ML20215J902
| ML20215J902 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/22/1986 |
| From: | Blackwood E TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20215J430 | List:
|
| References | |
| DAP-7, NUDOCS 8610270237 | |
| Download: ML20215J902 (70) | |
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TITLE TRErolNG AND GERIC IMPLICATIONS EVALUATIONS ~~~~~~~ ~~
NUMBER DAP-7 Revision Prepared Date Reviewed Date Approved Date 0
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TABLE OF CONTENTS Section Page Co v e r S h e e t......................................................
i Tab le o f Co n t en t s................................................. ii 1.0 P U RP O S E...................................................
I 2.0 SCOPE.....................................................
I 3.0 DEFINITIONS AND RESPONSIBILITIES.........................
2 4.0 I NS TR UCT I O N..............................................
9 b
5.0 D O CUME NTAT I ON..........................................
23 ATTACHMENTS A
EXPL ANATORY ATTRIBUTES MATRIX........................
A-1 B
TREND EVALUATION........................................
B-1 C
GENERIC IMPLICATIONS EVALUATION J
ENGitEERING EVALUATION.................................
C-1 D
EXAMPLE LIST OF POTENTIAL ROOT CAUSES OR d
C A US AL F A CTO RS.......................................... D-l E
EXAMPLE QUESTIONS FOR EVALUATION OF POTENTIAL ROOT CAUSES OR CASUAL FACTORS.............
E-l F
TREND EVALUATION FORM DAP-7-1 F-l G
TREND EVALUATION LOG DAP-7-2 G-1 H
S U M M A R Y OF D AP-7........................................ H-l i
TN-85-6262/7 11 i
9 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE 4
Number: DAP-7
Title:
TRENDING AND GEtERIC Revision i IMPLICATIONS EVALUATIONS l.0 PURPOSE J
This procedure establishes acceptable methods for performing two separate types of evaluations. They are: (1) identifying trends in DAP findings and 4
External Source issues (including resolved External Source issues), and evoluoting whether these trends are adverse, and (2) evaluating the generic implications of deficiencies, unclassified deviations, and identified adverse trends. The use of these methods or equivalent techniques for trending (such as completion of on issue Resolution Report (IRR) that encompasses those DIRs covered in the IRR d
or are part of an adverse trend covered in on IRR) will provide reasonable l
ossurance that trends or generic implications have been identified and evaluated.
2.0 SCOPE This procedure applies to DAP technical disciplines and the programmatic / generic implications discipline in trending and generic implications (including root cause) evoluotions of External Source issues and i
discrepancies identified during the DAP review of the design of CPSES.
j Equivalent techniques, such as an IRR, may be used if they are consistent with ld j
the requirements of Appendix E to the CPRT Program Plan. This procedure l
encompasses evoluotions of identified adverse trends, unclassilled deviations, 1
and deficiencies.
This procedure does not encompass the overall program i
evaluation of the quality of the design of CPSES (see DAP-9). Attachment H is ld on executive level summary of trending and generic implications evaluations and their relationships with other DAP octivities.
4
'O j
TN-85 4262/7 Page I of 26
9 COMANCFE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEtERIC Revision I IMPLICATIONS EVALUATIONS l
3.0 DEFINITIONS AND RESPONSIBILITIES i
3.1 Definitions 3.1.1 Trend As quoted from Appendix E of the CPRT Program Plan, "(a) trend is a set of related discrepancies (observations and/or deviations) having attributes that reflect a discernable commonality. Examples of possible commonalities include:
i The individual, group or individuals, or organization per-o forming the safety-related activity o
The program requirements, procedures, or controls governing the performance of the safety-related activity.
!O l
In this procedure, a multidisciplinary trend is one that offects more than one j
discipline.
This use of the term "multidisciplinary" is not limited to the j
multidisciplinary review activities in the DSAPs that deal with equipment l
qualification, FMEA, flooding, fire protection, etc.
i 3.l.2 Adverse Trend i
I A trend is considered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected (safety-significant) deficiency in the offected area of design. With respect to design, on adverse trend is programmatic in nature and is classified as a
}
programmatic deficiency.
A full safety-significance evaluation such as is l
provided in DAP-22 is not required to make a determination that,a trend is g
~
adverse.
l TN-85-4262/7 Page 2 of 26 i
i a
9 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEERIC Revision i IMPLICATIONS EVALUATIONS 3.l.3 Programmatic Deficiency A set of related design discrepancies that have been determined to constitute on adverse trend that is programmatic in nature. An adverse trend is referred to os a programmatic deficiency.
A trend is considered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of on undetected safety-significant deficiency in the offected design area. Programmatic deficiencies (like design deficiencies) cre subject to evaluations of safety-significance, root cause, generic implications, and odequacy of corrective action.
3.1.4 Unclassified Deviation A deviation or set of deviations for which it has been determined that it is more practical to proceed directly to analyzing root cause and generic implications and specifying of corrective actions. A safety-significance evaluation will not be done for unclassified deviations beccuse it would serve no useful purpose.
Unclassified deviations are those related to areas in which reverification or-redesign is being conducted. Unclassified deviations will be trocked as deficien-cies in that root cause end generic implications evoluotions will be done and b
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.
3.1.5 Trend Evaluation A process of developing and reviewing information (e.g., attributes) related to issues, discrepancies, observations, deviations, unclassified deviations, or de-ficiencies, that is intended to identify any trend and to determine whether it constitutes on adverse trend.
O TN-85-6262/7 Page 3 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEERIC Revision i IMPLICATIONS EVALUATIONS 3.1.6 Attributes A set of characteristics that describes on issue, discreponey, observation, deviation, unclassified deviation, or deficiency and con be used to identify a trend.
3.l.7 Attribute Matrix A matrix that contains all or a subset of records (Discreponey/ Issue Resolution (DIR) Reports) in the DAP tracking system (deficiency, deviation, unclassified deviation, observation, discreponey, issue, or any combination of these) and selected, relevant attributes that apply to each of the records included.
Matrices with different sets of attributes are generated by sorting DIRs that exhibit those selected attributes.
O 3.l.8 Common Attribute An attribute that is found by sorting of DIRs, or evoluotion, to be a common chorocteristic of a set of issues, discrepancies, observations, deviations, unclos-sified deviations, or deficiencies. A common. attribute exists when there are d
multiple DIRs that exhibit a particular attribute. A common attribute that relates to several DIRs or issues is on indication of a trend or pattern.
3.1.9 Generic implicotton A reasonable likelihood that on issue or discrepancy (DIR) offects some aspect of design other than the specific instance in which the finding is identified.
O TN-85-6262/7 Page 4 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEfERIC Revision i IMPLICATIONS EVALUATIONS 3.1.10 Generic implications Evoluotion The process of reviewing programmatic deficiencies, unclassified deviations, or j
design deficiencies identified or confirmed by the DAP to:
Determine whether related design deficiencies exist, o
investigate the root cause or casual factors, and o
o Determine limiting boundaries of applicability of the deficiency under review.
3.1.11 Root Cause The cause or causal factors that contributed to a programmatic deficiency, unclassified deviation, or design deficiency, i.e., why it occurred. A root cause may be determined during on evoluotion by testing a hypothesis or by making a preliminary judgement subject to confirmation. Root causes and causal factors j
and the extent of their applicability in design are based on objective evidence.
They are confirmed and bounded by the findings of evaluations (what does exist) i rather than by general statements of what could exist.
l l
l 3.1.12 Safety Significance 1
I As quoted from Appendix E of the CPRT Program Plan:
"Sofety-significant," for purposes of the CPRT Program, is defined to mean that the identified discrepancy, if uncorrected, would result in the loss of capability of the affected system, structure or component to perform its intended safety function.
For purposes of the CPRT.
Program, credit is not allowed for redundancy at the component, system, train or structure level.
O TN-85-4262/7 Poge 5 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE n
v Number: DAP-7
Title:
TRENDING AND GEtERIC Revision i IMPLICATIONS EVALUATIONS This definition, which is employed in the CPRT Progrom 4
for purposes of somple expansion, is more restrictive than j
that usually applied to the term " safety-significant" for regulatory purposes or in common parlance, in that it ignores redundoncies that do exist in real life. (Compare 10 CFR 50, Appendix A (introduction, " Single Follure");
10 CFR 50,55(e)(l).)
Identification of a deficiency as
" safety-significant" for purposes of the CPRT Program, therefore, is not equivalent to a statement that, in fact, the deficiency, if uncorrected, would have resulted in unsafe operation.
3.2 Responsibilities Responsibilities specific to this procedure are os follows:
3.2.1 Generic implications Coordinotor Establishes a program and methodology for (1) disci-o pline-specific trend evoluotions of observations, de-victions, unclassified deviations, or deficiencies (in-cluding External Source issues) that opply to a single DAP discipline, and (2) multidisciplinary trend eval-uotions.
Establishes a program and methodology for disci-o pline-specific and multidisciplinary generic implico-tions evoluotions of programmatic deficiencies, un-l classified deviations, and design deficiencies. This constitutes investigation of root causes and limiting ld boundaries of applicability.
l o
Reviews or manages reviews of results of trend and generic implications evoluotions for consistency and 1
potential ef fects in other disciplines.
Monoges the generic implicottons evoluotion pro ;,
o gram and molntains DAP-7.
l O
TN-85-6262/7 Page 6 of 26
j COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEPERIC Revision I IMPLICATIONS EVALUATIONS 1
Participates in determinations of adverse trends and Q
o root cause of multidisciplinary programmatic defici-encies, unclassified deviations, and design defici-encies.
Coordinates applicable programmatic considerations o
with the QA/QC Review Team or other TRT Review I '\\
/
Teams through proper interfaces.
.l i
Maintains auditable files and documentation for o
j multidiscipline trending and generic implications 1
evaluations.
Forwards evaluation results to the Design Adequacy o
i Program Monoger and Design Adequocy Program l
Review Team Leader for review, concurrence, or approval os appropriate.
3 j
Provides apparent cross-discipline concerns to other o
disciplines, os applicable, based upon review of dis-cipline-specific evaluations.
O 3.2.2 Discipline Coordinators Conduct or direct trend evaluations and generic o
implicottons evaluations within their discipline to j
assess whether trends exist, whether trends are odverse, whether generic implicottons exist and whether the bounds and root causes of generic implications appear to be localized within the disci-i pline.
Identify those implications which may be i
cross-discipline in nature to the Generic implico-l tions Coordinator and other potentially offected l
Discipline Coordinators.
l l
o Participate in the determination of root causes of programmatic design deficiencies within the disci-pline.
i Modify or create new oction plans as necessary to'-
o address generic implications identified by generic implications evaluations.
i O
TN-85-6262/7 Page 7 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEtERIC Revision i IMPLICATIONS EVALUATIONS Maintain auditable files and documentation for dis-o cipline-specific trend and generic implications evol-votions.
Review and concur in evoluotions done within their o
discipline.
Forward results of trend and generic implications o
evoluotions done within the discipline to the Generic Implications Coordinator for review and to the DAP Monoger and DAP Review Team Leader for review, concurrence, or opproval as appropriate.
3.2.3 Discipline Leoders/ Reviewers Perform, coordinate, and document trend evalua-o tions and generic implicottons evoluotions as as-signed.
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3.2.4 Design Adequacy Program Monoger Approves work assignments for portions of generic o
implications evoluotions (including root-couse inves.
A tigations) that appear to offect more than one L!.1 discipline, Directs implementation of a generic implications o
evoluotion of any special cose described in Appen-dix E of the CPRT Progrom Plan.
Porticipates in determination of adverse trends (at o
A his option) and root causes of DIRs that require root th cause evoluotion.
Reviews and concurs in the results of trend evoluo-o tions and generic implications evoluotions.
O TN-85-6262/7 Page 8 of 26
i COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
'3 O
Number: DAP-7
Title:
TRENDING AND GEbERIC Revision i IMPLICATIONS EVALUATIONS 3.2.5 Design Adequacy Program Review Team Leoder (RTL)
Participates in determination of adverse trends (at o
his option) and root causes of DIRs that require root d>
cause evaluation.
o Approves the results of trend evaluations and generic implications evaluations and submits results to the SRT for review as required.
Assists other non-QA/QC RTLs as requested in con-A o
ducting root cause and generic implications analy-41.1 ses.
4.0 INSTRUCTION These instructions provide requirements that shall be met in conducting trend evaluations per this procedure or as part of evaluations that lead to issue Resolution Reports and generic implications evaluations. Each of these types of d
evaluations or equivalent evaluations for trends as part of issue Resolution Reports shall be conducted by a specific DAP discipline for concerns that apply to that discipline, or by the Programmatic / Generic implications (PGI) discipline for portions of those concerns that offeet more than one discipline. Figure I shows the relationships of trend and generic implications evaluations with discrepancy classification, safety significance evaluation, corrective action evaluation, and closure. Attachment H is on overview that summarizes these ld relationships, and trending and generic implications evaluations. This attach-ment is for information only, and should give those not directly involved in trending and generic implications sufficient understanding of these evaluations to allow them to carry out interfacing activities without specific training in DAP-7. Figure 3 of DAP-2 is a more detailed chart that shows these.cctivities in the context of the flow of Discrepancy / Issue Resolution (DIR) reports within the DAP.
O TN-85-6262/7 Page 9 of 26
.g.
T-EXTERNAL Dia,
IR/DIR
, D'A SOURCE ISSUES IDENTIFIED SELF. INITIATED REVIEW EVALUATION Dap.21
- h DLPLICATE IR/DIRs TRANSFERRED TO DAP.2 EVALUATION; ATTRIBUTES PROECT.lDENTIFIED IDErfTIFIED ISSUES DAP.2/ ACTION PLAN 5 4
1 1i UNSUBSTANTIATED TREND CA IFIED D
C I
hLl
^
DAP.2 DAP.7 UNCLAS$lFED DEylATION TY DEVlATION
?
155UE RESOLUTION cp gq m
REPORT EVALUATION mumme DAP.22 DAPJ DEFICENCY O
TREND EVALUATION
- 4 DAP.7 l
1 P
7 ROOT CAUSE/CEPERIC AMRSE IWLICATIONS
, M ND EVALUATIONS m
DAP.7 LIMITING ROUNDARIES APO ROOT CAUSE NONADVER$E CORRECTIVE ACTION EVALUATION D69 20 4
CLOSURE C
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FIGURE I INTERRELATIONSHIPS OF DAP ACTIVITIES AND PROCEDURES DISCREPANCY CLASSIFICATION, SAFETY SIGNIFICANCE EVALUATION TRENDING, GENERIC IMPLICATIONS, CORRECTIVE ACTION, AND CLOSURE
- O I
REV.l TN-85-6262/7 Page 10 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE (3 i i
Number: DAP-7
Title:
TRENDING AND GEbERIC Revision i IMPLICATIONS EVALUATIONS 4.1 Trend Evaluations Each DAP technical discipline shall perform trend evoluotions described in, or equivalent to this section on information and findings that are identified within g
the review activities of that DAP discipline. The Discipline Coordinator shall determine when such evaluations will be performed.
Trend evoluotions of information and aspects of findings that may reasoncoly offect more than one technical discipline shall be performed under the direction of the Program-matic/ Generic implications Coordinator, who shall determine when such evalua-tions shall be performed. Additionally, the Programmatic / Generic implications Coordinator may elect to initiate cross-discipline trending based on the recom-mendations of findings of Discipline Coordinators who suspect a potential lh
- multidisciplinary trend.
The purpose of a trend evaluation is to determine whether a trend exists and whether an identified trend is adverse. Attachment B provides step-by-step instructions for performing a trend evaluation and docu-menting it on Attachment F (from DAP-7-1) in accordance with these instruc-tions. Departures from this guide, such as conducting on IRR that meets the intent of trend identification and evaluation, shall be justified and documented form DAP-7 and approved by the Discipline Coordinator or Program-on motic/ Generic implications Coordinator, as appropriate. His signature on the form indicates his opproval of any such exceptions.
4.1.1 Input Information During the course of implementing the DAP within each discipline, design-related discrepancies may result from:
(1) identification through the self-Initiated DSAP reviews, (2) confirmation in evaluations of open External Source issues, or (3) classification of External Source issues that had been closed by on external source. A Discrepancy / Issue Resolution report (DIR) per DAP-2 will be generated or revised to track these discreponcles. During reviews conducted n
v TN-85-6262/7 Page lI of 26 L
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE OQ Number: DAP-7
Title:
TRENDING AND GErfRIC Revision i IMPLICATIONS EVALUATIONS within the discipline, the attributes of each discrepancy shall be determined and documented on the DIR report to the extent reasonable to describe relevant ld information such as what, where, when, why, who, and how, regarding the discrepancy.
Information that indicates a possible multidisciplinary trend shall be referred to the PGl discipline. This information (l) could be contained in issue Records or DIRs, (2) could result from a discipline-specific trend evaluation that identified on adverse trend (programmatic deficiency) that could logically offect other disciplines, or (3) could result from a discipline-specific generic implications evoluotion that indicates that a problem is not limited to that discipline but ld could likely have resulted in safety-significant deficiencies in other disciplines.
4.1.2 Trend Attributss Ab The attributes for identifying and evaluating trends are:
o Design discipline o
Design organization o
Design activities IA o
System, structure, or component o
Classification, status and type of issue o
Potential safety significance (if identified) o Root cause (if identified) o Potential generic implicotton (if identified) o Nature of the problem or technical issues (e.g., IRR subject) ld O
V TN-85-6262/7 Page 12 of 26
9 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE (3
'j Number: DAP-7
Title:
TRENDING AND GEERIC Revision i
\\
IMPLICATIONS EVALUATIONS Review topic (group of HDAs) o Homogeneous design activity (HDA).
o Within these attributes, on additional tier of entries that could be relevant to each issue, or DIR evaluated, have been developed.
These entries in each attribute are Level ll subattributes. A third tier within some subattributes has been developed to describe and characterize the Level 11 ottributes as necessary.
d The Generic implications Coordinator shall develop a list of attributes, sub-attributes, and amplifying information. Any major revisions of Attachment A will be incorporated by procedure revision.
4.1.3 Trend Recognition
,O Reviewers shall conduct trend evaluations using information in issue Records and "D" type DIRs related to the self-initiated portion of the DAP. Information in evoluctions and other documents generated within the DAP and contained in b
DAP files may also be used. Reviewers may identify trends manually or may use computer-assisted sorts of DIRs to identify relationships among the data.
Duplicate issue Records of the same observation (such as those that report the same issue in different parts of one External Source document or in different External Source documents) are not multiple observations and shall be counted as a single observation for trending purposes. DIRs that are related to the some technical or programmatic issue may also be combined into primary issues, for example during development of DAP issue Resolution Reports (IRRs). These b
related issues will be transferred to primary issues per DAP-2, and the primary issues, in addition to individual related issues, will be used in trend evaluations.
Unsubstantiated issues will not be used in trend evaluations or generic Implico-tions evaluations.
I e
TN-85-6262/7 Page 13 of 26
COMANCHE PEAK RESPONSE TE AM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GENERIC Revision l IMPLICATIONS EVALUATIONS A trend shall be identified if a common attribute or set of attributes is found among a relatively large number of issues, observations, deviations, unclassified deviations, and deficiencies. The distribution of DIRs exhibiting these attributes may indicate o possible causal relationship. Due to the broad scope of the DAP, it is expected that a trend that is programmatic will be indicated by several DIRs that are related to o single issue, or exhibit the same attribute of the trend. Although final trends will be based on DIRs with final classifications, trending may be done also on issues and discrepancies offer entry in the DAP frocking system but before final classification. Final decisions as to existence and adversity of trends will be based on final classifications of DIRs.
b Reviewers may conduct trend reviews to gain information concerning their discipline, review topic, HDA, etc.
For example, o reviewer may trend information on one or more checklist attributes, in the event that such trend reviews are conducted, they are considered to be equivalent to trending described in this procedure, and each shall be documented or referenced on a form DAP-7-l. Trend reviews,if performed, should be documented as port of an oppropriate engineering evoluotion or issue Resolution Report, if a trend is identified through a frend review, the determination of whether it is adverse should also be documented in the engineering evoluotion or issue Resolution Report. DIRs shall be written for any identified trends (whether found to be adverse or non-adverse) and shall be processed in occordance with DAP-2.
After a trend is identified, the trend shall be evoluoted to determine whether it is adverse and programmatic in noture offer consideration of the requirements of 4.l.4 or 4.l.5 as appropriate.
4.l.4 Trends in Discreponcies Classified Only as Observations For trends found in discrepancies and External Source issues classified only as TN-85-6262/7 Page 14 of 26 I
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE q(U Number: DAP-7
Title:
TRENDING AND GEbERIC Revision I IMPLICATIONS EVALUATIONS observetions, expansion of the DAP scope of review should not be performed to determine whether similar observations could be found.
In this case, the reviewer should proceed directly to the trend evoluotion described in 4.l.6.
4.1.5 Trends in Discrepancies Classified as Observations and Deviations For trends indicated in discrepancies that include deviations, on investigation far the existence of similar deviations shall be considered. The following action shall be token within the oppropriate technical disciplines to determine whether similar deviations exist elsewhere.
o Decide how to determine whether similar deviations exist
[d if they have not already been identified. The method to make this determination may be to reuse on existing checklist, or part of a checklist that is sufficient to m
detect a deviation if it exists in the crea being reviewed, o
Determine from the project whether similar deviations had been identified in the post. This could have been documented in 50.55(e) or Port 21 reports to the NRC or in Project internal reports such as TDDRs, ECNs, TDRs, NCRs, etc. (50.55(e) and Port 21 reports will be docu-mented as "T" type DIRs per DAP-2 in the some format as l
DAP DIRs, to enable direct comparison of these reports d
to DAP deviations. Other project reports may also be documented by the DAP in "T" type DIRs for comparison purposes only).
Based on the chorocteristics of the deviation in the trend, o
determine whether and, if so, where else the deviation could logically exist.
Decide what, if any, ospect of design activities should be ld o
[
examined further in looking for other deviations that could be part of the some trend. This may be a review.
within the Homogeneous Design Activity (HDA) in which -
the deviation being evoluoted was found, within a related HDA or review topFc, or within on unrelated HDA, but in which a deviation in the some trend could logically exist.
IA Cs TN-85-6262/7 Page 15 of 26 l
l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Gh Number: DAP-7
Title:
TRENDING AND GEtERIC Revision i IMPLICATIONS EVALUATIONS 4.l.6 Trend Evaluation
)
For o trend to be programmatic, multiple instances of observations or deviations should relate to a design process or design control process, or other program-matic aspect of design. This con include a process, procedure, practice, work activity, methodology, or similar programmatic aspect of design. This part of the trend evaluation will determine whether the observations or deviations that make up the trend indicate a relationship to one or more processes. Due to the nature of the information used to detect trends, it is expected that trends identified will generally be programmatic.
For o trend to be adverse, it must be likely that undetected safety-significant deficiencies exist in the area (e.g., HDA, review topic, design activity) offected by the trend.
The evaluation of a trend for adversity shall be based on engineering judgment as to whether undetected safety-significant deficiencies related to the trend are likely to exist. The details of this evaluation and the scenario or conditions that cause the trend to be considered adverse shall be documented by the reviewer on form DAP-7-1 or its attachments, or in the engineering evoluotion or IRR that documents the adverse trend.
A safety-significance evoluotion (per DAP-22) is not required, but could be done to decide whether o trend is adverse. The decision as to whether o trend is adverse shall be based on a consensus of involved reviewers and DAP monogement, up to and I
including, the Review Team Leader.
If the trend evaluation indicates that the trend is adverse, the DIR that documents the trend shall be classified as a programmatic deficiency per DAP-2.
The review scope shall be expanded, when required by DAP-3,Jf additional reviews are needed to confirm that the trend is adverse. If the trend has been determined as adverse, guidance related to IRRs should be followed in deciding l
whether more reviews are necessary if the trend is identified as part of on IRR.
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TN-85-6262/7 Page 16 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Q,a Number: DAP-7
Title:
TRENDING AND GEbERIC Revision i IMPLICATIONS EVALUATIONS If the trend is not adverse, o DIR (closed observation) shall be written per DAP-2 to describe the trend and indicate that it is nonadverse. If the trend evolvation indicates that the trend identified in Section 4.1.3 does not actually exist, this result shall be documented on form DAP-7-l.
If the odverse trend is multidisciplinary, its multidisciplinary aspects shall be subject to o multidisciplinary generic implications evoluotion. If the adverse s
trend appears limited to o single discipline, the trend shall be subject to o discipline-specific generic implications evoluotion.
4.2 Generic implications Evoluotion The purpose of a generic implications evoluotion is to evoluote the root cause or causal factors and generic implications (limiting boundaries of applicability) of nQ discrepancies that require a ' generic implications evoluotion.
A discipline-specific generic implicottons evoluotion shall be performed for design deficiencies, unclassified deviations, and programmatic deficiencies that appear to be limited to a specific discipline. if more than one discipline oppears to be offected, a multidisciplinary implications evoluotion shall be performed for multidisciplinary aspects of the issue.
Attachment C provides step-by-step instructions for performing a generic implications evoluotion and documenting it in the form of on engineering evoluotion. Departures from this guide shall be justified and documented in the evoluotion, and opproved by the discipline coordinator (signified by his approval signature on the engineering evoluotion cover sheet).
For example, if root cause or limiting boundaries of applicability are obvious, tyre is not need to formulate and test hypotheses to find those answers that are ofready known.
In design arcos such as piping / pipe supports and cable troy and conduit supports, redesign or reverification programs are being performed to provide confidence lh TN-85-6262/7 Page 17 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEbERIC Revision i IMPLICATIONS EVALUATIONS that the final design and hardware configurations will be odequate. Because of the comprehensive nature of the corrective action, the focus of generic implications evaluations in areas undergoing redesign or reverification shcIl be to ld determine whether unclassified deviations, that appear to have contributed to the overall need for hardware modifications, have generic implications outside these design areas. Accordingly, within these design areas, identification of root causes of unclassified deviations is only for the purpose of determining whether the some root causes exist outside these design areas.
4.2.1 Preparation of Engineering Evolection An engineering evoluotion of root cause and generic implications of design ld deficiencies, unclassified deviations, and programmatic deficiencies shall be prepared in occordance with Attachment C.
It sha!! include the following
(
elements or justify those elements not included:
Identification of relevant design attributes o
Method of evaluation for generic implications o
Collection of information and objective evidence o
l o
investigation of root cause Determination of the limiting boundaries of applicability.
o These elements are addressed in separate sections below.
4.2.2 Identification of Relevant Design Attributes Attributes relevant to the programmatic deficiency, unclassified dev'iotion, or design deficiency being evaluated for generic implications shall be selected. The engineering evaluation shall document the basis for selection of relevant design O
TN-85-6262/7 Page 18 of 26
COMANCE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O
Number: DAP-7
Title:
TRENDING AND GEERIC Revision i IMPLICATIONS EVALUATIONS attributes.
Attachment A lists examples of design attributes from which relevant attributes may be selected; they are based, in part, on ANSI N45.2.ll.
Other attributes not listed in Attachment A may also be used, such as HDAs and review topics listed in the DSAPs. The level of detail of selected attributes may vary, depending on the nature of the evaluation, but the level of detail shall be Q sufficient for purposes of evaluating generic implications, finding the limiting boundaries of generic implications, and investigating root cause or causal factors. Discipline-specific generic implications evaluations may select other appropriate attributes such as those contained in discipline-specific checklists.
These attributes shall be those whose evaluation would be sufficient to confirm whether or not generic implications exist and, if so, to identify their limiting boundaries and investigate their root causes or casual factors. These attributes should chorocterize to the extent reasonable the what, where, when, why, who, I
and how of the design deficiency, unclassified deviation, or programmatic deficiency being evaluated.
4.2.3 Method of Evaluation for Generic implications 1
The method of evoluotion shall include consideration of the following:
Formulation of a hypothesis of one or more generic o
implications, root causes, and limiting boundaries of op-plicability o
Determination of the type of information needed to test Q
each hypothesis (e.g., which attributes need to be evolu-oted in which design activities, and what types of errors ossociated with these attributes will prove or disprove the hypothesis)
^
Identification of techniques to be used to gather informo ;
o tion (e.g., repeat part of a discipline-specific checklist, -
interview people, review project records, analyze other DAP findings or documentation in the discipline, etc.)
TN-85-4262/7 Page 19 of 26 n-,,., --,,.,,., - -
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i
Number: DAP-7
Title:
TRENDING AND GEtERIC Revision l IMPLICATIONS EVALUATIONS I
o identification of sources of information to be reviewed to test each hypothesis (e.g., what records or system of records, what organization, group, person, HDA, or review l
topic) if odditional design work needs to be reviewed, basis for o
selection of odditional reviews that will test the hypothe-sis Development of decision criteria to be used in proving or o
disproving the hypothesis Justification that the hypothesis is odequate, and that the o
method of analysis satisfies necessary and sufficient con-ditions needed to prove or disprove the hypothesis o
Development of the type and level of detail of documen-totion needed to support conclusions (generic implication and root cause) of the evoluotion (e.g., engineering evolu-otion, discipline-specific checklist completion record, DIR generation and revision, etc.).
4.2.4 Collection of Information and Objective Evidence The content and source of information'needed to test a hypothesized generic implication, root cause, or boundary of applicobility should be identified.
Techniques for collecting this information may include checklists, interview questions, written requests, DAP or project record reviews, or other oppropriate ld methods.
To the extent reasonable, the input information for the conclusions of the evoluotion shall be objective evidence. The techniques used to' gather informo-tion should guide DAP reviewers to this objective evidence.
Therefors, information that does not constitute objective evidence shall not be.used as a sole source of information to draw conclusions os to the validity and p' roof of a hypothesis. This restriction is intended to preclude reliance on inputs of personal opinion, recollection, hearsay, or bios, os a basis for DAP conclusions.
TN-85-6262/7 Poge 20 of 26
i 1
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEtERIC Revision I IMPLICATIONS EVALUATIONS 4.2.5 investigation of Root Cause investigation of root causes or casual factors of design deficiencies, unclassified deviations, or programmatic deficiencies shall be a systematic approach that is described in the engineering evaluation. A list of potential root causes or causal factors and a checklist of questions that may be appropriate are Attachments D and E, respectively, of this procedure. If the root cause or causal factors are evident (or obvious) as a result of evaluations of programmatic deficiencies, unclassified deviations, or design deficiencies, the methods used to reach that l
conclusion shall be documented in the engineering evaluation, and no odditional investigation of root cause is needed.
The determination of root cause shall be accomplished by consensus of DAP management, including the Review Team Leader, DAP Manager, and appropriate Discipline Coordinators, discipline leaders and reviewers.
Instances may arise in which a root cause may not be identifiable or cannot be confirmed even though a set of DAP findings may exhibit similar errors. In this instance, the errors will be resolved in accordance with DSAPs and controlling DAP procedures. The investigation conducted to determine o root cause shall be documented in the engineering evaluation which shall state that a root cause d
could not be confirmed.
1 4.2.6 Determination of Limiting Boundaries of Applicability The method of determining the limiting boundaries of applicability of a generic implication shall be described in the engineering evoluotion. This determination should be based on reviews that address to a reasonable extent whether and, if so, where else in design the some design deficiency, unclassified deviation.or programmatic deficiency was likely and was found to exist.
ld TN-85-4262/7 Page 21 of 26
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
/V)
Number: DAP-7
Title:
TRENDING AND GEtERIC Revision I IMPLICATIONS EVALUATIONS Boundaries may be established using techniques based on either deductive or inductive logic, or a combination thereof. These opproaches are explained in Attachment C. The determination that limiting boundaries have been found shall be based on judgment that potentially offected areas have been investigated b
sufficiently to identify the generic implication if it exists. The bases of this determination shall be substantiated by documentation in the engineering evalua-tion.
4.2.7 Conduct or Revision of the Engineering Evoluotion The engineering evoluotion of root cause and generic implications shall be Q conducted or revised in accordance with Attachment C, or equivalent format, provided all equivalent information is included.
After completion of the p
evoluotion, revisions may become necessary; for exampie, to revise hypotheses, b
to reflect additional information or to modify evoluotion techniques.
Such changes shall be documented in a revision to the engineering evoluotion subject to the instructions of Attachment C or DAP-8, as applicable.
4.3 Approval of Trend Evoluotions and Generic Implications Evoluotions 4.3.1 Trend Evoluotion After the trend evoluotion (form DAP-7-l) has been prepared (including con-sensus decision-making as to adversity) and signed by the reviewer, the Disci-pline Coordinator and DAP Manager shall review and sign the form when they are satisfied with it. The Discipline Coordinator shall ensure that oppropriate l
DIR forms are prepared in accordance with DAP-2. Depending upon the results of the trend evoluotion, DIRs may be required to document a:
Conclusion that a trend is a programmatic deficiency; or o
O TN-85-6262/7 Page 22 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEtERIC Revision: I IMPLICATIONS EVALUATIONS Conclusion that a trend is a nonodverse observation.
o if no trend is determined to exist, no DlR is required. The Review Team Leader ld approves trend evoluotions.
After concurrence and opproval as required above, the evaluation shall be assigned a control number in accordance with Section 5.3.
4.3.2 Engineering Evaluations for Collective Trend Evaluations Upon completion of all trend evaluations within each DAP discipline, each discipline shall prepare on engineering evaluation that documents all trending done in a DAP discipline.
This evaluation shall be reviewed and signed, indicating concurrence, by the DAP Coordinator and DAP Manager.
These e
engineering evaluations shall be approved by the Review Team Leader. Engi-neering evaluations shall be assigned control numbers per DAP-8.
4.3.3 Generic implications Engineering Evoluotions These evaluations shall be reviewed, concurred in, opproved, and assigned control numbers os stated in Section 4.3.2.
ld 5.0 DOCUMENTATION 5.I Documentation of Trend Evaluations and Generic Implications Evaluations Trend evoluotions and generic implications evoluotions shall be documented in a manner that explains what was done, what the results and conclusions were, what their bases were, and who reviewed and opproved the evaluation.
4 O
TN-85-6262/7 Page 23 of 26
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE b
Number: DAP-7
Title:
TRENDING AND GEtERIC Revision i d
IMPLICATIONS EVALUATIONS Eoch trend evaluation shall be documented on a completed form DAP-7-1 and, os necessary, supporting attachments. Documentation shall include:
Form DAP-7-1 and any continuations of text from the A
o blocks of information in this form 4 L\\
o The results of sorts / searches of attributes dato that support the trend evoluotion conclusion o
DIR numbers of DIRs that are part of a trend if a trend is found IA The number of the primary DIR written if a trend is found o
o The bases of a conclusion that a trend exists and that it is nonodverse or adverse.
As on alternative to the above requirements, on IRR that contains the above information is acceptable, provided that form DAP-7-l is prepared, and only references the IRR.
Documentation of each generic implications evaluation shall include use of the forms, structure, and opplicable ports of engineering evoluotions (DAP-8) as l
described in Attachment C of this procedure. The evoluotion format may be varied as appropriate to the scope of the evaluation provided that all required information is included. Supporting documentation, that consists of information and objective evidence of whether generic implications exist, and any discipline-specific checklists used in the evoluotion, shall be incorporated in, or oppended to, the engineering evoluotion.
Documentation of all trend evaluations done collectively within each DAP discipline shall consist of one trending engineering evaluation per discipline.
This evoluotion shall explain the process used for trend evaluations, list trends found and the number of trend evaluations done, and shall be sufficient to justify 3
l
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TN-85-6262/7 Page 24 of 26 l
l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEtERIC Revision i IMPLICATIONS EVALUATIONS the conclusion with reasonable assurance that no adverse trends remain unde-tected in the scope of activities reviewed by that discipline. Each individual trend evoluotion form DAP-7-l completed by the discipline, with attachments, shall be ottoched to the trending engineering evoluotion. The requirements of DAP-8 regarding opproval, modifications and revisions, shall apply to the trending engineering evoluotions.
5.2 Documentation of Trends and Generic implications Adverse trends shall be documented as programmatic deficiencies in primary Discreponey/ Issue Resolution (DIR) reports, marked " adverse trend," trocked per DAP-2, and processed according to DAP procedures and requirements. Non-odverse trends shall be documented in primary DIR reports per DAP-2 as observations marked "nonodverse trend." No DIR is needed if a trend evoluotion results in a conclusion that no trend exists. Root causes and generic implications I
shall be documented in the oppropriate portions of Discreponey/ Issue Resolution reports per DAP-2 for the primary issues and discrepancies which require these portions to be filled in. Supporting documentation of root causes and generic implications shall be contained in engineering evoluotions per this procedure.
l 5.3 Identification After opproval has been obtained, the trend evoluotion shall be assigned a control identifiention number by the DAP Monoger or his designated represento-tive os follows:
DAP-TE-XXX-YYY 9
o Sequential Number in the Discipline,
Discipline (per Attachment C of DAP-8) l TN-85-6262/7 Page 25 of 26 4
l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-7
Title:
TRENDING AND GEtERIC Revision i IMPLICATIONS EVALUATIONS This identification number, revision number, and date shall be entered into o Trend Evoluotion Log (Attachment G - Form DAP-7-2, Rev.1) maintained by each Discipline Coordinator. Trend evoluotion forms may be revised during the DAP to reflect new information, and ultimately the final classification of all DIRs in each trend.
b Engineering evoluotions that address trends and root cause/ generic implications evoluotions shall be identified per DAP-8.
5.4 Retention A copy of each final evoluotion shall be maintained and filed by the DAP Manager or his designated representative in accordance with DAP-14.
5.5 Revisions Revisions to evoluotions may be required to modify evoluotion methods, add, clarify, correct information, or reflect final classifications of DIRs. Revisions shall be prepared, reviewed, and opproved in the some manner os the appropriate type of original evoluotion, and shall comply with the opplicable provisions of DAP-8 regarding revised, voided and superseded evoluotions.
O TN-85-6262/7 Page 26 of 26
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ATTACHMENT A l
EXPLANATORY ATTRBUTES MATRIX Q
LEVEL 1 LEVEL 11 LEVEL 111 i
1.0 Design Discipline I.I Mechonical Systems and Components Ano!yses Fluid systems Facilities Piping j
Pump and volve operability Rodiation protection 1.2 Electrical, Instrumentation and Electric power equipment Control Electric power systems Electric cabling Electric equipment layout l&C equipment I&C control systems l&C instrument systems - NSSS I&C instrument systems -BOP l&C control room layout Equipment qualification Fire protection 1.3 Piping and Pipe Supports Piping analysis Support design l
Interface control i
I.4 Civil / Structural Cable trays / supports Conduits and supports Structural steel Concrete design HVAC supports Seismic analysis Other supports Seismic Gap Structural TN-85-6262/7 A-1 f
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ATTACHMENT A (continued)
LEVELI LEVEL 11 LEVEL 111 1.0 Design Discipline I.5 Programmatic / Generic implications Multidisciplinary (continued)
Discipline-specific 1.6 Other l
1.7 All 2.0 Design Organization 2.1 TUGCO (TUSI) 2.1 S ANCO l
2.2 TUGCO Nuclear Engineering (Tit) 2.16 CYGNA i
2.3 0)PE 2.17 CCL b
2.4 Gibbs & Hill 2.I8 Sorgent & Lundy 2.S Westing' house (outside NSSS Scope of Supply) 2.19 EPM 2.6 ITT Grinnell 2.20 SSAG 2.7 IPSI 2.8 PSE 2.9 Ebosco 2.10 Stone & Webster l
2.11 Impell 2.I2 Bohnson 2.13 DeLoval 2.14 KRANCO TN-85-6262/7 A-2
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ATTACHMENT A I
(continued i
LEVELI LEVEL ll LEVEL 111 1
3.0 Design Activity 3.I Design Program Requirements Organizational structure Responsibilites of organization i
Technical information exchanges Document control Design document maintenance and retention Management review Training Design inputs l
Document preparation Quality levels, acceptance standards, records Design verification Audits Corrective action Experience reports Design changes 3.2 Design input Requirements Performance requirements (capacity,
- roting, j
system output, others)
Codes, standards, and regulatory requirements Design conditions (environmental, loadings, fluid chemistry, voltoge, others)
Interfoce requirements Material requirements (including such items os compatibility, electrical insulation properties, l
coatings, and corrosion resistance)
Mechonical requirements Structural requirements l
TN-85-6262/7 A-3
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ATTACHMENT A (continued)
LEVELI LEVEL ll LEVEL 111 4
3.0 Design Activity 3.2 Design input Requirements Hydraulic requirements (continued)
(continued)
Chemistry requirements (including provisions for sampling)
Electrical requirements Layout / Arrangement requirements Operational requirements under various plant i
conditions Instrumentation and control requirements Accessibility, in-service inspection, and adminis-trative control requirements Redondoney, diversity, and separation require-ments Failure eifeets requirements Test requirements Fire protection or resistance requirements Processes, parts, and equipment suitable for oppli-cation Safety requirements (including radiation hozords, materials, escope provisions from enclosures,
, i.
grounding of electrical systems)
Handling, storage, and shipping requirements TN-85-6262/7 A-4
i ATTACHAENT A (continued) i LEVELI LEVEL 11 LEVEL lli 3.0 Design Activity 3.3 Design Process Translation of inputs (confir6ued)
Procedures 1
Design analyses Calculations Design outputs (drawings, specifications, other)
I Analysis / calculation errors Q
i 3.4 Interface Control External (identification, responsibility, commumcation, documentation)
Internal (identification, responsibility, 3
i communication, documentation) 1 3.5 Design Verification Selection and incorporation of inputs Description and reasonableness of assumptions Specification of quality and quality assurance requirements Identification of codes, standards, and regulatory I
requirements i
Consideration of construction / operating experience l
Satisfaction of design interface requirements Design method appropriateness Reasonableness of ou;put compared to input
{
Suitability of specified parts, equipment, and l
processes Materials compatiblity to other materials, use, and design environmental conditions l
TN-85-6262/7 A-5
ATTACHAENT A (continued 1
i LEVELI LEVEL ll LEVEL 111 3.0 Design Activity 3.S Design Verification Provision for in-service inspection accesaibility (continued)
(continued)
Consideration of radiation exposure 1
Specification of testing requirements Specification of handling, storoge, cleaning, and shipping requirements i
Specification of identification and records require-j ments 3.6 Document Control Program Preparation Approval issuonce Revision FSAR occuracy 3.7 Design Change Control Test results unsatisfactory Inierference Functional requirements not met Disposition of nonconformance Requirement changes i
Operational experience Design improvements 3
i 1
TN-85-6262/7 A-6 1
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ATTACHMENT A (continued) 1 LEVELI LEVEL 11 LEVELlli 3.0 Design Activity 3.8 Corrective Action Program i
(continued) inputs Process Interface
]
Verification Document control Change control Procedures Personnel Training Monogement j
3.9 Audits Personnel j
internal External i
Control Schedule Results Follow-up 4.0 System, Structure, See DAP Tracking System Component Affected Codes i
TN-85-6262/7 A-7
i ATTACHMENT A j
(continued 1
LEVELI LEVEL 11 LEVEL lil 5.0 Characteristics 5.1 Classification Not classified of issue Unsubstantiated Discrepancy
+
Observation l
Deviation Deficiency j
Unclassified deviation Programmatic deficiency I
5.2 Status Open Closed l
5.3 Type Generic i
isolated Tyg-l Cumulative Not cumulative g
Technical Tyg-2 Programmat,ic 6.0 Potential Safety 6.1 Reported or found by DAP Reported by External Source l
Significance Found by DAP to be safety-significant Found by DAP not to be safety-significant 4
6.2 Intended Safety Function RCS pressure boundary Containment integrity i
instrumentation j
Control Mechanical /structual support 4
Emergency power Isolation boundary Accident prevention Accident mitigation TN-85-6262/7 A-8
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ATTACHMENT A i
(continued)
LEVELI LEVEL ll LEVEL lil 6.0 Potential Safety 6.3 Type of loss of capabili+y Boundary failure Significance to perform intended safety Loss of electrical power / air / hydraulics (continued) function Monitor failure Control failure Delivery of cooling medium Component support failure Personnel protection Equipment protection Structural failure Analysis indeterminate to assure capability 7.0 Root Cause 7.1 Procedures Ambiguous incorrect application incomplete 4
Missed technical requirements Misunderstood regulatory requirements / comments Missed regulatory requirements Inodequate review for requirements / commitments Out of date Nonexistent Contradictory procedures Conflicting technical requirements
$ *g i
TN-85-6262/7 A-9 l
ATTACHMENT A (continued LEVELi LEVEL ll LEVEL 111 7.0 Root Cause 7.2 Procedure implementation inconsistent (continued)
Error in judgment Knowing violation Unknown violation Inodequate review that requirements met Simple mistake Procedure requirement not understood Inodequate input information Wrong codes / standards used Disregarded procedure Failed to get inputs 7.3 Communications Foilure within group Foilure between groups i
Inodequate between componies l
7.4 Inspection / Audit inodequate checklists inodequate training / qualification l
Inodequate surveillance of inspections Inadequate analysis of findings inodequate distribution of findings Not done Excessive deferrol/ backlog i
I' i
1 l
TN-85-6262/7 A-10
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ATTACHMENT A (continued LEVELI LEVEL II LEVELlit 7.0 Root Cause 7.5 Timeliness inodequate time allowed for task (conHnd Insufficient engineerlag done i
Inadequate to check changes against requirements /
commitments i
Untimely incorporation changes in requirements /
commitments Failure to incorporate changes in requirements /
commitments Untimely audits / inspections Severe schedule pressure 7.6 Documentation Failed to demonstrate compliance inodequate access to information illegible Missing
]
Incomplete Misfiled Inoccurate 7.7 Training /Oualification Inodequate for tasks performed (designers)
Nonexistent J
Fail to retrain offer errors Inodequate qualification standards 1
7.8 Transfer of Information Correct information used improperly incorrect information transferred improper interface Nonexistent interface Information not transferred l
TN-85-6262/7 A-l 1
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. ATTACHMENT A (continued)
LEVELI LEVEL 11 LEVEL 111 7.0 Root Cause 7.9 Planned Monogement Risk 4
(continued) 7.10 Post-Inspection / Turnover Controls i
7.1l Corrective Action Fail to recognize program breakdown
~
Fail to identify root cause Fail to prevent recurrence Foil to trend Fail to recognize recurrence Inodequate to correct problem Not implemented 7.12 Monogement Attention Lock of goals / objectives Lock of interest / indifference Inodequate for trends inadequate stoffing Fail to supervise i
Inodequate analysis of findings Lock of performance / effectiveness measures Inodequate policy for performance of work Foil to implement policies Fail to assess policies No feedback on policies No action on feedback received Planned / assumed risk Oversight 7.13 Random Error (root cause indeterminate)
TN-85-6262/7 A-12
ATTACHMENT A (continued i
LEVELI LEVEL ll LEVELlli 8.0 Potential Generic 8.1 Reported or found by DAP Reported by External Source implication Found by DAP to have generic implications Found by DAP not to have generic implications 8.2 Scope Affects one discipline l
Affects multiple disciplines 8.3 Indeterminate Results Analysis Quality of design Quality of systems, structures, of components (hardware) 8.4 Impact on Design Program Inputs Process interface Verification Document control Change control Corrective action
)
Audits 9.0 Nature of the '
9.1 Personnel Error (list specific error) i 1
Problem, '-
9.2 Procedure Content Error 9.3 Procedure implementation Error l
9.4 Management Control Error TN-85-6262/7 A-13 c
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1 ATTACHMENT A (continued 4
i LEVELI LEVEL 11 LEVEL 111 1
9.0 Nature of the 9.5 OA/OC Error i
Problem (continued) 9.6 Design P ogram inadequacy l
9.7 Violation of codes, stondords, j
requirements, or commitments j
9.8 Computer Code inadequacy 9.9 Analytical Method inadequacy 9.10 Interpretation Error 9.1l Assumption Error i
j 9.12 Calculation Error 9.13 Hardware Failure l
10.0 Review Topic (List number of Review Topic)
(Group of HDAs offected) j l1.0 Affected HDA (List one or more offected HDA numbers) i l'
1 i
TN-85-6262/7 A-14
OV ATTACHMENT B TREND EVALUATION 1.
PURPOSE To investigate whether a trend exists, to determine by evaluation and consensus decision-making whether any trend found is adverse with respect to the design of CPSES, and to document the evaluation on form DAP-7-1 in accordance with this attachment.
Equivalent techniques for trend g
evaluation as part of IRRs are authorized as on alternative to this attachment, provided they address the contents of this attachment and document a logical progression of facts and judgment that supports a O
conclusion in the IRR that a trend exists and whether it is adverse.
II.
SCOPE Limited to identification and evaluation of any trend that moy exist within a set of discrepancies (identified as a result of implementing the self--
initiated parts of the DSAPs) or Externoi Source issues with attributes d
selected from one or more of the categories below:
i Design Discipline l
l Design Organization Design Activities System, Structure, or Component i
Classification, Status, and Type Potential Safety Significance Root Cause Potential Generic Implication O
TN-85-6262/7 B-1
_ _ - -,. - - - - - -3 i
O Nature of Problem Review Topic (Group of HDAs)
Homogeneous Design Activity (HDA)
Discreponey Numbers (if appropriate) ll1.
METHOD OF REVIEW l.0 Trend Identification 1.1 Select the attribute to be trended and attributes constrained in this evaluation and list them on form DAP-7-l. Any number of attributes may be constrained depending on the breadth of the search. Any combination of attributes may also be selected p
since the design activities from ANSI N.45.2.ll are considered b
not to be mutually exclusive. Attributes not constrained will cause all values (subottributes) of those attributes to be in-cluded in the resulting subset of DIRs.
1.2 Using information from DAP dato systems (e.g., DAP Trocking System, or other DAP files), perform the following steps os j
needed to determine the opplicable subset of issue records and DIRs that reflect the selected attributes.
1.3 Count the number of issue records /DIRs that are in the subset of issue records /DIRs, each of which exhibits the attributes constrained.
l.4 For the attribute to be trended (not constrained), determine the
~
distribution of issue records /DIRs within each value of this ld attribute.
O TN-85-4262/7 B-2
10 b
I.5 Count the number of DIRs in each value of the attribute (or Level 11 subattribute) within each distribution. Record these counts for each value of the unconstrained attribute, the issue records (IR)/DIR numbers in the distribution, and the con-g strained attributes that opply to each distribution. Counts of DIRs may be recorded in computerized outputs (graphic and tabular).
Note: If a programmatic problem exists, there should be several non-duplicate irs /DIRs that reveal the same ot-tributes because of the comprehensiveness of the DAP Phase 3 scope. Although no absolute number of irs /DIRs can be defined as constituting a trend, the relative distribution of subattributes among irs /DIRs should reveal that some subattributes apply to o much greater p
fraction of DIRs than other subattributes.
The higher
J count subattributes in these relative distributions indicate l
trends. Low-count subattributes in these relative distri-butions are likely to indicate on isolated error rather than a programmatic weakness; however, this assumption should be evoluoted, confirmed, and documented either on form DAP-7-1 in the trend identification section or in a d
collective trend engineering evoluotion~ done within the discipline in which these low-count subottributes are found to occur.
l.6 Review the descriptions of issue records /DIRs with the higher ld count subattributes in each distribution.
1.7 If rcot causes have been reported or identified, compare root ld causes of DIFis with the higher count subattributes.
l.8 Determine whether a logical relationship oppears_ to exist among the DIRs with the higher count subottributes in each distribution.
Try to determine whether o correlation and a causal relationship exist (i.e., discrepancies, etc., are similar TN-85-6262/7 B-3
Ob enough to have the some potential cause, attributes, or sub-attributes, that indicate the some problem).
l.9 Identify any dissimilarities among the DIRs in the subset trended that show by contradiction that the discrepancies are not related, or that a trend does not exist.
l.10 Decide whether there are commonolities that indicate o trend.
1.1 l Describe any trend found in a new primary DIR (to be com-pleted offer trend evoluotion) per DAP-2. On form DAP-7-1, justify this determination, including the logical basis for the relationships among the discrepancies that make up the trend.
Alternatively, supporting documentation, that is equivalent to b
the above requirements, may be included in on IRR instead of on form 7-1 although form 7-1 is still required, but only with references to the IRR. This description, in conjunction with the attributes listed on form DAP-7-1, shall chorocterize and justify the trend. The relationship between discrepancies could involve links such as a n, eriod during which the errors occurred, procedure, person performing the work, creo of the plant, system involved, or type of component or commodity involved. Items such as these should be considered in identify-l ing common attributes that link discrepancies, and identifying
- trends, l
1.12 If a trend is found, evoluote the trend per Steps 2 (if the trend includes deviations), 3, and 4 below, if no trend is found, close the trend evoluotion per Section 6.
l
(
TN-85-6262/7 B-4 l
!l
O 2.0 identified Trends Containing Deviations if trends identified contain one or more deviations, investigate whether similar deviations are likely to exist but have not yet been found.
2.1 Decide how to determine whether the deviation is likely to exist ld elsewhere. The method to make this determination may be to reuse on existing checklist or part of a checklist that is sufficient to detect the deviation if it were to exist in the oreo being reviewed.
Q Alternatively, the review may conslut of checking completed DAP checklists or engineering evoluotions that would have detected the deviation elsewhere were it io exist. If a trend is found to exist based on ovalloble DAP documentation, there is no need to expand a review that would serve only as unnecessary confirmation of the Od trend that is already known.
2.2 Determine from project records (or "T" type DIRs that document project records) whether similar deviations have been identified in the post.
2.3 Based on the chorocteristics of the deviation being evaluated, deter-mine whether, and if so, where else, the deviation was logicolly likely to have occurred. Alternatively, use o process of elimination to d
exclude areas in which the deviation would not have been likely to exist or be safety-significant.
Record this determination and a statement of its basis.
2.4 Decide what aspect of design activities should be examined i'n looking for other instances of the deviation if odditional information is needed to determine that a trend exists. This may be a review within TN-85-6262/7 B-5
O the HDA, within a related HDA, or review topic in the discipline in which the deviation being evoluoted was found, or in other disciplines in which the deviation (due to its nature) could likely have existed as a safety-significant aeficiency.
2.S If Steps 2.1-2.4 above indicate that the deviation is likely to have existed elsewhere and additional reviews are necessary to confirm g
the trend, perform additional reviews of design activities or DAP records, and document the results. If other discrepancies are found, write DIRs per DAP-2, and determine whether these new discrepon-cies are port of the trend.
3.0 Trend Evaluation 3.1 Identify the programs, processes, procedures, work cetivities, methodologies, or other programmatic aspects that are potentially associated with the trend.
3.2 Evaluate these programmatic aspects to determine which ones are chorecteristic of the trend.
3.3 Review available results of DAP safety-significance evaluations or project evaluations that have been performed for any deviations
[
included in the trend.
3.4 Develop information on whether the trend under evaluation would have been likely to have resulted in a safety-signficant deficiency. If so, describe the basis why any undetected deficiencies are likely to b
exist or are likely to be caused in the future. Since this determina-tion relates to whether it appears that DAP deficiencies are likely to O
TN-85-6262/7 B-6
Ov exist, not confirmation that they do exist, o DAP-22 safety-signifi-conce evoluotion is not required, but may be performed on DIRs prior d
to o conclusion that a frend is adverse.
3.5 If one or more safety-significant deficiencies are believed to be likely to exist or be caused in future design work, then the trend should be proposed as adverse, and subject to a consen:vs decision as to its adversity by involved reviewers and DAP management.
3.6 Document determinations made in this part of the evaluation on form DAP-7-l, including review and approval signatures, if this determi-nation is made as part of on IRR, form DAP-7-1 shall be completed, d
but may only reference on IRR that contains this information.
4.0 Conclusions of the Trend Evoluotion l
4.1 If the trend is determined by DAP consensus to be adverse (and Q
thereby programmatic) write a primary DIR programmatic deficiency per DAP-2, and mark " Adverse Trend" on DAP-7-l.
l l
4.2 If the trend is determined by DAP consensus to be programmatic but d
l not adverse, write o primary DIR ob;ervation marked "Nonadverse Trend" per DAP-2, and mark "Non-adverse Trend" on DAP-7-l.
i 4.3 If the trend evaluation indicates that a trend does not exist, mark the "No Trend" box on form DAP-7-l, and do not write o primary DIR.
5.0 Review, Approval, and Documentation Sections 4.3 and 5.0 of the procedure part of DAP-7 apply.
l[
O TN-85-6262/7 B-7
O ATTACHMENT C GEERIC IWLICATIONS EVALUATION ENGlEERING EVALUATION 1.
PURPOSE To evoluote root cause or causal factors and generic implications (limiting boundaries of applicability) of programmatic deficiencies, unclassified devio-tions, and design deficiencies that appear to be discipline-specific or multi-disciplinary; and to document DAP octivities and these conclusions.
ld 11.
SCOPE Limited to identification and evoluotion of any root cause or causal factors and generic implications of one or more programmatic deficiencies, design deficien-cies, or unclassified deviations (hereafter referred to collectively as deficien-cles) that appear to be discipline-specific (or multidisciplinary), and whose DAP Trocking System (DAPTS) numbers and issue / Discrepancy titles shall be listed in the scope section of the evo!uotion.
Ill.
OVERVIEW: METHOD AND EXTENT OF REVIEW l.0 Describe the reason for conducting this engineering evoluotion (e.g.,
identification or receipt of DIRs listed in the scope section that appear to offect only this discipline (or are multidisciplinary), direc-tion from the DAP Manager to conduct on evoluotion that supports a multidisciplinary generic implications evoluotion, or other reason for initiotl<v).
TN-85 4262/7 C-l
2.0 ldentify the design attributes that are relevant to this evoluotion (O
using the following steps:
j 2.1 List the attributes of the DIRs (primary issues and supporting DIRs contained in the primary issue) in scope in the following d
categories as appropriate (more than one attribute may apply to each category; if so, list multiple attributes in each category):
l
)
Design Discipline Design Organization Design Activities A
System, Structure, or Component E Ol Classification, Status, and Type Potential Safety Significance Root Cause (if identified)
Potential Generic implication (if identified)
)
Nature of Problem (e.g., technical issue from an IRR) d 1
Review Topic (Group of HDAs)
Homogeneous Design Activity HDA)
/
2.2 Review Attachment A, Explanatory Attributes Matrix, to de-termine whether additional Level 11 design attributes should be included and that the design attributes in the DIRs are accu-g rate. If necessary, revise the listing in Subsection 2.1 above, including any revisions of the DIRs to reflect corrected inter-pretations of design activities.
2.3 Of the attributes listed in Subsection 2.1, select those that appear to be relevant to evaluating generic implications; that ld is, determining root cause or causal fcefors, limiting boundaries of applicobility (other HDAs, review topics, design activities, creas or items that are susceptible to the some condition).
Some of these attributes may be contained in discipline-specific checklists. Upon completion of this evaluation, the attributes TN-85-6262/7 C-2
~ ~ ~
~ - ~ ' ^ ~ ~
~
selected for the evoluotion should chorocterize to the extent reasonable the what, where, when, why, who, and how of the DIR(s) listed in scope. During the evoluotion, attributes listed in scope may be revised, odded or deleted.
3.0 Plan and document the method of evaluating the root cause and Q generic implications. Include the following steps as written, or modify, revise, or delete any of them, or odd other items and
)
justify the changes.
3.1 Review other information available that is relevant to the DIR(s) in scope that was not reviewed in Subsection 2 above, such as other DAP documentation. Docament the extent and scope of these reviews.
3.2 Based on knowledge of the DIR(s) in scope gained by the above reviews, form o hypothesis of one or more root causes and limiting boundorles of applicability.
3.3 Determine what information or type of information is needed to test the hypothesis (e.g., which attributes need to be evaluated within design octivities, and what 1 pes of
/
errors associated with these attributes will prove or disprove the hypotheses).
3.t; identify the techniques to be used to gather this informo-tion (e.g., reuse of port of a discipline-specific checklist, interview, analysis of other DAP findings or documenta-tion in the discipline (or multiple disciplines) including any applicable IRRs, review of project records, etc.)
l 3.5 Identify the sources of information to be reviewed to test i
the hypothesis (e.g., what recc:ds or system of records, what organization, group, person, review topic, IRR or h l
TN-85-4262/7 C-3
3.6 If additional reviews of design work are needed, select odditional reviews that will test the hypothesis.
3.7 Describe the planned approach to be used to investigate and test the postulated root cause. Refer to Attochments D and E for more information that may be helpful in evaluating potential root causes or causal factors. Use of these ottochments is not mandatory - they are provided as b
potentially useful guides.
3.8 Describe the planned approach to be used to investigate and determine the postulated limiting boundaries of op-4 plicability.
Include criteria for occepting these boundaries (e.g., other areas likely to contain the unclas-sified deviation, programmatic deficiency or design de-d ficiency under evoluotion were checked and the de-ficiency was not found, other likely areas that had been i
previously evaluated in the DAP were reviewed and conditions of the deficiency were not found, or due to the nature of the deficiency, it could not or is highly unlikely to exist outside the postulated boundaries).
i 4.0 Collect objective evidence and gather information according to the plan in Subsection 3 above. This may include one or o combination of the following steps or other techniques
,1 described in the plan, or it may be unnecessary if root cause and generic implications are already evident.
4.1 Review the DAP tracking system, Issues Records /DIR Reports, or other DAP documentation to determine which Q records are opplicable within the scope of this evoluotion.
l O
TN-85-6262/7 C-4
l Note:
This generic implications evoluotion may O
begin with only one deficiency, but it is possible that other records in the data will have attributes related to those of the deficiency.
4.2 Complete all or o portion of a DSAP checklist if the Q results of which will demonstrate whether the hypothe-sized generic implication extends to activities reviewed using the checklist. Document the acceptance criteria for any checklist used.
4.3 Develop information to be gathered by interviews or written responses, and conduct interviews or request written information.
The purpose of interviews is to identify sources and types of information that are objec-Q tive evidence on which the conclusions of this evoluotion will be based. Written responses may contain objective evidence or only information on where to find objective evidence.
4.4 Review appropriate project records or documentation (possibly only "T" type DIRs) to determine whether the deficiency had been detected, evoluoted, resolved or d
corrected in the post.
(
4.5 If a discipline-specific action plan does not encompass the activities needed to review generic implications of this deficiency, revise the DSAP, expand the scope of review, or justify that expanded scope is not required in on area of design that is undergoing reverificotton or redesign d
because the results of this design activity will accom-modate this review.
4.6 Document the information and objective evidence that was gathered or reviewed as part of this evoluotion.
TN-85-6262/7 C-5
O 5.0 investigate the hypothesized root cause or causal factors of the deficiency.
5.1 The investigation method used will be a systematic op-prooch that includes a logical flow of facts and relation-ships of conditions and events, develops and evaluates probable causes, and results in a conclusion of root causes or causal factors that is supported and justified. Attach-ments D and E contain examples of potential root causes or causal factors that may be appropriate, although use of Attachments D or E is not mandatory.
1 5.2 Based on the investigation in Subsection 5.1 above, deter-mine the root cause or causal factors, which shall be l
based on a consensus of DAP technical personnel and b
monogement, including the Review Team Leader, DAP Monoger, and appropriate discipline coordinators, disci-pline leaders, and reviewers.
5.3 If no root cause (or common cause, in the cose of several individual issues that oppear to be on adverse trend) can 1
be identified, document the investigation of root cause, and the result that a root cause could not be found, and therefore that the trend is not adverse.
g 6.0 Evaluate the postulated limiting boundaries of applicability of I
the deficiency. Based on the specific nature of the deficiency, use either deductive or inductive logic described below or o combination, as oppropriate, to confirm limiting boundaries.
I 6.1 Using deductive logic, starting with a general hypothesis of limiting boundaries of the deficiency, revie$ previous DAP reviews of design work outside the area in which the 4
deficiency was identified, but where it would have been Q TN-854262/7 C4 4
likely to exist as a safety-siginificant deficiency. Ifthis
(/
method is used, a conclusion that the deficiency does not exist elsewhere shall be based on the obsence of finding safety-significant deficiencies in other potentially of-fected areas, or on revising the hypothesis and expanding the review to potentially offected areas until the deficiency which probably would have existed is no longer d
found.
6.2 Using inductive logic, and starting with the specific Q
instances in which the deficiency was found as the hypo-thesized limiting boundaries, based on engineering judge-ment that shall be documented, discord several or all l
other design activities or areas as potential locations of a safety-significant deficiency. The basis for o conclusion using this opproach is that the activities or oreas dis-corded are unrelated to the nature of the deficiency being p
evoluoted. The governing criterion for decidhg that a V
deficiency is self-limiting to a given area is that it is unlikely that the same error could have resulted in a safety-significant deficiency outside of the identified area.
IV.
BASES FOR DOCUMENTATION SELECTION DAP-8, Section 4.1.3 opplies.
This information is described in the oppropriate ports of the generic implications evoluotion sections above.
V.-
SOURCE AND REFERENCE DOCUMENTATION DAP-8, Section 4.1.4 opplies. This information, os described previously in the oppropriate, arts of the generic implications evaluation sections, will be documented in the steps in which it is tsed.
O TN-8S-6262/7 C-7
VI.
ACCEPTANCE CRITERIA DAP-8, Section 4.1.5 applies. The criteria for accepting this engineering evaluation cre as follows:
The generic implications of the deficiency in the scope of o
this evaluation were evaluated sufficiently to form a documented basis for acceptance or rejection of the i
hypothesized root cause.
The generic implications of the deficiency were evaluated o
]
sufficiently to form a documented basis for acceptance or rejection of the hypothesized limiting boundaries of op-plicability.
Vll. EVALUATION f
Conduct and document the evaluation in accordance with the Overview:
Method and Extent of Review described in Section 111 of the engineering evaluation. If revisions of this section are found to be necessary during the 3
evaluation, DAP-8, Section 5.0 applies.
Vll. RESULTS AND CONCLUSIONS Document the results, conclusions, and bases for conclusions of this generic implications evaluation. Review DAP-8, Section 4.l.7, and incorporate the j
stems listed that are oppropriate.
In general, these should include the following:
Any additional discrepancies identified during this evalua-i o
tion and that they are properly classified per DAP-?. os "D" type or "C" type DIRs; i
l o
Confirmed root cause or causal factors of the DIR(s) that were evaluated; i
Confirmed limiting boundaries of applicability of the. ~
o deficiency that were evaluated; o
Any other open items; o
identification of issues that have been resolved.
I TN-85-6262/7 C-8 4
t
IX.
FORMAT l.
Organize this evaluation in the format specified in DAP-8, Section 4.3, except that the main text of the evaluation is specified as indicated below.
2.
Engineering Evaluation Cover Sheet.
3.
Abstract.
b 4.
Main text of the evaluation as follows:
Reason for the evaluation (Section 111.1);
o o
Design attributes relevant to this evaluation (Section Ill.2);
1 Method of analysis (Section Ill.3);
o Collection of information (Section 111.4);
o Root-cause investigation (Section 111.5);
o Limiting boundaries of applicability (Section 111.6);
o o
Results and conclusions (Section Vill).
X.
REVIEW, APPROVAL, AND DOCUMENTATION l
l DAP-8, Sections 4.2 and 5.0 apply.
la O
C-9
--,n-
ATTACHMENT D OV EXAWLE LIST OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS This appendix is provided as nonmondatory guidance for investigations of root causes of programmatic deficiencies, design deficiencies, and unclassified devia-tions.
l.
Procedures not odequately specific to control situations actually encoun-tered in pedorming tasks.
2.
Personnel not odequately trained in the opplicability of procedures avail-oble for the task.
3.
Personnel did not adequately research requirements and commitments prior to developing procedures or performing work.
4.
Inodequate understanding of regulatory requirements or commitments.
5.
Inodequate understanding of the required documentation to demonstrate compliance with regulatory requirements or commitments.
O 6.
Lock of okquote system or odministrative controls to ensure that licensing / regulatory commitments were reflected in procedures or pro-cesses.
I l
7.
Inodequate communications within a functional group (i.e., some people did I
work correctly while others did not).
8.
Inodequate communications between functional groups (e.g., correct infor-motion was passed between groups but was used incorrectly, incorrect information passed between groups).
9.
The deficiency resulted from a planned management-assumed risk.
10.
Procedures used were incorrect for the opplication.
I 1.
Procedures were incomplete or failed to incorporate all technical require-ments.
12.
Lock of odequate inspection checklists.
13.
Lock of odequate inspector qualification / training.
i 14.
Engineering not sufficiently complete when activity was performed.
15.
Inodequate time allowed to perform task properly.
TN-85-6262/7 D-l
ATTACHMENT D O
(continued) 16.
Error in judgement by qualified person.
- 17. Personnel performed task knowingly in violations of procedures.
18.
Lock of odequate administrative controls to ensure that procedural re-quirements were met.
19.
Failed to identify root causes of previous deficiencies.
20.
Failed to take appropriate action to prevent recurrence of deficiencies.
21.
Inodequate monogement attention to + rends in deficiencies or failure to trend deficiencies.
22.
Inodequate survelliance of inspection activities.
23.
Lock of odequate accessibility to documentation (design, construction, testing, or QA) 24.
Inscrutobility of documentation.
25.
Lock of odequate system or administrative controls to ensure that changes n design, construction, testing, or QA octivities were evoluoted (timely) ld against licensing / regulatory commitments.
26.
Lack of timeliness in identifying, submitting, or receiving opproval for changes to licensing / regulatory commitments.
27.
Lock of adequate post-inspection / turnover controls over hardware.
28.
Connot determine a root cause (isolated error).
e O
TN-85-6262/7 D-2 4
ATTACHMENT E EXAWLE QUESTIONS FOR EVALUATION OF POTENTIAL ROOT CAUSES OR CAUSAL FACTORS This appendix is provided as nonmondatory guidance for root cause investigation checklists used for programmatic deficiencies, design deficiencies, and unclassi-fled deviations.
YES NO l o.
Was the deficiency a direct violation of Appendix B or other regulatory requirements?
Ib.
Was the deficiency a direct noncompliance with licensing / regulatory commitments?
Q I c.
Was the deficiency a direct violation of project proc-edures?
2.
Did a deficiency similar to that identified occur previously?
3.
Did the NRCTRT or CPRT find multiple incidents of Q
l essentially the some deficiency?
4a.
If the deficiency was identified previously, was action identified to prevent recurrence?
Ab.
Was the corrective action odequate?
5.
Was the identified corrective action octually imple-mented?
6.
Was there odequate technical input to the activity?
7.
Did the activity make correct use of industry codes and stondords?
8.
Was the work conducted in accordance with procedures 9.
Did people involved (e.g., craf t, inspectors, etc.) know how to obtain technical input?
10.
Was there odequate internal communication (i.e.,
within the group responsible for the activity)?
O TN-85-6262/7 E-l
s ATTACHMENT E O
(continued)
YES NO I 1.
Was there odequate external communication (e.g.,
between TUCCO and Gibbs and Hill and between TUGCO and NRC)?
ld 12.
Was information regarding previous occurrences avail-able to personnel?
13.
Were previous identical or similar occurrences trended?
14.
Were people trained in the activities they performed?
15.
Were changes to requirements identified on a timely basis?
16.
Was information required to perform the task avall-able to personnel?
17.
Was required information kept up to dote?
18.
Did a planned activity result in a degradation of the Q
process in which the deficiency occurred?
19.
Was the division of responsibility among participants clear?
20.
Were audits or inspections conducted on a timely basis?
21.
Were there conflicting procedural requirements?
i 22.
Were there conflicting technical requirements?
i 23.
Were schedule pressures held to an acceptabe level?
24.
Were there adequate, up-to-date management policies to address the situations encountered in performance of the work?
i l
25.
Were thes policies adequately implemented?
i O
l TN-85 4262/7 E-2
ATTACHMENT E (continued)
YES NO 26.
Was eere o feedback loop to allow information flow back to policymakers regarding problems with poli-cies?
27.
Did upper level monogement individuals demonstrate on interest in lower level activities through personal involvement?
28.
Were goals and objectives odequately defined?
29.
Were personnel performing tasks, that proved to be defective, odequately qualified for the work they were asked to perform?
O i
TN-85-6262/7 E-3
ATTACHMENT F Evaluation Number: DAP-TE-COMANCHE PEAK ADEQUACY PROGRAM Rev.:
TREND EVALUATION Number of Sheets:
A DAP Discipline:
l_2 TREND EVALUATION - LEVEL II Attribute or Technical Issue Trended:
Date:
Other Attributes Selected (constrained).
List as appropriate:
Discipline Classification Generte tapitcation Design organization status Probles Design Activity Type Review Topic Activity Attribute safety significance HDA systesi/ structure / Comp.
Root Cause DIR Nos.
Number of DIRs in Thie Subset:
Name of Each Subattr
.te in Trended Attribute /No. of DIRs/DIR Nos.
TREND DESCRIPTION Date:
O Yes No Trend Identified Deviation included Additional Reviews Required Additional Reviews Completed (Describe in Attachment)
Discioline specific Multidisciplinary TREND EVALUATION Programs Affected:
Date:
Potential for Safety-Significant Deficiency:
Description and Bases of Evaluation:
==
Conclusion:==
O Adverse Trend O Nonadverse Trend O No Trend (Prepare DIR for Programatic Deficiency)
(Prepare DIR for observation)
Prepared by/Date
/
DAP Manager /Date
/
Discip1tne Coordinator /Date
/
Approved by RTL/Date
/
Dap Form 7-1
AT1 ACh..eNT G Discipline:
COMANCIE PEAK DESIGN ADEQUACY PROGRAM TREND EVALUATION LOG A
REVISION DATE CONTROL l.D. NO.
St.PERSEDED TRENDED ATTRIBUTE OR BY TECHNICAL ISSUE O
I 2
3 4
5 6
_9 I
e l
FORM DAP-7 2 REV.l
ATTACHMENT H O
lb
SUMMARY
OF DAP-7 TREPOING Ato GEFERIC IWLICATIONS EVALUATIONS This summary is on overview of the DAP procedure on Trending and Generic implicottons Evoluotions, DAP-7, and the interrelationships among various evolu-otions that are conducted on Discreponey/lssue Resolution reports (DIRs) depending on their classification. This summary is intended to familiarize those DAP personnel not directly involved in trending and generic implications evoluotions with these activities. Understanding the content of this summary should give those DAP personnel not directly involved with trend and generic implications evoluotions sufficient knowledge of these activities, so that they do not need to read the other parts of DAP-7. Those DAP personnel who will be g
doing trending and generic implications evolutions within a specific discipline or across disciplines should read and understand DAP-7 and its c her attachments before conducting these types of evoluotions.
Interrelationships Figure I of DAP-7 (also included in this attachment) depicts the relationships among:
DIR identification, evoluotion, and classificotton o
o Safety significance evoluotion o
Trend identification and evoluotion Root cause and generic implications evoluotion o
Corrective action evoluotion, and o
o Closure The DAP procedures that opply to these activities are included in Figure 1.
All DIRs are eventually classified according to the DAP definitions, and'all DIRs other than those found to be unsubstantiated or duplicate issues will be included ld in trend evoluotions.
O TN-85-6262 H-1
7 2
Safety significance evaluations are conducted on deviations, except for those deviations that are being oddressed by proceeding directly to corrective action.
These exceptions, called unclassified deviations, are cssociated with designs undergoing redesign or reverification, such as piping and pipe supports, cable lh trays and supports, and conduit supports.
If the deviation is found to be safety-significant, it is classified as a deficiency and subject to evaluations of root cause, generic implications, and corrective action. Even though the safety significance of unclassified deviations is not evaluated, DIRs with this classification also undergo evoluotions of root cause, generic implications, and corrective action. In addition, if adverse trends are found (classified as programmatic deficiencies), they too undergo root cause, generic implications, and corrective action evaluations.
Trend Evaluations Trends may be initially identified based on information coded on the DIR form and entered in a data system for searches, sorts, and displays. This information is colled Level 11. The Level 11 information is explained in more detail (Level 111),
which is used to ensure proper selection of Level ll DIR attributes.
If the g
distribution of DIRs in Level 11 attributes shows a concentration, the DIRs in that concentration are reviewed for occuracy and to identify whether their charac-l teristics indicate a trend.
Judgement on the part of personnel within DAP disciplines is also used to identify the existence of a trend.
Trends are evaluated to determine whether it is likely that existence of the trend could have resulted in the occurrence of undetected (safety significant) deficiencies in the offected area of design. If it appears likely (based on a DAP-22 safety-significance evaluation or engineering Judgement regarding final g
classification of DIRs within the discipline), then a trend is termed adverse, and a programmatic deficiency is created as a primary DIR. Trends determined not to be adverse are termed nonadverse, o DIR is written as on observation marked nonadverse, and no further evaluation of the trend is done in the DAP. All of the O
D TN-85-6262 H-2
a l
DIRs generated are transmitted (at on oppropriate stoge in the process) to the i
Comanche Peak Project organization.
If a trend contains any DIRs classified as deviations, then the DAP will consider I
additional reviews of design or completed DAP work to determine whether Q
similar deviations exist in areas of design that could be affected, if a trend contains only DIRs classified as observations, then no additional reviews are called for.
Individual trend evaluations are documented on a Trend Evaluation form and any attachments, such as continuations of various blocks on the form or computer-generated printouts of charts and tables, in each DAP discipline, one engineer-ing evaluation will be written to summarize all trend evaluations in that discipline. The engineering evoluotion will also establish a basis for concluding Q
that a sufficient level of trending was completed in that discipline.
As trends may be specific +o one discipline or multidisciplinary in nature, trend evaluations will be done both within specific DAP disciplines and across DAP disciplines. Trend evaluations may be started on DIRs prior to their receiving final DAP classifications..Upon changes or final classifications, these trend I
j evaluations will be updated and revised as necessary. Trend evaluations are i
approved by the DAP Review Team Leader.
i l
Generic Implications Evaluations Generic implications evaluations are used to investigate root causes or casual factors and to determine limiting boundaries of applicability of certain classifi-cations of DIRs. This evaluation applies to design deficiencies, programmatic deficiencies, and unclcssified deviations.
l The intent of this evaluation is to determine the attributes (or charact, eristics) of Q
the design process or design control process that are associated with the deficiency, etc., under evaluation. Some of these attributes may have been identified in trend evaluations. Based on this knowledge, hypotheses are then O
TN-85-4262 H-3 i
o formed as to potential root causes (or contributing causal factors) and potential boundaries of applicability of the deficiency.
The method of testing these hypotheses is then developed and implemented. Additional information, includ-ing objective evidence, is gathered as needed from DAP or CPSES project sources.
The root cause or causal factors are determined based on consensus of DAP management and involved reviewers. Limiting boundaries of applicability are then determined, also based on consensus of DAP management and involved reviewers. During these determinations, it may become necessary to revise the g
hypotheses and conduct other reviews to test them. If this occurs, iteration will continue, leading to the final consensus as to root causes and limiting boundaries of applicability. The DAP Review Team Leader approves generic implications evaluations.
i Generic implications evaluations are documented in the format of engineering evaluations.
The results of these evaluations are also documented in the O
appropriate blocks of the DIRs to which they apply. Similar to trend evaluations, generic implications evaluations may be done within or across DAP disciplines, depending on whether root cause and limiting boundaries are limited by disci-pline.
I I
i O
tO TN-85-6262 H-4 r_,.
,w-
T=
T-e EXTERNAL DIR IR/DIR DtR SOUR S UES I
IDENTIFED C
yh I
y D*.2 O
I DLPLICATE IR/DIRs TRANSFERRED TO De-2 EVALUATION:
ATTRIBUTES PROJECT.lDENTIFED IDENTIFIED ISSLES De 2/ ACTION PLAP6 4
1i UN5ta$TANTIATED TREND IDE CA IN CLAS IFIED
(
D&-2 DM.7 LNCLA$5 FED
""*I'0" C
ISSUE RESOLUTION SIC CANCE REPORT EVALUATION DW-22 D&J
- "~
""'~
' O EVALUATION De.)
1 P
I ROOT CAUSE/CEFERIC ADVERSE
-l IWLICATIONS
-"END EVALUATIONS m
D9.1
(
LIMITINGBOUNDARE$ I I
APC ROOT CAU5E g
%g MEND CORRECTIVE ACTION EVALUATION l
De 2o CLOSURE
^
t FIGURE I INTERRELATIONSHIPS OF DAP ACTIVITIES AND PROCEDURES DISCREPANCY CLASSIFICATION, SAFETY SIGNIFICANCE EVALUATION TRENDING, GErfRIC IMPLICATIONS, CORRECTIVE ACTION, AND CLOSURE I
H-5 REV.I TN-85-4262/7 l
. -..