedure, proctice, work activity, methodology, or similar TN-85-6262/7 Page 14 of 25
COMANCIE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l
DAP-7 ~
Title:
TRENDING AND GENERIC Revision: 0 '
j N) Number: IMPLICATIONS EVALUATIONS i
programmatic aspect of design. This part of the trend evoluotion will determine whether the observations or deviations that make up the trend indicate o relationship to one or more processes. Due to the nature of the information used to detect trends, it is expected that trends identified will generally be program-matic.
For o trend to be adverse, it must be likely that undetected safety-significant deficiencies exist in the area (e.g., HDA, review topic, design activity) offected by the trend. The evoluotion of a trend for adversity shall be sufficient to determine whether undetected safety-significant deficiencies related to the -
trend are likely to exist. The details of this evoluotion and the scenario or conditions that cause the trend to be considered adverse shall be documented by the reviewer on form DAP-7-1 or its attachments.
j If the trend evoluotion indicates that the trend is adverse, a programmatic I
deficiency shall be written per DAP-2 and the review scope expanded when required by DAP-3. If the trend is not odverse, o DIR (closed observation) shall be written per DAP-2 to describe the trend and indicate that it is nonadverse, if the trend evoluotion indicates that the apparent trend identified in Section 4.1.3 does not octually exist, this result shall be documented on form DAP-7-l.
If the odverse trend is multidisciplinary, it shall be subject to a multidisciplinary generic implications evoluotion. If the adverse trend appears limited to o single discipline, the trend shall be subject to o discipline-specific generic implications evoluotion.
4.2 Generic Implications Evoluotion The purpose of a generic implications evoluotion is to evoluote the root cause or causal factors and generic implications (limiting boundaries of applicability) of O discrepor.cies that require o generic implications evoluotion. A discipline-TN-85-6262/7 Page 15 of 25 1
- l. .
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COMANCFE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
\ Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 j IMPLICATIONS EVALUATIONS i
specific generic implications evoluotion shall be performed for design deficien-cies, unclassified deviations, and programmatic deficiencies that appear to be limited to -a specific discipline, if more than one discipline oppears to be "
offected, a multidisciplinary generic implications evoluotion shall be performed for multidisciplinary aspects of the issue. Attachment C provides step-by-step instructions for performing a generic implications evoluotion and documenting it in the form of an engineering evoluotion. Departures from this guide shall be justified and documented in the evoluotion and opproved by the discipline coordinator (signified by his opproval signature on the engineering evoluotion cover sheet). For example, if root cause or limiting boundaries of applicability -
are obvious, there is no need to formulate and test hypotheses to find those onswers that are already known.
In design oreos such as piping / pipe supports and cable troy and conduit supports, redesign or total reverification programs are being performed to provide confidence that the final design and hardware configurations will be adequate.
Because of the comprehensive ncture of the corrective action, the focus of generic implications evoluotions in areas undergoing redesign or total reverifico-tion shall be to determine whether unclassified deviations that appear to have contributed to the overall need for hardware modifications have generic implico-tions outside these design areas. Accordingly, within these design creas, identification of root causes of unclassified deviations is only for the purpose of determining whether the some root causes exist outside these design oreos.
4.2.1 Preparation of Engineering Evoluotion An engineering evoluotion of generic implications of design deficiencies, unclassified deviations, and programmatic deficiencies shall be prepared in occordance with Attachment C. It shall include the following elements or justify those elements not included:
s TN-85-6262n Page 16 of 25
COMANCif PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i I
, Number: DAP-7
Title:
TRENDING AND GENERIC Revision: O l IMPLICATIONS EVALUATIONS i
o identification of relevant design attributes o Method of evoluotion for generic implications o Collection of information and objective evidence o investigation of root cause o Determination of the limiting boundaries of applicability.
These elements are addressed in separate sections below.
4.2.2 Identification of Relevant Design Attributes Attributes relevant to the programmatic deficiency, unclassified deviation, or
- design deficiency being evoluoted for generic implications shall be selected. The engineering evaluation shall document the basis for selection of relevant design attributes. Attachment A lists examples of three levels of design attributes
) from which relevant attributes may be selected; they are based in part on ANSI N45.I I. Other attributes not listed in Attachment A may also be used, 1
such as HDAs and review topics listed in the DSAPs. The level of detail of selected attributes may vary, depending on the nature of the evoluotion (e.g.,
Attachment A, LevelI, Level 11, and Level lli categories of attributes), but the level of detail shall be sufficient for purposes of evaluating generic implications, finding the limiting boundaries of generic implications, and investigating root cause or causal factors. Discipline-specific generic implications evaluations may i select other oppropriate attributes such as those contained in discipline-specific j checklists. These attributes shall be those whose evoluotion would be sufficient to confirm whether or not generic implications exist ond, if so, to identify their limiting boundaries and investigate their root causes or causal factors. These attributes should chorocterize to the extent reasonable the what, where, when, l
why, who, and how of the design deficiency, unclassified deviation, or program-l motic deficiency being evoluoted.
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TN-85-6262/7 Page 17 of 25
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
% Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0
) IMPLICATIONS EVALUATIONS 4.2.3 Method of Evaluation for Generic implications The method of evaluation shall include consideration of the following:
o Formulation of a hypothesis of one or more generic implications, root causes, and limiting boundcries of applicability o Type of information needed to test each hypothesis (e.g.,
which attributes need to be evaluated in which design activities, and what types of errors associated with these
, attributes will prove or disprove the hypothesis) _
o identification of techniques to be used to gather informa-tion (e.g., repeat part of a discipline-specific checklist, interview people, review project records, analyze other DAP findings or documentation in the discipline, etc.)
N o identification of sources of information to be reviewed to test each hypothesis (e.g., what records or system of records, what organization, group, person, HDA, or review topic) o if odditional design work needs to be reviewed, basis for selection of odditional reviews that will test the hypothe-sis i o Development of decision criteria to be used in proving or disproving the hypothesis o Justification that the hypothesis is odequate, and that the j method of analysis satisfies necessary and sufficient l conditions needed to prove or disprove the hypothesis o Development of the type and level of detail of documen-totion needed to support conclusions (generic implication and root cause) of the evoluotion (e.g., engineering evolu-otion, discipline-specific checklist completion record, DIR generation and revision, etc.).
TN-85-6262/7 Page 18 of 25
-. . __ _ __ . .~ ._ _
COMANCFE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
[ Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 Q IMPLICATIONS EVALUATIONS 4.2.4 Collection of Information and Objective Evidence The content and source of information needed to test a hypothesized generic implication, root cause, or boundary of applicability should be identified.
Techniques for collecting this information may include checklists, interview questions, written requests, record reviews, or other appropriate methods.
To the extent reasonable, the input information for the conclusions of the evaluation shall be objective evidence. The techniques used to gather informo-tion should guide DAP reviewers to this objective evidence. Therefore, informo- -
tion that does not constitute objective evidence shall not be used as a sole source of information to draw conclusions os to the validity and proof of a hypothesis.
This restriction is intended to preclude reliance on inputs of personal opinion,
[ y recollection, hearsay, or bias as a basis for DAP conclusions.
V 4.2.5 Investigation of Root Cause Investigation of root causes or causal factors of design deficiencies, unclassified deviations, or programmatic deficiencies shall be a systematic approach that is described in the engineering evaluation. A list of potential root causes or causal factors and a checklist of questions that may be appropriate are in Attachments D and E, respectively, of this procedure. If the root cause or causal factors are evident (or obvious) as a result of evaluations of programmatic deficiencies,
- unclassified deviations, or design deficiencies, the methods used to reach that conclusion shall be documented in the engineering evoluotion, and no additional investigation of root cause is needed.
The determination of root cause shall be accomplished by consensus of DAP mona3ement, including the Review Team Leader, DAP Manager, and appropriate Discipline Coordinators, discipline leaders and reviewers.
)
TN-85-6262/7 Page 19 of 25
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 IMPLICATIONS EVALUATIONS Instances may arise in which a root cause may not be identifiable or cannot be confirmed even though a set of DAP findings may exhibit similar errors. In this instance, the errors will be resolved in accordance with DSAPs and controlling DAP procedures; the investigation conducted to determine o root cause and the result that a root cause could not be confirmed shall be documented in the engineering evaluation.
4.2.6 Determination of Limiting Boundorles of Applicability The method of determining the limiting boundaries of applicability of a generic -
Implication shall be described in the engineering evoluotion. This determination should be based on reviews that address to o reasonable extent whether and, if so, where else in design the some design deficiency, unclassified deviation, or l programmatic deficiency did or may exist.
Boundaries may be established using techniques based on deductive and inductive !
logic. The first involves reviewing relevant aspects of design work to determine deductively whether the generic iriplication exists elsewhere. A conclusion that
- the generic implication does not exist elsewhere shall be based on the obsence of
. finding the generic implication in other potentially offected oreos or on exponding the review until the generic implication is no longer found. The ,
determination that limiting boundaries have been found shall be based on judgment that potentially affected creas have been investigated sufficiently to l identify the generic implication if it exists. The bases of this determination shall be substantiated by documcatotion in the engineering evoluotion.
The latter technique for establishing the boundary of applicability of a generic implication involves inductive logic. That is, based on the specific nature of the f generic implication, it may be reasonable to discord several or all other design activities or areas as potential locations of a generic implication. This is because these activities or areas are unrelated to the nature of the generic ;
C I TN-85-6262/7 Page 20 of 25
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE p Number: DAP-7
Title:
TRENDING AND GENERIC IMPLICATIONS EVALUATIONS Revision: 0 implication being evoluoted. The governing criterion for deciding that a generic implication is self-limiting to on identified area is that it is unlikely that the error could have resulted in the occurrence of a safety-significant deficiency ~
outside of the identified area. Either one or o combination of these techniques may be used.
4.2.7 Conduct or Revision of the Engineering Evoluotion The engineering evoluotion shall be conducted or revised in accordance with Attachment C. After completion of the evoluotion, revisions may become -
necessary; for example, to revise hypotheses, to reflect additional information or
. to modify evoluotion techniques. Such changes shall be documented in a revision to the engineering evoluotion subject to the instructions of Attachment C and DAP-8, as applicable.
4.3 Approval of Trend Evoluotions and Generic Implications Evoluotions 4.3.1 Trend Evoluotion After the trend evoluotion (form DAP-7-l) has been prepared and signed by the reviewer, the Discipline Coordinator and DAP Manager shall review and sign the form when they are satisfied with it. The Discipline Coordinator shall prepare or cause to be prepared oppropriate DIR forms in accordance with DAP-2.
Depending upon the results of the trend evoluotion, such DIRs may be required for:
o Conclusion that a trend is o programmatic deficiency; or o Conclusion that a trend is a nonadverse observation.
The Review Team Leader opproves trend evoluotions.
TN-85-6262/7 Page 21 of 25
COMANCFE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
' Number: DAP-7
Title:
TRENDING AND GENERIC Revision: 0 J IMPLICATIONS EVALUATIONS 1
Af ter concurrence and approval as required above, the evoluotion shall be assigned a control number in accordance with Section 5.3.
4.3.2 Engineering Evoluotions for Collective Trend Evoluotions After on engineering evoluotion that documents all trending done in a DAP discipline is prepared (and checked per DAP-8), it shall be reviewed and signed, . -
indicating concurrence, by the Discipline Coordinator and DAP Manager. These -
engineering evoluotions shall be opproved by the Review Team Leader. Engi- ,
neering evoluotions shall be assigned control numbers per DAP-8. -
4.3.3 Generic Implications Engineering Evoluotions s
c These evoluotions shall be reviewed, concurred in, opproved, and assigned control -
numbers os stated in Section 4.4.2. ,;
1
- \
- 5.0 DOCUMENTATION 5.1 Documentation of Trend Evoluotions and Generic Implications Evoluotions Trend evoluotions and generic implications evoluotions shall be documented in a manner that explains what was done, what were the results and conclusions, what are their bases, and who reviewed and opproved the evoluotion.
Eoch trend evoluotion shall be documented on a completed form DAP-7-1 and, os necessary, supporting attachments. Documentation shall include:
i
! o Form DAP-7-1 y 1 !
o The results of sorts / searches of attributes dato .that s l support the trend evoluotion conclusion ;
TN-85-6262/7 Page 22 of 25
COMANCtf PEAK RESPONSE TEAM - DESIGN ADEGUACY PROCEDURE 7
DAP-7
Title:
TRENDING AND GENERIC Revision: 0 w ) Number:
^
IMPLICATIONS EVALUATIONS A -
o DIR numbers of DIRs that are part of a trend if a trend is found o Form DAP-7-2 for additional attributes identified as o result of expansion of attributes to Level 111 or beyond information contained in the DAP Tracking System o The number of the DIR written if a trend is found o Any continuations of text from the blocks of information
- in form DAP-7-l.
. , Documentation of each generic implications evoluotion shall include use of the -
s forms, structure, and applicable parts of engineering evoluotions (DAP-8) that
,' are contained in Attachment C of this procedure. Supporting documentation, th t consists of information and objective evidence of whether generic implico-n tions exist and any discipline-specific checklists used in the evoluotion, shall be incorporated in or appended to engineering evoluotion documentation or refer-enced if this information is contained elsewhere in DAP files.
Documentation of oh trend evoluotions done collectively within each DAP discipline shall consist of one trending engineering evoluotion per discipline.
This evoluotion shall explain the process used for trend evoluotons, list trends found and the number of trend evoluotions done, and shall be sufficient to justify the conclusion with reasonable assurance that no adverse trends remain undetected in the scope of octivities reviewed by that discipline. Each individual trend evoluotion form DAP-7-1 completed by the discipline with attachments shall be attached to the trending engineering evoluotion. The requirements of DAP-8, including modifications and revisicns, shall opply to the trending engineering evoluotions.
5.2 Documentation of Trends and Generic implications
[ Adverse trends shall be documented as programmatic deficiencies in lq) - .
Discreponey/ Issue Resolution (DIR) reports, marked "odverse trend," trocked per Q,A TN-85-6262/7 Page 23 of 25
/*
1N COMANCif PE AK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE D) Number: DAP-7
Title:
TRENDING AND GENERIC (d IMPLICATIONS EVALUATIONS Revision: O n
DAP-2, and processed according to DAP procedures and requirements. Non-odverse trends shall be documented in DIR reports per DAP-2 as observations marked "nonodverse trend." Root causes and generic implications shall be documented in the oppropriate portions of Discreponey/ Issue Resolution reports per DAP-2 for the issues and discrepancies which require these portions to be filled in.
5.3 Iderc ' . cation After opproval has been obtained, the final trend evaluation shall be assigned a -
control identification number by the DAP Manager or his designated representa-tive as follows:
DAP-TE-XXX-YYY a
9 Sequential Number in the Discipline Discipline (per Attachment C of DAP-8)
This identification number, revision number, and date shall be entered into a Trend Evaluation Log (Attachment H (form DAP-7-3)) maintained by each Discipline Coordinator or designee.
Engineering evaluations shall,be identified per DAP-8.
5.4 Retention The original copy of all final evaluations shall be maintained and filed by the DAP Manager or his designated representative in accordance with DAP-14.
TN-85-6262/7 Page 24 of 25
4 D COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE DAP-7
Title:
TRENDING AND GENERIC Revision: 0 IMPLICATIONS EVALUATIONS C) Number:
5.5 Revisions Revisions to evoluotions may be required to modify evoluotion methods, add, clarify, or correct information.
Revisions shall be prepared, reviewed, and opproved in the some manner os the original evoluotion.
Superseded final evoluotions shall either be identified as such on each page or securely bound with at least the cover page so identified. The oppropriate Trend -
Evoluotion Log shall also note this occurrence. Superseded evoluotions shall be retained in the files for historical reference.
)
o O
TN-85-6262/7 Page 25 of 25
ATTACHMENT A EXANPLE ATTRIBUTES MATRIX LEVELI LEVEL ll LEVELlit 1.0 Design Discipline I.I Mechanical Systems and Components Analyses Fluid systems Facilities Piping Pump and valve operability Radiation protection 1.2 Electrical, instrumentation and Electric power equipment Control Electric power systems Electric cabling Electric equipment layout -
I&C equipment I&C control systems I&C instrument systems - NSSS -
l&C instrument systems - BOP I&C control room layout Equipment qualification Fire protection 1.3 Piping and Pipe Supports Piping analysis Support design Interface control I.4 Civil / Structural Cable trays / supports Conduits and supports Structural steel Concrete design HVAC supporis Seismic analysis Other supports Seismic Gap Structural TN-85-6262/7 A-l
i ATTACHENT A oi
} (continued) 1
~
j LEVELl LEVELll LEVEL lli
- i.0 Design Discipline 1.5 Programmatic / Generic Implications Multidisciplinary
! (continued) Discipline-specific l 1.6 Other l 1.7 All i
2.0 Design Organization 2.1 TUGCO (TUSI) 2.2 TUGCO Nuclear Engineering (TNE) l 2.3 CPPE 1
2.4 Gibbs & Hill i
l 2.5 Westinghouse (outside NSSS Scope of Supply) 2.6 ITT Grinnell l
! 2.10 Stone & Webster
! 2.1 I impell
- 2.12 Bahnson 2.13 DeLoval 2.14 KRANCO TN-85-6262/7 A-2
l C O O .
- ATTACHMENT A l (continued)
) LEVELI LEVEL 11 ' LEVEL 111 1
- 3.0 Design Activity 3.1 Design Program Requirements Organizational structure Responsibilites of organization Technical information exchanges i Document control
- Design document maintenance and retention l Monogement review 1 Training I Design inputs Document preparation
! Quality levels, acceptance stondords, records i Design verification Audits
! Corrective action Experience reports l Design changes 1
1 3.2 Design input Requirements Performance requirements (copocity, rating, a system output, others) l a
Codes, standards, and regulatory requirements i Design conditions (environmental, loadings, fluid chemistry, voltage, others)
Interface requirements Materio! requirements (including such items os
- compatibility, electrical insulation properties, coatings, and corrosion resistance) 1 Mechanical requirements
! Structural requirements 1
1 I TN-85-6262/7 A-3
1 l
q ATTACHMiNT A 1
(continued 1
4
{ LEVELI LEVELil LEVEL ill i 3.0 Design Activity 3.2 Design Input Requirements Hydraulic requirements j (continued) (continued)
Chemistry requirements (including provisions for I sampling) ,
?
1 Electrical requirements
- Layout / Arrangement requirements Operational requirements under various plant conditions Instrumentation and control requirements Accessibility, in-service inspection, and adminis-trative control requirements i
j Redundancy, diversity, and separation require-ments
- Failure effects requirements I
Test requirements l Fire protection or resistance requirements l
Processes, parts, and equipment suitable for oppli-cation j Safety requirements (including radiation hozords, i materials, escope provisions from enclosures, j grounding of electrical systems) l Handling, storage, and shipping requirements 1
i i
k i
l 4
t TN-85-6262/7 A-4 i .
C ( )
t . .
ATTACHMENT A (continued)
I I
LEVELI LEVEL ll LEVELlli
- 3.0 Design Activity 3.3 Design Process Translation of inputs
! (continued) Procedures
! Design analyses
! Calculations
- Design outputs (drawings, specifications, other) 3.4 Interface Control External (identification, responsibility, communication, documentation)
Internal (identification, responsibility, communication, documentation) i 3.5 Design Verification Selection and incorporation of inputs Description and reasonableness of assumptions Specification of quality and quality assurance
) requirements identification of codes, standards, and regulatory j requirements Consideration of construction / operating experience
- l Satisfaction of design interface requirements Design method oppropriateness Reasonobleness of output compared to input l Suitobility of specified por ts, equipment, and processes Materials compatiblity to other materials, use, and design environmental conditions i.
TN-85-6262/7 A-5
l -
- ATTACHMENT A i
I (continued l LEVELI LEVEL 11 LEVEL III *
! 3.0 Design Activity 3.5 Design Verification Provision for in-service inspection accessibility (continued) (continued) l Consideration of radiation exposure l
- Specification of testing requirements Specification of handling, storage, cleaning, and shipping requirements Specification of identification cnd records require-ments s 3.6 Document Control Preparation '
Approval
- Issuance I
- Revision l FSAR occuracy l 3.7 Design Change Control Test results unsatisfoetory l Interference
! Functional requirements not met j Disposition of nonconformance Requirement changes j Operational experience ;
l Design improvements ;
j Review of changes !
4 i
l I
l i i TN-85-6262/7 A-6
_ _ - - - .-- - - - . ._ -~ .- . _. - -- - - -- -
d .
ATTACHAENT A l (continued l
LEVELI LEVEL 11 LEVELll!
3.0 Design Activity 3.8 Corrective Action Program (continued) Inputs Process Interface Verification Document control
- Change control Procedures '
Personnel Training Management t .
! 3.9 Audits Personnel -
I internal External Control Schedule Results !
Follow-up ;
4.0 System, S tructure, See DAP Trocking System Component Affected Codes e
e i TN-85-6262/7 A-7 m - , w - . . - . . - ,
l ATTACHMENT A i
(continue 4 l
i LEVELI LEVEL 11 LEVEL.Ill i 5.0 Characteristics 5.1 Classification Discreponcy j of issue Observation Deviation 1 Deficiency l Unclassified deviation l Programmatie deficiency 1
- ! 5.2 Status Open
, Closed 4
{ 5.3 Type Generic j isolated i
Cumulative Not cumulative Technical
, Programmatic
- 6.0 Potential Safety 6.1 Reported or found by DAP Reported by External Source i Significance Found by DAP to
- be safety-significant Found by DAP not to be safety-significant 6.2 Intended Safety Function RCS pressure boundary i Containment integrity j Decay heat removal 1 Instrumentation 1 Control Mechonical/structual support Emergency power Isolation boundary .
] Accident prevention j Accident mitigation
- TN-85-6262/7 A-8 i
C U -
ATTACHMENT A (continued)
LEVELI LEVEL 11 LEVELlli 6.0 Potential Safety 6.3 Type of loss of capability Boundary failure Significance to perform intended safety Loss of electrical power / air / hydraulics (continued) function Monitor failure Control failure Delivery of cooling medium Component support failure Personnel protection Equipment protection Structural failure Analysis indetegminate to assure capability 7.0 Root Cause 7.1 Procedures Ambiguous Incorrect application incomplete Missed technical requirements Misunderstood regulatory requirements / comments Missed regulatory requirements inadequate review for requirements / commitments Out of date Nonexistent Contradictory procedures Conflicting technical requirements TN-85-6262/7 A-9 -
l -
l ATTACHAENT A
( -
l (contmued LEVELI LEVEL ll LEVELlli 7.0 Root Cause 7.2 Procedure implementation inconsistent i (continued) Error in judgment j Knowing violation -
Unknown violation l Inodequate review that requirements met j Simple mistake Procedure requirement not understood inadequate input information Wrong codes /stondords used Disregarded procedure Failed to get inputs
7.3 Communication
Failure within group Failure between groups inodequate between companies 4
7.4 Inspection / Audit Inodequate checklists 1
Inodequate training / qualification i
Inadequate surveillance of inspections I
Inodequate onolysis of findings
! Inodequate distribution of findings l Not done
- Excessive deferrol/bocklog j
i l
TN-35-6262/7 A-10 4
~
\ - .
l ATTACHMENT A (continued LEVELI LEVEL 11 LEVEL 111 l 7.0 Root Cause 7.5 Timeliness inadequate time allowed for task l (continued)
Insufficient engineering done l Inodequate to check changes against requirements /
l commitments 1
Untimely incorporation changes in requirements /
commitments a
Failure to incorporate changes in requirements /
, commitments
- Untimely audits / inspections
! Severe schedule pressure i
I 7.6 Documentation Failed to demonstrate compliance
! Inodequate access to information lifegible Missing l Incomplete j Misfiled l Inoccurate i 7.7 Training /Ooolification inadequate for tasks performed i (designers) Nonexistent Foil to retrain offer errors inadequate qualification stondords i
l 7.8 Transfer of Information Correct information used improperly incorrect information transferred i
Improper interface Nonexistent interface Information not transferred i
I
! TN-85-6262/7 A-1 i j
. w ATTACHMENT A J
(continued i
I l LEVELI LEVEL 11 - LEVELlli i
{ 7.0 Root Cause 7.9 Planned Management Risk l (continued) ..
7.10 Post-Inspection / Turnover Controls
] 7.11 Corrective Action Fail to recognize program breakdown
] Foil to identify root cause
] Fail to prevent recurrence
- Fail to trend
{ Foil to recognize recurrence -
j inodequate to correct problem i Not implemented l
! 7.I2 Monogement Attention Lock of goals / objectives l Lock of interest /indif ference ,.
l Inodequate for trends
- inadequate stoffing l Fail to supervise Inodequate analysis of findings Lock of performance / effectiveness measures Inodequate policy for performance of work Foil to implement policies Fail to ossess policies ,
No feedback on policies 3
- No action on feedback received i Planned / assumed risk
]
Oversight i 7.13 Random Error (root cause l
indeterminate) i t
TM-85-6262/7 A-12 i .-. _ - _ .__.
x -
ATTACHAENT A (cont'wwed LEVELI LEVEL!! LEVEL 111 8.0 Potential Generic 8.1 Reported or found by DAP Reported by External Source implication Found by DAP to have generic implications Found by DAP not to have generic implications 8.2 Scope Affects one discipline Af fects multiple disciplines 8.3 Indeterminate Results Analysis Quality of design -
Ooolity of systems, structures, of components (hardware) 8.4 Impact on Design Program inputs Process Interfoce Verification '
Document control Change controf Corrective action Audits 9.0 Nature of the 9.1 Personnel Error (list specific error)
Problem 9.2 Procedure Content Error 9.3 Procedure implementation Error 9.4 Monogement Control Error TN-85-6262/7 A-13
ATTACHMENT A (continueet LEVELI LEVEL II LEVELIft 9.0 Nature of the 9.5 OA/OC Error Problem (continued) 9.6 Design Program inadequacy 9.7 Violation of codes, standards, requirements, or commitments 9.8 Computer Code Inadequacy 9.9 Analytical Method inadequacy 9.10 ' interpretation Error 9.1i Assumption Error 9.I2 Calculation Error 9.13 Hardware Failure 10.0 Review Topic (List number of Review Topic)
(Group of HDAs offected)
I1.0 Affected HDA (List one or more offected HDA numbers)
TM-85-6262/7 A-14
ATTACHMENT B
(
TREPO EVALUATION
- l. PURPOSE To investigate whether o trend exists, to evaluate whether any trend found is adverse with respect to the design of CPSES, and to document the evaluation on form DAP-7-1 in occordance with this attachment.
ll. SCOPE Limited to identification and evaluation of any trend that may exist within a set of discrepancies or issues with attributes selected from one or more of the categories below:
- Design Discipline q Design Organization Design Activities Design Attributes (within Design Activities) i System, Structure, or Component Classification, Status, and Type
- Potential Safety Significance
- Root Cause
! Potential Generic implication
. Nature of Problem
^
Review Topic (Group of HDAs)
Homogeneous Design Activity (HDA)
Discrepancy Numbers (if oppropriate) l i
1 l
l I
l TN-85-6262/7 B-l
Ill. METHOD OF REVIEW - .
1.0 Trend identification 1.1 Select the attribute to be trended and attributes constrained in this . evaluation and list them on form DAP-7-l. Any number of attributes may be constrained depending on the breadth of the search. Attributes not constrained will cause all values (sub-attributes) of those attributes to be included in the resulting subset of DIRs.
l.2 Using information from the generic implications dato system (PGIDATA), DAP Tracking System, or DAP files, perform the following steps as needed to determine the distribution of attributes in the applicable subset of irs and DIRs.
1.3 Count the number of irs /DIRs that are in the subset of irs /DIRs, each of which exhibits all of the attributes con-strained.
j l.4 For the attribute to be trended (not constrained), determine the distribution of irs /DIRs within each value of this attribute.
l 1.5 Count the number of DIRs in each value of the attribute (or subattribute) within each distribution. Record these counts for each value of the unconstrained attribute, the IR/DIR numbers in the distribution, and the constrained attributes that opply to each distribution. This may be done by printing outputs (graphic and tabular) from PGIDATA.
i Note: If a programmatic problem exists, there should be several non-duplicate irs /DIRs that reveal the same attributes because of the comprehensiveness of the DAP Phase 3 scope. Although no absolute number of irs /DIRs con be defined as constituting a trend, the relative i
distribution of subottributes among irs /DIRs should reveal that some subottributes apply to o much greater fraction of DIRs than other subattributes. The higher TN-85-6262/7 B-2 .
count subattributes in these relative distributions indicate trends. Low-count subattributes in these relative distri- <
butions probably indicate an isolated error rather than a programmatic weakness; however, this assumption should be evaluated, confirmed, . and documented on form DAP-7-1 in the trend identification section.
P l.6 Review the descriptions of irs /DIRs with the higher count
~
subottributes in each distribution.
1.7 Determine whether a logical relationship exists among the DIRs with the higher count subattributes in each distribution.
l.8 If root causes have been reported or identified, compare root causes of DIRs with the higher count subattributes. '
l.9 Enter any additional information (Level 111) found in the text on PGIDATA Field Codes (form DAP-7-2) for the DIRs reviewed.
r These forms should be referred to reviewers (via the Discipline i
k Coordinator) who signed the DIRs to fill in the Levellli information for each DlR in the subset of higher count subattri-butes. Af ter preparation and approval by the Discipline Coordi-notor, keep the original with DAP-7-I and send a copy of form DAP-7-2 to the Generic Implications Coordinator in Bethesda.
Upon receipt, this information will be entered (in Bethesda) in, the generic implications data system containing the evaluation attributes, subattribute, and more detailed Level lil informa-tion, l.10 Fer the DIRs whose information was expanded to Level 111, determine the distribution and counts of DIRs that reflect the some Level ill information. Try to determine whether a corre-lotion and a causal relationship exist (i.e., discrepancies, etc.,
are similar enough to have the same potential cause, or l ottributes, subottributes, and Level 111 information indicate the same problem).
)
_ _TN-85_-6262/_7 _ _ _ _ _ _B-3__ _ _ _ _ _ _ _ _ _ _ _ __
A 1.11 Identify any dissimilarities among the DIRs in the subset trended that show by contradiction that the discrepancies are not related, and that a trend does not exist.
. l.12 Decide whether there are commonolities that indicate o trend.
1.13 Describe any trend found in a new DIR (to be completed offer trend evoluotion) per DAP-2. On form DAP-7-1, justify this determination, including the logical basis for the relationships
. omong the discrepancies that make up the trend. This descrip-tion, in conjunction with the attributes listed on form DAP-7-l, chorocterizes the trend. The relationship between discrepon-cies could involve links such as a time period during which the errors occurred, procedure, person performing the work, oreo of the plant, system involved, or type of component or commodity involved items such as these should be considered in identify-p ing common attributes that link discrepancies.
1.14 If a trend is found, evoluote the trend per Steps 2 (if the trend includes deviations),3, and 4 below. If no trend is found, close the trend evoluotion per Section 6.
2.0 identified Trends Containing Deviations if trends identified contain one or more deviations, investigate whether similar deviations exist but have not yet been found.
2.1 Decide how to determine whether the deviation exists else-where. The method to make this determination may be to reuse on existing checklist or part of a checklist that is sufficient to detect the deviation if it exists in the area being reviewed.
Alternatively, the review may consist of checking completed DAP checklists or engineering evoluotions that would have detected the deviation elsewhere were it to exist.
- - - - . -TN-85-6262/_7_ . _ . -
B-4
2.2 Determine from the project whether similar deviations have been identified in the post.. ,
2.3 Based on the chorocteristics of the deviation being evoluoted, determine whether ond, if so, where else the deviot on could logically exist as a safety-significant deficiency. Alternatively, use o process of elimination to exclude areas in which the deviation could not logically exist or be safety-significant.
- Record this determination and a brief statement of its basis.
2.4 Decide what aspect of design activities should be examined in looking for other instances of the deviation. This may be a review within the HDA, within a related HDA, or review topic in the discipline in which the deviation being evaluated was found, or in other disciplines in which the deviation (due to its nature) could likely exist as a safety-significant deficiency.
2.5 If Steps 2.1-2.4 above Indicate that the deviation could likely exist elsewhere os a safety-significant deficiency, perform odditional reviews of design activities or DAP records, and document the results. If other discreponcles are found, write DIRs per DAP-2, and determine whether these new discrepon-cies are part of the identified trend.
3.0 Trend Evaluation 3.1 Identify the programs, processes, procedures, work activities, methodologies, or other programmatic aspects that are poten-tiolly associated with the trend.
3.2 Evaluate these programmatic aspects to determine which ones are characteristic of the trend.
k TN-85-6262/7 B-5
/\
t :
C/ 3.3 Review available results of safety-significance evoluotions that were performed for any deviations included in the trend.
3.4 Decide whether the trend under evoluotion could have likely resulted in a safety-significant deficiency. If so, describe the safety significance of any undetected deficiencies that could now exist or be caused in the future.
3.5 If it is likely that one or more safety-significant deficiencies could exist or be caused in the future, the trend is adverse.
3.6 Document determinations made in this port of the evaluation on form DAP-7-1.
4.0 Conclusions of the Trend Evoluotion
/3 U) i 4.1 If the trend is adverse (and thereby programmatic), write a programmatic deficiency per DAP-2, and mark " Adverse Trend" on DAP-7-l.
4.2 If the trend is programmatic but not adverse, write an observa-tion marked "Nonadverse Trend" per DAP-2, and mark "Non-adverse Trend" on DAP-7-l.
4.3 If the trend evaluation indicates that a trend does not exist, mark the "No Trend" box on form DAP-7-l.
5.0 Review, Approval, and Documentation Sections 4.4 and 5.0 opply.
O V
TN-85-6762 /7 G-6
1 ATTACHMENT C J .
EERIC IMPLICATIONS EVALUATION ENGlEERING EVALUATION
- l. PURPOSE To evaluate root cause or causal factors and generic implications (limiting boundorles of applicability) of programmatic deficiencies, unclassified devia-tions, and design deficiencies that appear to be discipline-specific or multidisci-plinary; and to document DAP octivities and conclusions reached in this regard, ll. SCOPE Limited tc. Identification and evaluation of any root cause or causal factors and Os generic Inyplications of one or more programmatic deficiencies, design deficien-cles, or unclassified deviations (hereaf ter referred to collectively as deficien.
cles) that appear to be discipline-specific (or multidisciplinary), and whose DAP Trocking System (DAPTS) numbers and issue / Discrepancy titles are listed as follows:
DAPTS No, Issue / Discrepancy Title Ill. OVERVIEW: METHOD AND EXTENT OF REVIEW l.0 Describe the reason for conducting this engineering evoluotion (e.g.,
identification or receipt of DIRs listed in the scope section that appear to of feet only this discipline (or are multidisciplinary), direc-tion from the DAP Manager to conduct on evoluollon that supports a multidisciplinary generic implications evaluation, or other reason for Initiation).
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.[ 2.0 Identify the design attributes that are relevant to this evoluotion D' using the following steps:
2.1 List the of tributes of the DIRs in scope in each of the following categories (more than one attribute may apply to oo'c h cate-gory; if so, list multiple attributes in each category):
Design Discipline Design Organization Design Activities Design Attributes (within Design Activities)
System, Structure, or Component Classification, Status, and Type Potential Safety Significance Root Cause Potential Generic implicotton Nature of Problem Review Topic (Group of HDAs)
Homogeneous Design Activity (HDA)
Discrepancy Numbers (if appropriate) 2.2 Review Attachment A, Example Attributes Matrix, to deter-mine whether odditional design attributes should be included. If so, include them in the listing in Subsection 2.1.
2.3 Of the attributes listed in Subsection 2.1, select those that oppear to be relevant to evoluoting generic implications. That l Is, determining root cause or causal factors, limiting boundorles of applicability (other HDAs, review topics, design activities, arcos or items that are susceptible to the some condition).
Some of these attributes may be contained in discipline-specific checklists. Upon completion of this evoluotion, the attributes i
selected for the evoluotion should chorocterize to the extent l reasonable the what, where, when, why, who, and how of the TN-85-6262/7 C-2 l
DIR(s) listed in scope. Attributes in addition to those of the DIR(s) in scope may be selected.
3.0 Plan and document the method of evoluoting the DIR(s) in scope for root cause and generic implications. Include the following steps os written, or modify, revise, ne delete any of them, or odd other items and justify the changes.
3.1 Review other information ovalloble that is relevant to the DIR(s) in scope that was not reviewed in Subsection 2 above.
Document these reviews.
. 3.2 Based on knowledge of the DIR(s) in scope gained by the above reviews, form o hypothesis of one or more root causes and limiting boundorles of applicability.
3.3 Determine what information or type of information is needed to test the hypothesis (e.g., which attributes need to be evoluoted in which design activities, and what types of errors associated with these attributes will prove or disprove the hypothesis).
3.4 Identify the techniques to be used to gather this information (e.g., reuse of part of a discipline-specific checklist, interview, analysis of other DAP findings or documentation in the disci-pline (or multiple disciplines), review of project records, etc.),
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! 3.5 Identify the sources of information to be reviewed to test the hypothesis (e.g., what records or system of records, what organization, group, person, review topic, or HDA).
3.6 If odditional reviews of design work are needed, select addi-tional reviews that will test the hypothesis.
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3.7 Describe the planned opproach to be used to investigate and test the postulated root cause. Refer to Attachments D and E ,
for more information that may be helpful in evoluoting poten-tial root causes or causal factors.
3.8 Describe the planned approoch to be used to investigate and determine the postulated limiting boundorles of applicability.
Include criteria for occepting these boundorles (e.g., other areas likely to contain the deficiency under evaluation were checked and the deficiency was not found, other likely creas that had been previously evoluoted in the DAP were reviewed and conditions of the deficiency were not found, or due to the nature of the deficiency, it could not or is highly unlikely to exist outside the postulated boundorles).
4.0 Collect objective evidence and gather information according to the y) plan in Subsection 3 above. This may include one or a combination of the following steps or other techniques describt.J in the plan.
4.1 Review the DAP trocking system dato base, issues Records /DIR Reporta, or the generic implications dato system to determine which records are applicable within the scope of this evalua-tion.
Note: This generic implications evaluation may begin with only one deficiency, but it is possible that other records in the data will have attributes related to those of the deficiency.
4.2 Complete all or o portion of a DSAP checklist, the results of which will demonstrate whether the hypothesized generic impli-cotion extends to octivities reviewed using the checklist.
Document the acceptance criteria for any checklist used.
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( ) 4.3 Develop information to be gathered by interviews or written responses and conduct interviews or request written informa- I tion. The purpose of interviews is to identify sources and types of information that is objective evidence on which the conclu-sions of this evoluotion will be based. Written responses may contain abjective evidence or information on where to find objective evidence. ,
4.4 Review appropriate project records or documentation to deter-mine whether the deficiency had been detected, evoluoted, and ,
resolved in the post.
4.5 If a discipline-specific action plan does not encompots the , -x activities needed to review generic implications of this defi-ciency, revise the DSAP, or expand the scope of review occordingly to accommodate this review.
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/ 4.6 Document the information and objective evidence that pas gathered or reviewed as part of this evaluation. ,
5.0 investigate the hypothesized root cause or causal factors of the deficiency. .
5.1 The investigation method used will be o systematic approach that includes a logical flow of facts and relationships of >
conditions and events, develops and evaluates probable causes, and results in a conclusion of root causes or causal factors that is supported and justified. Attachments D and E contain examples of potential root causes or causal factors that may be oppropriate.
J 5.2 Based on the investigation in Subsection 5.I obove, determine '
the root cause or causal factors. This is based on a concensus V of DAP management, including the Review Team Leader, DAP TN-85-6262/7 C-5
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-"s Monoger, and appropriate discipline coordinators, discipline
, % p.' leaders, and reviewers, y-4 h , 5.3 If no root cause (or common cause in the case of several h j individual issues that appear to be on adverse trend) con be identified, document the investigation of root cause and the s'
result that a root cause could not be found.
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6.0 Evaluate the postulatpd limiting boundaries of applicability of the i% ., deficiency. Based on the specific nature of the deficiency, use either i . ,- -deductive or inductive logic described below or o combination as 1 s.
- oppropriate to confirm limiting boundaries.
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- 6.1 Using deductive logic, starting with a general hypothesis of
_, limiting boundaries of the deficiency, review previous DAP
,s reviews of design work outside the area in which the deficiency l
i' was identified, but where it could likely exist as a safety-l significant deficiency. If this method is used, a conclusion that
, the deficiency does not exist elsewhere is based on the absence of finding safety-significant deficiencies in other potentially affected areas or on revising the hypothesis and exponding the
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review to potentially affected areas until the deficiency is no e (k longer found.
6.2 Using Inductive logic, starting with the specific instances in which the deficiency was found as the hypothesized limiting L boundaries, discard several or all other design activities or
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t i areas os potential locations of a safety-significant deficiency.
n The basis for o conclusion using this opproach is that the 1 activities or areas discarded are unrelated to the nature of the s ~
i b deficiency being evaluated. The governing criterion for decid-
- ing that a deficiency is self-limiting to a given area is that it is
. unlikely that the same error could have resulted in a safety-i significant deficiency outside of the identified area.
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V IV. BASES FOR DOCUMENTATION SELECT lON DAP-8, Section 4.1.3 opplies. This information is described in the appro-priate parts of the generic implications evoluotion sections above.
V. SOURCE AND REFERENCE DOCUMENTATION DAP-8, Section 4.1.4 opplies. This information, os described previously in the appropriate parts of the generic implications evoluotion sections, will be documented in the steps in which it is used.
VI. ACCEPTANCE CRITERIA DAP-8, Section 4.1.5 applies. The criterio for accepting this engineering evoluotion are os follows:
d o The generic implications of the deficiency in the scope of this evoluotion were evoluoted sufficiently to form o documented basis for acceptance or rejection of the hypothesized root cause.
o The generic implications of the deficiency were evoluoted sufficiently to form o documented basis for acceptance or rejection of the hypothesized limiting boundaries of appli-cobility, o The hypothesis was validated to encompass the root cause and limiting boundaries of applicability that were found.
If this is not the case, to the extent necessary, the root cause and limiting boundaries were revised, odditional information was gathered, and a reevaluation resulted in acceptance of the final hypothesized root cause or causal factors and limiting boundaries.
Vll. EVALUATION Conduct and document the evoluotion in accordance with the Overview:
Method and Extent of Review described in Section Ill, if revisions of this HTM-Md2M'#b7 C7
section are found to be necessary during the evoluotion, DAP-8, Sec-tion 5.0 opplies.
Vill. RESULTS AND CONCLUSIONS Document the results, conclusions, and bases for conclusions of this generic implications evoluotion. Review DAP-8, Section 4.1.7, and incorporate the items listed that are oppropriate. In general, these will include the following:
o Any odditional discrepancies identified during this evoluotion and that they are properly classified per DAP-2; o Confirmed root cause or causal factors of the DIR(s) that were evoluoted; o Confirmed limiting boundaries of applicability of O the deficiency that were evoluoted;
,b o Any other open items; o identification of issues that have been resolved.
IX. FORMAT l
! l. Organize this evoluotion in the format specified in DAP-8, Sec-I tion 4.3, except that the main text of the evoluotion is specified as indicated below.
- 2. Prepare the Engineering Evoluotion Cover Sheet.
- 3. Write the obstract upon completion of the evoluotion.
- 4. The main text is os follows:
o Reason for the evoluotion (Section 111.1);
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o Design attributes relevant to this evoluotion (Section Ill.2);
o Method of analysis (Section Ill.3);
o Collection of information (Section 111.4);
o Root-couse investigation (Section Ill.S);
o Limiting boundaries of applicability (Section 111.6);
o Results and conclusions (Section Vill).
X. REVIEW, APPROVAL, AND DOCUMENTATION DAP-8, Sections 4.2 and 5.0 opply.
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i Appropriate sections of this attachment may be incorporated directly into the engineering evoluotion.
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ATTACHMENT D EXAMPLE LIST OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS This appendix is provided as nonmondatory guidance for investigations of root causes of programmatic deficiencies, design deficiencies, and unclassified devio-tions.
- l. Procedures not odequately specific to control situations cetually encoun- '
tered in performing tasks.
- 2. Personnel not odequately trained in the applicability of procedures avail-oble for the task.
- 3. Personnel did not adequately research requirements and commitments prior to developing procedures or performing work.
- 4. Inodequate understanding of regulatory requirements or commitments, p
- 5. Inodequate understanding of the required documentation to demonstrate compiionce with regulatory requirements or commitments.
- 6. Lock of odequate system or administrative controls to ensure that licensing / regulatory commitments were reflected in procedures or pro-Cesses.
- 7. Inodequate communications within a functional group (i.e., some people did work correctly while others did not).
- 8. Inodequate communications between functional groups (e.g., correct infor-motion was possed between groups but was used incorrectly, incorrect information possed between groups).
- 9. The deficiency resulted from o planned management-assumed risk.
- 10. Procedures used were incorrect for the application.
- 11. Procedures were incomplete or failed to incorporate all technical require-ments.
- 12. Lock of odequate inspection checklists.
- 13. Lock of adequate inspector qualification / training.
- 14. Engineering not sufficiently complete when activity was performed.
- 15. Inodequate time allowed to perform task properly.
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ATTACHMENT D (continued)
- 16. Error in judgment by qualified person.
- 17. Personnel performed task knowingly in violation of procedures.
- 18. Lock of odequate administrative controls to ensure that procedural requirements were met.
- 19. Foiled to identify root causes of previous deficiencies.
- 20. Failed to take appropriate action to prevent recurrence of deficiencies.
- 21. Inodequate monagement attention to trends in deficiencies or failure to trend deficiencies.
- 22. Inodequate surveillance of inspection activities.
- 23. Lock of odequate accessibility to documentation (design, construction, testing, or QA 24, inscrutobility of documentation.
- 25. Lock of odequate system or administrative controls to ensure that changes in design, construction, testing, or QA alvities were evoluoted (timely) against licensing / regulatory commitments.
- 26. Lock of timeliness in identifying, submitting, or receiving opproval for changes to licensing / regulatory commitments.
- 27. Lock of odequate post-inspection / turnover controls over hardware.
- 28. Connot determine o root cause (isolated error).
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b ATTACHMENT E EXAMPLE OLESTIONS FOR EVALUATION OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS This appendix is provided as nonmandatory guidance for root cause investigation checklists used for programmatic deficiencies, design deficiencies, and unclassi--
fled deviations.
YES NO l.a. Was the deficiency a direct violation of Appendix B or other regulatory requirement?
1.b. Was the deficiency a direct noncomplianceith licensing / regulatory commitments?
l.c. Was the deficiency a direct violation of project proce-D dures?
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i Did a deficiency similar to that identified occur pre-2.
viously?
- 3. Did the NRCTRT or CPRTind multiple incidents of essentially the some deficiency?
l 40. If the deficiency was identified previously, was action l
identified to prevent recurrence?
Ab. Was the corrective action odequate?
- 5. Was the identified corrective action octually imple-mented?
- 6. Was there odequate technical input to the activity?
- 7. Did the activity make correct use of industry codes and standards?
- 8. Was the work conducted in accordance with procedures?
- 9. Did people involved (e.g., craf t, inspectors, etc.) know how to obtain technical input?
- 10. Was there odequate internal communication (i.e., within the group responsible for the activity)?
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ATTACHMENT E (continued)
YES NO l 1. Was there adequate external communication (e.g.,
between TUGCOond Gibbs and Hill and between TUCCO and NRC)?
- 12. Was information regarding previous occurrences avail-oble to personnel?
- 13. Were previous identical or similar occurrences trended?
- 14. Were people trained in the activities they performed?
- 15. Were changes to requirements identified on a timely basis?
- 16. Was information required to perform the task ovoilable to personnel?
- 17. Was required information kept up to dote?
- 18. Did a planned activity result in a degradation of e process in which the deficiency occurred?
- 19. Was the division of responsibility among participants cleor?
- 20. Were audits or inspections conducted on a timely basis?
- 21. Were there conflicting procedural requirements?
l 22. Were there conflicting technical requirements?
l l 23. Were schedule pressures held to on acceptable level?
- 24. Were there adequate, up-to-date management policies to oddress the situations encountered in performance of the work?
- 25. Were these policies adequately implemented?
- 26. Was there a feedback loop to allow information flow back to policymakers regarding problems with policies?
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ATTACHMENT E (continued)
YES NO
- 27. Did upper level monogement individuals demonstrate on interest in lower level activities through personal i involvement?
- 20. Were goals and objectives odequately defined?
- 29. Were personnel performing tasks, that proved to be defective, odequately qualified for the work they were asked to perform?
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ATTACHMENT F Evoluotisn Numbsr: DAP-TE- -
COMANCtE PEAK ADEQUACY PROGRAM Rev:
TREPO EVALUATION Number of Sheets:
s DAP Discipline:
TREND IDENTIFICATION - LEVEL 11 Attribute Trended: Date:
Other Attributes Selected (constrained). List as appropriate:
4 Discipline Clossification Generic Implication Design Orgeirotion Status Problem Design Activity Type Review Topic Activity Attribute Safety Significance HDA System / Structure / Comp. Root Cause DIR Nos.
Number of DIRs in This Subset:
Nome of Each Subattribute in Trended Attribute / No. of DIRs / DIR Nos.
TREND IDENTIFICATION - LEVEL 111 Nome of Subottributes Expanded to Level til / No. of DIRs / DIR Nos. Date:
Yes No Trend
Description:
Deviation included Additional Reviews Required Additional Reviews Corryleted (Describe in Attachment)
Discipline Specific Multidisciplinary Date Trend Identified:
TREND EVALUATION Programs Affected: Date:
Potential for Safety-Significant Deficiency:
Description and Bases of Evoluotion:
b ,clusion: O Adverse Trend O Nonadverse Trend O No Trend
( (Prepore DlR for Programmatic Deficiency) (Prepare DlR for Observation)
Prepared By/Date / DAP Monoger/Date /
Discipline Coordinator /Date / Approved By RTL/Date /
FORM DAP-7-1 REV.0
ATTACHMENT G
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Entry Dote PGIDATA:
COMANCIE PEAK DESIGN ADEQUACY PROGRAM DIR NO"-
PGIDATA FIELD CODES FORM
's DIR Rev. NO.:
Circle expanded attributes on this forrn. Keep original. Send Copy to PGl Coordinator for dato entry.
FIELD / CODE FIELD / CODE FIELD / CODE FIELD / CODE FIELD / CODE FIELD / CODE TREtc DESACT RADX 5 I6 M8 A 1-n TEST 6 17 M9 N (per DAPTS) MSCS 7 18 M10 IDRC 8 19 Mit TRENDATE PROGREO 9 110 Ml2 MM/DD/YY Ett DOCCON 111 M13 ORC EE DETl5UTYP Mit Resp PREP NOCL COMMUNIC DISCPLIT 194X APPR 150L Cl RANDOM l DCON 1550 GENR C2 R 2 DDOC REV CUML C3 3 MCRV FSAR NCUM PCl@L 4 TRAN UPCT AUD lNSP R CHCCON F
6 7 OULV
%5 SA{ESIG h A3 N
IWR p DVER FUNC N A4 SCOPE ECMDIS AUDT DISP A5 OPE ANAL CORA RECS A6 MULT FL5Y SAFEFN EXPR OPE X $l A7 FACS DCHC ImpR Sy itCTRSLT PPE REVU TIMELY ANAL
$3 FLOO l@UTREQ Tl ODES
$4 HVAC NL CORACT T2 GHOW 55 P&V PREF EPL T3 56 RAD CSRC PROC T4 IMPACT 57 DCND tr@T 58 T5 PROG ELECDis INFC PRC5 76 lt@T
$9 PREO MATL IWC 510 T7 PRCS PR$Y MECH VER] INFC CABL STRT DOCC DOCUMTN VERF LO55 CAP EOLY HYDL CHCC DI DCON FP Li CEM PCDR L2 D2 CHCC ELEC PERS L3 03 CORA V INCODis LAYT TRNC D4 AUDT La EQiP OPER MCMT L5 D5 CR5Y I&C L6 D6 PROBLEM INNS ISI AUDITS 07 PERS L7 N SEP Ett L8 PCOR CRLY TEST PERS L9 QUAL TRG PIMP EQ FPRO INT Ll0 Of MGMT APPL EXT G2 OAOC PIPEPSDIS INDS CONT ROOT Q3 PROC ANAL H55P SKED 0 Q4 CSRC SUPT RSLT I CCOD NfC PROESS FLUP 2 XFERtNFO ANAL Ett 3 XI INTR CIV5TRDl5 TRN5 SYSTEM / 4 X2 ASMP CTTS PCDR STRUCTURE / 5 X3 CALC CDCS ANAL COMPOENT 4 X4 HDWR STEL CALC 7 X5 CRET OTPT 8 PR08DETL HVAC 9 Rg$g (,,,, go SEl5 INTFCON 10 Y describe OSP Ett il N problem SGAP ElDN 82 in more STRU ERSP 13 POSTTOC detoiD ECOM CLASS Y PCIDIS EDOC 0 PROCEDUR N Review Topic f MDIS iion I pi D5PC IRSP 2 P2 CORR ICOM 3 P3 FI DE50RG IDOC 4 P4 F2 TUCC 5 p5 F3 TM VERIF 6 P6 F4 CPPE Ett 7 P7 F5 GH ltet P8 F6 HDA is W ASMP STATUS P9 F7 ITT QUQA I Pio l W SI C$RC 2 Pil MGMT
! w PSE COEX MI l ESA$ gygg l$$yg7ypg ppogggpg gy l
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IMP REAs 1 12 M4 8 $ ult 2 13 M5 LtilE XPD l DELAV MATL 3 14 M6 Y KRAN g$l g l$ M7 Prepared By/Date / Discipline Coordinator /Date /
1 REV.O l __ FORM DAP.7 2_ _ __ __ _
i N ATTACHAENT H Discipline:
COMANCE PEAK DESIGN ADEQUACY PROGRAM l TREPO EVALUATION LOG CONTROL l.D. NO. SUPERSEDED TRENDED ATTRIBUTE BY 0 1 2 3 4 5 6 I
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ATTACHMENT I d
SUMMARY
OF DAP-7 TRENDING AND GEERIC lMPLICATIONS EVALUATIONS This summary is on overview of the DAP procedure on Trending and Generic Implications Evoluotions, DAP-7, and the interrelationships among various evoluotions that are conducted on Discreponey/ issue Resolution reports (DIRs) depending on their classification. This summary is intended to familiarize those DAP personnel not directly involved in trending and generic implications evoluotions with these activities. Understanding the content of this summary should give those DAP personnel not directly involved with DAP-7 sufficient knowledge of these activities, so that they need not read the remainder of DAP-7. Those DAP personnel who will be doing trending and generic implico- ,
tions evoluotions should read DAP-7 and its other ottochments before conducting these types of evoluotions.
Interrelationships Figure I of DAP-7 (also included in this attachment) depicts the relationships among:
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DIR identification, evoluotion, and classification o Safety significance evoluotion o Trend identification and evoluotion o Root cause and generic implications evoluotion o Corrective action evoluotion, and o Closure.
The DAP procedures that opply to these activities are included in Figure 1.
All DIRs are eventually classified according to the DAP definitions, and all DIRs other than those found to be unsubstantiated will be included in trend evalua-l tions.
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Q) Safety significance evoluotions are conducted on deviations, except for those deviations that are being addressed by proceeding directly to corrective action.
These exceptions, called unclassified deviations, are associated with designs undergoing complete redesign or verification, such as piping and pipe supports, cable trays and supports, and conduit supports.
If the deviation is found to be safety-significant, it is classified as a deficiency and subject to evoluotions of root cause, generic implications, and corrective action. Even though the safety significance of unclassified deviations is not evoluoted, DIRs with this classification also undergo evoluotions of root cause, generic implications, and corrective action. In addition, if adverse trends are found (classified as programmatic deficiencies), they too undergo root cause, generic implications, and corrective action evoluotions.
Trend Evaluations O
V Trends con be initially identified based on information coded on the DIR form and entered in a dato system for searches, sorts, and displays. This information is called Level ll. For each trend, the Level ll information is expanded as appropriate to the next level of detail (Levellil), which is also entered in the dato system. This expansion is intended to to localize and provide a better understanding of the characteristics of the trend. Judgment on the part of DAP personnel is also used to identify the existence of a potential trend.
Trends are evaluated to determine whether it is likely that existence of the trend could have resulted in the occurrence of undetected safety-significant deficiencies in the offected area of design. If it appears likely, then a trend is termed adverse, and a programmatic deficiency is created as a DIR. Trends determined not be adverse are termed nonadverse, a DIR is written as on observation marked nonadverse, and no further evaluation of the issue is done in the DAP. All of the DIRs generated are transmitted (at on oppropriate stage in the process) to the Comanche Peak Project organization.
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5 ) If a trend contains any DIRs classified as deviations, then the DAP will consider
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odditional reviews to determine whether similar deviations exist in areas of design that could be affected. If a trend contains only DIRs finally classified as observations, then no additional reviews are colled for.
Individual trend evoluotions are documented on a Trend Evoluotion form and any attachments, such as continuations of various blocks on the form or computer-9enerated printouts of charts and tables. In each DAP discipline, one engineer-ing evoluotion will be written to summarize all trend evoluotions in that discipline. It will also establish a basis for concluding that a sufficient level of trending was completed in that discipline.
As trends may be specific to one discipline or multidisciplinary in nature, trend evoluotions will be done both within specific DAP disciplines and across DAP disciplines. Trend evoluotions may be started on DIRs prior to their receiving final DAP classifications. Upon changes or final classifications, these trend p evoluotions will be updated and revised as necessary. Trend evoluotions are Q opproved by the DAP Review Team Leader.
Generic implications Evoluotions Generic implications evoluotions are used to investigate root causes or causal factors and to determine limiting boundaries of applicability of certain classifi-cations of DIRs. This evoluotion applies to design deficiencies, programmatic deficiencies, and unclassified deviations.
The methodology for this evoluotion is to determine the attributes (or chorocter-istics) of the design process or design control process that are associated with the deficiency, etc., under evoluotion. Some of these attributes may have been identified in trend evoluotions. Based on this knowledge, hypotheses are then formed as to potential root causes (or contributing causal factors) and potential boundaries of applicability of the deficiency. The method of testing these hypotheses is then developed and implemented. Additional information, includ-k ing objective evidence, is gathered as needed.
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The root cause or causal factors are determined based on consensus of DAP management and involved reviewers. Limiting boundaries of applicability are then determined. During these determinations, it may become necessary to revise the hypotheses and conduct other reviews to test them. If this occurs, iteration will continue, leading to the final consensus as to root causes and limiting boundaries of applicability. The DAP Review Team Leader opproves generic implications evaluations.
Generic implications evoluotions are do.comented in the format of engineering evaluations. The results of these evaluations are also documented in the oppropriate blocks of the DIRs to which they apply. Similar to trend evaluations, generic implications evaluations may be done within and across DAP disciplines, depending on whether root cause and limiting boundaries are limited by disci-
. pline.
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- T* 9 EXMRNAL DR m IR/D R m DE ELF.HTIATED M 5 5 - MNTFED '
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EVALUATlON; ATTRBUTES ICENTFIED owa/ ACTO 4 ptApe 4
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" E D FLED C summe LEVEL 11 op4 op.7 ONATION m EXPAN5 ION TO
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- ROOT CAUE/CEPERIC IWLICATIOPS 'E m EVALUATIOPE l w ow.1 UmrTNG SOLDCARE5 ROOT NONACNERE CORRECTfvE CAL 8E TRE'c ACTION EVALUATION op.m 1
- CLOSURE C FIGURE I INTERRELATIONSHIP OF DAP ACTIVITIES APO PROCEDURES DISCREPANCY CLASSIFICATION, SAFETY SIGNIFICANCE EVALUATION, TREPOING, EFERIC IMPLICATIONS, CORRECTIVE ACTION, APO CLOSURE DAP.7 REV.O TN-85-6262/7 l-5
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