ML20215J988
| ML20215J988 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/18/1986 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20215J430 | List:
|
| References | |
| DAP-24, NUDOCS 8610270290 | |
| Download: ML20215J988 (17) | |
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Ov TITLE: Comunication of Potential Safety Concerns NUMBER: DAP-24 Revision Prenared DjLt1 Reviewed Qitti Acoroved Qitta 910 %i & Yg l Aft!llG O
8610270290 861010
- PDR ADOCK 05000445 A PDR C0r1TiiOLLED COPY NO. 9I -
BK-001 i
i TABLE OF CONTENTS SECTION P_Afd Cover Sheet.................................................... 1 Tabl e o f Co n t en t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.0 PURP0SE................................................... 1 4
- 2.0 SC0PE..................................................... 1 3.0 DEFINITIONS AND RESP 0NSIBILITIES.......................... 1 f
1 4.0 INSTRUCTION............................................... 3 i 5.0 DOCUMENTATION............................................. 7 ATTACHMENTS i
A POTENTIAL SAFETY C0NCERN.................................. A-1 B TERMINATION CHECKLIST..................................... B-1 i
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BK-001 it i
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q COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-24
Title:
Communication of Potential Revision: 0 Safety Concerns 1.0 PURPOSE This procedure provides a method for communicating, documenting, and resolving Potential Safety Concerns related to the design or construction of the Comanche Peak Steam Electric Station (CPSES). This procedure also requires that personnel leaving the Design Adequacy Program or TRT-CSM Program be offered an opportunity, and encouraged, to relay safety concerns to DAP management.
2.0 SCOPE This procedure applies to all third-party personnel involved in the CPRT Design Adequacy Program (DAP) or in the TRT Civil / Structural and Mechanical (CSM) program in technical or consulting roles, who have safety concerns which he/she believes are not getting adequate s) resolution through normal methods (e.g., DIRs, CARS).
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions j 3.1.1 Technical Personnel Third-party personnel who have been approved by the Review Team Leader and who have performed work of a technical, technical review, technical supervision or management, or technical consulting nature on the DAP or in the TRT-CSM Program.
3.1.2 Potential Safety Concern A potential safety concern as used herein is a belief by any technical personnel that a situation exists with regard to the design or i O BK-001 Page 1 of 7 l
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O COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE d
Number: DAP-24
Title:
Communication of Potential Revision: 0 Safety Concerns construction of CPSES which creates a nuclear safety hazard or a regulatory noncompliance, and for which corrective action may be
- warranted but is not satisfactorily occurring or documented.
- 3.1.3 Termination Checklist i
A checklist (Attachment B to this procedure) which technical personnel l shall complete upon termination from the DAP or TRT-CSM Program.
Support personnel are not required to complete Termination Checklists.
4 3.1.4 Safety Concern Evaluation Committee A committee composed of the President of TERA Corporation, the DAP
[ Review Team Leader (RTL), and the DAP QA Manager (QAM). The DAP l Manager or TRT Issues Manager may function as an alternate for any one of the above if needed. Only one alternate may be on the committee on any given issue.
l 3.2 Resnonsibilities 3.2.1
) DAP Technical Personnel All technical personnel are encouraged to follow DAP procedures to
! document safety concerns but may d'cument o potential safety concerns f using the format of Attachment A to this procedure under the conditions l discussed in paragraph 4.1 of this procedure.
1 3.2.2 DAP Discipline Coordinators and CSM ISAP Issue Coordinators DAP Discipline Coordinators and ISAP Issue Coordinators shall attempt to resolve potential safety concerns brought to them in accordance with this procedure. They shall request that technical personnel under O
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
,O Number: DAP-24
Title:
Communication of Potential Revision: 0 Safety Concerns their jurisdiction complete a termination checklist at the time of termination from the DAP or ISAP programs.
3.2.3 Safety Concern Evaluation Committee i The Safety Concern Evaluation Committee shall review all documented potential safety concerns, concur with those that have been resolved, and obtain resolution of those that are unresolved, in accordance with this procedure.
3.2.4 DAP Training Coordinator The DAP Training Coordinator shall track, via the DAP Personnel Data
- Base, the status of completion of the Termination Checklists by technical personnel included on the DAP Personnel Roster,
() maintain the record of completed Termination Checklists.
and shall 4.0 INSTRUCTION 4.1 General It should be noted that the DAP and TRT-CSM programs are a third-party function, and that the normal vehicle for documenting design problems resulting from reviews is via DIRs as discussed in DAP-2, Documentation of Issues and Discrepancies. This procedure is not intended to l displace the DIR process. It is intended to supplement the DIR process
- by providing technical personnel a means, without fear of retribution or punitive effects, to document potential safety concerns. DAP management wants to ensure that all design and construction problems related to CPSES identified by DAP and TRT-CSM are properly documented
, and resolved. All technical personnel are encouraged to resolve potential safety concerns when possible through normal interaction with their peers and supervisors; however, they are also encouraged to use BK-001 Page 3 of 7
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-24
Title:
Communication of Potential Revision: 0 Safety Concerns I
the mechanisms afforded by this procedure when normal interactions fail to resolve the potential safety concern.
4.2 Potential Safety Concerns 4.2.1 Documentation Technical personnel should document potential safety concerns using Part 1 of Attachment A to this procedure.
4.2.2 Communication Attachment A to this procedure should then be forwarded to the originator's Discip'iine Coordinator (or Issue Coordinator for CSM ISAPs) with copies to the members of the Safety Concern Evaluation O Committee.
4.2.3 Resolution The Discipline Coordinator shall, with review and consultation with the I
originator and others as appropriate, evaluate the potential safety concern and propose appropriate action to resolve, if any, and complete Part 2 of Attachment A to this procedure.
The Discipline Coordinator and the originator shall concur, if possible, in the corrective action, or that none is called for, whichever is appropriate, and forward the completed Attachment A to the Safety Concern Evaluation Committee.
If the Discipline Coordinator and the originator do not concur on the method of resolution or that a safety concern exists, the Discipline Coordinator shall document his evaluation and opinion in Part 2 of Attachment A and forward to the Safety Concern Evaluation Committee with a copy to the originator.
l BK-001 Page 4 of 7 i
4 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O Number: DAP-24
Title:
Communication of Potential Safety Concerns Revision: 0 i
The Safety Concern Evaluation Committee shall review and concur with all potential safety concern resolutions. If the originator and the Discipline Coordinator did not concur on resolution, the Safety Concern
- Evaluation Committee shall perform its own evaluation of both positions
- and establish final resolution. Final resolution shall be documented j with copies back to the originator and Discipline Coordinator.
! It should be noted that the originator, if he/she still feels a j potential safety concern exists, has recourse to the CPRT Senior Review ,,
} Team directly, via the SRT chairman, or through SAFE TEAM, which is the employee concern resolution program endorsed, functioning and supported by TUEC Senior Management. (Reference the CPRT Program Plan, Section l II, and Appendix F,Section II.A.4, and PAG-09, Rev. 0.) He/she also has direct access to the NRC as needed.
4.3 Technical Personnel Termination i
4.3.1 Initiation of Termination Checklist i
l The DAP Manager, Engineering Manager, System Engineering Manager, or l TRT Issues Manager, as appropriate, shall request that technical personnel complete the Termination Checklist prior to becoming inactive on the DAP and TRT-CSM programs.
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l 4.3.2 Interview '
Discipline Coordinators or appropriate Managers (DAP Manager, Engineering Manager, Systems Engineering Manager, or TRT Issues i
Manager) shall offer to discuss the completed Termination Checklist at the technical personnel's convenience. If the terminated person indicates on the checklist that he/she has safety or quality concerns, the Discipline Coordinator or appropriate Manager should attempt to interview him/her to further explore the details of the concern.
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE V Number: DAP-24
Title:
Communication of Potential Revision: 0 Safety Concerns Interview results, if conducted, shall be documented in writing by the Discipline Coordinator and appended to the Termination Checklist.
4.3.3 Results A copy of each completed Termination Checklist (along with interview results, if any) shall be provided to the Review Team Leader by the Discipline Coordinator or Manager. The Review Team Leader shall review the Termination Checklist and document his review by signature. He will determine if the Termination Checklist contains information that represents a valid safety concern. He will initiate action on any safety concerns and advise the Safety Concern Evaluation Committee of such action. He shall route his copy of the Termination Checklist to the Training Coordinator for the DAP Record copy.
4.3.4 Tracking The DAP Training Coordinator shall track, via Personnel Roster, whether or not a Termination Checklist is required for each person, and whether l or not one has been received for the records. The Training Coordinator shall initiate action to obtain a Termination Checklist if a person is i
transferred to Inactive Status and a termination checklist has not been received.
4.3.5 Follow-up l
l The Safety Concern Evaluation Committee shall track to closure those safety concerns which were identified via Termination Checklists, and for which the Committee or the RTL alone initiated corrective actions.
The Committee shall concur when the corrective action is complete and the item can be closed.
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE O~ Number: DAP-24
Title:
Communication of Potential Revision: 0 Safety Concerns 4.4 Effective Date This procedure shall apply to all personnel who terminate from the DAP or TRT-CSM programs after September 1, 1986. Discipline Coordinators shall attempt to contact personnel who terminated prior to September 1, 1986 and obtain Termination Checklists where possible.
5.0 DOCUMENTATION 5.1 Potential Safety Concerns Copies of all correspondence or records generated under Section 4.2 of this procedure shall be maintained in the DAP General File, File Code 13.7. If DIRs are issued, they shall be hardled and filed in accordance with DAP-2.
5.2 Termination Checklists A record copy of all Termination Checklists (and interview results, if any) will be maintained by the DAP Training Coordinator as part of the DAP Personnel Training and Qualification files. (File Code 2.0) 5.3 Corrective Action Copies of all correspondence and documents associated with corrective actions initiated by the Safety Concern Evaluation Committee as a result of Section 4.3 (Termination Checklists and interviews) shall be filed in the DAP General File, File Code 13.7. If DIRs are issued as
- appropriate to document safety concerns, they shall be handled and filed in accordance with DAP-2.
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ATTACHNENT A POTENTIAL SAFETY CONCERN Part 1 (To be completed by DAP or TRT-CSM ISAP personnel having knowledge of a potential safety concern (Originator)
- 1. Name and position:
- 2. DSAP or ISAP Affected:
- 3. Description of potential safety concern: (Be as specific as possible. Use attachments if needed. List references, DIRs, or other documents known to you which relate to your concern.)
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- 4. Description of appropriate corrective action if known. Otherwise, state " unknown":
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O 5. Signature and Date:
Note: Please transmit copies of this document to:
- 1. Your Discipline Coordinator or ISAP Coordinator
- 2. Safety Concern Evaluation Committee members:
Don K. Davis, President, TERA, Berkeley, California
, Howard A. Levin, DAP Review Team Leader, TERA, Bethesda, Maryland
- Q.B. DuBois, DAP QA Manager l c/o TERA, Berkeley, California Part 2 (To be completed by the Discipline Coordinator or ISAP Issue Coordinator).
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- 1. Name and position:
- 2. Do you concur with the Potential Safety Concern as described in Part I?
Yes (Go to Step 3)
! No (Explain your reasoning below) l O
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- 3. Do you concur with the Corrective Action as started in Part 1 (if stated):
Yes (Go to Step 4)
No (Explain below)
Not stated (Discuss below whether Corrective Action is called for or not) 4
- 4. Discipline Coordinator or ISAP Issue Coordinator, Signature and Date:
- 5. Discipline Coordinator or ISAP Issue Coordinator - Review Part 2 p
above with the Originator.
Performed (Initial and Date)
Not performed (State reason)
- 6. Originator - Do you concur with the information as written in Part 2 above?
Yes Signature and Date No Signature and Date (Explain below if desired)
Note: Please transmit copies of this document to:
TRT Issues Manager (If CSM ISAP scope)
- 2. Safety Concern Evaluation Committee members:
Don K. Davis, President, TERA, Berkeley, California BK-001 A-3
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Howard A. Levin, DAP Review Team Leader, TERA, Bethesda, Maryland i
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- Q. B. DuBois, DAP QA Manager, c/o TERA, Berkeley, California s
- 3. Originator I
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'4 l ATTACHMENT B TERMINATION CHECKLIST j
f Since you are leaving the Comanche Peak Steam Electric Station Design l
Adequacy Program, we wish to take this opportunity to ensure that any concerns you might have developed are recorded for DAP management's
- evaluation and potential action.
4 While we have always encouraged you to feel free to discuss any issue, we recognize that for some reason you may have felt some reluctance to do so. Before you leave DAP, we ask that you provide your concerns and suggestions in a free and open way.
Any items which you care to document will be evaluated by management
- and appropriate action will be taken.
i l To guide your thoughts, but in no way restrict them, some specific questions have been listed below. The space provided should not be considered indicative of the length of the response solicited. You are requests.J to answer each question thoughtfully, completely, and to the best of your knowledge. Please use additional sheets if necessary.
, Although you may use any style you wish, you need to be as specific as
- possible. As you know, it is virtually impossible to evaluate a l " problem" which has been stated as a generality, i
i l If for some reason you are reluctant to complete Part I of this checklist, please sign acknowledgement of Part 2.
PART 1
- 1. Are there any areas where DAP or TRT-CSM management took actions l which you consider to be not in conformance with the CPRT Program i Plan or procedures?
!O BK-001 B-1
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- 2. Are there any areas where you felt that DAP or TRT-CSM management was aware of but failed to properly document a design or quality discrepancy or issue?
- 3. Are there any cases where you felt that you were ,, essured either to accept (sign-off, endorse, or stopped from documenting) a condition which you felt was adverse to quality or were prevented from properly performing your third-party role? If yes, please explain.
- 4. Are there any other items you would like to document?
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The above listed items represent all of the concerns which I have regarding the quality of the Design Adequacy Program for the Comanche Peak Steam Electric Station.
(Signature)
(Date)
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TERMINATION CHECKLIST PART 2 I have been given an opportunity to express any concerns which I might have regarding the Design of the Comanche Peak plant. I have also been requested to document any issues relative to safety or quality which I do not feel have been appropriately handled or documented by the Design Adequacy Program.
I have no issues which I wish to document.
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(Signature) l (Date) l O
BK-001 B-3