ML20215K108
| ML20215K108 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/17/1986 |
| From: | Hansel J, Zill R EVALUATION RESEARCH CORP. |
| To: | |
| Shared Package | |
| ML20215J430 | List:
|
| References | |
| CPP-016, CPP-16, NUDOCS 8610270365 | |
| Download: ML20215K108 (19) | |
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EVALUATION RESEARCH CORPORATION COGOLLED CO?Y CONTROL N0_ "^: nec-co,g COMANCHE PEAK RESPONSE TEAM PROJECT PROCEDURE FOR ALL QA/QC ISSUE-SPECIFIC ACTION PLANS PROCEDURE NO: CPP-016 REVISION: 3 ISSUE DATE: 09/17/86 ,
SAFETY SIGNIFICANCE EVALUATIONS OF DEVIATION REPORTS paho2;gggggggggp A
PREPARED BY: __
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- ON-4i1TE QA RF@ENTATIVE APPROVED BY
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Q C' REVIEW TEAM ' LEADER '/ /
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4 CPP-016 Rsvision 3 j 1.0 PURPOSE This procedure establishes the method to perform evaluations of reported construction deviations to identify any construction deficiencies. .
2.0 APPLICABILITY This procedure is applicable-to safety-related hardware constructed i
and QC accepted at Comanche Peak Steam Electric Station (CPSES),
Unit 1, 2, and areas common to both units that have been subjected to reinspection and/or documentation review as part of the Quality i
of Construction Program.
3.0 REFERENCES
3.1 CPP-010. " Preparation of Deviation Reports."
3.2 CPP-011. " Evaluations of Adverse Trend Analyses, Construction Deficiencies, and QA/QC Program Deficiencies."
3.3 CP-QP 16.3, " Processing CPRT Deviation Reports / Observation Notices."
() 3.4 CPP-021. "CPSES Project Corrective Action."
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l 3.5 CPP-004, " Project Working Files."
l 4.0 GENERAL The QA/QC Safety Significance Evaluation Group (SSEG) evaluates construction deviations, normally documented on Deviation Reports (DRs) in accordance with Reference 3.1 but occasionally documented I an out-or-scope observation menos, to identify any construction l deficiencies. The safety significance evaluations (SSEs) examine the performance of the "as constructed" hardware in relationship to its intended or required performance as defined by the engineering requirements. Evaluations are thoroughly reviewed and approved by l individuals knowledgeable in the applicable discipline (s), then i
distributed to ensure any further reinspections/ reviews are
! identified, as required by Reference 3.2, and to ensure that the l
CPSES Project satisfactorily defines and implements action to correct any construction deficiencies in accordance with References 3.3 and 3.4.
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CPP-016 R:vicien 3 4.1 Responsibilities 4.1.1 QA/QC SSEG Supervisor The QA/QC SSEG Supervisor ensures that DRs received for evaluation are logged and dispositioned in a timely manner. The Supervisor ensures that knowledgeable personnel perform evaluations in accordance with established procedures and approves each SSE.
4.1.2 QA/QC SSEC Lead Discipline Engineer QA/QC SSEG Lead Discipline Engineers review SSEs to ensure that they are performed in accordance with technically acceptable methods.
4.1.3 QA/QC Review Team Leader The QA/QC Review Team Leader reviews and approves SSEs which identify apparent construction deficiencies.
4.1.4 QA/QC SSEG Discipline Engineer QA/QC SSEG Discipline Engineers perform and document evaluations which determine whether the reported deviations are apparent construction deficiencies.
4.1.5 Checker A checker examines any calculations prepared and made part of the SSE.
4.1.6 QA/QC Records Administrator i
The QA/QC Records Administrator advises the QA/QC Coordinating Engineer of the status of approved evaluations and ensures their distribution. The QA/QC Records Administrator also maintains the file of SSEs.
their associated memorandums, and marks SSEs as required.
4.2 Policy Activities performed under this procedure shall conform to the policies contained in the latest Comanche Peak Response Team (CPRT) Program Plan and Issue-Specific Action Plans.
Should an activity be designated as the responsibility of a Lead Discipline Engineer, or higher, it may be delegated by that engineer to an individual under his or her supervision.
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CPP-016
, Revicion 3
() 4.3 Conflicts In the case of a conflict between this procedure and the documents referenced in Section 4.2, the latter shall govern.
4.4 Definitions 4.4.1 Construction Deficiency - Any identified construction deviation that has been determined to be safety-significant.
4.4.2 Safety-Significant - An identified discrepancy which, if uncorrected, would result in the loss of capability of the affected system, structure, or component to perform its intended safety function. Credit is not allowed for redundancy at the component, system, train or structure level.
5.0 PROCEDURE 5.1 Deviation Report Receipt and Assignment Upon receipt of a valid DR forwarded for evaluation in accordance with Reference 3.1, or a concern from a Review Team t
O other than the QA/QC Review Team, the QA/QC SSEG Supervisor ensures that it is logged in accordance with Attachment 6.1, then forwarded to the appropriate personnel for evaluation.
The SSEG Supervisor forwards valid DRs to the appropriate QA/QC SSEG Lead Discipline Engineer for evaluation. However, when a deviation appears to be in an area under evaluation by a Review Team other than the QA/QC Review Team, the Supervisor may, with the concurrence of the appropriate Review Team Leader and the QA/QC Review Team Leader, reassign it to that Review Team for safety significance evaluation.
Accor/ingly, the SSEG Supervisor shall obtain writter.
confirmation from the responsible individual of the other-Review Team which attests that procedures established to identify construction deficiencies meet the intent of this procedure. In the absence of such confirmation, the SSEG Supervisor shall, as required, provide written direction to perform evaluations in accordance with this procedure.
5.2 Safety Significance Evaluations 5.2.1 QA/QC SSEG Lead Discipline Engineers ensure that l
sufficient documentation relative to the reported condition is available for an analysis of safety significance. Should additional documentation be O necessary, the Lead ensures that a memorandum is prepared to the appropriate individual in order to obtain the information. Then the Lead assigns DRs to QA/QC SSEG Discipline Engineers for evaluation.
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I CPP-016 Rcvision 3 5.2.2 The SSEG Discipline Engineers perform an evaluation of the construction deviation described in the DR based upon the following guidelines:
(a) The Discipline Engineer becomes familiar with the physical arrangement of the referenced item to perform the evaluation with the proper perspective.
This may be accomplished by reviewing the Verification Package, project documents, and/or performing a plant inspection.
(b) The intended safety function of the referenced item is determined. The description of the intended safety function is determined by its performance in the specific application.
(c) The manner in which the attribute resulting in the construction deviation contributes to the likely l performance of the intended safety function of the referenced ites is determined. Licensing regulations, licensing commitments, and engineering documents which substantiate this determination are referenced.
(d) The required level of performance to meet the intended safety function of the item is identified by reference to plant design documents.
, (e) The likely performance of the referenced item considering its deviating attribute is determined either quantitatively or qualitatively. Project calculations may be referenced, or other I
calculations prepared by the SSEG. Should an SSEG -
calculation longer than a simple formula be used in the determination, a separate calculation sheet shall be prepared in accordance with Attachment '
6.4. The calculation shall include as applicable:
A concise statement of the problem or question, i.e., the objective.
Clear identification of any assumption.
A reference or description of the calculation method.
Clear identification of inputs which include, as applicable, the technical document title, number, issue date, revision designation, and section, page, or table numbers, or incoming letter O identification number, date, originator's name, addresses name, file location, and originator's source (when available).
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CPP-016 Rsvision 3 O References to applicable codes, standards, etc., including issue and addenda information.
A conclusive statement relative tc the calculation objective and based on the analysis, i.e., the results which specify whether or not the deviation violates any code requirements.
Clear identification of computer programs.
NOTE: Calculations utilizing programmable calculators or desk top computers shall include the program listing.
(f) Should the inspected item be unlikely to perform its intended safety function, the reported construction deviation is considered to be safety-significant and is identified as a construction deficiency.
5.2.3 QA/QC SSEG Discipline Engineers document evaluations of construction deviations in accordance with the following requirements:
O Form CPP-016.2A and CPP-016.2B shall be used for the evaluations. See Attachment 6.2 for instructions on filling in the form.
The evaluation format shall be in accordance with Attachment 6.3.
l Separate calculations originated by the SSEG to be used l as a part of the evaluation shall use the form shown on Attachment 6.4. Separate calculations are required for all calculations except for simple equations which fit into the text.
Attachments to the evaluations shall be labeled 1, 2, 3 etc. and referenced in the evaluation. SSEG calculations shall be numbered with the evaluation number and'shall have its attachments lettered A, B, C, etc. The calculation with its own attachments chall be referenced in the evaluation, but not given another attachment number.
Evaluations including SSEG prepared calculations, shall be prepared in ink or, if reproduced, shall have ink l signatures.
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CPP-016 Ravision 3
, O Calculations prepared by the SSEG shall be checked by a technically competent engineer other than the preparer.
The checker shall sign and date both the calculation cover sheet and the SSE evaluation sheet. For small calculations, which are an integral part of the evaluation text, the reviewer may also sign as checker.
The QA/QC SSEG Lead Discipline Engineer may elect to obtain concurrence in the evaluation by a specialist or
- QA/QC SSEG Discipline Engineer in a related discipline.
Accordingly, the responsible individual (s) initial and date the SSE in the " CHECKER" and/or " REVIEWED BY" portions of the form.
When the SSEG does not prepare a calculation, or it is inappropriate to obtain the concurrence of a specialist or other QA/QC SSEG Discipline Engineer, the preparer marks "N/A" (not applicable) in the
" Checker" portion of the form, then forwards it to the appropriate QA/QC SSEG Lead Discipline Engineer for review.
5.2.4 C m lative impact evaluations are performed for multiple deviations against the same inspection package (same ites inspected). The purpose of this evaluation is first to assure that the ites inspected can perform O its intended function and second to identify combinations of attributes which could result in adverse trends. Cumulative impact evaluations shall be by the use of CI in place of the DR in the evaluation number. Ex. I-S-SBPS-XXX-CI-SSE Evaluations shall be made of all inspection and document attribute deviations to identify those which are inter-related and to perform analysis of all combinations of these attributes which rre inter-related.
If construction deficiencies have been identified by tha individual analysis of deviations they are not included in the cumulative impact evaluation. The cumulative impact evaluation conclusion shall state that it is reached exclusive of the construction deficiency separately identified.
A cumulative impact completeness meno shall be attached to the final cumulative impact analysis to verify that each DR written has been accounted for and those that are required to be analyzed have been includsl in the CI analysis. The meno shall be signed by the Supervisor of the SSEG and by the SSEG Lead Discipline O Engineer. The meno shall list every DR and its final status.
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CPP-016 Ravision 3 O The format for cumulative impacts shall, as a minimum, identify the DR's, provide a brief description of the DR's, and provide sufficient analysis and discussion to support the conclusions concerning independence, .
. inter-relationship, and item's performance.
Attachments not furnished in the individual SSE's for the package and necessary for the conclusion shall be provided in the CI.
5.2.5 Deviation Reports may in two cases be processed by the SSEG without reaching conclusions concerning the hardware's ability to perform its intended function.
5.2.5.1 Missing information - Deviation Reports which do not provide information on the ,
"as-built" hardware (i.e. document review- '
deviation reports discussing missing documents or missing notations on documents) are indeterairste with respect to the hardware's ability to perform its intended 1 safety function. The need to develop a separate program to obtain this information is identified in the population results i report analysis.
The SSE for the deviation report shall state
.O that no conclusion can be reached concerning the ability of toe hardware to perform its intended functica with respect of the attribute in question. The deviation report
- on missing information alone does not mean that the hardware will not perform its intended function. The SSE will be documented in accordance with section 5.2.3 of this procedure.
5.2.5.2 No hardware performance evaluation required -
Deviation types where construction ,
deficiencies or adverse (or unclassified) trends have resulted in a TUGCO corrective action program to find and correct all the construction deficiencies of the particular attribute of the deviations do not require the performance of a safety significance technical evaluation for population sample expansion.
The SSE form (Attachment 6.2) shall be used to document the existence of a TUGC0 program and to verify that the deviation type is satisfactorily included in the program.
,O Appropriate documents confirming the program shall be attached to the SSE form.
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CPP-016
, Ravision 3 O The responsible population engineer shall cosign the SSE form with the SSE engineer in the preparer block and the lead population engineer shall cosign the form in the
, reviewer block.
5.3 Review and Approval Technically competent individuals other than the preparer review and approve all evaluations before the results or conclusions provide input to or confirm other engineering decisions.
5.3.1 Checker A technically competent engineer, other than the preparer, checks calculations prepared during the evaluation for accuracy and use of methodology.
Checkers indicate their concurrence with independent calculations by signing and dating them in the appropriate space on the SSE and on the calculation cover sheet form (Attachment 6.4).
5.3.2 QA/QC SSEC Lead Disciplina Engineer l The QA/QC SSEG Lead Discipline Engineer knowledgeable in the applicable discipline ensures that each SSE is complete, accurate, and otherwise consistent with the requirements of this procedure. He ensures that the DR has been analyzed in a manner consistent with other similar DRs. The responsible Lead concludes that an l individual competent in the calculation discipline can
! rationalize the original work without recourse to the
. preparer.
5.3.3 QA/QC SSEC Supervisor The QA/QC SSEG Supervisor, reviews the SSE to ensure that the method, any assumption used, and the results of the evaluation are appropriate.
Evaluations determined not to be safety-significant are approved by the QA/QC SSEG Supervisor and sent to the Records Administrator for distribution and control.
Evaluations that identify any construction deficiencies are approved by the QA/QC SSEG Supervisor and taken to the QA/QC Review Team Leader (RTL) for approval prior to being sent to the Records Administrator for distribution and control by the SSEG supervisor.
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CPP-016 Ravision 3 5.3.4 0A,0C Review Team Leader The QA/QC RTL reviews safety significant SSEs, as required, to ensure that the reported condition does not overlap a concern being investigated by another organization, e.g., another CPRT Review Team.
Should the review by the QA/QC RTL reveal that the reported condition was previously identified, it shall be documented on a memorandum prepared by the QA/QC RTL and addressed to " File". The memorandum shall provide instructions regarding the disposition of any affected DRs and indicate the concurrence of either the preparer /
reviewer (s)/ approver (s) of the referenced SSE, or the individuals acting in those capacities should the original signatories be no longer assigned to the CPRT.
The affected SSE is also marked, in the space provided for the signature approval of the QA/QC RTL, "PREVIOUSLY REPORTED. Refer to (RTL)'s memorandum dated (Date) attached."
The QA/QC RTL returns approved safety significant SSEs and those marked "PREVIOUSLY REPORTED...." (with the required memorandum) to the SSEG Supervisor for transmittal to the QA/QC Records Administrator for distribution and control.
5.4 Distribution and Control 5.4.1 Records Administrator Upon the receipt of SSEs from the QA/QC SSEG Supervisor, the QA/QC Records Administrator advises the -
Coordinating Engineer and documents their transmittal on uniquely numbered memorandums which include provision for the TUGC0 QA Coordinator to acknowledge receipt. In addition, the QA/QC Records Administrator maintains records to ensure that the TUGC0 QA Coordinator is in receipt of all valid SSEs, e.g., a file of transmittals forwarded to and received from the TUCCO QA Coordinator in a loose-leaf binder. Copies, without attachments, are also sent to:
QA/QC Engineering Supervisor or Issue Coordinator
- QA/QC Inspection Supervisor l
l QA/QC Lead Discipline Engineer The QA/QC Interface Coordinator RTL other than the QA/QC RTL (Refer to Section 5.1) 10
CPP-016 Rsvision 3 Copies sent to the TUGC0 QA Coordinator are evaluated
,,) by TUGC0 for reportability in accordanc9 with Reference 3.3.
Evaluations approved by the QA/QC RTL are sent to the individuals named above and the CPRT Program Director.
The Records Administrator maintains the file of distributed SSEs and associated memorandums (marked (ISAP Number] - 5.C). .
NOTE: Superseded SSEs shall be clearly marked
" SUPERSEDED. Refer to (SSE Number) Dated (Date)." Cancelled SSEs shall be clearly marked " CANCELLED. Refer to (Name)'s memo dated (Date)."
5.5 Revision Should it be necessary to make a change to a SSE that would alter its result or make major changes in the analysis such that much of tho original evaluation must be re-written, the cognizant individual prepares a new SSE which includes the appropriate change (s), is identified to include, as applicable, the new DR number and clearly denotes " SUPERSEDES (SSE Number) Dated (Date)."
' O In addition, the cognizant individual prepares a memorandum which is addressed to " File" and provides a reasonable explanation regarding the change. The memorandum notes the superseded and superseding SSE numbers. The memorandum, with the new SSE attached, is routed for review. The new SSE is reviewed, approved, distributed, and controlled in the same manner as the one it supersedes.
Minor changes in the evaluation or the associated calculations shall be considered a revision. The changes shall be identified by a line in the margin and the revision number in a triangle beside it. The calculation signature sheet shall be signed off in the appropriate revision blocks. The SSE cover sheet shall be initialled, dated, and identified for the appropriate revision. The SSE number shall contain the revisions number.
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Ex. I-S-SBPS-XXX-DRIX-SSE (Rev. 1)
Otherwise, the cognizant individual shall make any innocuous changes to SSEs in accordance with Reference 3.5 and ensure that any previous recipients of the SSE are advised of its current status by distribution of the revised SSE.
5.6 Cancellation 1
O Should there be documented evidence that, in effect, cancals a previously issued SSE, e.g., a memorandum that cancels a DR (see Reference 3.1), the cognizant individual ensures that the
- recipients of those SSEs are advised by memorandum of their
( correct status.
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CPP-016
- , Rsvision 3 l
l l The memorandum is addressed to " Distribution" and provides a l .
reasonable explanation regarding the cancellation and is routed for review and approval to the same organizations /
disciplines that performed the previous review and approval.
Copies of all memorandums, as noted for diotribution, are sent j
to the:
Responsible QA/QC Engineering Supervisor or Issue i Coordinator '
QA/QC Inspection Supervisor i
QA/QC Lead Discipline Engineer i
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- QA/QC Interface Coordinator QA/QC Coordinating Engineer i
RTL other than the QA/QC RTL (Refer to Section 5.1)
I QA/QC Records Administrator TUG 00 QA Coordinator l
Copies of memorandums which address SSEJ approved by the QA/QC RTL are sent to the the individuals named above and the CPRT l
O Program Director.
5.7 Out-of-Scope Observations Safety Significance Evaluations Out-of-Scope Observations will be evaluated, documented, logged and processed in accordance with this procedure.
6.0 ATTACHMENTS 6.1 Safety Significance Evaluation Log Instruction 6.2 Safety Significance Evaluation Form (Sample and Instruction) 6.3 Format for the Analysis Section of the SSE 6.4 Calculation Form (Sample)
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Attachmsnt 6.1 CPP-016 Revision: 3 Page 1 of 1 O SAFETT SIGNIFICANCE EVALUATION LOG INSTRUCTION The SSEG shall maintain a log of all valid DRs sent to the SSEG for evaluation according to the population of the DR. The log may be maintained electronically or manually.
The QA/QC SSEG Supervisor ensures that valid DRs are logged by entering the:
(1) Log Report Name (2) Los number. The log number is similar to the applicable Deviation Report number e.g., I-E-CABL-056-1. If a cumulative impact evaluation is deemed necessary, "CI" shall be used in place of 3R number.
(3) Date of receipt of Deviation Reports from QA/QC Records Administrator (not applicable to CIs).
(4) Date the Safety Significance Evaluation approved by the QA/QC SSEG Supervisor was sent to the QA/QC Records Administrator for distribution in accordance with Section 5.4 of this procedure.
() (5) Note cases where DR's are transferred or returned from the SSEG and the reason (s).
(6) Note status changes of DRs received or SSEs issued such as ,
invalidation, cancellation, revision, superceded, etc.
(7) A hard copy printout of the log shall be produced once a week for the SSEG file.
(8) The instructions for operation and maintenance of the electronic log shall be kept in the SSEG hard copy log file. Backup floppy disk copies of the electronic log shall also be filed in the hard copy log.
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Attachesnt 6.2 CPP-016 Revision: 3 INSTRUCTIONS TO COMPLETE 4
FORMS CPP-016.2A and CPP-016.2B
" SAFETY SIGNIFICANCE EVALUATION" (1) The evaluation number consistent with the DR number or the Out-of-Scope Observation number.
Ex. I-S-SBPS-XXX-DR- E-SSE or Serial No. XXX-SSE (2) Page number information excluding attachments.
(3) The analysis.
(4) Signature of preparer and date. Circle "will not" for non safety-significant evaluations and cross out "will". Circle "will" for construction deficiencies and cross out "will not".
(5) Signature of checker and date. If neither a checker or a specialist signature is to be needed the preparer enters "N/A" (not applicable) in the appropriate spaces.
( (6) QA/QC SSEG Lead Discipline signature and date.
NOTE: The 'same space may be used to indicate the concurrence of a specialist or QA/QC SSEG Discipline Engineer in a related discipline (refer to paragraph 5.2.3).
Upon the completion of a satisfactory review, the Supervisor indicates that the requirements in Paragraph 5.3.3 have been met by:
(7) QA/QC SSF.G Supervisor signature and date.
(8) QA/QC RTL signature and date.
. NOTE: Should the evaluation resuir in a construction l deficiency, the approval of the QA/QC RTL is also required. Otherwise, the SSEG Supervisor enters "N/A" in the space provided for that approval.
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Actschm2nt 6.3 CPP-016 Revision: 3 Page 1 of 2 FORMAT FOR ANALYSIS SECTION OF SSE ANALYSIS:
I. Description of Inspected Item and Deviation (a. State the name of the item inspected and give its ID.)
(b. Describe each deviation occurrence listed on the Deviation Report. The description should be brief but relate the discrepancy to the item inspected.)
II. Function of Inspected Item (Describe briefly the application specific function (s) of the inspected item. For items which perform indirect functions with respect to plant and public safety, the direct function of the affected system, component or structure may be described - if necessary, to support the conclusion.)
( III. Evaluation Objective l
(Describe briefly the performance parameter (s) of the l inspected item that must be evaluated to deteunine the effect j of the deviation on the item's ability to perform its t function (s). Also describe non-functional attributes (such as separation) that relate to plant or public safety that are affected by the deviation and are evaluated.)
IV. Evaluation (a. Develop the facts into a logical assessment of the item's performance.)
(b. Reference attachment calculations. Simple calculations can be included in text provided a cale. check is performed.)
(c. Compare performance to acceptance criteria such as code stress allowables.
(d. Provide the necessary references for equations, theory, and data.)
(e. Provide attachments of information necessary for others
( to review and be convinced of its correctness.)
Attachtsnt 6.3 CPP-016 Revision: 3 Paga 2 of 2 Indicate impact on all affected design margins, if O (f.
readily quantifiable.)
(g. Indicate when code allowables have not been met and provide justification if still acceptable.
V. Conclusion
- a. Non safety significant deviations.
(1. State that the inspected item can still perform its intended function with the existing deviation.)
- b. Construction deviations.
( For construction deficiencies, state that the inspected ites and the affected systems do not perform their intended function.)
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,, g( c-OOl A Attach =ent 6.2
's CPP-016 Q Revision: 3
\Oh Page 1 of 3 O\ goc f V
- COMANCHE PEAK RESPONSE TEAM SAFETY SIGNIFICANCE EVALUATION EVALUATION NUMBER: (1) SSE SHEET 1 0F (2)
PREPARER: (4) DATE: (4)
QA/QC SSEG DISCIPLINE ENGINEER CHECKER: (5) DATE:
THE FOLLOWING ANALYSIS SUPPORTS THE CONCLUSION CONCERNING THE SAFETY SIGNIFICANCE OF THE CONDITION DESCRIBED IN THE DEVIATION REPORT (S).
ANALYSIS:
(3) l l
l CONCLUSION: (4)
BASED UPON THIS ANALYSIS. THE REPORTED CONDITION WILL/WILL NOT RESULT IN THE INABILITT i 0F THE AFFECTED ITEM TO PERPORM ITS INTENDED SAFETT RELATED FUNCTION.
REVIEWED BY: (6) DATE: (6)
QA/QC SSEG LEAD DISCIFLINE ENGINEER (7) DATE: (7)
O APPROVED BY: -QA/QC SSEG SimERVIS01 APPROVED BY: (8) DATE: (8)
' QA/QC REVIEW TEAM LEADER CPP-016.2A, Revision 2 ,
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' ' Accachment 6.2 CPP-016 Revision: 3 Page 2 of 3 COMANCHE PEAK RESPONSE TEAM SAFETY SIGNIFICANCE EVALUATION EVALUATION NUMBER (1) SSE, SHEET OF
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CPP-016.25. Revision L
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