ML20210H775
| ML20210H775 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/07/1987 |
| From: | Dougherty F, Schafer R, Turi P TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20210F162 | List:
|
| References | |
| DI-M-003, DI-M-3, NUDOCS 8702110474 | |
| Download: ML20210H775 (10) | |
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TITLE: Technical Mequacy Review of NCRs, Rev. O NUMBER: DI-M-003 i
Prepared Date Reviewed Date Approved Defe 8 vision a 2L i+,ju Mn $& )
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4 COMANCtE PEAK RESPONSE TEAM - DAP DISCPLpE INSTRUCTION Number: DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 0 1.0 PURPOSE This instruction defines the method by which DAP will conduct a review of Project NCRs to assess the adequacy of those dispositions which required technical justification.
2.0 SCOPE The DAP will conduct a review of Project activities related to determining the technical adequacy of CPSES NCRs. The scope of the DAP review will include:
o A review of the Project's assessment of technical adequacy of 300 previously issued NCRs that were selected for a sampling program conducted by the Project, o A review of the newly issued Project procedure for NCRs as well as the current NCR training program, and o A review of the Project's NCR verification effort. This includes both the Project's verification of all previously issued NCRs for technical adequacy and the Project's (n) activities for NCRs issued under the new CPSES procedure.
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions 3.1.1 Nonconformances (ANSI N45.2, Criterion 16)
Nonconforming items may be disposed of by acceptance as is, by scrapping or repairing the defective item, or by rework to complete or correct to a drawing or specification. Such measures shall provide assurance that the item is identified as nonconforming and controlled. The measures shall require documentation verifying the acceptability of nonconforming items which have the disposition of repair or use as is. A description of the change, waiver or deviation that has been accepted shall be documented to record the change and denote the as-built condition.
3.1.2 Scrap Disposition Assigned when it is determined that an item is unsuitable for its intended purpose and cannot be feasibly or economically reworked or repaired.
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e COMANOE PEAK RESPON5E TEAM - DAP DISCPLitE IN5TRUCTION Number: DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 0 3.1.3 Rework Disposition Assigned when actions are required to correct the nonconforming conditions and bring the affected items into compliance with the specified design requirements.
3.1.4 Repair Disposition Assigned when actions are required to repair the nonconforming conditions to an acceptable state, not necessarily in compliance with the existing design. Repair dispositions should include appropriate technical justification for acceptance of the item with characteristics that do not comply with the specified design requirements.
3.1.5 Use-As-Is Disposition Assigned when sufficient technical justification can be established such that the nonconforming characteristics do not result in adverse conditions, and when the affected item will continue to meet all functional requirements including performance, maintainability, fit, and safety.
3.2 Resoonsibilities 3.2.1 Reviewer The Reviewers are responsible for performing a technical adequacy review of selected NCRs in accordance with this t
instruction.
! 3.2.2 Group Leader The Group Leader is responsible for implementing this instruction. This includes providing training for the reviewers, evaluating reviewer comments, facilitating document transfer, and summarizing review results.
3.2.3 Discipline Coordinator The Mechanical Discipline Coordinator is responsible for reviewing this instruction, recommending its approval to the DAP Manager, and approving the resulting engineering evaluations.
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COMANC>E PEAK RE.5PON5E TEAM - DAP DISCPLitE IN5TRUCTION Nurnber: DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 0 i
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l 3.2.4 DAP Manager -
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In accordance with DAP 10, the DAP Manager is responsible for approval of this instruction.
- 4.0 INSTRUCTION j 4.1 Pro.iect NCR Review DAP will conduct a review of NCRs evaluated by the Project as part of a Project-initiated sampling effort. The Project NCR Review Team randomly selected 300 NCRs and subjected them to as many as three levels of review, depending upon the effort required to determine adequacy (the third level required a determination of safety significance). The DAP review will include a minimum of 10% of the Project's sample, with selection based upon an engineering review of the sample NCRs.
The DAP will obtain a copy of the 300 NCR review packages
. (includes NCR, any su documentation, and Project NCR i
Evaluation Worksheet)pportingThe Group Leader, or his designee, will select at least 30 NCRs from the sample of 300. These
- will then be sorted according to DAP discipline, in l preparation for the technical adequacy review. Obtaining a reasonable number of NCRs from each discipline will be considered by the Group Leader in the NCR selection process.
Additional NCRs may be selected if necessary so that a i
reasonable number of NCRs from each discipline can be j . subjected to review.
! The technical adequacy review will be conducted by a team of DAP discipline engineers with at least one representative from each of the four DAP disciplines (i.e., Mechanical,
! Electrical /ISC, Civil / Structural, and Piping).
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! Reviewers will evaluate each NCR and the Project's assessment i of the NCR using an NCR Review Worksheet for initial j documentation purposes. The Reviewer will fill out the NCR i
Review Worksheet (Attachments A and B) for each NCR evaluated, l recording the NCR number in the space in item 1 on the ,
I worksheet. The second item in the worksheet asks the Reviewer to determine if the disposition provided on the NCR fully i
addresses the statement of nonconformance. This check is not i-of technical adequacy but determines if the disposition accounts for each nonconforming item identified on the NCR, and if the disposition is a complete solution. The third item calls for the Reviewer to assess the technical adequacy of the l NCR disposition, independent of the assessment made by the O, e9>rs l
COMANCE PEAK RESPONSE TEAM - DAP DISCPLIE INSTRUCTION Number: DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: O Project NCR Review Team. The first part of item 4 agAs the ReviewertorecordtheProject'stechnicaladequac{)
(as shown on the Project "NCR Evaluation Worksheet conclusion. If the Project NCR Review Team concurred with the NCR disposition, the Reviewer can proceed to item 5 on the Worksheet.
Otherwise, the Reviewer should evaluate the supplemental documentation (e.g., calculations, ASNE code cases, etc.)
supplied by the Project NCR Review Team used in making an
-adequacy determination. Any discrepancies identified by the Reviewer in evaluating the Project NCR Review Team's adequacy assessment shall be documented on Type "C" DIRs in accordance with DAP-2.
After reviewing the NCR and any supporting documentation assembled by the Project NCR Review Team, the Reviewer should state whether or not he/she concurs with the ade determination made by the Project NCR Review Team (i.e.quacy , is the nonconformance resolved?). The basis for the Reviewer's decision should be cited, using Attachment B ("Worksheet ContinuationSheet") as needed. If the Reviewer disagrees with the final disposition reached by the Project NCR Review l Team, this shall be recorded on a Type "C" DIR. Upon completion, the Reviewer will sign the Worksheet, attach any O- continuation sheets and the NCR package, and return this to the Group Leader. Also, any DIRs written by the Reviewer will be brought to the attention of the Group Leader. The responsible Discipline Coordinator will process DIRs in accordance with DAP-2.
The DAP technical adequacy review will draw upon the criteria lists developed as part of the overall DAP effort to assess compliance with design requirements. If any of the selected samples include a Project Safety Significance determination, the Project's definition for safety significance (i.e.,10 CFR 50.55(e)) will be used by reviewers to assess adequacy, as opposed to that found in the Program Plan. Program Plan's definition of safety si nificance is more(The restrictive than that found in 10CFR50.55 e) in order for the CPRT to achieve reasonable assurance ob ectives for its limited review scope. In this review, the Project's ability to reach a safety significance conclusion will be evaluated.
Accordingly, DAP must apply the same definition in order to measure compliance). Upon completion of the initial review, the Group Leader will decide if a reasonable assurance conclusion can be drawn regarding the adequacy of the Project's NCR review effort. If not, additional NCRs within the Project's sample population may be selected for review, up to a complete review of the 300 NCRs.
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COMANCPE PEAK RESPON5E TEAM - DAP DISCPLIE INSTRUCTION Number: DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 0 Upon completion of the Project NCR Review, each Reviewer will retrieve their NCR Review Worksheets from the Group , Leader, and summarize results on Attachment C, the NCR Review Record.
After signing the NCR Review Record, Reviewers will return it, along with other review documentation, to the Group Leader.
The findings of this )hase of the DAP review will be summarized by the Group .eader in an Engineering Evaluation prepared in accordance with DAP-8.
4.2 Review of Procedure and Trainino Procram (LATER) 4.3 Overview of Pro.iect NCR Proaram (LATER) 5.0 DOCUNENTATION 5.1 NCR Review Worksheet The NCR Review Worksheets will be retained by the Group Leader O until the review results are transferred onto the NCR Review Records and incorporated into the Engineering Evaluations.
5.2 NCR Review Record The NCR Review Record will be signed by the Reviewer responsible. Upon completion, the NCR Review Record will be given to the Group Leader, who will include the forms in the Engineering Evaluation. NCR Review Records will be retained as records in accordance with DAP-14.
5.3 Enaineerino Evaluation The results of the DAP review will be summarized in an '
t Engineering Evaluation in accordance with DAP-8. The Engineering Evaluation will be retained as a record in accordance with DAP-14.
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ATTACHNENT A NCR Review Worksheet
- 1. NCR Number
- 2. Does the NCR adequately describe the nonconforming condition?
b .
- 3. Does the NCR disposition address the stated nonconforming condition?
, 4. Does the NCR disposition adequately and correctly resolve the stated nonconforming condition?
- 5. Does the Project NCR Review concur with the NCR disposition?
() If not, does supplemental documentation assembled by the Project NCR Review Team adequately support the NCR disposition (including 50.55(e) evaluations completed by the NCR Review Team)?
i If supplemental documentation is inadequate, list Type "C" DIRs issued.
- 6. Do you concur with the Project NCR Review Team's final disposition of the NCR7 Attachment B as necessary)(State basis for your answer, using If not, list Type "C" DIRs issued.
Reviewer '
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Page of ATTACHMENT B l Worksheet Continuation Sheet 6
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ATTACIMENT C NCR REVIEW RECORD PAGE OF
- DISCIPLINE REVIEWER DATE i
NCR Descriptfor. Adequate? NCR Disposition Addresses ER Technically Does Project Concur With Do You Concur k nconforming Condition? Adequate? NCR Disposition With Final Ols-dCR # position of NCR7 Does Supplemental Yes Ib Docu. Support NCR Yes No Yes No Yes Dispositlon? yes J %Ihist gg)
Yes No (List DIRs) i i
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[d - Rev. 2: December 1, 1986 ELECTRICAL INSTRUNENTATION AND CONTROL DISCIPLINE INSTRUCTIONS Table of Contents Instruction No. Title Revision RiLt1 DI-EIC-001 (Not Issued--Cancelled)
DI-EIC-002 Documentation of the Basis for 0 4/11/86 Selection of Systems, Structures, Components, and Documents for Review DI-EIC-003 Administrative Review 0 11/25/86 i of EIC Design Checklists 4
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