ML20215J965

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Rev 1 to Design Adequacy Procedure DAP-22, Preparation of Safety Significance Evaluations
ML20215J965
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 09/18/1986
From:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20215J430 List: ... further results
References
DAP-22, NUDOCS 8610270277
Download: ML20215J965 (12)


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TITLE PREPARATION OF SAFETY SIGNIFICANCE EVALUATIONS -

NUMBER DAP-22 Revision Prepared Date Reviewed Date Approved Date 0 Y23 Yu ,g

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PDR O TN-85-6262/22 i "

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l TABLE OF CONTENTS .

Section Page Cov e r S h e e t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i Tab le o f Con t e n t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii I.0 P URP O S E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 2.0 SCOPE..................................................... I 3.0 DEFINITIONS AND RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . . . I 4.0 I NS T R U CT I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 5.0 DO CU ME NT ATI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Q

ATTACHMENTS A COMANCHE PEAK ADEQUACY PROGRAM SAFETY SIGNIFICANCE EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1 B COMANCHE PEAK DESIGN ADEOUACY PROGRAM SAFETY SIGNIFICANCE EVALUATION LOG ................... B-1 1

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l TN-85-6262/22

COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-22

Title:

PREP ARATION OF SAFETY Revision: I O- SIGNIFICANCE EVALUATIONS l.0 PURPOSE This procedure defines the scope and methodology applicable to the preparation and opproval of safety significance evoluotions required by DAP procedures or the CPRT Program Plan (including Appendix A).

2.0 SCOPE This procedure opplies to evoluotions performed to determine whether o devio-4 tion (as defined in DAP-2) is safety significont. It may also be opplied in any other circumstance when the DAP is required to determine whether on item is safety significant.

3.0 DEFINITIONS AND RESPONSIBILITIES O 3.1 Definitions 3.1.1 Sofety Significance Evoluotion lb A Safety Significance Evoluotion is a specialized type of engineering evoluotion that is a principal means of documenting the conclusion of whether a deviation (as defined in DAP-2) is safety significont and should be classified as a deficiency.

3.I.2 Safety Significant "Sofety-significont," for the purposes of the CPRT Program, is defined to mean that, the identified discreponey, if uncorrected, would result in the loss of capability of the offected system, structure or component to perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redondoney of the component, system, train or structure level.

O TN-85-6262/22 Page I of 8

> COMANCHE PEAK RESPONSE TEAM DESIGN ADEQUACY PROCEDU5tE Number: DAP-22

Title:

PREP ARATION OF SAFETY Revision: I SIGNIFICANCE EVALUATIONS This definition, which is employed in the CPRT Program for purposes of sompte expansion, is more restrictive than that usually applied to the term " safety-significant" for regulatory purposes or in common parlance, in that it ignores redundancies that do exist in real life. (Compare 10CFR50, Appendix A (introduction, " Single Failure"); 10CFR50.55(e)(1).) Identification of the devio-tion as " safety-significant" for purposes of the CPRT Program, therefore, is not necessarily equivalent to the statement that, in fact, the deficiency, if uncor-rected, would have resulted in unsafe operation.

l 3.2 Responsibilities 3.2.1 Reviewers Third party design odequocy personnel shall prepare nd check the safety significance evoluotions. Preparation and checking shall be performed by dif ferent individuals.

3.2.2 Discipline Coordinators Discipline Coordinators shall have the following responsibilities:

o Prepare or cause to be prepared DIR forms when required by results of safety significance evoluotion o Establish the scope of safety significance evoluotions to be performed within their respective disciplines o Ensure that qualified reviewers are assigned to prepare and check each safety significance evoluotion l o Review safety significance evoluotions prepared within

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their discipline (Note: discioline coordinator may oct as both checker and reviewer) o Sign oppropriate DIR forms per DAP-2 TN-85-6262/22 Page 2 of 8

COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-22

Title:

PREPARATION OF SAFETY Revision: I O' SIGNIFICANCE EVALUATIONS o Expand the review scope to the extent necessary to ochieve reasonable assurance that deficiencies have been I identified, in accordance with DAP 3.

3.2.3 Design Adequacy Program Manager The DAP Manager shall have the following responsibilities:

o Concur in the results of safety significance evoluotions o Assign control identification numbers to each completed ..

safety significance. evoluotion using the safety signif-icance evoluotion log o Sign DIR forms in accordance with DAP-2.

3.2.4 Review Team Leader The Review Team Leader shall have the following responsibilities:

o Approve safety significance evoluotions that conclude on item is safety significant o Sign oppropriate DlR forms in occordance with DAP-2 offer completion of safety significance evoluotions.

4.0 INSTRUCTION 4.1 Scope of Safety Sionificance Evoluotion l

Discipline Coordinators shall determine the need for and scope of scfety significance evoluotions. As a minimum, safety significance evoluotions are l required to disposition all DIRs classified as deviations; however, no safety significance evoluotion is required for " unclassified deviations" (as defined in Appendix E of the CPRT Program Plon).

O TN-85-6262/22 Page 3 of 8

A COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-22

Title:

PREPARATION OF SAFETY Revision: I SIGNIFICANCE EVALUATIONS 4.2 Format of Sofety Significance Evoluotions All safety significance evoluotions shall use as their first sheet a DAP safety significance evaluation form (Attachment A) containing the following information:

o The title of the DIR being evoluoted and its DIR number (if applicable, the DIR number should be that of the oppropriate primary DIR) lg g

o The DAP discipline for which the evaluation opplies o The DAP Action Plan Number to which the evoluotion opplies o The method of evaluation o A revision control block indicating originator, checker and opproval signatures and dotes o The criteria (other than the general criterio contained in this procedure) that were used to determine safety signif-icance (i.e., acceptance criteria) ld o A list of oppropriate references o The main text of the evaluation shall include documenta-tion of the activities described in this procedure 4.3 Reference Documents i

in order to perform o safety significance evaluation, the use of reference documents, other than those upon which the deviation being evoluoted was based, is likely to be necessary. Because of the DAP commitment to evaluate the plant as of April I,1985, reviewers shall consider the revision status of reference documents when performing their reviews. In general, safety significance evoluotions shall be performed using documentation in effect on April I,1985.

Exceptions to the general rule may result from factors such as the DIR being based on documents dated offer March 31,1985; informn' ion needed to evaluate the safety significance of the deviation being ovalloble only in documents dated TN-85-6262/22 Page 4 of 8

l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Revision: I O Number: DAP-22

Title:

PREP ARATION OF SAFETY SIGNIFICANCE EVALUATIONS offer March 31,1985; or other reasons. Such exceptions shall be identified and discussed within the text of the safety significance evaluation. A special case I exists where the DIR is related to a condition as described in project documentation dated prior to April I,1985; however some or oil of that documentation has been revised. In this event, the safety significance evaluation g

shall consider both the documentation prior to April I,1985, and the subsequent documentation. The safety significance evoluotion shall discuss any differences in conclusions due to differences in such documentation.

4.4 Preparation of Safety Significance Evoluotions ld The reviewer assigned responsibility for o safety significance evoluotion shall assure himself (or herself) that the deviation described in the DIR being evoluoted is understood by the reviewer. Using the definition of safety f significance contained in this procedure, the assigned reviewer shall determine k

l whether the DIR that is the subject of the evoluotion constitutes deficiency. In l making this determination, the DIR shall be con:!dered safety significant if either it is safety significant based on current documentation or it is safety j significant based on documentation in effect on April I,1985. In the event that l o DIR is safety significant based on documentation in effect on April I,1985, but is no longer a safety significant deficiency (because, for example, design changes have occurred, commitments have changed, etc.), the safety significance evoluotion shall note that the design is no longer deficient. In such cases, the revised DIR that changes the classification to " deficiency" may be issued as a

" closed" DlR in the deficiency category, provided all other conditions for closure are met. The evaluation shall use the format described in 4.2 (above). After completion, the evaluation shall be given to o checker designated by the Discipline Coordinator. The checker shall review the evaluation and determine whether the evoluotion is correct and in conformance with this procedure. The originator and checker shall resolve all comments. The originator and checker shall sign the evaluation form.

O TN-85-6262/22 Page 5 of 8

COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-22 O

Title:

PREPARATION OF SAFETY SIGNIFICANCE EVALUATIONS Revision: I 4.S Approvo! of Sofety Sionificance Evoluotion ld After the safety significance evoluotion hos been reviewed, the Discipline Coordinator shall opprove it if he is satisfied with it. The Discipline Coordinator shall prepare or cause to be prepared oppropriate DIR forms in accordance with DAP-2. Depending upon the results of the safety significance evoluotion, such DIRs may be required for:

o Conclusion that a deviation is a deficiency o Conclusion that a deviation is not safety significant.

If the item is determined not to be safety significant the DAP Manager shall concur in the safety significance evoluotion. If the item is determined to be ld safety significant the DAP Manager's concurrence and the RTL's opproval are both required.

After approval and concurrence os required above, the safety significance

! evaluation shall be assigned on control number in accordance with Section 5.1.

4.6' Reconciliation of Final Documents and Evoluotions Prior to completion of the Design Adequacy Program, the DAP Manager shall provide oppropriate Project personnel with a bibliography of plant documentation (including, os applicable, revision number or date) relied upon to reach conclusions on the adequacy of the CPSES design. CPSES project management will be asked to identify any plant documentation in the bibliography that has g

been changed or superseded either by revision or by development of new docurnentation. DAP personnel shall examine such documentation to the extent necessary to determine whether the changes substantively alter DAP conclusions on the adequacy of those aspects of the plant design that were found not to contain safety significant deficiencies or unclassified deviations. This TN-85-6262/22 Page 6 of 8 l

s COMANCHE PEAK RESPONSE TEAM - DESIGN ADEOUACY PROCEDURE Number: DAP-22

Title:

PREP ARATION OF SAFETY Revision: I O SIGNIFICANCE EVALUATIONS examinotion of revised plant documentation shall not be opplicable to design arcos that are subject to overviews of corrective action under DAP 20.

The method, scope, and extent of such examinations of new or revised plant documentation shall be documented in revisions to discipline-specific results reports, engineering evoluotions, or other oppropriate DAP documentation. Any areas identified where DAP conclusions would be substantially altered as a result of revised documentation will be re-evoluoted by DAP and dispositioned enpropriately.

5.0 DOCUMENTATION 5.1 Identification O v After opproval has been obtained, the final engineering evoluotion shall be ossigned a control identification number by the DAP Manager or his designated representative os follows:

DAP-SS-YYY DIR Number This identification number, revision number and date shall be entered into the Safety Significance Evoluotion Log by the DAP Manager or his designee.

5.2 Retention The original copy of all final safety significance evoluotions shall be maintained and filed by the DAP Manager or his designated representative in accordance with dAP-14.

TN-85-6262/22 Page 7 of 8

e COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-22

Title:

PREPARATION OF SAFETY Revision: I SIGNIFICANCE EVALUATIONS 5.3 Revisions Revisions to safety significance evaluations may be required to add additional information or clarify and correct misinformation (e.g., inputs).

Revisions shall be prepared, checked and approved in the same manner as the original evaluation.

Superseded final evaluations shall either be identified as such on each page or securely bound with at least the cover page so identified. The Safety Significance Evaluation Log shall also note this occurrence. Superseded evalua-tions shall be retained in the files for historical reference.

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ATTACHMENT A Evoluotion Number: DAP-SS-COMANCE PEAK ADEQUACY PROGRAM Rev:

SAFETY SIGNIFICANCE EVALUATION Number of Sheets:

DAP Discipline:

O Issue / Discrepancy Title and Number:

Description of issue / Discrepancy:

Structure (s), System (s), or Component (s) Af fected:

COMPLETE THE FOLLOWING. USE ATTACHMENTS AS NECESSARY.

Method of Evoluotion:

Acceptance Criterio:

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References:

i Evoluotion:

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Conclusion:

OSofety Significant Not Safety Significant (Prepare DIR for Deficiency)

Prepared By/Date / Checked By/Date /

Discipline Coordinator /Date / DAP Manager /Date /

Approved By RTL/Date /

Form DAP-22 Rev.I

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ATTACHAENT B I -4 i Z ~

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A COMANCE PEAK DESIGN ADEQUACY PROGRAM M SAFETY SIGNFICANCE EVALUATION LOG E

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REVISION DATE '

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{ CONTROL D.NO. BY TITLE O I 2 3 4 5 6 i

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