ML20215J830
| ML20215J830 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/09/1986 |
| From: | Blackwood E TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20215J430 | List:
|
| References | |
| DAP-2, NUDOCS 8610270204 | |
| Download: ML20215J830 (58) | |
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TITLE DOCUMENTATION APO TRACKING OF ISSUES APO DISCREPANCIES _
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V TABLE OF CONTENTS Section Page CoverSheet...................................................... i T ab l e o f Co nt en t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii 1.0 P UR P O S E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 2.0 SCOPE..................................................... I 3.0 DEFINITIONS AND RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . I 4.0 I NS TR U CT I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
-s S.0 D O CU ME NT A T I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 b
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ATTACHMENTS A IS S UE RE COR D COVE R SHEE T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-l B CONSTRUCTION OA/OC ISSUES LOG . . . . . . . . . . . . . . . . . . . . . . . . . B-l C ISSUE RECORD ............................................ C-l D DISCREPANCY / ISSUE RESOLUTION RECORD ................. D-l E INTERPRETATION OF DAP TRACKING SYSTEM
" TYPE" BLOCKS ......................................... E-1 F USE AND INTERPRETATION OF DESIGN ACTIVITY ......................................... F-I l .
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TN-85-6262/2 ii l
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE f Number: DAP-2 O
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 4 l.0 PURPOSE This procedure defines the requirements for documentation, tracking and resolu-tion of External Source issues and of discrepancies identified during the conduct of the Design Adequacy Program (DAP) and the Civil / Structural / Mechanical (CSM) ISAPs that are part of the CPRT Program Plan.
k 2.0 SCOPE This procedure opplies to issues identified by external sources and to discrepon-cies identified during implementation of the self-initiated portion of the DAP.
Where indicated, this procedure also applies to documentation of DAP overviews of corrective action; capture of information about TUCCO-identified reportable b or potentially reportable issues; and documentation of discrepancies found during evoluotions conducted under the CSM 15Aos .
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions 3.1.I External Source issue
, An error or concern related to design or design processes identified by on l organization other than the Comanche Peak Project or the Comanche Deck l Response Team (CPRT) and contained in public documents on the NRC dockets for the Comanche Peak Steam Electric Station (CPSES). Open External Source issues are documented in "E" type Discreponey/ Issue Resolution (DIR) Reports.
External Source issues resolved by on external source are documented in "R" l type DIRs.
O v'J TN-8S-6262/2 r)oge I of 45 l
t COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES 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.I.3 Open 3.l.3.1 Open issues 4
Issues are considered to be open until there is reasonable assurance that the following conditions, as determined under the DAP, have been met:
o it has been determined that:
a) the issue is unsubstantiated, or, b) the issue
- 1) has been resolved by on external source and requires no additional investigation by the CPRT except as an input to trend evaluation, and ii) has been appropriately classified by the CPRT (e.g., os on observation, deviation or deficiency);
or, lk c) the issue is a discrepancy determined by the CPRT to have been resolved and meets the conditions for closure of a discrepancy listed in paragraph 3.1.3.2 of this procedure; and, o The bases for any one of the above-mentioned determina-
! tions have been documented.
This definition opplies only to "E" type DIRs.
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TN-85-6262/2 Page 2 of 45
4 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE D Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
\ ISSUES AND DISCREPANCIES 3.l.3.2 Open Discrepancies Discrepancies are considered to be open until there is reasonable assurance that the following conditions, as determined under the DAP, have been met:
o The DAP has determined that the discrepancy has been appropriately classified (e.g., as on observation, deviation or deficiency). ld o The DAP has determined that oppropriate resolutions and corrective actions, os required by the CDRT Program Plan and DAP-20, have been established.
lk 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 l[
Plan.
O y/ o The basis for the above-mentioned determinations have been documented.
This definition opplies only to "D" type DIRs.
lk 3.l.4 Closed issues and discrepancies are considered closed when the oppI!coble conditions outlined in 3.l.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) combining duplicate issues that appear in one or more of External Source documents, (2) combining duplicate discrepancies that have been entered in the DAP tracking system, or (3) com-bining DAP-identified, related discrepancies ("D" DIRs) or External Source issues TN-85-6262/2 Page 3 of 45
i I
s COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O
V Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 !
ISSUES AND DISCREPANCIES into primary issues. The issue to which duplicate issues, or related discrepancies (that may be addressed in an IRR) are transferred is referred to as'th'e primary issue.
k 3.l.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. Figure I depicts the relationship among the classifications. (Note: The arrows indicate the general progression of classifications, but do not limit the proper reclassification of is:ues or discrepancies that were improperly classified.)
k 3.1.7 Unsubstantiated An External Source issue or DAP-identified discrepancy that has been deter-mined, by the DAP, to be not valid.
ld 3.1.8 Discrepancy Any identified error related to design inputs, implementing documents and outputs, i.e., assumptions, procedures, calculations, analyses, drawings or speci-fications for safety-related structures, systems or components that could have on adverse impact on the adequacy of their design. All discrepancies are ultimately either classified as observations, deviations, unclassified deviations, deficiencies or programmatic deficiencies, or are found, upon additional investi-gotion by the DAP, to be unsubstantiated. Substantiated issues become dis-crepancies within the DAP.
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O TN-85-6262/2 Page 4 of 45
4 O :
ACTION PLAN RESULTS d EXTERNAL NOT EXPLICITLY DEFINED g ADVERSE SOURCE BY AN EXTERNAL o
m TREND ISSUE SOURCE ISSUE o
2 UNSUBSTANTIATED 9
9 b
$ DISCREPANCY b
O OBSERVATION l
DEVIATION v v PROGRAMMATIC UNCLASSIFIED DEFICIENCY DEFICIENCY DEVIATION i
FIGURE I RELATIONSHIP AMONG CLASSIFICATIONS ,
O Page 5 of 45 TN-85-6262/2
\
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
, Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
! ISSUES AND DISCREPANCIES 3.l.? Observation Any identified design discrepancy that has been determined, under the DAP, not to constitute a design deviation. An observation may be technical (related to a technical aspect of design) or programmatic.
3.1. I 0 Deviation Any identified design that has been determined, under the DAP, to constitute a verified failure to meet a design criteria commitment or specification. In this regard, design criteria commitments include regulatory requirements, FSAR commitments, other licensing commitments, applicable code and standard re-quirements or other project-specific design criteria or commitments.
- 3. I. I I Unclassified Deviation A deviation or set of deviations related to areas in which reverification or redesign is being conducted and for which it has been determined that it is more practical to proceed directly to analyzing root cause and generic implications and specifying 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 and generic implications evaluations will be done and corrective action will be evoluoted. 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 noted during DAP overview of corrective action are discussed in Section 4.9.
\' TN-85-6262/2 Page 6 of 45
b COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE O
y Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 4
- 3. l . I 2 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 have been determined to constitute on adverse trend that is programmatic in nature. An adverse trend is referred to os a programmat'ic deficiency. A trend is considered to be adverse if it is determined that the identified pattern or commonolity is likely to have resulted in the occurrence of on undetected safety-significant deficiency in the offected design area. Programmatic deficiencies (like design deficiencies) are subject to evoluotions of safety-significance (DAP-22), root cause and generic implications (DAP-7), and adequacy of corrective action (DAP-20). A programmatic deficiency may be identified during the preparation of issue Resolution Reports.
k 3.1.14 Safety Significant A deviation that, if uncorrected, would result in the loss of capability of the of fected system, structure or component 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 l information regarding the CPRT definition of safety significant.
I 3.1.15 Root Cause The cause or causal factors that contributed to o programmatic deficiency, unclassified deviation, or design deficiency, (i.e., why it occurred). A root cause I
may be determined during on evoluotion by testing a hypothesis or by making a preliminary judgement subject to confirmation. Root causes and cous~ol factors TN-85-6262/2 Page 7 of 45 i
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOVACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
, ISSUES AND DISCREPANCIES and the extent of their applicability in design ore based on objective evidence.
They are confirmed and bounded by the findings of evaluations (what cioes exist) rather than by general statements of what could exist.
3.1.16 Generic implication A reasonable lil<elihood that on issue or discrepancy (DIR) af fects some aspect of design other than the specific instance in which the finding was identified.
3.1.17 Generic implications Evaluation The process of reviewing programmatic deficiencies, unclassified deviations, or design deficiencies identified in self-initiated portions of the DAP, or originated as External Source issues and confirmed by the DAD to:
O o Determine whether related design deficiencies exist, o investigate the root cause or causal factors, o Determine limiting boundaries of applicability of the deficiency under review.
3.l.18 issue Record l 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).
lk 3.1.19 issue Record Cover Sheet 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).
4 TN-85-6262/2 Page 8 of 45
4 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
.O C/
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES l l
l 3.1.20 Construction /OA/OC (OOC) Issues Log A form (DAD-2-2) prepared by the Design Adequacy Review Team during the review of External Source documents that lists issues that are within the scope of the OOC Program (See Attachment B). Use of this form is optional.
lk 3.1.21 Discrepancy / issue Resolution Report (DIR)
A form (DAP-2-4) prepared by the Design Adequacy Review Team to track the status, classification and resolution of oil open issues and of all discrepancies identified during conduct of the DAP (See Attachment D).
3.l.22 issue Resolution Report (IRR) q A type of engineering evaluation prepared in accordance with DAP-8 that provides on integrated summary of the concerns expressed in DIRs and that sets forth the criteria by which DAP will evoluote any proposed corrective action.
3.1.23 Primary issue A DlR that is originated (or revised) to reflect all aspects of (l) duplicate External Source issues ('E" type DIRs), (2) duplicate DAP-identified discrep-g oncies 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 DIRs may be grouped as an input to on IRR, as documentation of a trend or as a compilation of DIRs that facilitates evoluotion, resolution, or closure regardless of whether the primary DIR is included in on IRR or a trend. A primary issue DIR that is the subject of an IRR may be classified as on unclassified deviation, a programmatic deficiency, or other classification as appropriate.
TN.85-6262/2 Page 9 of 45
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4 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES l
3.1.24 "C" Type DIR I A record 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 port of either the External Source issue review or the self-initiated part of the DAP. Section 5.5.8 defines the information required in "C" DIRs. "C" DIRs are open until odequate information is received to allow resolution of the DIR.
3.1.25 "T" Type DIR A record in the general format of Form DAP 2-4 that documents selected evaluations done outside the DAD in response to o problem related to design.
Sections 5.5.7 defines the information required in "T" DIRs.
O LJ 3.1.26 "D" Type DIR A record in the 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.
3.1.27 'E" Type DIR A record in the format of Form DAP 2-4 that documents open issue Records (Form 2-3) in a format that allows resolution. (Note: Issue Records record the historic statement of the issue os expressed by the external source. Issue Records are not subject to revision.)
O- TN-85-62(2/2 Page 10 of 45
4 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE m Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES 3.2 Responsibilities 3.2.1 Review Team Leader The Review Team Leader is responsible for:
o Approving the classification of discrepancies as defi-ciencies, programmatic deficiencies or unclassified devia-tions; o Approving the closure of deficiencies, programmatic defi-ciencies and unclassified deviations; o Transmitting deficiencies, programmatic deficiencies and unclassified deviations to the CPRT Senior Review Team and to appropriate Project personnel.
lk These responsibilities may be delegated to the DAP Manager.
The Review Team Leader 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 Monoger)
The DAP Manager is responsible for:
i o Approving the classification of discrepancies os devia-tions; o Concurring in (or approving, if authorized by the Review Team Leader) the classification of discrepancies as defi-ciencies, programmatic deficiencies or unclassified devio-tions; o Approving the closure of deviations;
- O TN-85-6262/2 Page ll of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 O() .lSSUES AND DISCREPANCIES o Recommendin Team Leader)g (or opproving, closure if authorized of deficiencies, by thedefi.-
programmatic Review ciencies and unclassified deviations; o Transmitting to appropriate Project personnel on a weekly basis copies of new and revised DIRs that are: l[
- "D" DIRs
- "E" DIRs classified as a deviation, unclassified devi-otion, deficiency, or programatic deficiency
- "C" DIRs lg
- DIRs that were closed.
The DAP Monoger may perform any of the functions of the Reviewers, Discipline Coordinators or the Programmatic / Generic Implications Coordinator.
3.2.3 Programmatic / Generic Implications (PCI) Coordinator O The Programmatic / Generic Implications Coordinator (or his designee) is respon-sible for:
o Assigning numbers to approved issue Records and DIRs; o Ensuring dato entry to the Design Adequacy Program Tracking System; o Revising DIRs to correct or enter missing data os dele- A gated by the DAP manager; l.i\.
o Monoging the DAP Tracking System (DAPTS);
o issuing periodic status reports to addressees os deter-mined by the DAP Manager; l o Ensuring that o DlR is created for each open issue Record; o Returning unsigned hard copies of DIRs to Discipline Coordinators for potential revisions; O TN-85-6262/2 Doge 12 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE
'D Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF (J ISSUES AND DISCREPANCIES Revision: 4 o Maintaining on auditable record of all Issue Records, DIRs, and revisions to DIRs.
o Performing the Discipline Coordinator's functions related to DIRs generated within the PGI discipline.
3.2.4 Discipline Coordinator The Discipline Coordinator is responsible for:
o Approving issue Record Cover Sheets, OOC lssues Logs, and issue Records; o Concurring with the identification of External Source documents which discuss GOC issues; o Approving the status of Externo! Source issues; v'
) o Approving the classification of closed External Source Issues; d o Identifying duplicate External Source issues or related DAP-identified discrepancies and approving the transfer of duplicate issues or DAP-identified discrepancies to the primary issue; o Approving the classification of open issues os unsubstanti-ated issues or as discrepancies; l o Performing actions for which a revi wer is responsible (Section 3.2.5);
o Concurring with or approving DIRs (depending upon classi-fication as detailed in Section 4);
g o Approving the identification of discrepancies that are not explicitly defined by on External Source issue; o Approving the classification of discrepancies as observo-tions; o Approving the closure of observations; O TN-85-6262/2 Page 13 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES o Concurring in the classification of discrepancies as devia-tions, deficiencies, programmatic deficiencies, or unclos-sified deviations; o Recommending the closure of deviations; o Forwarding copies of Issue Record Cover Sheets for documents that discuss OOC issues, and specifically iden-tified issues requiring clarification as to DAP versus OOC coverage, to the DAP Construction Quality Interface Manager for transmittal to the OOC Interface Coordi-notor (OOC issued at the discretion Logs orCoordinator of the Discipline Issue Records may);be included o Forwarding signed Issue Record Cover Sheets and Issue Records to the Generic Implications Coordinator;
, o Forwarding DIRs for which the recommended classifica-tion is deviation, deficiency, unclassified deviation, or progammatic deficiency (including closure of these classi-fications) to the DAP Manager; o Forwarding DIRs and revisions to DIRs to the Generic Implications Coordinator offer appropriate approvals have been obtained; o Determining whether scope expansion is required, as di-rected in DAP-3; o Approving the reassignment of issues or discrepancies to the OOC Program, TRT Testing Review Team or TRT 2
Electrical Review Team Programs, and transmitting (directly or via the OOC Interface Manager) these issues g or discrepancies to the oppropriate Review Team Leader; 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. ld l
1 TN-85-6262/2 Page 14 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES 3.2.5 Reviewer The Technical Reviewer is responsible for:
o Reviewing External Source documents; o identifying External Source issues; b i
o Preparing issue Record Cover Sheets; o Preparing OOC transmittols including issue Record Cover Sheets, Issue Records or OOC lssue Logs as appropriate; o Preparing Issue Records; o Recommending the status of External Source issues; o Recommending the classification of closed External Source issues; b
o Recommending the classification of open issues os unsub-stantiated issues er os discrepancies; o Identifying discrepancies that are not explicitly defined by External Source issues; lg o Preparing DIRs and revisions to DIRs; o Recommending the classification of discrepancies; o Reviewing information provided by others to close issues or discrepancies;
'l o Forwarding issue Record Cover Sheets, Issue Records, OOC Issues Logs, DIRs and revisions to DIRs to the Discipline Coordinator.
3.2.6 Construction Quality Interface Monoger The Construction Quality Interface Manager is responsible for forwarding information received from the Discipline Coordinators on OOC issues to the TN-85-6262/2 Page IS of 45 4
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
- Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
/) ISSUES AND DISCREPANCIES V
appropriate OOC program interface person, and for maintaining a record or copy of information transmitted to the OOC Program. (Interfaces with'the TRT Testing Review Team or the TRT Electrical Review Team are the responsibility of the DAP Discipline Coordinator who identifies on issue that should be transferred to either of these teams.)
3.2.7 TRT issues Manager The TRT lssues Manager's responsibilities for signing DIR forms are the some 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 O
V Effective Date: For the purpose of entering references 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 ef fective since August 4, lo86.
4.1 Identification of External Issues l[
4.l.1 General The identification of issues is accomplished by the systematic review of
- documents which describe concerns related to the design or design process (External Source documents). Identification of External Source issues is on on-going activity throughout the DAr> ,
ld l
l The Reviewer shall complete on issue Record (using attached Form DAP-2-3) for each issue related to the design or design process, regardless of the indicated TN-85-6262/2 Page 16 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF O ISSUES AND DISCREPANCIES Revision: 4 status of the issue. This shall include issues identified by the OOC (including OA/OC) Review Team or other TRT Review Team and transferred to t'he Design b Adequacy Review Team for evaluation.
If, during the initial source document review, it is apparent that on issue has both technical and programmatic components, these components will be docu-mented on two separate issue Records. One issue Record will document the technical aspect of the concern and the other will document the programmatic aspect of the concern.
4.1.2 OOC or Other TRT Review Team Issues ld Where on issue is noted by the DAP reviewer to be potentially relevant to the Quality of Construction (OOC) program or other TRT review team, it shall be documented in one of the following forms:
- By notin on the issue Record Cover Sheet (Form DAP-2-l)gthat construction or other TRT review team issues are discussed within the document. ld By noting on the OOC issues Log (Form DAP 2-2) or issue Record (Form DAP-2-3) specific issues that require con-firmation that they are or are not covered within the scope of the OOC or another CORT 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 OOC or another CDRT lI Program.
- By any combination of the above.
4.1.1 Determination of issue Status For each design issue, the Reviewer will mal <e a determination as to whether the issue is open or closed using the criteria specified in paragraph 3.l.3.1. Any b O TN-85-6262/2 Page 17 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE p) i v
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 4 issue considered unresolved by the External Source will be designated open under the DAo.
lk If the issue is determined to be open, Part I of the issue Record will be completed to the extent appropriate based on External Source document contents in accordance with paragraph S.4.1.
If the issue is determined to be closed, the issue will be classified and Darts I and 2 of the issue Record will be filled out as completely as possible.
4.l.4 Disposition of Issue Records When the review of a source document is complete, the Reviewer shall attach an issue Record Cover Sheet (using attached Form DAP.21) to the complete set of O "
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 appropriate 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 h
(including issue Records with original signatures that apply to his discipline) to the Generic implications Coordinator for entry into the DAoTS. Issue Records and issue Record Cover Sheets shall be retained in auditable files by the Generic Implications Coordinator. As use of OOC lssues Logs is optional, there is no requirement that files of GOC !ssues Logs be auditable.
If any OOC issues are identified, the Discipline Coordinator responsible for initial source document review will send a copy of the relevant documentation described in Section 4.1.2 to the OOC Interface Coordinator via the DAP Construction Quality Interface Manager. If issues identified are determined within the DAP to be within the purview of a TRT review team, the Discipline 1
s i TN-85-6262/2 Page 19 of 45 l
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COMANCHE PEAK RESPONSE TE AM - DESIGN ADEOUACY PROCEDURE Number: DAP-2 (qj
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 4 Coordinator will send a copy of relevant documentation to the appropriate TRT Review Team Leader. All issues that are entered in the DAr)TS ond then transferred to another review team shall be closed in the DAP tracking system with reference to the transfer memorandum odded to the DIR.
For each open issue, the Generic implications Coordinator for his designee) will transfer the information from the issue Record to on unsigned DIR and forward two copies of the DIR to the Discipline Coordinator responsible for the Action Plan designoted in the DIR. The Discipline Coordinator shall distribute one of these copies to the Reviewer to whom he assigns responsibility for review of the issue Record.
The Discipline Coordinators will review the initial set of DIRs for duplicate issues and will, by revision of the DIRs, designate (in the status field) duplicate issues as " transferred to " and indicate the issue number per Section 5.5.2 to which the duplicate was transferred (the primary issue). There are different l[
methods by which a primary issue may be created. The easiest method to describe a primary issue should be used without creating 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 necessary.
o An existing E XXXX ("E" type) DIR that encompasses the duplicate issue records may be designated as the primary issue without revising the content of the primary DIR; o An existing E-XXXX DIR that does not completely en-compass all aspects of duplicate issues may be revised to reflect all aspects of duplicate issues and to state in the
" Description" block that this DIR is the primary issue and reflects duplicate iseues, or; o A new E XXXX DIR may be written as the primary issue with the issue description stating that this DlR is a compilation of duplicate issues and encompasses all aspects of duplicate issues. If a new DIR is created, o .
m l
(v') TN-85-6262/2 Page lo of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE (3 Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 (j ISSUES AND DISCREPANCIES 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 revised to reflect another classification because additional or revised information developed during the review process. The d
revised DIR cannot be accepted if the issue is not classified. 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 retention in on auditable file.
O L) 4.2 Identification of Discrepancies by DAP Self-Initiated Program Reviewers shall prepare o new DlR 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 of fer March 31,1986. DIRs originated before April l, 1986 may be done using Rev. O of DAP-2-4 and need not be rewritten on a Rev. 2 form.
There is no Rev. I of DAP-2-4. Do not use Rev. O of DAP-2-4 af ter March 31,1986. Future revisions of DAP-2 forms shall be used for DIRs originated offer the ef fective date of the revision to DAP-2.
If originated within the DAP, the DIR (D-XXXX DIR), including any supple-mentory sketches, notes and explanatory information, shall be prepared with the objective of allowing a person not familiar with the work, but technically qualified, to understand it without extensive additional inquiry and research.
Supplementory sketches, notes and explanatory information shall be'o part of TN-85-6262/2 Page 20 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES
[Om) discipline files. The DIR shall describe the content of this additional inf ormation relative to the discreponey so that by itself the DlR describes the discreponey.
If the DIR is on External Source issue, the details of the description are based on information contained in the External Source document. These details may not be sufficient to enable a technically qualified person to understand the issue without further inquiry or research.
The Discipline Coordinator shall review, approve, and sign the DIR that describes the discrepancy and forward the DIR to the Generic Implications Coordinator for entry to the DAPTS and retention in on auditable file.
If, during the implementation of an Action Plon, it is determined that the issue / discrepancy under review should be reassigned to the OOC orogram for resolution, the issue / discrepancy will be designated as closed and a copy of the DIR will be forwarded to the OOC Interface Coordinator by the DAP Construc-tion Quality Interface Manager after opproval by the Discipline Coordinator, if an issue / discrepancy should be reassigned to another TRT review team (Testing or Electrical), the DIR will be closed in the DAPTS and sent to the appropriate Review Team Leader by the Discipline Coordinator.
4.3 Classification of Discrepancies When sufficient information hos become available, the reviewer shall classify each discrepancy as ;ither on observation or a deviation. The classification will lk l
be documented by the reviewer through revision of the DIR. If classified as an observation, the DIR must also be marked closed and the description of
! resolution included, os no further action other than trending will be taken by the DAP regarding the observation. Recommended actions by the CPSES Project
- vill not be included in the description of resolution field in the DIR.
l O U TN-85-6262/2 Page 21 of 45 l
l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES Issues classified as unsubstantiated or os discrepancies, and discrepancies classi- l l
fied as observations, require the signature of the reviewer and the opproval signature of the Discipline Coordinator on the DIR. j Classification of a discrepancy as o deviation requires the 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 o deviation other than on unclassified deviation, it will be evaluated for safety significance, as required by DAP-22.
If the deviation is determined to be o deficiency or on unclassified deviation, the DIR will be revised to reflect this new classification. All deficiencies and unclassified deviations will be evaluated for root cause and generic implications, lk 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 opproval signature of the Review Team Leader.
For o DIR to be classified as on unclassified deviation, the reviewer shall verify that a program undertaken by the CPSES Project does encompass a review of all aspects of the discreponey. The DIR shall contain in the reference block a reference to o procedure, document, plan, etc., that contains evidence that the discrepancy will be addressed. Af ter this verification and documentation on tne DlR is complete, the DIR may be approved as on unclassified deviation in an open status. After evaluations of root cause/ generic implications (DAP-7) and any necessary corrective action plan (DAP-20) have been completed by the DAP, the unclassified deviation shall be closed provided it meets other conditions for closure per this procedure.
If the DIR documents on adverse trend, the DIR shall be classified as a programmatic deficiency and shall receive the some concurrence and approval TN-85-6262/2 Page 22 of 45
_.___.,_._..,--o -- - . -~
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE
,, Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES (O) signatures as a deficiency, described in this Section 4.3.
l[
If the DlR documents a subject to be addressed in on issue Resolution Report (IRR), the "D" type DIR shall be written as a primary issue similar to a primary External Source 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 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 on IRR shall be written offer DAP occeptence of the proposed corrective action (see DAPs 8 and 20). If g
primary issues that are addressed in IRRs are deficiencies, unclassified devia-tions or programmatic deficiencies (adverse trends), the requirements of DAP-7 shall be met. Regarding documentation of a trend evaluation, o DAP-7 trend evaluation or authorized substitute, such as generation of on IRR (and a trend h) evoluotion form DAP-7-l) 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 on IRR.
4.4 Revisions Revisions to DIRs shall be mode, verified, opproved and signed in the some manner as the original document. Revised DIRs with necessary approvals completed shall be forwarded to the Generic Implications Coordinator for entry d
into the DAPTS (replacing the superseded revision) and retention of the signed revision in on auditable file. The active DAPTS will contain only the most current revision of DIRs.
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, etc.). The Generic k
kl TN-85-6262/? Page 23 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES Implications Coordinator may add TUGCO-supplied TDDR numbers to the DAPTs without revision of the DIR.
Two hard copies of the revised DIR (with blank date blocks but with typed nomes of signators on the lost revision) will be returned to the Discipline Coordinator of ter 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 by mark-up and signatures on a copy of the then-current DIR.
4.5 Dato Entry The Generic implications Coordinator (or his designee) will ensure that the information from each approved Issue Record, DIR, and DlR 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 disciplines.
lk Af ter verification that the information contained in the DAPTS is occurate, the signed originals will be filed in the controlled DAP files by a DAP Tracking System operator responsible to the Generic implications Coordinator.
Externally resolved issue numbers (R-XXXX), open issue numbers (E-XXXX), and DAP identified discreponey numbers (D-XXXX) will be sequentially assigned by the Generic implications Coordinator (or his designee). These identification numbers will be noted on the issue Records and DIRs along with the date of entry into the DAPTS. Issue / discrepancy numbers remain unchanged throughout the h conduct of the DAP except as necessary to implement changes in the DAP Tracking System structure.
i O
a TN-85-6262/2 Page 24 of 45 l
l l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
<O ISSUES AND DISCREPANCIES 4.6 Disposition of DIRs When the reviewer has completed the preparation or revision of the DIR, the reviewer will sign the DIR and submit it to the oppropriate Discipline Coordi-notor for disposition.
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. When the DlR has been approved, the Discipline Coordinator will forward it to the Generic implications Coordinator for entry into the DAPTS.
Eoch week the Generic Implications Coordinator (or his designee) will forward hard copies of new and revised DIRs (that meet one of the following conditions) received during that week to the DAP Monoger for forwarding to appropriate
- Project personnel. The conditions for DIRs transmitted are
o All DIRs that were closed during that week regardless of classification; o All open D-XXXX DIRs that were opened or revised during that week;
! o All E-XXXX DIRs that were classified during that week as a deviation, unclassified deviation, deficiency, or pro-l grammatic deficiency; i
o All C-XXXX DIRs that were opened or revised during l that week.
l I
i The DAP Monoger will request that TUCCO odvise him of the TUGCO Design Deficiency Report (TDDR) number assigned by TUGCO to each D or E type DIR sent to TUGCO. Upon receipt of TDDR numbers from TUCCO, the Generic Implications Coordinator shall ensure that these TDDR numbers are entered in i
O TN-854262/2 Page 25 of 45 L_.____-.-_______ - - - - - --
RESPONSIBILITY FOR APPROVING O CLASSIFICATION AND CLOSURE CLASSIFICATION
, EXTERNAL AP RESULTS SOURCE NOT EXPLICITLY DEFINED ISSUE BY EXTERNAL SOURCE ISSUE CLOSED OPEN DISCIPLINE COORDINATOR UNSUBSTANTIATED DISCREPANCY O
OBSERVATION DAP MANAGER NDEVIATION l REVIEW I TEAM PROGRAMMATIC UNCLASSlFIED DEFICIENCY LEADER DEFICIENCY DEVIATION FIGURE 2 i
RELATIONSHIP BETWEEN CLASSIFICATlON .
AND APPROVAL AUTHORITY TN-85-6262/2
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE p Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 Q ISSUES AND DISCREPANCIES the corresponding DIRs in the DAPTS. This may be done without revising the DIR.
Upon receipt of a DIR that has been classified as a deficiency, programmatic deficiency or unclassified deviation, the Review Team Leader will, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of approval of the DIR, transmit a copy of the DIR to the CPRT Senior Review Team and to appropriate Project personnel.
lh 4.7 Comparison of External Source issues and DAP Discrepancies with Appropriate CPSES Project Records of Discrepancies in order to incorporate CPSES (Project) records of discrepancies for comparison purposes into the DAP, appropriate project records will be reviewed. These records may include documented evaluations done pursuant to IOCFR 50.55(e)
O and 10CFR 21 and other historical records of evaluations (such as Significant Deficiency Analysis Reports (SDARs)) regarding design problems that are rele-vont 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 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 discrepancies for trending purposes, selected project records will l 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 record. The identification number and date of entry into DAPTs will be noted on the DIR form. Specific entries on "T" type DIRs are covered in Section 5.5.7.
O TN-85-6262/2 Page 27 of 45 l
I 1
i I
COMANCHE PEAK RESPONSE TEAM DESIGN ADEOUACY PROCEDURE I l
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
~
ISSUES AND DISCREPANCIES These "T" type DIRs do not require resolution by the DAP because they represent only documentation of project findings and, through project resolution mechonisms, will be resolved. "T" type DIRs will not become part of the DAP Tracking System as committed to in the CORT 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 evoluotions and IRR development.
4.8 Discrepancies identified During Overview of Corrective Actions Discrepancies in corrective actions identified during overview activities are significantly dif ferent from External Source issues or discrepancies that are identified by the DAP during the self-initiated portions of the DSAPs. Because these areas of design are subject to reverification or redesign, there is a need only to describe and track these discrepancies to closure as part of the corrective action overview described in DAP-20. There is no need to develop or I
record all of the information required of discrepancies identified in the self-initiated parts of the DSAPs because trending, root cause and generic l
implications evaluations by DAP are not applicable to corrective action activities. The information required to be documented on the corrective action
("C" type) DIRs is contained in Section 5.5.8.
5.0 DOCUMENTATION l
5.1 Summary issue Record Cover Sheets, Issue Records, OOC issues Logs (if used) and DIRs shall be prepared using the attached forms. All per+inent information shall be documented clearly and completely as required for each different form and each i
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 k
b
'd TN-85-6262/2 Page 29 of 45
i COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE p
V Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 4 contained in Figure 3. This example process does not include the preparation of IRRs.
All records required by DAP General File No. 4.0 or subfiles shall be maintained in the TERA Bethesda Office under the control of the PGl Coor'dinator. Copies may be maintained at other DAP work locations os desired.
S.2 lssue 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 contain the name of the t
organization which issued the document being reviewed.
Each External Source document reviewed will be assigned on identification number by the DAP. The Document I.D. field will contain this CPRT identifico-tion number. A cross-reference between Document I.D. and the title or description of the External Source document shall be maintained.
The Description field will contain any additional information needed to describe the document, including any document ID number assigned by the issuing organization.
l The Addressee Organization field will contain the name of the organization to which the document is addressed (if applicable).
The Document Date field will contain either the date of issuance of the IA document or, if the document is a meeting transcript, the date that the meeting was held.
l O TN-85-6262/2 oge 29 of 45 1
l l
l
OPEN E xTERNAL ACTION PL AN SOURCE ISSUES IMPLE MENT ATION O
1 F OPEN YES EXTERNAL ISSUES '
" DISCREPANCY / ISSUE RESOLUTION SUBSTANTIATED
?
REPORT: CLASSIFY ISSUES AND 7 ACTION PL AN RESULTS NOT COVERED IN ISSUES AS NO OC 7 DISCREPANCIES 1 r YES CLOSE ISSUE i f ON DISCREPANCY /
ISSUE RESOLUTION OTHER DISCREPANCIES EVALUATE PER ACTION PL AN REPORT REVISION OR EXPANSION
, r + NO m DATA ENTRY C T pp q P NO UPCRADE CLASSIFICATION DOCUMENT ISSUE 7 CLOSURE IN DIS C. DISC. COORD. . CONCUR RD-RESULTS REPORT COORD. DAP MCR. . CONCUR APPROVE YES RTL . APPROVE O 1 f CLOSE DISCREPANCY SIGN P SRT . REVIE W RCVISE DISCREPANCY REPORT AS OBSERVATION UPCRADE TO DEVIATION t ISSUE CLOSED (WITH OR WITHOUT UNSUBSTANTIATED CORRECTIVE ACTION)
IN REVISED DISCREPANCY / ISSUE RESOLUTION REPORT 4w 1 Y
COPY TO PROJECT DATA ENTRY W/ REQUEST FOR F TDDR#
DATA ENTRY qy DAT A ENTRY TDDR#
f FROM DROJECT 1 V DOCUMENT IN DISC.
RESULTS REPORT COORD.
DIRECT NO CORRECTIVE A ACTION 1 V ?
ISSUE / OBSERVATION CLOSED O UNCLAS$1FIED DEVIATION FIGURE 3 TN-85-6262/2 CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW nm m -
, A N EVALUATE PER ACTION PL AN REvlSION OR EXPANSION ,
1 P EVALUATE SAFETY p SIGNIFICANCE YES OTHE NO C DISCREPANCIES y 1 r NO UPCRADE CLASSIFICATION l I CLOSE DISCREPANCY AS DEVIATION (WITH YES DISC.
CORRECTIVE AC'lON COORD.. 1 I EVALUATION) IN RE- CONCUR, DISC. COORD. - CONCUR VISED DISCREPANCY / DAP MCR. REVISE DISCREPANCY REPORT DAP MCR. - CONCUR ISSUE RESOLUTION APPROVE UPCRADE TO DEFICIENCY REPORT RTL - APPROVE SRT - REVIEW l
O DATA ENTRY
+ +
COPY TO PROJECT DATA ENTRY W/ REQUEST FOR TDDR#
1 I 1 V DOCUMENT IN DISC.
RESULTS REPORT COORD. DATA ENTRY TDDR #
FROM PROJECT 1 Y ISSUE / DEVIATION EVALUATE PER ACTION PLAN REVISION OR EXPANSION b CRAVM lC DEFICIENCY) l l EVALUATE ROOT CAUSE/
l CEFERIC IMPLICATIONS l
l FIGURE 3 (Continued)
CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW TN-85-6262/2 Page 31 of 45
l l
o T IDENTIFY / EVALUATE CORRECTIVE ACTION PL AN =,
DATA ENTRY j 9 P EVALUATE CORRECTIVE ACTION IMPLEMENTATION P
ORRECTIVE ACTIOr4 ACCEP, TABLE YES P
CLOSE DISCREPANCY AS DEFICIENCY, UNCLASSIFIED DEVIATION OR PROGRAM. DISC. COORD.
MATIC DEFICIENCY (WITH CORRECTIVE DAP MCR. CONCUR O ACTION EVALUATION) IN REVISED DISCREPANCY / ISSUE RESOLUTION REPORT RTL . APPROVE SRT REVIEW 1 Y DATA ENTRY 1 V DOCUMENT IN DISC.
RESULTS REPORT COORD.
1 F l
ISSUE / DEFICIENCY l CLOSED l
l l
FIGURE 3 (Continued)
CPRT DESIGN ADEOUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW TNM262/2 Page 32 of 45
~_
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
]'
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES The number of issue Records that are ottoched 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.
5.3 OOC !ssues Log If the Reviewer elects to use the OOC issues Log, under the guidance of Section b
4.1.2, the log con be used to either summarize the issue or refer to specific issue Records which describe the issue in greater detail.
If the OOC issues Log is used, it shall be signed by the Reviewer and the Discipline Coordinator.
lh 5.4 issue Record Issue Records (Attachment C) are divided into 2 parts. Only Port I need be completed for open issues. Both Ports I and 2 will be completed for closed issues and may be used for open issues. Since the issue Record documents a
" snapshot" of information contained in the External Source document, the issue g
Record does not have o provision for revision, it contains historical "os found" information.
The maximum number of chorocters allowed for each field is indicated on the issue Record. Continuations beyond these maximum numbers of chorocters are acceptable. Continuations will be made available with DIRs by placing them in a notebook at each tracking system terminal, or os on alternative in the future will be accessible within the computerized DAPTS. They are identified by DIR number, issue name, and revision number (if Rev. I or above). Continuations are h
O TN-95-6262/2 Page 33 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE g^s Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 (j ISSUES AND DISCREPANCIES not now entered in the DAP tracking system, but may be included in the DAPTS in a future revision of the DAPTS structure.
The Date Entered DAPTS and issue // fields shall not be completed by the Reviewer except when on E-XXXX DIR number is received from the PGl Coordinator for a new primary issue. Otherwise, these fields shall be completed at the time of data entry into the DAPTS.
5.4.1 Part i 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 description (e.g., what is wrong and what is offected) to the extent that this information is included in the External Source document, so that those familiar with the review may identify the issue by its title. Keywords may lh be used in the title. Potential cause of the issue should not be used as 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 criterio and procedures should be identified to the extent they are specified by the source document. The source of any information not icken k
directly from the source document shall be included in the description.
Comments including resolution status as contained in the source document may be added in the Description of Resolution / Comments field of Part 2 whether or not the issue status is closed.
The page number of the source document on which the issue is discussed, along with the External Source issue identifier number (if applicable), will b~e entered l[
Q b TN-85-6262/2 Page 34 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES in the corresponding fields.
The structure (s), system (s), or component (s) offected will be identified if it can be readily determined from the source document. This identification may include components, component types, system names, locations, or structures.
The CPRT document identifier number will b2 entered in the DOC. ID field.
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 corresponding fields.
b If the issue has been determined to be closed, the classification of the issue will be indicated in the Classification field.
lk O The DAP discipline will be identified. For disciplines comprised of subdiscipline orcos of design in DAP-7, Attachment A, the subdiscipline will also be docu-mented if contained in the External Source document. Additional subdisciplines may be designated.
lk For open issues, and for closed issues that are not classified as unsubstantiated, it is noted on the issue Record whether the source document states that the issue:
o is an isolated error or has potential 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. -
TN-85-6262/2 Page 35 of 45
I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
- m. Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 (d ISSUES AND DISCREPANCIES For open or closed substantiated issues, the design organization a.nd design activity will be documented if that information con be readily determined from the source document. The design organization is the organization originally responsible for the work offected by the issue. The Design Activity field refers to design requirements discussed in ANSI N45.2.ll-1974 and Attachment F of this procedure.
For open issues, the number of the Action Plan (including the revision number) under which the issue will be investigated shall be written in the indicated fields.
If the open issue is to be evaluated within a self-initiated part of a DSAP, enter the most appropriate Review Topic and Homogeneous Design Activity (HDA) numbers within that DSAP. If the crea of design associated with the issue is to
- i. )
be addressed in an area of the design that is subject to reverification or redesign (e.g., piping and pipe supports, cable tray supports or conduit supports) Review g
Topic and HDA numbers are not required because Review Topics and HDAs do not apply to those creas of design that will undergo reverification or redesign. If Review Topic and HDA numbers are not required, enter either "NA" in both of these fields or, at the Discipline Coordinator's option, on appropriate Review Topic or HDA.
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 issues determined to be closed during document review.
The basis for determining that on 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 organi-zation to resolve the issue and any additional clarifying comments that the TN-85 6262/2 Page 36 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
( Number: DAP-2 (3,/
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 4 reviewer determines are necessary to document closure of the Issue Record.
The Safety Significance field documents the safety significance of the issue if the originating / investigating organization described safety significance in the External Source document.
lk The Root Cause field documents the root cause of the issue if determined by the originating / investigating organization and described in the source document. If any generic implications are discussed in the source document, they should be included in this field.
5.4.3 Sign-Off 3 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 initials) are
[
required on the issue Record (and DIR) forms as of April I,1986. Initials of the Reviewer and Discipline Coordinator are acceptable on issue Record and DIR forms prior to April I,1986 (in lieu of signatures) based on past revisions of this procedure.
5.5 Discreponey/ Issue Resolution (DIR) Reports 5.5.1 "D" Type DIRs The DIR contains information that is similiar to information contained in External Source issue Records, but the DlR information is active rather than historical. Active DIRs are comprised of External Source issues that were g
l identified initially as open and all issues identified in the self-initiated parts of the DS Aos and documented in "D" type (D-XXXX) DIRs. Differences.between the DIR fields and the issue Record fields are described below.
O TN-85-6262/2 Page 37 of 45 i
l t
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE 4
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES The revision number of the DIR shall be indicated in the Revision field. The original DlR will designated as Revision 0.
The "AP// 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 DSAP) under which the discrepancy was identified. For External Source issues, the field will contain "N/A" (not applicable).
The "APf/ To" field will indicate the Action Plan number under which the issue or discrepancy is being investigated. 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 evolvate the discrepancy as part of the DSAP.
The " Dependent On" field will contain a list of issue or discrepancy numbers which must be resolved prior to closure of the issue or discrepancy described on the DIR.
g The Design Discipline and Subdiscipline, Type, Trend (if identified and docu-mented in a DAP-7 trend evaluation or acceptable substitute, such as on IRR),
Design Organization, and Design Activity fields shall be entered during the course of evaluating or revising DIRs classified as an observations, deviations, deficiencies, programmatic deficiencies, or unclassified deviations. Attach-ment E contains guidance on interpretation of entries in the Type and Trend blocks. Attachment F contains guidance on use and interpretation of the Design Activity blocks.
If the DIR resulted from implementation of a self-initiated portion (not corrective action overview) of a Discipline Specific Action Plan (DSAP),
af fected Homogeneous 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 octivities, other than DS AP implementation
(
Q TN-SS-6262/2 Page 38 of 45 i
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O
V Number: DAP -2
Title:
DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES Revision: 4 of overview of corrective actions, the HDA number and Review Topic most closely related to the DlR shall be entered in Rev. O of "D" type DIRs or a revision of "E" type DIRs. 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 this discipline. Review Topics and HDA numbers may not be applicable to other areas of the DAP (e.g., creos subject to reonalysis 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. The Safety Significance Evoluotion will be conducted in accordance with DAP 22. The Root Cause/ Generic Implications O
Q field will be completed for unclassified deviations, deficiencies, and program-matic deficiencies per DAP-7. This information is not required on the DIR revision that initially classifies the discrepancy, but may be developed during evaluation of the issue and entered in o later revision to the DIR.
[ Prior to closure of any DIR originated from on External Source issue or self-initiated DS AP review (other than " Transferred to:" 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 (e.g., safety significance must be filled in for a deviation prior to closing the DIR).
As of April I,1986, signatures (not initials) are required as specified in DAP-2 for the various classifications of discrepancies. Initials on IR/DIRs prior to April I,1986 are acceptable (in lieu of signatures) based on past revisions of this procedure.
O TN-85-6262/2 Page 39 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE
('
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES 5.5.2 Duplicate DIRS ("D" or "E" Type)
If an identical issue or DIR is found to have been entered in the DADTS more than once, one DIR shall be retained in the DAPTS and each other DIR that is a copy of the retained DlR shall be designated as " transferred to" and duplicate; e.g., D-XXXX(D). A statement that the DIR is a duplicate (copy) of another DIR shall be entered in the Description of Resolution field.
The " Status" 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 shall be the final revision of the duplicate issue DIR. Duplicate "E" type or "D" type DIRs are considered closed and will not be revised or included in trend evaluations.
d(7 5.5.3 Related (Not Duplicate) DIRs Transferred to Primary issues
'E" or "D" type DIRs that are related tc, a technical or programmatic issue ( such as one to be covered in c primary 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 transferred to a primary issue (DIR) in either on open or closed status. The IRR number shall be entered in the IRR field on the primary DlR 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 "(O)", e.g., E-XXXX(0), or D XXXX(0) in the status block. A
" Closed" transferred to DIR will contain the primary DIR number followed by
"(C)", e.g., E-XXXX(C), or D-XXXX(C) in the status block of the machine-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 DlR until the primary issue (or IRR) is closed. .
A V
TN-85-6262/2 Page 40 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE O
'd Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES 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 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 evoluotion and resolution of the issue, only the status block shall be revised from "Open" to " Closed," that is, from E-XXXX(0) to E-XXXX(C) or D-XXXX(0) to D-XXXX(C). The " Transferred to:" E-XXXX or D-XXXX 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 trend evaluations.
5.5.4 Transfer of DIRs to Other CPRT or TRT Review Teams d k if, during implementation of an Action Plan, it is determined that the issue / discrepancy should be reassigned to the OOC Program, or the TRT Testing or Electrical Review Teams for resolution, the issue / discrepancy will be designated as closed in the status field. The DAPTS is used to track DIRs related to Civil / Structural, Mechanical, and Miscellaneous TRT issues through closure. The Description of Resolution field will document that the issue / discrepancy was reassigned to OOC or other TRT review team, and the Reference field will reference the memo documenting that reassignment. DIRs transferred to another CPRT review team will not be counted or considered in trend evoluotions within the DAP. A receipt acknowledgement shall be requested from the Review Team Leader to whom the DIR is transferred.
5.5.5 Unsubstantiated DIRs l If an issue is determined to be unsubstantiated, the issue will be assigned a status of closed, classification will be marked unsubstantiated and the basis for this TN-85-6262/2 Page 41 of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
(~- ISSUES AND DISCREPANCIES determination will be documented in the Description of Resolution field.
5.5.6 Unclassified Deviations if an issue meets the requirements of an unclassified deviation, the DIR must include a specific reference to the procedure, document, plan, etc., that encompasses the aspects of the issue that are the subject of the unclassified deviation. This reference must be listed on the DIR form prior to an approval as on unclassified deviation by the Review Team Leader.
5.5.7 DIRs Documenting CPSES Project-Identified Discrepancies Reports issued pursuant to 10CFR 50.55(e) or 10CFR 21 are reviewed only to document information in a form compatible to DAP DIRs. These DIRs are identified as "T" type DIRs. "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 No: T-XXXX l o Rev No:
o Entry Date o issue / Discrepancy Title o Description of issue / Discrepancy l
o Structure (s), System (s) or Component (s) Affected l -
- o Discipline l o Design Organization o Design Activity -
TN-85-6262/2 Page 4? of 45
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4
{d
\
ISSUES AND DISCREPANCIES o Description of Resolution o References o Review Topic and HDA (when applicable) o Safety Significance o Root Cause/ Generic implications o Review and approval signatures of Reviewer and a Disci.
pline Coordinator.
These DIRs are to be used as supplemental information during trend analyses or root cause/ generic implications evaluations of DAP-identified discrepancies or External Source issues. No v.tries for status, classification, type, trend, or subdiscipline are required on the "T" type DIR. b 5.5.8 DIRS Documenting Discrepancies Noted in Overview of Corrective Action DAP-20 requires that DIRs be written to document discrepancies identified by DAP in the overview of corrective actions. Such DIRs are issued only to track these discrepancies until resolution. These DIRs are written on form DAP-2-4, and are assigned "C" type DIR numbers. They are subject only to the following documentation requirements:
I o DIR No: C-XXXX o Rev No:
l o Entry Date i
o issue /Discreponey Title l
TN-85-6262/2 Page 41 of 45
I l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENT ATION AND TRACKING OF Revision: 4 !
ISSUES AND DISCREPANCIES o Description of Issue / Discrepancy o AP// From o AP// To o Structure (s), System (s) or Component (s) Affected o Status o Discipline o Design Organization (doing reverification or redesign) o Description of Resolution o References o Signatures (of Reviewer and approval of Discipline Co-ordinator).
m Because these corrective action ("C" type) DIRs are only to track corrective actions, classification, type, trend, design activity, Review Topic, HDA, TDDR//,
safety significance and root cause/ generic implications entries are irrelevant.
These DIRs will not be included in trend evaluations as they are not relevant to DAP reviews of 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.
S.5.9 Backfit of "C" Type DIRs Discipline Coordinators are responsible for ident'fying DIRs prepared prior to the approval of Rev. 4 of DAo-2 that address DAo overviews of corrective action and shall ensure that these DIRs are transferred to"C" type DIRs as follows:
l o Change the Status to Transferred to C-XXXX(D);
o State whether the overview discrepancy is open or closed; TN-85-6262/2 Page 44 of 45 l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 4 ISSUES AND DISCREPANCIES
}
o in the Description of Resolution block, write: 'This DIR D-XXXX resulted from an overview of corrective action and has been renumbered as a "C" type DIR."
o Sign the DIR form (only the Discipline Coordinator's signature is required);
o Send the DIR to the Generic implications Coordinator for dato entry.
Upon receipt of the DIR, the Generic Implications Coordinator shall ensure that the existing "D" type DlR is transferred to a "C" type DlR as follows:
o Revise the "D" type DIR to reflect any changes in the incoming revision, including status and the next revision number.
o Assign a C-XXXX DIR number in the status block of the "D" type DIR.
Copy the revised DIR, assign the some C-XXXX DIR O o number (Rev. 0), change the status field to open or closed as indicated on the incoming revision, and ensure that a reference to the duplicate "D" DIR number in the in-coming revision is included in the record.
l o Delete information from the incoming DlR from fields that are not required to be included in the "C" type DIR.
Unless otherwise approved by the DAP Manager or the RTL, Discipline Coordinators shall complete the backfit of "C" type DIRs by September 30,1986 or four weeks from the approved date of Rev. 4 of DAP-2 (whichever is later).
5.6 SRT Review of DIRs The Senior Review Team may review any DIR and identify the need for clarification, expansion of review or reassessment by DAo personnel.
TN-85-6262/2 Page 45 of 45 i - -- __ --- -
ATTACHMENT A COMANCIE PEAK DESIGN ADEQUACY PROGRAM ISSUE RECORD COVER SFEET
) Source Document
Title:
Originating / Investigating Organization:
Document ID:
Description:
Addressee Organization:
Document Date:
No. of issue Records Attached:
Signatures:
I I Reviewer Date Discipline Coordinator Date FORM DAP.21 REV. 0 i
O TN-85-6262/2 A-l L ____ _ -- - - - - - - -
. ATTACHMENT B COMANCE PEAK DESIGN ADEQUACY PROGRAM CONSTRUCTION /QA/OC ISSUES LOC Brief issue Description identifier # Page #
I I l I signatures:
Reviewer Date Discipline Coordinator Date FORM DAP.2 2 TN-85-6262/2 B-l agv o
ATTACHMENT C COMAM PEAK DESIGN ADEQUACY PROGRAM Date Entered DAPTS:
ISSUE RECORD issue #:
PARTl Issue
Title:
noi Description of issue: um Identifier #: noi Page #: c,3 Doc. ID am Structure (s), System (s) or Component (s) Affected:
030 Status: Class (Closed Issues Only):
O Open D Closed D Observation D Deficiency OProgrammatic Deficiency D Deviation D Unsubstantiated l ;
Discipline: 0 Mech. O C/S Type:
O Elec./l&C D Other: 1. O Ceneric D isolated D p;p;ng 2. O Cumulative O Not Cumulative Subdiscipline: em 3* I'* " **' U "' " '* * * *
Design Organization: (m Review Topic #: HDA #s:
] Design Activity: ld; O Program Req. O Interfoce Control O Change Control D input D Verification D Corr. Action D Process D Documen* Control D Audits O investigate Further Through Action Plan #: om Rev.
PART2 Description of Resolution / Comments:
(627)
Safety Significance Documented:
l[
l (379) l Root Cause/ Generic implications Documented:
l/d\
t30n l Signatures:
i l
Reviewer Date Discipline Coordinator Date
[ FORM DAP.2 3 W
ATTACHMENT D COMANCFE PEAK DESIGN ADEQUACY PROGRAM Data Entarsd DAPTS:
DISCREPANCY / ISSUE RESOLUTION REPORT issue / Discrepancy #:
Rev. #:
Issue /Discreponey
Title:
,4 o, Description of issue /Discreponey: 2')
AP #: From: To: Dependent On:
,,o3 Structure (s), System (s) or Component (s) Affected:
( 0 11 Status: O Open Class: o Discreponey a unciass Deviation D Closed O Observation 0 Deficiency D Transferred to: O Programmatic Deficiency 0 Deviation 0 Unsubstantiated Discipline: a Mech, o C/s Type: 1. o cenerie o isolated D Elec./l&C D Cen. impt. 2. O Cumulative Q Not Cumulative O Piping O Other: 3. O Technical O Programmatic Subdiscipline: (su Trend: i. o Agy ,,,, o sonogy ,,,
Design Organization: (2n HDA rs: (20)
Design Activity: O Progrom Req. O Interfoce Control O Change Control (one or more) O Input D Verification O Corr. Action R " T*P Ic #' (0 0 Process O Document Control O Audits IRR #:
Description of Resolution (incl. Corrective Action) (42n TODR # (to3
References:
(307)
Safety Significance:
078)
Root Cause/ Generic Implications:
(270)
Signatures:
1
! Reviewer Discipline Coordinator TRT/DAP Manager Review Team Leader Date Date Date Date SRT Comments (As Required): (22 9 SRT Signature Date FORM DAP.2 4 REV.4 )
ATTACHMENT E INTERPRETATION OF DAP TRACKING SYSTEM
" TYPE" BLOCKS Type: Generic or Isolated Cumulative or Not Cumulative Technical or Programmatic Trend - Adverse or Nonadverse 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 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 O not throughout) that discipline. Marking " Generic" in this example does not imply that the same error occurred outside the discipline indicated in the DIR.
~
If the some error is found in other disciplines, whether it is generic to these other disciplines is determined on a discipline-by-discipline basis.
o isolated should be checked if the discrepancy described in the DIR appears to be on 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 calculo-tion of post-LOCA 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 program-matic and generic blocks would be checked.
o Cumulative should be checked if the discrepancy described in the DIR is believed to impact the design in combination with other identified discre-pancies. For example, small unconservatisms may .
usually be neglected in design. If it were confirmed TN-85-6262/2 E-l
that most of the conduit supports are designed to
, maximum capacity, the cumulative effect of many unconservatisms may be significant. All DIRs con-sidered to have o cumulative effect on the design should be checked cumulative.
o Not Cumulative should be checked if the discre-pancy described in the DIR is by its nature not likely to impact the design if considered in combination with other discrepancies. For example, if an error in a calculation has no significant impact on a design output, then this error cannot have a cumulo-j tive effect with any other discreponey, and it should
- be marked not cumulative.
o Technical should be checked if the discrepancy described in the DIR relates to o technical concern.
For example, DlR D-0019 states that "TUGCO Cole.
SRB-109C, SET 3, Rev. 6 contains a modeling error and two unjustified assumptions that are important to the results." This DlR is correctly described as technical, o Programmatic should be checked if the discrepancy described in the DIR relates to o design process or O design control process (e.g., program, process, pro-cedure, work activity, methodology, or similar pro-grammatic aspect of design). For example, if during i
review of a technical discrepancy, it becomes op- "
l parent that a procedure for controlling the design work associated with the technical discrepancy was inadequate, incomplete, not implemented, or non-existent (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 interpretation of the term
" generic", a programmatic discrepancy should be interpreted within the confines of the discipline in which it was found. This does not mean that the discreponcy is programmatic to other disciplines although it may be. If a discipline coordinator believes that the discrepancy could likely offeet
- other disciplines, then DAP-7 requires that the 4 discipline coordinator identify the discrepancy to j the Programmatic / Generic Implications Coordinator and other potentially offected discipline coordi-notors. Checking the programmatic block alerts the PGl coordinator to the possibility of effects on other disciplines. Similar or related programmatic.
- O.
TN-85-6262/2 E-2
O 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 discrepan-cies and has been determined to constitute on adverse trend. A trend is considered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occur-rence of on undetected safety-significant deficiency in the offected design area. To mark the Trend block, a trend evaluation documented per DAP-7 on form DAP-7-1 must have been completed. k o Trend Nonadverse should be checked if the DIR is the result of a trend evaluation of design discre-pancies and has been determined to consistute a trend, but the trend is not adverse (not likely to have resulted in the occurrence of an undetected safety-significant deficiency in the area offected).
To mark the Trend block, a trend evaluation docu-mented per DAP-7 on form DAP-7-1 must have been completed. k O
O TN-85-6262/2 E-3
p ATTACHMENT F O
USE AND INTERPRETATION OF DESIGN ACTIVITY The DlR form contains nine design activities (DESACT) that are brood categories of various aspects of design. These design activities are based on ANSI N.45.2.ll-1974. They are used in initial trending of discrepancies, and they are contained in Attachment A, Example Attributes Matrix, of DAP-7 as Level 11 attributes.
D The design activities that are associated with the discrepancy should be checked when the DIR is written, or when the DESACT is identified and the DIR is revised in the course of evaluating the discrepancy, if the discrepancy relates to more than one DESACT, multiple DESACTs may be checked. The DAPTS tracking system is configured to capture combinations of DESACTs if more than one applies.
DESACT is a key attribute used in trending and generic implications 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 result-ing distributions of numbers of DIRs in these combinations (subsets) con be i identified, displayed, and analyzed, if these distributions are skewed so that some combinations have large numbers of discrepancies, then this pattern is i
indicative of a trend. Level ill information in DAP-7, Attachment A is intended to assist in ensuring proper Level ll DESACTs are marked in the DIR.
Interpretations of design activity attributes follow. These interpretations supplement descriptions found in ANSI N45.2.11-1974:
o Program Requirements - Specifies that there be program procedures addressing organizational structure, authority, .
responsibility, interfaces, management, and requirements TN-85-6262/2 F-l 1
e i
O v
related to the other design activities listed below. For example, discrepancies that resulted from o lock of procedures for design verification or change control.
o input Requirements - Specifies requirements to ensure A that design inputs or changes in these inputs (those ' l_4\.
criterio, parameters, bases, or other design requirements, including regulatory requirements, codes and standards, upon which detailed final design is based) are identified, documented, reviewed, approved, and controlled.
Level 111 of Attachment A _to DAP-7 contains a listing of kinds design inputs that may apply. This list is not all inclusive.
o h
Design Process - Specifies the use of procedures suffi-cient to assure that applicable design inputs are correctly translated into specifications, drawings, procedures, or instructions, and to ensure that oppropriate quality stan-dards 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 on offected DESACT on a DIR, however, a narrower inter-pretation should be used. That is, design process relates to controls (job specifications, work instructions, planning O sheets, procedure manuals, test procedures, or any other type of written form) and the implementation of these controls applied to analyses, calculations, and other direct h work activities used to produce design output drawings, specifications, or other documents, o Interface Control - Specifies requirements for external and internal interfaces. These interfaces are relation-ships between companies (external) and design groups or organizations within a company (internal). Requirements relate to identifying interfaces in writing, defining, and Q documenting responsibilities, establishing lines of com-munication, controlling the f'ow of design information, and documenting design information (including changes) i transmitted in drawings, specifications, or other con-
{ o trolled documents.
Verification - The process of reviewing, confirming, or Q
substantiating the design by one or more methods to provide assurance that the design meets the specified
, design inputs. Verification methods include design re-view, alternate calculations, and qualification testing.
l
' 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 standardiza-O TN-85-6262/2 F-2 L . _ . , --- - - - --- - - - - - - - - - ~ ~ ~ ~ ~ ~~~
o e
O Q tion, state-of-the-art, and similarity with previously proven designs. Where changes to previously verified designs have been made, design verification is required for the changes, including evaluation of the effects of 4 those changes on the overall design.
o Document Control - Specifies requirements for proce-dures to control issuance of design documents and changes thereto. Document control requirements relate to prepo-ration, opproval, issuance, and revisions of design docu-ments. Procedures cover responsibilities for preparing, reviewing, opproving, issuing, and revising documents, identifying documents, coordinating, and controlling interface documents, ascertaining that proper documents are used, and establishing distribution lists that are up-dated and current.
lg 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 o Change Control - Specifies requirements for controlling h changes to approved design documents to assure that impacts of changes are carefully considered, required actions are documented, and change information is trans-mitted to all offected persons and organizations. Changes shall be justified and subjected to design control measures commensurate with thore opplied to the original design.
Reasons for changes listed in Attachment A of DAP-7 are valuable as attributes in determining 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 k reflect design changes are reviewed and approved by the j some groups or organizations which reviewed and op-proved the original design documents.
l o Corrective Action - Specifies requirements for proce-dures for reporting deficiencies and determining corree-tive action of specific errors, in addition, for significant or recurring deficiencies, determining the cause and insti-tuting changes in the design process or quality assurance program to prevent recurrence of similar types of defi-ciencies is also required. Attachment A of DAP-7 lists examples of objects of corrective action (e.g., design ,
activities, procedures, personnel, training, and manage-ment). For example, if on error had been detected in the TN-8S-6262/2 F-3
o
=
o V past and corrective action was taken but the same type of error continued to recur, then corr,ective action would be checked as an inef attribute fective.on the DIR because corrective o
action was apparently d
- Audits - Specifies requirements to plan, conduct and document audits to verify compliance with all aspec,ts of the OA program for design. If a discreponey 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 judgeme whether the problem documented in those DIRs (with final classifications) in the subsets that exhibit trends is likely to constitute on adverse trend. If an adverse trend is likely to exist, o DlR classified as a programmatic deficiency is written, without first performing a safety significant evoluotion.
. The formal safety significance evaluation, root cause and generic implications evoluotions are don in the process of evolvating the progammatic deficiency. This information, as t where the trend applies, (how widespread is the problem), what organization and O discipline were involved, and what is the cause of the trend will be developed as part of evaluations of the trend regarding safety significance (not required for unclassified trends), root cause and generic implications, if a trend is identified based on DIRs that have not received final classifications, the trend shall be considered potentially adverse and preliminary until all DIRs in the trend receive final classifications.
The end result of identification of on adverse trend is a concise description of a problem. This description could have been originated based on judgment of DAP personnel and confirmed by analyzing the DIR dato. Alternatively, the descrip-tion may have been originated as a result of analyzing the DIR dato and I confirmation by one or more DAP disciplines. Problem description precedes decisions as to whether the trend is adverse and, if so, that a programmatic '
deficiency exists. Problem description also precedes determining why the trend occurred (root cause or causal factors), and whether it offects other creas of design not yet identified (generic implications).
s TN-85-6262/2 F-4
. ___ . _