ML20210H798
| ML20210H798 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1986 |
| From: | Dougherty F TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20210F162 | List:
|
| References | |
| DAP-2, NUDOCS 8702110477 | |
| Download: ML20210H798 (70) | |
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u- TlTLE DOCUMENTATION Ato TRACKING OF ISSUES AfO DISCREPANCIES f NUMBER DAP-2 Revision Prepared Date RAviewed Date Approved Date 0
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i TABLE OF CONTENTS Section '
P.agg cover Sheet.......................................... i
- Table of contents.................................... 11 ,
1.0 PURP0SE......................................... 1 i 2.0 SC0PE........................................... 1
)
3.0 DEFINITIONS AND RESP 0NSIBILITIES................ 1 4
4 4.0 INSTRUCTION..................................... 20 1 5.0 DOCUMENTATION................................... 36
- ATTACHMENTS A ISSUE RECORD COVER SNEET........................ A-1 B CONSTRUCTION QA/QC ISSUES 10G................... B-1 l C ISSUE REC 0RD.................................... C-1 1
! D DISCREPANCY / ISSUE RESOLUTION RECORD............. D-1 J
E INTERPRETATION OF DAP TRACTING SYSTEM 4 " TYPE" BI4CES................................... E-1
! F USE AND INTERPRETATION OF -
DESIGN ACTIVITY................................. F-1 1
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( COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 lSSUES AND DISCREPANCIES 1.0 PURPOSE 1
! This procedure defines the requirements for documentation, f tracking and resolution of External Source Issues and of discrepancies identified during the conduct of the Design f j Adequacy Program (DAP) and the Civil / Structural / Mechanical (CSM) ISAPs that are part of the CPRT Prograa' Plan.
2.0 SCOPE 1
This procedure applies to issues identified by external j sources and to discrepancies identified during implementa- '
tion of the self-initiated portion of the DAP. Where indicated, this procedure also applies to documentation of l DAP overviews of corrective action; capture of information l about TUGCO-identified reportable or potentially reportable issues; and documentation of discrepancies found during '
evaluations conducted under the CSM ISAPs.
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions 3.1.1 External Source Issue An error or concern related to design or design processes identified by an organisation other than the Comanche Peak Project or the Comanche Peak Response Team (CPRT) and contained in public documents on the NRC dockets for the Comanche Peak Steam Electric Station (CPSES). - Open l
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TN-85-6262/2 Page 1 of 57 l O ,
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- COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 l lSSUES AND DISCREPANCIES l
External Source Issues are documented in "E" type Discre-pancy/ Issue Resolution (DIR) Reports. External Source Issues resolved by an external source are documented in "R" type DIRs. _
3.1.2 Status The designation, as determined under the DAP, of an issue or discrepancy as open or closed, and whether it has been transferred to a primary issue or is a duplicate of another ,
issue already entered in the DAP tracking system.
3.1.3 Open 3.1.3.1 Open External Source Issues ld Issues are considered to be open until there is reasonable l
assurance that the following conditions, as determined under the DAP, have been met:
e It has been determined that:
a) the issue is unsubstantiated, or, b) the issue l
i) has been resolved by an external source and requires no additional investiga-tion by the CPRT except as an input to trend evaluation, and
- 11) has been appropriately classified by the CPRT (e.g., as an observation, deviation or deficiency); or, ,l-l TN-85-6262/2 Page 2 of 57 1
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES c) the issue is a discrepancy determined by the t CPRT to have been resolved and meets the conditions for closure of a discrepancy listed in paragraph 3.1.3.2 of this proced-ure; and,
, o The bases for any one of the above-mentioned determinations have been documented.
~
This definition applies only to "E" type DIRs.
l 3.1.3.2 Open DAP-Identified Discrepancies k Discrepancies are considered to be open until there is reasonable assurance that the following conditions, as determined under the DAP, have been met:
O o The DAP has determined that the discrep-ancy has been appropriately classified (e.g., as an observation, deviation or t deficiency).
1 .
o The DAP has determined that appropriate resolutions and corrective actions, as required by the CPRT Program Plan and DAP-20, have been established.
o It has been determined that the root cause and the generic implications for certain classifications of DIRs have been investigated as required by the CPRT Program Plan.
c, The basis for the above-mentioned determinations have been documented.
This definition applies only to "D" type DIRs. -
l Q TN-85-6262/2 Page 3 of 57 O
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revisiom 5 ISSUES AND DISCREPANCIES 3.1.4 Closed !
Issues and discrepancies are considered closed when the applicable conditions outlined in 3.1.3 have been met.
This definition applies to "E", "R" and "D" type DIRs.
3.1.5 Transferred to The designation used to describe the result of (1) com-l bining duplicate issues that appear in one or more of External Source documents, (2) combining duplicate discre-pancies that have been entered in the DAP tracking system, or (3) combining DAP-identified, related discrepancies ("D" DIRs) or External Source Issues into primary issues. The '
issue to which duplicate issues, or related discrepancies (that may be addressed in an IRR) are transferred is i
referred to as the primary issue.
3.1.6 Classification The designation used to indicate the characteristics of an*
issue or discrepancy regarding its validity, consistency with design commitments and nuclear safety- significance.
The classifications are: unsubstantiated, observation, deviation, unclassified deviation,
- deficiency and programmatic deficiency.
unclassified trend, Figure 1 depicts ld the relationship among the classifications. (Note: The arrows indicate the general progression of classifications, but do not limit the proper reclassification of issues or discrepancies that were improperly classified.)
TN-85-6262/2 Page 4 of 57
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ACTION PLAN RESULTS d EXTERNAL NOT EXPLICITLY DEFINED ADVERSE SOURCE BY AN EXTERNAL TREND ISSUE SOURCE ISSUE
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l OSSERVATION DEVIATION 1 r 1 r PROGRAMMATIC UNCLASSIFIED DEFICIENCY DEFICIENCY DEVIATION FIGURE I RELATIONSHP AMONG CLASSIFICATIONS i
Page 5 of 57 TN45-6262/2 l
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES 3.1.7 Unsubstantiated l
An External Source Issue or DAP-identified discrepancy that
- e has been det'rmined, by the DAP, to be not valid.
l 3.1.8 Discrepancy
! Any identified error related to design inputs, implementing documents and outputs, i.e., assumptions, procedures, calculations, analyses, drawings or specifications for safety-related structures, systems or components that could have an adverse impact on the adequacy of their design.
I All discrepancies are ultimately either classified as observations, deviations, unclassified deviations, defi-ciencies or programmatic deficiencies, or are found, upon O additional investigation by the DAP, to be unsubstantiated.
Substantiated issues become discrepancies within the DAP.
3.1.9 Observation Any identified, substantiated design discrepancy that has ld been determined, under the DAP, not to constitute a design j deviation. An observation may be technical (related to a technical aspect of design) or programmatic.
3.1.10 Deviation Any identified design that has been determined, under the DAP, to constitute a verified failure to mest a- design criteria commitment or specification. In this regard i TN-85-6262/2 Page 6 of 57 i
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE ,
1 Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 l ISSUES AND DISCREPANCIES design criteria commitments include regulatory require-ments, FSAR commitments, other licensing commitments, applicable code and standard requirements or other project-specific design criteria or commitments.
3.1.11 Unclassified Deviation A deviation or set of deviations for which it has been determined that it is more practical to proceed directly to l[ '
analyzing root cause and generic implications and specify-ing corrective actions. A safety-significance evaluation
,will not be done for unclassified deviations because it would serve no useful purpose. Unclassified deviations will be tracked as deficiencies in that root cause, generic implications evaluations, and corrective action will be evaluated. In areas where reverification or redesign is being performed, the assessment of root cause and generic implications is only for the purpose of identifying potential problems ' in other design areas. Discrepancies t noted during DAP overview of corrective action are discussed in Section 4.8. ,
3.1.12 Deficiency Any identified design deviation that has been determined, under the DAP, to be a safety-significant deviation.
3.1.13 Programmatic Deficiency A set of related design discrepancies that ha[e' been determined to constitute an advarse trend that is TN-85-6262/2 Page 7 of 57 l
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I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES programmatic in nature.
An adverse trend is referred to as a programmatic deficiency. A trend is considered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected safety-significant deficiency in the affected design area. A programmatic deficiency can include any identified design control program deviation meeting one or ;
more of the following criteria:
Inadequacy of a design control program element such that substantive revision of the program or other corrective action is k required to bring it into compliance with the regulatory requirements FSAR commit-ments, or other licensing com,mitments; or Extensive evaluation would be required to determine the effect on the quality of design.
Programmatic deficiencies (like design deficiencies) are subject to evaluations of safety-significance (DAP-22),
root cause and generic implications (DAP-7), and adequacy of c6rrective action (DAP-20). A programmatic deficiency may be identified during the preparation of Issue Resolu-tion Reports. '
j ,3.1.14 Unclassified Trend
. trend for which it has been determined that it is more
}kractical to proceed dirsctly to analyzing root cause and denaric implications and specifying corrective actions. A d
i safety-significance evaluation will not be done for l
unclassified trends because it would rserve no useful TN-85-6262/2 Page 8 of 57
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 j ISSUES AND DISCREPANCIES purposc, Unclassified trends will be tracked as adverse trends (programmatic deficiencies) in that root cause, generie: implications, and corrective action will be evaluai:ed. In areas where reverification or redesign is being performed, the assessment of root cause and generic implications is only for the purpose of identifying potential problems in other design areas. Discrepancies l
noted during DAP overview of corrective action are discuss-ed in section 4.8.
t 3.1.15 safety significant i
l A deviation that, if uncorrected, would result in the loss of capability of the affected system, structure or com-l ponent to perform its intended safety function. Credit is not allowed for redundancy at the component, system, train or structure level. Refer to Appendix E, CPRT Program Plan for additional information regarding the CPRT definition of safety significant.
3.1.16 Root Cause ,
lk The cause or causal facy: ors that contributed to a program-matic deficiency, unclassified deviation, unclassified trend, or design deficiency, (i.e., why it occurred) . A i
root cause may be determined during an evaluation by testing a hypothesis or by making a preliminary judgement subject to confirmation. Root causes and causal factors and the extent of their applicability in design are based on objective evidence. They are confirmed and bounited by the findings of evaluations (what does exist) rather than TN-85-6262/2 Page 9 of 57 l
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l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES by general statements of what could exist. I n 's p e c i a l cases, actions beyond those listed for any given classifi-cation may be warranted. For example, it may be considered appropriate to assess root cause for a particular deviation d
, or non-adverse trend.
i j 3.1.17 Generic Implication A reasonable likelihood that an issue or discrepancy (DIR) affects some aspect of design other than the specific instance in which the finding was identified.
3.1.18 Generic Implications Evaluation lk The process of reviewing programmatic deficiencies, '
unclassified deviations, unclassified trends, or design v deficiencies identified in self-initiated portions of the lk DAP, or originated as External Source Issues and confirmed by the DAP to:
o Determine whether related design deficien-cies exist, o Investigate the root cause or causal factors, o Determine limiting boundaries of applica-bility of the deficiency under review.
1 In special cases, actions beyond those listed for any given classification may be warranted. For example, it may be considered appropriate to assess generic implicationtr for a particular deviation or non-adverse trend.
TN-85-6262/2 O Page 10,of 57
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. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES 3.1.19 Issue Record A form (DAP-2-3) prepared by the Design Adequacy Review Team during the review of External Source documents which contains a description of the issue and a ' record of its disposition by the DAP (See Attachment C) .
3.1.20 Issue Record cover Sheet l[
A form (DAP-2-1) prepared by the Design Adequacy Review Team that identifies the source document for an attached set of Issue Records (See Attachment A).
3.1.21 Construction /QA/QC (QOC) Issues Log l[
A form (DAP-2-2) prepared by the Design Adequacy Review l Team during the review of External source documents that lists issues that are within the scope of the QOC Program -
(See Attachment B). Use of this form is optional.
3.1.22 Discrepancy / Issue Resolution Report (DIR) l[
A form (DAP-2-4) prepared by the Design Adequacy Review Team for entry in the Tracking System to track the status, ld classification and resolution of all open issues and of all discrepancies identified during conduct of the DAP (See Attachment D).
TN-85-6262/2 Page 11 of 57 l
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE ,
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: S ISSUES AND DISCREPANCIES 3.1.23 Issue Resolution Report (IRR) lh A type of engineering evaluation prepared in accordance with DAP-8 that provides an integrated summary of the concerns expressed in DIRs and that sets forth the criteria by which DAP will evaluate any proposed corrective action. .
3.1.24 Primary Issue lk A DIR that is originated (or revised) to reflect all aspects of (1) duplicate External source Issues ("E" type DIRs), (2) duplicate DAP-identified discrepancies that are found to have been entered in the DAP Tracking System ("D" type DIRs), or (3) "E" or "D" type DIRs that are not duplicates but are related to a technical or programmatic design issue and are grouped into a single DIR. Related i O DIRs may be grouped as an input to an IRR, as documentation
- of a trend or as a compilation of DIRs that facilitates evaluation, resolution, or closure regardless of whether the primary DIR is included in an IRR or a trend. A l primary issue DIR that is the subject of an IRR may be classified as an unclassified deviation, a programmatic deficiency, or other classification as appropriate.
.3.1.25 "C" Type DIR A computer record subject to in-process revision in the general format of Form DAP 2-4 that documents a discrepancy found as a result of DAP overviews of corrective action. '
These DIRs are not part of either the External Source Issue review or' the self-initiated part of the DAP. Section TN-85-6262/2 Page 12 of 57
j COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE I Number: DAP -2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES 5.5.8 defines the information required in "C" DIRs. "C" DIRs are open until adequate information is received to allow resolution of the DIR. -
3.1.26 "T" Type DIR A computer record subject to in-process revision in the general format of Form DAP 2-4 that documents selected evaluations done outside the DAP in response to a problem related to design. Sections 5.5.7 defines the information required in "T" DIRs.
3.1.27 "D" Type DIR l
A computer record subject to in-process revision in the d
format of Form DAP 2-4 that documents a discrepancy (or other classification including programmatic deficiency) identified either by the self-initiated portions of the DAP or by third-party investigations of External Source Issues.
3.1.28 "E" Type DIR ,
A computer record in the format of Form DAP 2-4 that A
documents open Issue Records (Form 2-3) in a format that allows resolution. (Note: Issue Records record the historic statement of the issue as expressed by the external source. Issue Records are not subject to revision other than correction of mistakes, such as computer entry '
d errors, etc.)
TN-85-6262/2 O Page 13 of 57
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES 3.2 Responsibilities P
3.2.1 Review Team Leader The Review Team Leader is responsible for:
o Approving the classification of discrepancies as deficiencies, programmatic deficiencies, unclas-sified trends, or unclassified deviations; ld o Approving the closure of deficiencies, program-i matic deficiencies, and I unclassified deviations; unclassified trends, ld
, o Transmitting deficiencies, programmatic defi-i ciencies, unclassified trends, and unclassified deviations to the CPRT Senior Review Team and to ld appropriate Project personnel.
These responsibilities may be delegated to the DAP Manager.
The Review Team Imader may perform any of the functions of the Reviewers, Discipline Coordinators, the Generic Implications Coordinator or the DAP Manager.
3.2.2 Design Adequacy Program Manager (DAP Manager)
The DAP Manager is responsible fort o Approving the classification of discrepancies as deviations; o Concurring in (or approving, if authorized by the Review Team Leader) the classification of discrepancies as deficiencies, prognimaatic deficiencies, unclassified trends, or unclas-sified deviations; lh TN-85-6262/2 Page 14 of 57 1
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES i
o Approving the closure of deviations; i
o Recommending (or approving, if authorized by the Review Team Leader) closure of deficiencies, l
programmatic deficiencies, unclassified tre.nds, and unclassified deviations; ld
! o Transmitting to appropriate Project personnel on a weekly basis copies of new and revised DIRs that are "D" DIRs "E" DIRs classified as a deviation, unclas-sified deviation, unclassified deficiency, or programmatic deficiency trend, ld I -
"C" DIRs DIRs that were closed.
The DAP Manager may perform any of the functions of the Reviewers, Discipline Coordinators or the Programmatic /
Generic Implications Coordinator.
t 3.2.3 Programmatic / Generic, Implica'tions (PGI) Co-ordinator .
The Programmatic / Generic Implications coordinator (or his designee) is responsible for: l o Assigning numbers to approved Issue Records and DIRs; o Ensuring data entry to the Design Adequacy Program Tracking System; TN-85-6262/2 Page 15 of 57 O
I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: S l lSSUES AND DISCREPANCIES o Revising DIRs to correct or enter missing data as delegated in this procedure or by the DAP manager; o Managing the DAP Tracking System (DAPTS);
l o Issuing periodic status reports to i addressees as determined by the DAP l Managers l
o Ensuring that a DIR is created for each open Issue Record; o Returning unsigned hard copies of DIRs to Discipline Coordinators for review A and potential revisions; 421 o Maintaining an auditable record of all Issue Records, DIRs, and revisions to DIRs in the form th'at they were entered /A ,
in the Tracking System. E '
, O o Performing the Discipline Coordinator's functions related to DIRs generated within the PGT discipline.
3.2.4 Discipline Coordinator The Discipline Coordinator is responsible for:
o Approving Issue Record Cover Sheets, QOC Issues Logs, and Issue Records; o Concurring with the identification of External Source documents which discuss QOC issues; o Approving the status of External Source Issues; o Approving the classification of closed External Source Issues; TN-85-6262/2 Page 16 of 57
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l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES o Identifying duplicate External source Issues or related DAP-identified discrepancies and approving the issues l transfer of duplicate or DAP-identified discrepancies to the primary issue; l
o Approving the classification of open issues as unsubstantiated issues or as discrepancies; o Performing actions for which a reviewer is responsible (section 3.2.5);
o Concurring with or approving DIRE (dependin] upon classification as detailed J.n Section 4);
o Approvino the identification of
) discrepanules that are not explicitly i defined by an External Source Issue; o Approving .the classification of discrepancies as observations; j o Approving the closure of observations; o Concurring in the classification of discrepancies as deviations, defi-ciencies, programmatic deficiencies, unclassified trends, or unclassified deviations; ld o Recommending the closure of deviations; i o Forwarding copies of Issue Record Cover Sheets for documents that discuss Qoc issues, and specifically identified issues requiring clarification as to DAP versus QOC coverage, to the DAP Construction Quality Interface Manager for transmittal to the QOC Interface i l Coordinator (QOC Issued Logs or Issue Records may be included at the discre-tion of the Discipline Coordinator);
I l TN-85-6262/2 Page 17 of 57 i
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j . COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES o Forwarding signed Issue Record Cover Sheets and Issue Records to the Generic Implications coordinator; o Forwarding DIRs for which the recom-mended classification is deviation, deficiency, unclassified deviation, unclassified trend, or programmatic deficiency (including closure of these ld classifications) to the DAP Manager; o Forwarding DIRs and revisions to DIRs to the Generic Implications Coordinator after appropriate approvals have been obtained;
- o Determining whether scope expansion is j required, as directed in DAP-3; o Approving the reassignment of issues or discrepancies to the QOC Program, TRT l Testing Review Team or TRT Electrical l Review Team Programs, and transmitting
< (directly or via the QOC Interface Manager) these issues or discrepancies to the appropriate Review Team Leader; ,
I l o Ensuring that, within his discipline, all open issues, and all discrepancies not explicitly defined by External
, source Issues, are closed prior to the completion of the DAP. -
o Ensuring that machine-printed outputs (hard copies) of DIRs from the DAP Tracking system are reviewed. k 3.2.5 Reviewer The Technical Reviewer is responsible for o , Reviewing External Source documents; TN-85-6262/2 Page 18 of 57 '
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e COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES o Identifying External Source Issues; o Preparing Issue Record Cover Sheets; o Preparing QOC transmittals including Issue Record Cover Sheets, Issue Records, or QOC Issue Logs as appropriate; o Preparing Issue Records; o Recommending the status of External source Issues; o Recommending the classification of closed External Source Issues; o Recommending the classification of open issues as unsubstantiated issues or as discrepancies; o Identifying discrepancies that are not explicitly defined by External Source Issues; o Preparing DIRs and revisions to DIRs; o Recommending the classification of discrepancies; o Reviewing information provided by others to close i'ssues or discre-pancies; o Forwarding Issue Record Cover Sheets, Issue Records, QOC Issues Logs, DIRs, and revisions to DIRs to the Discipline Coordinator.
o Reviewing machine-printed outputs (hard copies) of the DIRs from the DAP A Tracking System for accuracy, and 2 revising them as necessary.
TN-85-6262/2 Page 19 of 57
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES
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! 3.2.6 Construction Quality Interface Manager i
The Construction Quality Interface Manager is responsible for forwarding information received from the Discipline coordinators on Qoc issues to the appropriate Qoc program interface person, and for maintaining a record or copy of information transmitted to the Qoc Program. (Interfaces with the TRT Testing Review Team or the TRT Electrical Review Team are the responsibility of the DAP Discipline Coordinator who identifies an issue that should be trans-
! ferred to either of these teams.)
3.2.7 TRT Issues Manager .
j The TRT Issues Manager's responsibilities for signing DIR l
forms are the same as the DAP Manager's responsibilities, ,
to the extent that DIRs are generated in the course of TRT ,
reviews. In these cases, this procedure applies to the TRT Issues Manager wherever the term "DAP Manager" appears..
4.0 INSTRUCTION .
Effective Date: For the purpose of entering referencer, in the tracking system data base for Action Plan numbers, '
Review Topics, HDA numbers, or CPSES Project-assigned TDDR numbers, Revision 4 of DAP-2 is considered to have been effective since August 4, 1986.
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TN-85-6262/2 Page 20 of 57
l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES 4.1 Identification of External Issues 4.1.1 General The identification of issues is accomplished by the systematic review of documents which describe concerns l related to the design or design process (External Source
- documents). Identification of External Source Issues is an
- on-going activity throughout the DAP.
The Reviewer shall complete an Issue Record (using attached i Form DAP-2-3) for each issue related to the design or design process, regardless of the indicated status of the issue. This shall include issues identified by the Qoc (including QA/QC) Review Team or other TRT Review Team and transferred to the Design Adequacy Review Team for evalua-O tion.
l If, during the initial source document review, it is j apparent that an issue has both technical and programmatic components, these components may be documented on a single Issue Record. ,
lk 4.1.2 QOC or Other TRT Review Team Issues Where an issue is noted by the DAP reviewer to be poten-tially relevant to the Quality of construction (QoC) program or other TRT review team, it shall be documented in one of the following forms:
By noting on the Issue Record Cover Sheet (Form DAP-2-1) that construction TN-85-6262/2 Page 21 of 57
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES or other TRT review team issues are discussed within the document.
By noting on the QOC Issues Log (Form DAP 2-2) or Issue Record (Form DAP-2-3) specific issues that require confirm- i ation that they arm or are not covered within the scope of the QOC or another CPRT Program. This will typically be done for issues that are not included in the scope of the DAP and where it is uncertain that they are covered in the scope of the QOC or enother CPRT Program.
By any combination of the above.
i j 4.1.3 Determination of Issue Status For each design issue, the Reviewer will make a determina-tion as to whether the issue is open or closed using the O criteria specified in paragraph 3.1.3.1. Any issue l considered unresolved by the External Source will be
! designated open under the DAP.
l If the issue is determined to be open, Part 1 of the Issue Record will be completed to the extent appropriate based on External Source document contents in accordance with paragraph 5.4.1.
If the issue is determined to be closed, the issue will be classified and Parts 1 and 2 of the Issue Record will be filled out as completely as possible.
TN-85-6262/2 Page 22 of 57
_ _ _ _ - . _ . . _ . _ . _ _ _ _ _ . _ _ _ . _ _ _ . _ _ __ _ _ ~ _ __ __. ._ _ _ _ . _
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE I
I Number: DAP-2
Title:
DOCUMENTATION AND TRACKINC OF Revision: 5 ISSUES AND DISCREPANCIES 4.1.4 Disposition of Issue Records '
When the review of a source document is complete, the i Reviewer shall attach an Issue Record Cover Sheet (using '
i attached Form DAP-2-1) to the complete set of Issue Records. The package will then be submitted by the Reviewer to the Discipline Coordinator responsible for the
- review. The Coordinator responsible for source document
! review will forward portions of the package to the appro-priate DAP Discipline Coordinator for review and approval ,
of External Source Issues within that discipline. Upon approval of these External Source Issues, the Discipline Coordinator will forward his portion of the package
. (including Issue Records with original signatures that
! apply to his discipline) to the Generic Implications O Coordinator for entry into the DAPTS.
Issue Record Cover Sheets shall be retained in auditable Issue Records and )
- files by the Ge7eric Implications Coordinator. As use of Qoc Issues Iogs is optional, there is no requirement that j files of Qoc Issues Iags be auditable.
l .
! If any QOC issues are identified, the Discipline Coordina-tor responsible for initial source document review will I send a copy of the relevant documentation described in j section 4.1.2 to the Qoc Interface Coordinator via the DAP Construction Quality Interface Manager. If issues identi-fled are determined within the DAP to be within the purview
(
1 of a TRT review team, the Discipline Coordinator will send l a copy of relevant documentation to the appropriate TRT Review Team Leader. All issues that are entered in the DAPTS and then transferred to another review team shall be 1
( TN-85-6262/2 Page 23 of 57 4
i
l *
. COMANCHE PE AK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE 1
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES closed in the DAP tracking system with reference to the transfer memorandum added to the DIR.
1 For each open issue, the Generic Implications Coordinator (or his designee) will transfer the information from the l Issue Record to an unsigned DIR and forward two copies of
! the DIR to the Discipline Coordinator responsible for the l Action Plan designated in the DIR. The Discipline Coordi-
! nator shall distribute one of these copies to the Reviewer to whom he assigns responsibility for review of the Issue Record.
1 The Discipline coordinators will review the initial set of j DIRs for duplicate issues and will, by revision of the DIRs, designate (in the status field) duplicate issues as l
4 . " transferred to" and indicate the issue number per Sec-tion 5.5.2 to which the duplicate was transferred (the primary issue). There are different methods by which a primary issue may be created. The easiest method to describe a primary issue should be used without creating i
additional, unnecessary paperwork. Regardless of the method used, all fields that are filled in on the primary issue should be checked for accuracy and revised as i-necessary.
j o An existing E-XXXX ("E" type) DIR that l encompasses the duplicate issue records i may be designated as the primary issue j without revising the content of the primary DIR; o An existing E-XXXX DIR that does not
. completely encompass all aspects of 3 duplicate issues may be revised to l
l l
TN-85-6262/2 Page 24 of 57 1
l 4
+e-,rn--v.,,, .--.---. _ _ _ --,e.,m- ,r- n,. , _ . - - - - - - - - - - - - - - - -
I .
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES O
reflect all aspects of duplicate issues and to state in the " Description" block i that this DIR is the primary issue and reflects duplicate issues, or; o A new E-XXXX DIR may be written as the primary issue with the issue descrip-tion stating that this DIR is a i compilation of duplicate issues and encompasses all aspects of duplicate issues. If a new DIR is created, a new E-XXXX number for the primary issue shall be assigned by the Generic
! Implications coordinator (or his
, designee) for entry in the " transferred to" block of duplicate issues.
, During the first revisions to the DIR, each open issue
) shall be classified as a discrepancy unless the DIR was i
revised to reflect another classification because addi-tional or revised information developed during the review .
process. If it is determined that the DIR is not a DAP-I related issue, no classification is needed. The revised DIR cannot be accepted if the issue is not classified, unless the DIR is transferred to a primary DIR or to a CPRT d ,
l
{ team outside the DAP. To be classified as an observation, the issue must be designated as closed, and a description of resolution (why the DIR is closed) must be included on the DIR.
The Discipline coordinators will send the revised (signed)
DIRs (both duplicate and primary issues) to the Generic Implications coordinator for entry into the DAPTS and -
i i
retention in the file of Tracking system input forms. ld i
TN-85-6262/2 Page 25 of 57 i,O i
l i
- . . , ~ _ , . . _ . - _ . . . . - - _ . , . _ . - - - . , _ _ . - - __ .. -- - - - - , , _ _ - - - -
- COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number
- DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES i 4.2 Identification of Discrenancias by DAP Self-Initiated
- Procram Reviewers shall prepara a new DIR for each discrepancy that is found during implementation of a'self-initiated part of Discipline specific Action Plan (DSAP) . Revision 2 of form DAP-2-4 shall be used for DIRs originated by reviewers after March 31, 1986. DIRs originated before April 1, j
1986 may be done using Rev. O of DAP-2-4 and need not be rewritten on a Rev. 2 form. There is no Rev.1 of DAP-2-4.
Do not use Rev. O of DAP-2-4 after March 31, 1986. Future
- revisions of DAP-2 forms shall be used for DIRs originated after the effective date of the revision to DAP-2.
i If originated within the DAP, the DIR (D-XXXX DIR),
l including any supplementary sketches, notes and explanatory
{ information, shall be prepared with the objective of >
j allowing a person not familiar with the work, but techni-l cally qualified, to understand it without extensive
- additional inquiry and research. Supplementary sketches,
{ notes, and explanatory information shall be a part of I
I discipline files. The DIR sh'all describe the content of.
j .
this additional information relative to the discrepancy so that by itself the DIR describes the discrepancy. If the DIR is an External Source Issue, the details of the i description are based on information contained in the f External Source document. These details may not be
- sufficient to enable a technically qualified person to j understand the issue without further inquiry or research.
i l
i TN-85-6262/2 Page 26 of 57 i
I j * ,
l
COMANCFE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES The Discipline Coordinator shall review, approve, and sign the DIR that describes the discrepancy and forward the DIR l to the Generic Implications Coordinator for entry to the DAPTS and retention in the file of Tracking System input forms.
If, during the implementation of an Action Plan, it is determined that the issue / discrepancy under review should be reassigned to the QOC Program for resolution, the issue / discrepancy will be designated as closed, and a copy of the DIR will be forwarded to the QOC Interface Coordina-tor by the DAP Construction Quality Interface Manager after approval by the Discipline Coordinator. If an issue / dis-crepancy should be reassigned to another TRT review team l (Testing or Electrical), the DIR will be closed in the DAPTS and sent to the appropriate Review Team Leader by the Discipline Coordinator. Issues / discrepancies that are transferred to another Review Team need not be classified k within the DAP. I 4.3 classification of Discrenancies
- i When sufficient information has become available, the j reviewer shall classify each discrepancy as either an I
observation or a deviation. The classification will be documented by the reviewer through revision of the DIR. If I
classified as an observation, the DIR aust also be marked closed and the description of resolution included, as no l further action other than trending will be taken by the DAP regarding the observation. Recommended actions by the
- TN-85-6262/2 Page 27 of 57 j
l i
i
- COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES CPSES Project will not be included in the description of resolution field in the DIR.
Issues classified as unsubstantiated or as discrepancies, and discrepancies classified as observations, require the signature of the reviewer and the approval signature of the Discipline coordinator on the DIR.
classification of a discrepancy as a deviation requires the j signature of the reviewer, the concurrence signature of the Discipline Coordinator, and the approval signature of the DAP Manager on the DIR. .
If the discrepancy is determined to be a deviation other than an unclassified deviation, it will be evaluated for safety significance, as required by DAP-22. Several 2
deviations may be combined into a primary DIR and covered by a safety significance evaluation of that primary DIR.
d If the deviation is determined to be a deficiency or an unclassified deviation, the DIR will be revised to reflect !
this new classification. All deficiencies, programmatic deficiencies, unclassified deviations, and unclassified trends will be evaluated for root cause and generic d
implications, as required by DAP-7. The revision requires the signature of the reviewer, the concurrence signature of the Discipline coordinator and Design Adequacy Manager, and the approval signature of the Review Team Leader.
For a DIR to be classified as an unclassified deviation, or TN-85-6262/2 Page 28 of 57
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES
- unclassified trend, the reviewer shall verify that program undertaken by the CPSES Project does encompass a a
ld
- review of all aspects of the discrepancy. The DIR shall I contain in the reference block a reference to a procedure, document, plan, etc., that contains evidence that the discrepancy will be addressed. After this verification and documentation on the DIR is complete, the DIR may be !
approved as an unclassified deviation, or unclassified t
trend, in an open status. After evaluations of root l
! cause/ generic implications (DAP-7) and any necessary
! corrective action plan (DAP-20) have been completed by the i
DAP, the unclassified deviation or trend shall be closed, lk provided it meets other conditions for closure per this procedure.
l l
If the DIR documents an adverse trend, the DIR shall be classified as a programmatic deficiency and shall receive ;
the same concurrence and approval signatures as a defi-ciency, described in this Section 4.3.
I If the DIR documents a subject.to be addressed in an Issue Resolution Report (IRR), the "D" type DIR shall be written as a primary issue similar to a primary External Source j Issue discussed in Section 4.1.4. Non-primary "D" type DIRs or non-primary External Source Issues "E" type DIRs that are related to the primary issues in an IRR shall be !
" transferred to" the primary issues addressed in the IRR in i a manner similar to that set forth in the part of Section ;
4.1.4 regarding combination of issues. The primary issue !
DIR related to an IRR shall be written after DAP acceptance !
I of the proposed corrective action (see DAPs 8 and 20) . If l l
l TN-85-6262/2 Page 29 of 57 :
1
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
- Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 l ISSUES AND DISCREPANCIES I
primary issues that are addressed in IRRs are deficiencies, unclassified deviations, or programmatic deficiencies (adverse trends), the requirements of DAP-7 shall be met.
I Regarding documentation of a trend evaluation, a DAP-7 trend evaluation or authorized substitute, such as genera-tion of an IRR (and a trend evaluation form DAP-7-1) shall be conducted to document an identified, possibly adverse trend. "D" type DIRs may be written or designated as primary issues irrespective of whether they are included in an IRR.
.4.4 Revisions Revisions to DIRs shall be made, verified, approved, and signed in the same manner as the original document.
Revised DIRs with necessary approvals completed shall be O forwarded to the Generic Implications coordinator for entry into the DAPTS (replacing the superseded re'tision) and retention of the signed revision in an auditable file. The active DAPTS will contain only the most current revision of DIRs.,
The Generic Implications coordinator may be delegated authority to revise DIRs to incorporate new or revised information that is primarily used for sorting and indexing
, purposes (e.g., HDA numbers, review topic numbers, design j activity, IRR numbers, etc.). The Generic Implications Coordinator is authorized to add TUGCO-supplied TDDR numbers to the DAPTs without revision of the DIR, and to h
revise any DIR to correct a data entry error.
l l
TN-85-6262/2 Page 30 of 57 O
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES Two hard copies of the revised DIR (with blank date blocks but with typed names of signators on the last revision) will be returned to the Discipline coordinator after entry into the DAPTs. The Discipline Coordinator will distribute one copy to the reviewer who is assigned responsibility for the DIR. Subsequent revisions will be made, after review of the DIR, by mark-up and signatures on a copy of the j then-current DIR.
4.5 Data Entry The Generic Implications Coordinator (or his designee) will ensure that the information from each approved Issue Record, DIR, and DIR revision is entered into the DAPTS and verified. Codes and descriptions of codes currently in the DAPTS will be distributed periodically by the Generic Implications Coordinator (or designee) to the DAP disci-i plines.
After verification that the information contained in the DAPTS is accurate, the signed, originals will be filed in the controlled DAP Tracking System input files by a DAP Tracking System operator responsible to the Generic lg Implications Coordinator.
Externally resolved issue numbers (R-XXXX), open issue numbers (E-XXXX), and DAP identified discrepancy numbers (D-XXXX) will be sequentially assigned by the Generic Implications coordinator (or his designee) . These identi-fication numbers will be noted on the Issue Records and l DIRs along with the date of entry into the DAPTS.
TN-85-6262/2 Page 31 of 57
_- -_. . , - - _ - . - - - - - .__,.m _ _ _ - . _ _ _ _ - . _ - _ . _ _ . . _ , _ _ , - _ , , _ , _ . _
r_.7 -y-.....m_._
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES Issue / discrepancy numbers remain unchanged throughout the conduct of the DAP except as necessary to implement changes in the DAP Tracking System structure.
4.6 Disnosition of DIRs I
When the reviewer has completed the preparation or revision of the DIR, the reviewer will sign the DIR and submit it to the appropriate Discipline Coordinator for disposition.
l The Discipline Coordinator will ensure that all required signatures and approvals are obtained as delineated in Section 3.2 of this procedure and depicted in Figure 2.
I When the DIR has been approved, the Discipline Coordinator will forward it to the Generic Implications Coordinator for entry into the DAPTS.
j Each week the Generic Implications Coordinator (or his l designee) will forward hard copies of new and revised DIRs (that meet one of the following conditions) received during that -week to the DAP Manager for forwarding to appropriate Project personnel. The conditions for DIRs transmitted ares o All DIRs that were closed during that week regard:ess of classification; o All open D-XXXX DIRs that were opened or revised during that week; o All E-XXXX DIRs that were classified during that week as a deviation, unclassified deviation, deficiency, or ,
programmatic deficiency; t TN-85-6262/2 Page 32 of 57
RESPONSIBILITY F N CLASSIFICATION C SFC O AND CLOSURE l
EXTERNAL AP RESULTS SOURCE NOT EXPLICITLY DEFINED ISSUE BY EXTERNAL SOURCE ISSUE CLOSED OPEN DISCIPLINE i
COORDINATOR UNSUBSTANTIATED DISCREPANCY O OBSERVATION DAP MANAGER N
DEVIATION REVIEW TEAM PROGRAMMATIC UNCLASSIFIED DEFICIENCY LEADER DEFICIENCY DEVIATION FIGURE 2 RELATIONSHP BETWEEN CLASSIFICATION AND APPROVAL AUTHORITY O Page 33 of 57 TN-85-6262/2
i COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AN,D DISCREPANCIES o All C-XXXX DIRs that were opened or revised during that week.
The DAP Manager will request that TUGC0 advise him of the TUGC0 Design Deficiency Report (TDDR) number assigned by TUGC0 to each D or E type DIR sent to TUGCO. Upon receipt ,
of TDDR numbers from TUGCO, the Generic Implications Coordinator shall ensure that these TDDR numbers are entered in the corresponding DIRs in the DAPTS. This may be done without revising the DIR.
i Upon receipt of a DIR that has been classified as a deficiency, programmatic deficiency, unclassified devia-tion, or unclassified trend, the Review Team Leader will, .
l within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of approval of the DIR, transmit a copy of
! the DIR to the CPRT Senior Review Team and to appropriate i Project personnel.
=
4.7 Connarison of External source Issues and DAP Discre-mancies with Annrenriate CPSES Proiect Records of Discrepancies i
In order to incorporate CPSES (Project) records of discre-i pancies for comparison purposes into the DAP, appropriate project records will be reviewed. Periodic checks will be conducted to determine whether new project records warrant review, and preparation of "T" Type DIR if appropriate.
d These records may include documented evaluations done pursuant to 10CFR 50.55(e) and 10CFR 21 and other histori-cal records of evaluations (such as Significant Deficiency Analysis Reports (SDARs)) regarding design problems that TN-85-6262/2 Page 34 of 57
.-_.--w ,
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
! Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 I -
ISSUES AND DISCREPANCIES are relevant to the DAP. The purpose of these DAP reviews is to capture information regarding project-identified design problems in a format that is consistent with DAP data on External Source Issues ("E" type DIRs) and DAP identified discrepancies ("D" type DIRs). The information taken from DAP review of project records may be used in DAP trend evaluations and Issue Resolution Reports (IRRs) even 1 though CPSES project-identified discrepancies do not constitute a portion of DAP-identified discrepancies. In
- order to facilitate direct comparison of project records with External Source Issues and DAP-identified discrepan-
.cies for trending purposes, selected project records will be documented in the format of DAP "D" type DIRs. The Generic Implications Coordinator shall assign a unique sequential number with a "T" prefix (T-XXXX) to each such '
computer record. The identification number and date of l entry into DAPTs will be noted on the DIR form. Specific 3 entries on "T" type DIRs are covered in Section 5.5.7.
i .
l These "T" type DIRs do not require resolution by the DAP because they represent only, documentation of project l findings and, through project resolution mechanisms, will l be resolved. "T" type DIRs will not become part of the DAP l
Tracking System as committed to in the CPRT Program Plan or other CPRT documents, and all entries required on "D" type DIRs are not required on "T" type DIRs. As a separate data base, however, "T" type DIRs will be available for use by
- the DAP in trend evaluations and IRR development.
TN-85-6262/2 Page 35 of 57
. _ . .- ~_.- . _. . _ ._ __
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEGUACY PROCEDURE Numbe.r: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES 4.8 Discrenancies Identified Duriner overview of Corrective Actions Discrepancies in corrective actions identified during overview activities are significantly different from External Source Issues or discrepancies that are identified l by the DAP during the self-initiated portions of the DSAPs. j
! Because these areas of design are subject to reverification l
or redesign, there is a need only to describe and track -
l l these discrepancies to closure as part of the corrective
, action overview described in DAP-20. There is no need to j develop or raccrd all of the information required of 1 l discrepancies identified in the self-initiated parts of the I
DSAPs because trending and root cause and generic implica-tions evaluations by DAP are not applicable to corrective action activities. The information required to be docu-mented on the corrective action ("C" type) DIRs is con-1 tained in Section 5.5.8.
. 5.0 DOCUMENTATION l
~
5.1 Summary Issue Record cover Sheets, Issue Records, QOC Issues Logs (if used) and DIRs shall be prepared using the attached forms. All pertinent irformation shall be documented clearly and completely as required for each different form and each type of DIR as specified in this Section 5. A flow chart of a typical report generation process for External Source Issues and self-initiated "D" type DIRs is contained in Figure 3. This example process does not TN-85-6262/2 Page 36 of 57 m
y--9 ep w e v e W-es-y- yyr-- w wy, y,'mMFw_ -N'W- - = = ' - = * ' ^ ^ ~ - - ^ ' " * ' - " " ~ ~ ^ - ^ - " " " ' - - - " "
OPEN EXTERNAL ACTION PLAN J SOURCE ISSUES IMPLEMENTATION I
1 F OPEN WS '
EXTERNAL ISSUES Dl5CREPANCY/155UE RESOLUTION SUBSTANTIATED REPORT: CLA55tFY 155UE5 Af JD 7 7 ACTION PLAN RESULTS NOT COVEREDIN155UES AS l No OC 7 DISCREPANCIES YE5 CLOSE 155UE ON DISCREPANCY /
155UE RESOLUTION OTFER EVALUATE PER ACTION PLAN REPORT DISCREPANCIES REVl510N OR EXPAtJ510N
% g .
T DATA ENTRY p
NO UPCRADE CLA551F CATION DOCUMENT 155UE DISC.
CLOSURE IN COORD.
Di$C. 15C. COORD. - CONCUR RESULT 5 REPORT COORD. DAP MCR. . CONCUR j APPROVE YES RTL . APPROVE
! 1 F SIGN SRT . REVIEW
" REVISE DISCREPANCY REPORT CLOSE DISCREPANCY
+
A5 OBSERVATION UPCRADE TO DEVIATION 155UE CLOSED (wlTH OR WITHOUT l UNSUBSTANTIATED COPMECTivE ACTIOM IN Rt VISED Dl5CREPANCY/155UE 4T
.L T
RESOLUTION REPORT COPY TO PROKCT DATA ENTRY W/ REQUEST FOR TDDR#
DATA ENTRY DATA ENTRY TDDR#
FROM PROKCT 1 P ,
DOCUMENT IN DISC.
RESULT 5 REPORT COORD.
DIRECT NO -
CORRECTIVE A ACTION I
155UE/00$ERVATION CLOSED UNCLAS$1FIED DEVIATION O FIGURE 3 TN-85-4262/2 CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW Page 37 of 57
EVALUATE PEft ACTION PLAN
, .O REVISION OR EXPANSION EVALUATE SAFETY p SIGNIFICANCE I
i YE5 OTER NO C DISCREPANCIES y T
S V NO UPCRADE CLA551FICATION CLO5E DISCREPANCY ygg A5 DEVIATION (WITH DISC.
CORRECTIVE ACTION COORD. -
EVALUATION)IN RE- CONCUR, DISC. COORD. - CONCUR I VISED DISCREPANCY / DAP MCR. REVISE DISCREPANCY REPORT DAP MCR. - CONCUR
, 155UE RESOLUTION APPROVE UPCRADE TO DEFICIENCY RTL - APPROVE i REPORT SRT - REVIEW
+ +
DATA ENTRY COPY TO PROJECT DATA ENTRY W/ REQUEST FOR TDOR#
1 I DOCUMENT IN DISC.
RE5 ULT 5 REPORT COORD. DATA ENTRY
. TDDR#
FROM PROJECT 1
ISSUE /DEVIATlON EVALUATE PER ACTION PLAN REVl510N OR EXPAN510N b CRAMM T C DEFICIENCY) l l EVALUATE ROOT CAUSE/
l CEERIC IMPLICATlONS i
FIGURE 3 (Continued)
CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM i
DISCREPANCY / ISSUE RESOLUTION REPORT FLOW l TN-854262/2 Page 38 of 57
o T IDENTIFY / EVALUATE CORRECTIVE ACTION PLAN DATA ENTRY j I i
1 V EVALUATE CORRECTIVE ACTION IMPLEMENTATION i ORRECTIVE ACTIOt ACCEPTABLE
?
YE5 1 P CLOSE DISCREPANCY AS DEFICIENCY, UNCLA551FIED DEVIAflON OR PROGRAM. DISC. COORD.
MATIC DEFICIENCY (WITH CORRECTIVE DAP MCR. CONCLR ACTION EVALUATION)IN REVISED RTL. APPROVE DISCREPANCY /155UE RESOLUTION REPORT SRT - REVIEW O
4 DATA ENTRY DOCUMENT IN DISC.
RESULTS REPORT COORD.
155UE/ DEFICIENCY CLOSED FIGURE 3 (Continued)
CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW TN-85 4262/2 Page 39 of 57
l l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 '
ISSUES AND DISCREPANCIES l include the preparation of IRRs.
All records retIuired by DAP General File No. 4.0 or subfiles shall be maintained in the TERA Bethesda Office under the control of the PGI Coordinator. Copies may be maintained at other DAP work locations as desired.
5.2 Issue Record Cover Sheet The Source Document Title field will include the complete title of the document reviewed. For untitled documents (e.g. , letters) , the field will indicate that the document is untitled along with the subject, or contents, of the document.
The originating / Investigating organization field will iO contain the name of the organization which issued the document being reviewed.
i Each External Source document reviewed will be assigned an
- identification number by the QAP. The Document I.D. field will contain this CPRT identification number. A f cross-reference between Document I.D. and the title o'r description of the External Source document shall be maintained.
The Description field will contain any additional informa-tion needed to describe the document, including any document ID number assigned by the issuing organization.
The Addressee Organization field will contain the name of TN-85-6262/2 Page 40 of 57 O
j COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES the organisation to which the document is addressed (if l applicable). ,
l I l The Document Data field will contain either the date of issuance of the document or, if the document is a meeting transcript, the date that the meeting was held.
i The number of Issue Records that are attached to the Issue Record Cover sheet shall be recorded in the space provided.
[, Upon completion of the Issue Record Cover Sheet, the
! Reviewer and the Discipline Coordinator shall sign this
, cover sheet to indicate their reviews are complete.
f 5.3 00C Issues Log
- O If the Reviewer elects to use the QOC Issues Log, under the guidance of section 4.1.2, the log can be used to either summarize the issue or refer to specific Issue Records
- which describe the issue in greater detail.
I .
! If the Qoc Issues Log is used, it shall be signed by the Reviewer and the Discipline Coordinator.
i 5.4 Issue Record
} Issue Records (Attachment C) are divided into 2 parts.
- only Part I need be completed for open issues. Both Parts l 1 and 2 will be completed for closed issues and may be used
! for open issues. Since the Issue Record documents a i " snapshot" of information contlined in the External Source i
l TN-85-62C2/2 Page 41 of 57 i
! I
.-n-,
I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES l document, the Issue Record does not have a provision for revision. It contains historical "as found" information.
The maximum number of characters allowed for each field is indicated on the Issue Record. Continuations beyond these maximum numbers of characters are acceptable. Continua-tions will be made available with DIRs by placing them in a notebook at each tracking system terminal, or as an alternative in the future will be accessible within the
, computerized DAPTS. They are identified by DIR number, i
issue name, and. revision number (if Rev. 1 or above).
!~ Continuations may be entered in the DAP tracking system, j
(if they are text), or may be appended to output DIRs if they are an exhibit such as a calculation or sketch.
k l The Date Entered DAPTS and Issue $ fields shall not be
- completed by the Reviewer except when an E-XXXX DIR number
- is received from the PGI Coordinator for a new primary
! issue. Otherwise, these fields shall be completed at the '
time of data entry into the DAPTS.
5.4.1 Part 1
- This part of the form will be completed for each issue identified during review of each source document.
A brief title for the issue will be entered in the Issue Title field. The title should summarize the issue descrip-tion (e.g., what is wrong and what is affected) to the extent that this information is included in the External Source document, so that those familiar with the review may TN-85-6262/2 Page 42 of 57
' 1
! 1
! COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i i
! Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 '
ISSUES AND DISCREPANCIES 'i identify the issue by its title. Keywords may be used in the title. Potential cause of the issue should not be used es a title.
A complete description of the issue, to the extent that it is documented in the source document, will be written in the Issue Description field. Failures to meet specific project criteria and procedures should be identified to the l extent they are specified by the source document. The j source of any information not taken directly from the
], source document shall be included in the description.
) Comments including resolution status as contained in the l source document may be added in the Description of Resolu-tion / Comments field of Part 2 whether or not the issue status is closed.
l The page number of the source document on which the issue is discussed, along with the External source Issue identi-l fier number (if applicable), will be entered in the corresponding fields. ,
The structure (s), system (s) , or component (s) affacted will i be identified if it can be readily determined from the source document. This identification may include compon-ents, component types, system names, locations, or struc-tures.
i ,
j The CPRT document identifier number will be entered in the
- DOC. ID field.
l l
TN-85-6262/2 Page 43 of 57 i l l
1 i <
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEGUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES
~
The status of the issue (as determined by the DAP) will be entered in the status field. open issues must have an Action Plan number and revision entered in the corres- l ponding fields.
If the issue has been determined to be closed, the classi-
! fication of the issue will be indicated in the classifica-i tion field. If closed due to transfer to another Review Team, the issue need not be classified.
i The DAP discipline will be identified. For disciplines comprised of subdiscipline areas of design in DAP-7, Attachment A, the subdiscipline will also be documented if
- contained in the External Source document. Additional l subdisciplines may be designated.
l '
l For open issues, and for closed issues that are not
- classified as unsubstantiated, it is noted on the Issue i
Record whether the source document states that the issues i a Is an isolated error or has potential i
generic implications; o May have potential cumulative effects -
with other issues; o Is considered to be a technical or programmatic concern.
If this information cannot be readily determined, the field will be left blank. Attachment E contains guidance on
- interpretations of these terms.
i l
TN-85-6262/2 Page 44 of 57 i
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 l
- ISSUES AND DISCREPANCIES O For open or closed substantiated issues, the design
~
- organization and design activity will be documented if that l information can be readily determined from the source 1 document. The design organization is the organization originally responsible for the work affected by the issue.
l The Design Activity field refers to design requirements
! discussed in ANSI N45.2.11-1974 and Attachment F of this procedure.
l For open issues, the number of the Action Plan (including i
the revision number) under which the issue will be investi-j gated shall be written in the indicated fields.
I I If the open issue is to be evaluated within a self-initi-
'hted part of a DSAP, the most appropriate Review Topic and Homogeneous Design Activity (HDA) numbers within that DSAP - -
{
any be entered. If the area of design associated with the issue is to be addressed in an area of the design that is ld l
i subject to reverification or redesign (e.g., piping and pipe supports, cable tray supports or conduit supports) l Review Topic and HDA numbers are not required because
! Review Topics and NDAs do not apply to those areas of j -
design that will undergo reverification or redesign. If Review Fopic and HDA numbers are not required, enter either l "NA" in both of these fields or, at the Discipline Coordi-nator's option, an appropriate Review Topic or HDA or other code, such as PPS for piping and pipe support issues.
l 1
i I
! TN-85-6262/2 , Page 45 of 57 l
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- - - - , . -. -,,,n_------
, i COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES l 5.4.2 Part 2 This part of the form will be completed (to the extent required based upon classification of the issue) for all l issues determined to be closed during document review.
The basis for determining that an issue is closed will be documented in the Description of Resolution field. This >
field shall also document any corrective action identified in the source document by the originating / investigating organisation to resolve the issue and any additional l' . clarifying comments that the reviewer determines are .
j necessary to document closure of the Issue Record. I l The safety significance field documents the safety signifi- ,
) cance of the issue if the originating / investigating l organisation described safety significance in the External i
source document.
[ The Root Cause field documents the root cause of the issue j if determined by the originating / investigating organisation j and described in the source document. If any generic
! implications are discussed in the source document, the'y l should be included in this field.
l 5.4.3 sign-Off Upon completion, to the extent possible, of the Issue Record, the Reviewer shall sign at the bottom of the Issue Record. The Discipline Coordinator shall also sign to indicate that the review is complete. Signatures (not TN-85-6262/2 Page 46 of 57 i
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES
, initials) are required on the Issue Record (and DIR) forms as of April 1, 1986. Initials of the Reviewer and Dis-cipline coordinator are acceptable on Issue Record and DIR forms prior to April 1, 1986 (in lieu of signatures) based on past revisions of this procedure.
5.5 Discrenanev/ Issue Resolution fDIR) Renorts
- 5.5.1 "D" Type DIRs 4
1 , The DIR contains information that is similiar to informa-i tion contained in Ext.arnal source Issue Records, but the DIR information is active rather than historical. Active DIRs are comprised of External Source Issues that were identified initially as open and all issues identified in the self-initiated parts of the D8APs and documented in "D" type (D-XXXX) DIRs. Differences between the DIR fields and the Issue Record fields are described below.
1 The revision number of the DIR shall be indicated in the l Revision field. The original DIR will designated as I
Revision 0.
The "APG From" field is used only for discrepancies that are not explicitly defined by External Source Issues. This field will contain the Action Plan number (ISAP or D8AP) under which the discrepancy was identified. For External
- source Issues, the field will contain "N/A" (not applic-l able).
l 1
TN-85-6262/2 Page 47 of 57
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES The "APf To" field will indicate the Action Plan number under which the issue or discrepancy is being investi-gated. For example, a discrepancy identified during implementation of a TRT ISAP may be assigned to that ISAP or to a DAP DSAP if it is appropriate to evaluate the discrepancy as part of the DSAP.
The " Dependent On" field will contain a list of issue or discrepancy numbers which must be rotolved prior to closure of the issue or discrepancy described on the DIR.
The Design Discipline and Subdiscipline, Type, Trend (if identified and documented in a DAP-7 trend evaluation or acceptable substitute, such as on IRR), Design Organisa-tion, and Design Activity fields shall be entered during '
the course of evaluating or revising DIRs classified as an
!O observations, deviations, deficiencies, programmatic l deficiencies, or unclassified deviations. Attachment E j contains guidance on interpretation of entries in the Type l and Trend blocks. Attachment F contains guidance on use j l and interpretation of the Design Activity blocks. ,
l l If the DIR resulted from implementation of a self-initiated
! portion (not corrective action overview) of a Discipline !
Specific Action Plan (DSAP), affected Monogeneous Design '
Activity number (s) and the Review Topic number shall be entered. For DIRs that describe technical issues and that :
originated from External source Issues or DAP activities, !
I other than DSAP implementation of overview of corrective I actions, the NDA number and Review Topic most closely i related to the DIR shall be entered in Rev. O of "D" type TN-85-6262/2 Page 48 of 57
(
COMANCHE PEAK RESPOhSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP.2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES DIRs or may be entered in a revision of "E" tyh DIRs. lg Documentation related to such revisions shall be filed in the DAP tracking system file or annotated on the signature copy of the revised DIR. Since HDA and Review Topic numbers do not apply to the Piping Discipline, PPS will be entered in HDA and Review Topic numbers on DIRs assigned to 1
this discipline. Review Topics and HDA numbers may not be applicable to other areas of the DAP (e.g., areas subject to reanalysis or design, trends, programmatic concerns) .
In such cases "NA" shall be entered into those locations.
The safety significance field will be completed only for deviations, deficiencies, and programmatic deficiencies, or primary DIRs which encompass DIRs in these former classi-fications. The safety Significance Evaluation will be l conducted in accordance with DAP 22. The Root cause/ Generic Implications field will be completed for unclassified deviations, unclassified trends, deficiencies, .
and programmatic deficiencies per DAP-7. This information is not required on the DIR revision that initially classi-fies the discrepancy, but may.be developed during evalua-tion of the issue and entered in a later revision to the DIR.
1 Prior to closure of any DIR originated from an External source Issue or self-initiated DSAP review (other than
" Transferred tos" open, closed or duplicate DIRs), all entries on the DIR that are required by this procedure for the final classification of the DIR shall be completed i (e.g., safety significance must be filled in for a TN-85-6262/2 Page 49 of 57
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES l
deviation (or primary DIR covering the deviation) prior to closing the DIR).
l[
j i As of April 1, 1986, signatures (not initials) are required as specified in DAP-2 for the various classifications of l
I discrepancies. Initials on IR/DIRs prior to April 1,1986 -
are acceptable (in lieu of signatures) based on past I
- revisions of this procedure.
l t
5.5.2 Euplicate DIRS ("D" or "E" Type)
If an identical issue or DIR is found to have been entered i
in the DAPTs more than once, one DIR shall be retained in
- the DAPTS and each other DIR that is a copy of the retained l DIR shall be designated as " transferred to" and duplicate; '
! e.g., D-XXXX(D). A statement that the DIR is a duplicate j (copy) of another DIR shall be entered in the Description of Resolution field. This closes the duplicate DIA and no e
! further revisions or entries are required.
g I l The estatus" block of each duplicate External source "E" type Issue or duplicate "D" type DIR shall be marked Transfered to: "(DIR Number)" of the primary issue. This l shall be the final revision of the duplicate issua LIR. !
Duplicate "E" tyre or "D" type DIRs are considered closed and will not be revised or included in trend evaluations. j 1
TN-85-6262/2 Page 50 of 57 i
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- -,- ~r-e-, .---._ -m,_w- w- ,,,,--r-e
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revislom 5
- ISSUES AND DISCREPANCIES
- 5.5.3 Related (Not Duplicate) DIRs Transferred to Primary Issues f "E" or "D" type DIRs that are related to a technical or programmatic issue ( ouch as one to be covered in a primary i DIR that may be the subject of an IRR) , a trend, or a '
- primary issue that is not part of an IRR or trend may be l
{ transferred to a primary issue (DIR) in either an open or l
closed status. The IRR number shall be entered in the IRR
- field on the primary DIR when the proposed corrective action is approved by DAP in accordance with DAP-20.
! An "Open" transferred to DIR will contain the primary issue
- DIR number followed by "(0)", e.g. , E-XXXX(0) , or D-XX.tX(0) in the status block. A " closed" transferred to DIR will I
contain the primary DIR number followed by "(c)". e.g. , E ,
XXXX(c), or D-XXXX(c) in the status block of the machine-j printed DIR. After a DIR's status is marked " transferred to (open or closed)," no further revisions are required or should be made to this DIR until the primary issue (or IRR)
- is closed.
l l .
At closure of the primary issue, all " transferred to (open or closed - not duplicate)" issues or DIRs associated with !
that primary issue will be reviewed by the discipline to l ensure that each " transferred to" issue has been resolved, and then each non-primary DIR shall be designated " closed" in a final revision of each " transferred to" DIR. Because the " transferred to" cross-reference to the primary issue is the track to evaluation and resolution of the issue, only the status block shall be revised from "Open" to I c
TN-85-6262/2 Page 51 of 57 O {
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: S ISSUES AND DISCREPANCIES j
j " Closed," that is, from E-XXXX(0) to E-XXXX(C) or D-XXXX(0) l to D-XXXX(C). The " Transferred to:" E-XXXX or D-XXXX l number remains on these DIRs. All other information that DAP-2 requires to be documented in the tracking system is ;
entered only on the primary issue DIR. The primary issue DIR does not list related issue "E" or "D" type DIRs that were transferred to it. Related DIRs will be included in i trend evaluations.
( !
5.5.4 Transfer of DIRs to Other CPRT or TRT Review l Teams i .
$f, during implementation of an Action Plan, it is deter-mined that the issue / discrepancy should be reassigned to l l the Qoc Program, or the TRT Testing or Electrical Review -
Teams for resolution, the issue / discrepancy will be i l designated as closed in the status field. Classification, Type, Design Activity, Review Topic and MDA numbers do not need to be contained in those DIRs since they are not l related to design. The DAPTS is used to track DIRs related i to civil / structural, Mechanical, and Miscellaneous TRT issues through closure. The' Description of Resolution j .
field will document that the issue / discrepancy was re- l
- l. assigned to 00C or other TRT review team, and the Reference field will reference the meno documenting that reassign-ment. DIRs transferred to another CPRT review team will .
not be counted or considered in trend evaluations within the DAP. The Discipline Coordinator or his designee is responsible for transmitting the DIRs to other RTLs. A l receipt acknowledgement shall be requested from the Review Team Leader to whom the DIR is transferred. '
TN-85-4262/2 Page 52 of 57 i
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 -
I ISSUES AND DISCREPANCIES 5.5.5 Unsubstantiated DIRs f If an issue is determined to be unsubstantiated, the issue will be assigned a status of closed, classification will be l marked unsubstantiated, and the basis for this determi- l nation will be documented in the Description of Resolution i field. ,
5.5.6 Unclassified Deviations or Unclassified Trends l[
If an issue meets the requirements of an unclassified deviation, or unclassified trend, the DIR aust include a specific reference to the procedure, document, plan, etc.,
ld '
that encompasses the aspects of the issue that are the subject of the unclassified deviation or trend. This lg reference must be listed on the DIR form prior to an O approval as an unclassified deviation or trend by the ld Review Team Leader. ,
5.5.7 DIRs Documenting CPSEs Project-Identified i Discrepancies -
r Reports issued pursuant to 10CFR 50.55(e) or 10CFR 21 are .
l reviewed only to document information in a form compatible I l to DAP DIRs. These DIRs are identified as "T" type DIRs. j "T" type DIRs shall be considered complete, with no further entries needed on form DAP-2-4, when the DIR documents the (
following information to the extent that it is contained in ;
the report or supporting analysis: (
o DIR Not T-XXXX o Rev Not
[
TM-85-6262/2 Page 53 of 57 I
j COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIES i
{ o Entry Date l o Issue / Discrepancy Title
- o Description of Issue / Discrepancy i ,
o structure (s), system (s) or Component (s)
Affected o Discipline '
o Design Organisation 1
o Design Activity
- ~
o Description of Resolution i
i o References i o Review Topic and HDA (when applicable)'
o safety significance o Root Cause/Gensric Implications 1 .
o Review signatures of j and approval l Reviewer and a Discipline Coordinator.
i t
These* DIRs are to be used as supplemental information during trend analyses or root cause/ generic implications
- l evaluations of DA.-identified discrepancies or External
! source Issues. No entries for status, classification, l type, trend, or subdiscipline are required on the "T" type DIR.
i i
I
!o ........,. , age .. o, ,, i i
--.__m__,m,.._,_ . _ - . _
- ~_ - _ . . - .
1 I
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 l lSSUES AND DISCREPANCIES '
l 5.5.8 DIRS Documenting Discrepancies Noted in Overview Corrective Action i
! DAP-20 requires that DIRs be written to document discrepan-cies identified by DAP in the overview of corrective j actions. Such DIRs are issued only to track these discre-l pancies until resolution. These DIRs are written on form DAP-2-4, and are assigned "C" type DIR numbers. They are j subject only to the following documentation requirements:
I o DIR Not C-XXXX o Rev No: ;
i j o Entry Data f o Issue / Discrepancy Title o Description of Issue / Discrepancy
! o APG From o APG To o structure (s), System (s) or component (s)
Affected .
! o status o Discipline o Design organisation (doing reverifica-tion or redesign) o Description of Resolution l
li o References -
o signatures (of Reviewer and approval of Discipline coordinator) .
TN-85-6262/2 Page 55 of 57 !
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQ'UACh PROCEDURE l 4
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 ISSUES AND DISCREPANCIE5
! Because these corrective action ("C" type) DIRs are only to
! track corrective actions, classification, type, trend, design activity, Review Topic', HDA, TDDRf, safety signifi-l cance and root cause/ generic implications entries are j irrelevant. These DIRs will' not be' included in trend i i evaluations as they are not relevast to DAP reviews of l original designs within the self-initiated parts of DSAPs.
- Revisions to "C" type DIRs shall be used as appropriate to*
{ update the DIR information. "C" type DIRs shall be closed when corrective action -overview per DAP-20 has been ,
{ ,
accomplished.
i
, 5.5.9 Backfit of "C" Type DIRs i,
j Discipline Coordinators are responsible for identifying
- DIRs prepared prior to the approval of Rev. 4 of DAP-2 that I address DAP overviews of corrective action, and shall
! ensure that these DIRs are transferred to "C" type DIRs as follows:
i f e Change the Status to.Transfaired to Ca XXXX(D);
o State whether the overview dircrepancy
-j is open or closed; ,
1 o In the Description of Resolution block, l writet "This DIR D-XXXX resulted from '
an overview of corrective action and has been renumbered as a "C" type DIR." l o
Sign the DIR form (only the Discipline Coordinator's signature is required); ,
I l i
l TN-85-4262/2 Page 56 of 57 i
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i
, . COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 5 t ISSUES AND DISCREPANCIES iO
- o send the DIR to the Generic Implica-1 tions coordinator for data entry.
Upon receipt of the DIR, the Generic Implications Coordina- '
- tor shall ensure that the existing "D" type DIR is trans-i ferred to a "C" type DIR as follows
l o Revise the "D" type DIR to reflect any
! changes in the incoming revision, i including status and the next revision
- number.
j o Assign a C-XXXX DIR number in the .
j , status block of the "D" type DIR. I i o copy the revised DIR, assign the same C-XXXX DIR number (Rev. 0), change the l status field to open or closed as
! indicated on the incoming revision, and i ensure that a reference to the dupli- . ,
cate "D" DIR number in the incoming I
! revision is included in the record.
! o Delete information from the incoming
} DIR from fields that are not required
,! to be included in the "C" type DIR.
! l i Unless otherwise approved by the DAP Manager or the RTL,
! Discipline Coordinators shall complete the backfit of "C" type DIRs by October 31, 1986 or four weeks from the !
l approved date of Rev. 5 of DAP-2 (whichever is later) .
j 5.6 ERT Review of DIRs i
The senior Review Team may review any DIR and identify the l j need for clarification, expansion of review or reassessment !
j by DAP personnel.
l l TN-85-6262/2 Page 57 of 57
- O i
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! l
l ATTACHMENT A COMANCIE PEAK DESIGN ADEQUACY PROGRAM ISSUE RECORD COVER SEET Source Document
Title:
i Originating / Investigating Organization:
Document ID:
Description:
l, Addressee Organization:
Document Dates i No. of issue Records Attached:
i Signatures: .
Reviewer . Date Discipline Coordinator Date
~'
FORM DAP.21 REV. 0 l
l l,
l
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l, e
O TN-85-6262/2 A-l ;
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.s
ATTACHMENT B COMANCE PEAK DESIGN ADEQUACY PROGRAM O CONSTRUCTION /QA/QC ISSUES LOG Brief Issue Description Identifier # Page#
l l
l I
Signatwem O ai-r o- oi cieii c rei ete, o 1-Form DAP.2-2
- (TN-85-6262/2) B-l Rev.0
, ATTACHMENT C
- i COMANCtf PEAK DESIGN ADEQUACY PROGRAM Date Entered DAPTS: l ISSUE RECORD issue #:- ;
PARTI l Issue
Title:
O Description of issue:
um urn l
Identifier #: gia Page #: si Doc. ID g,,
Structure (s), System (s) or Component (s) Affected:
(I3I)
Status: Class (Closed issues Only):
, ,,,, ,c,,,,, , ,, , ,,
. OProgrommotic Deficiency D Deviation D Unsubstantiated '
Discipline gg gg,, Type: ,, a %,, , , , ,
O Piping 2. O Cumulative O Not Cumulative Subdiscipline: (a) 3* " **' "**""
Design Organization: (m Review Topic #: HDA #s:
Design Activity: O Progrom Rog.
O D Input D Process D Interfoce Control O Verificotton D Document Control O Change Control D Corr. Action D Audits Q investigate Further Through Action Plan #: tem Rev.
PART2 Description of Resolution /CNements:
i
{
u271 Safety Significance Documented:
t 0 79)
Root Cause/ Generic implications Documented:
0 07)
O Signatures:
Reviewer Date Discipline Coordinator Date FORM DAP-2-3 TN-85-6262/2 C-1 REV. 4
l.
ATTACHMENT D COMANCE PEAK DES!GN ADEQUACY PROGRAM ta Entarad DAPTS:
"i '
issua/Diserooney DISCREPANCY / ISSUE RESOLUTION REPORT p ,
Issue /Discreponey
Title:
g, Description of issue /Discreponey: nu) l AP #: From: . To: Dependent On: ,
Structure (s), System (s) or Component (s) Affected:
(131)
Status: O Open D Closed Class: D Discreponey D Unclou Deviation O Unclossifed Trends D Observation D Deficioney D Tronsferred tes O Progrommotic Deficiency D Deviation D Unsubstantiated Discipline: O Mech. O C/5 Type: 1. O cenerie D laosoted
, O Elec./l&C D con. Impf. 2. O Cumulative D Not Cumulative O Piping D Other: 3. O Technical D Progrommotic Subdiscipline: us) Trend: i, a 4%,, a %,,
Design Organization: on PGA ras om Design Activity: D Program Reg. O laterfoe.Centrol O Change Centrol a s .. y ,ic e, (one or more) D Input D verification D Corr. Action #3 D Process D Document Centrol D Audits IRR #:
Description of Resolution (incl. Corrective Action) um TDDR# go)
References:
I non Sofety Significance: ,
om Root Cause/ Generic implications:
070)
Signatures: -
Reviewer Discipline Coordinator TRT/DAP Monoger Review Team Leader Date Date _
Date Date SRT Comments (As Required): ms)
O SRT Signature Date FORM DAP.2 4 TN-85-4262/2 D-l agy, 3
- i. - - . - - - . - _ _ . - - . - - - _ _ . . _ _ _ _ _ . . _
s ATTACHMENT E O INTERPRETATION OF DAP TRACKING SYSTEM s
" TYPE" BLOCKS Type: Generic or Isolated Cumulative or Not Cumulative Technical or Programmatic Trend - Adverse or Nonadverse i
All four of . these choices should be interpreted within the confines of the discipline. Clarification of terms follows:
o Generic means that the discrepancy applies or potentially applies to other aspects of. i design within the discipline related to the DIR. For example, use of SRSS in combining
, dead weight and seismic loads is generic to the piping / pipe support discipline since this error appears to have occurred extensively (if not throughout) that discipline. Marking i " Generic" in this example does not imply that ths same error occurred outside the disci-pline indicated in the DIR. If the . same error is found in other disciplines, whether it is generic to these other disciplines is determined on a discipline-by-discipline basis, o Isolated should be checked if the discrepancy described in the DIR appears to be an error whose characteristics make it unlikely to have spread to other aspects of design within the discipline. For example, technical aspects of an error in a calculation of post-IDCA hydrogen generation would be isolated by the narrow scope of this aspect of design.
If a programmatic aspect of this error could apply to other activities (such-as control of design inputs) in the discipline, this
- programmatic aspect would be described in another DIR, and programmatic and generic
- blocks would be checked.
l l o cumulative should be checked if the dis-crepancy described in the DIR is believed to impact the design in combination with other identified discrepancies. For example, small O TN-85-6262/2 E-1 1
- i. _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
unconservatisms may usually be neglected in O design. If it were confirmed that most of the conduit supports are designed to maximum capacity, the cumulative effect of many unconservatisms may be significant. All DIRs considered to have a cumulative effect on the design should be checked cumulative.
o Not Cumulative should be checked if the discrepancy described in the DIR is by its nature not likely to, impact the design if considered in combination with other dis-crepancies. For example, if an error in a '
calculation has no significant impact on a design output, then this error cannot have a cumulative effect with any other discrepancy, and it should be marked not cumulative.
o Technical should be checked if the dis-crepancy described in the DIR relates to a technical concern. For example, DIR D-0019 states that "TUGCO Calc. SRB-109C, SET 3, Rev. 6 contains a modeling error and two unjustified assumptions that are important to
.the results." This DIR is correctly described as technical.
o Programmatic should be checked if the
, discrepancy described in the DIR relates to a
! design process or design control process l (e.g., program, process, procedure, sork activity, methodology, or similar program-matic aspect of design). For example if i
during review of a technical discrepancy,, it
- becomes apparent that a precedure
~ for controlling the design work associated with the technical discrepancy was inadequate, incomplete, not implemented, or nonexistent (if a procedure was required or committed to), then this new discrepancy should be documented in a new D-XXXX DIR and marked programmatic. Similar to the above inter-pretation of the term " generic," a program-matic discrepancy should be interpreted within the confines of the discipline in which it was found. This does not mean that the discrepancy is programmatic to other disciplines although it may be. If a discipline coordinator believes that the discrepancy could likely affect other disciplines, then DAP-7 requires that the discipline coordinator identify the TN-85-6262/2 E-2
w ,
discrepancy to the Programmatic / Generic O Implications coordinator and other poten-tially affected discipline coordinators.
checking the programmatic block alerts the PGI coordinator to the possibility of effects on other disciplines. Similar or related l programmatic discrepancies will be identified or confirmed through trend evaluations of discrepancies across disciplines.
o Trend - Adverse should be checked if the DIR is the result of a trend evaluation of design discrepancies and has been determined to con-stitute an adverse trend. A trend is con-sidered to be adverse if it is determined that the identified pattern or commonality is likely tc havn resulted in the occurrence of an undetected safety-significant deficiency in the affected design area. To mark the Trend block, a trend evaluation, documented per DAP-7 on form DAP-7-1, must have been completed.
o Trend - Nonadverse should be checked if the DIR is the result of a trend evaluation of design discrepancies and has been determined to constitute a trend, but the trend is not l
adverse (not likely to have resulted in the occurrence of an undetected safety-signif-icant deficiency in the area affected) . To mark the Trend block, a trend evaluation,
. documented per DAP-7 on form DAP-7-1, must have been completed.
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ATTACHMENT F USE AND INTERPRETATION OF DESIGN ACTIVITY ,
The DIR form contains nine design activities (DESACT) that are broad categories of various aspects of design. These design activities are based on ANSI N.45.2.11-1974. -They are used in initial trending of discrepancies, and they are contained in Attachment A, Example Attributes Matrix, of DAP-7 as Level II attributes.
l The design activities that are associated with the discrepancy should be checked when the DIR is written, or when the DESACT is i identified and the DIR is revised in the course of evaluating the
- discrepancy. If the discrepancy relates to more than one DESACT, multinle DESACTs may be checked. The DAPTS tracking system is l configured to capture combinations of DESACTs if more than one applies.
DESACT is a key attribute used in trending and generic implica-tions evaluations. In trending, for example, counts of the DIRs that show each DESACT and combinations of DESACTs are used to determine the distribution of DIRs among DESACTs. When DESACTs are combined with other attributes, such as cuts by discipline, subdiscipline, design organization, type, and classification, the resulting distributions of numbers of DIRs in these combinations (subsets) can be identified, displayed, and analyzed. If these distributions are skewed so that some combinations have large
- O. numbers of discrepancies, then this pattern is indicative of a trend. Level III information in DAP-7, Attachment A, is intended to assist in ensuring proper Level II DESACTs are marked in the DIR.
Interpretations of design activity attributes follow. These interpretations supplement descriptions found in ANSI N45.2.ll-1974:
1 o Program Requirements - Specifies that there be program procedures addressing organizational structure, authority, responsibility, interfaces, management, and requirements related to the other design activities listed below. For example,
, discrepancies that resulted because procedures l were found not to exist to control a particular .A design activity should be categorized as Program 421 Requirements.
o Input Requirements - Specifies requirements to ensure that design inputs or changes in these l
inputs (those criteria, parameters, bases, or other design requirements, including regulatory requirements, codes and standards, upon which l
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detailed final design is based) are identified, documented, reviewed, approved, and controlled.
Level III of Attachment A to DAP-7 contains a listing of kinds of design inputs that may apply.
4 This list is not all inclusive.
o Design Process - Specifies the use of procedures sufficient to ensure that applicable design inputs are correctly translated into specifications, drawings, procedures, or instructions, and to '
ensure that appropriate quality standards and changes thereto are identified, documented, reviewed, approved, and controlled. In a broad sense, all design activities may be considered part of the design process. For the purpose of marking design process as an affected D2SACT on a DIR, however, a narrower interpretation should be used. That is, desi (job specifications,gn process
_ work relates to controls instructions, planning sheets, procedure manuals, test procedures, or any other type of written form) and the implementation of these controls applied to analysas, calcula-tions, and other direct work activities used to produce design output drawings, specifications, or other documente.
o Interface Control - Specifies requirements for external and internal interfaces. These inter-
.O faces are relationships between companies (exter-nal) and design groups or organizaitions within a company _ (internal). Requirements related to identifying interfaces in writing, defining, and documenting responsibilities, establishing lines of communication, controlling the flow of design
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information, and documenting design information i (including changes) transmitted in ' drawings, l
specifications, or other controlled documents.
o Verification -
The process of reviewing, con-firming, or substantiating the design by one or '
more methods to provide assurance that the design meets the specified design inputs. Verification methods include design review, alternate calcula-tions, and qualification testing. Attachment A to DAP-7 includes 15 aspects of design reviews that are based on ANSI N45.2.ll-1974. The extent of design verification required is a function of importance to safety, complexity, degree of standardization, state-of-the-art, and similarity
'to previously proven designs. Where changes to previously verified designs have been made, design verification is required for the changes, O TN-85-6262/2 F-2
including evaluation of the effects of those changes on the overall design.
o Document Control - Specifies requirements for procedures to control issuance of design documents and changes thereto. Document control require-monts relate to preparation, approval, issuance, and revisions of design documents. Procedures cover responsibilities for preparing, reviewing, ,
approving, issuing, and revising documents, identifying documents, coordinating, and control-ling interface documents, ascertaining that proper documents are used, and establishing distribution lists that are updated and current.
Document control should be checked if DIRs are written for discrepancies- in licensing documents, such as the FSAR or revisions or updates to the FSAR, that are noted during a review. In such ;
cases, the DIR - description should identify the licensing document and the discrepancy in it that was found.
o change control -
Specifies requirements for controlling changes to approved design documents i
to assure that impacts of changes are carefully i considered, required actions are documented, and change information is transmitted to all affected persons and organizations. changes shall be justified and subjected to design control measures commensurate with those applied to the original design. Reasons for changes listed in Attachment A of DAP-7 are valuable as attributes in deter-mining whether change control is involved because they may indicate a pattern of why changes -
occurred (e.g., unsatisfactory test results, interference, disposition of nonconformances, failure to meet ' functional requirements, etc.).
Documents which reflect design changes are reviewed and approved by the same groups or organizations which reviewed and approved the original design documents.
o corrective Action - Specifies requirements for procedures for reporting deficiencies and deter- .
mining corrective action of specific errors. In addition, for significant or recurring defi-ciencies, determining the cause and instituting changes in the design process or quality assurance program to prevent recurrence of similar types of deficiencies is also required. Attachment A of DAP-7 lists examples of objects of corrective O
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44 i
[ action (e.g., desi activities, procedures,
- personnel, training, gn and management) . For exam-ple, if an error had been detected in the past and corrective action was taken, but the same type of error continued to recur, then corrective action would be checked as an attribute on the DIR because corrective action was apparently ineffec-tive.
o Audits - Specifies requirements to plan, conduct, and document audits to verify compliance with all aspects of the QA program for design. If a discrepancy relates to failure to conduct audits, inadequacy of audits, or failure to follow up on correcting findings resulting from audits, then this DESACT should be checked on the DIR.
The next step in trending is to determine, based on engineering judgement, whether the problem documented in those DIRs (with final classifications) in the subsets that exhibit trends is likely to constitute an adverse trend. If an adverse trend is likely to exist, a DIR classified as a programmatic deficiency is written, without first performing a safety significance evalua-tion. The formal safety significance evaluation, root cause and generic implications evaluations are done in the process of evaluating the programmatic deficiency. This information, as to
.O where the trend applies, (how widespread is the problem), what organization and discipline were involved, and what is the cause l of the trend will be developed as part of evaluations of the l trend regarding safety significance (not required for unclas-sified trends), root cause and generic implications. If a trend is identified based on DIRs that have not received final clas-sifications, the trend shall be considered potentially adverse l and preliminary until all DIRs in the trend receive final classifications.
The end result of identification of an adverse trend is a concise description of a problem. This description could have been originated based on judgement of DAP personnel and confirmed by analyzing the DIR data. Alternatively, the description may have been originated as a result of analyzin the DIR data and confirmation by one or more DAP disciplines.g Problem description also precedes determining why the trend occurred (root cause or causal factors), and whether it affects other areas of design not yet identified (generic implications).
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