ML20236N946
| ML20236N946 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/11/1987 |
| From: | Shafer R, Turi P TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20236N530 | List:
|
| References | |
| DDI-M-003, DDI-M-3, NUDOCS 8708120162 | |
| Download: ML20236N946 (21) | |
Text
_.
4-e TITLE:. Technical Adequacy Review of NCRs NUMBER:
DI-M-003 Revision Prepared Date Reviewed Date Approved Date W.
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. TABLE'0F CONTENTS Section Pace
' Cover Sheet.................................................
i T a bl e o f C o n t e n t s...........................................
ii 1.0 PURP0SE................................................
I 2.0 SC0PE..................................................
1-i 3.0 DEFINITIONS AND RESP 0NSIBILITIES.......................
1 4.0 INSTRUCTION............................................
3 1
I 5.0 DOCUMENTATION..........................................
12 Attachments A NCR REVIEW WORKSHEET.....................................
A-1 B WORKSHEET CONTINUATION SHEET.............................
B-1 C NCR REVIEW REC 0RD........................................
C-1 fsV D SCREENING REVIEW REC 0RD..................................
D1 E NCR TECHNICAL REVIEW WORKSHEET...........................
E-1 i
F NCR TECHNICAL REVIEW REC 0RD..............................
F-1 G SURVEILLANCE F0RM........................................
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COMANCHE PE AK 'tESPONSE TE AM - DAP DISCIPLitE INSTRUCTION Number: DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 3 1.0 PURPOSE This instruction defines the method to be used in conducting a ld review of Project NCRs to assess the adequacy of those dispositions which required technical justification.
2.0 SCOPE The scope includes a review of Project activities related to A
determining the technical adequacy of CPSES NCRs. The scope m
of this review will include:
o A review of the Project's assessment of technical adequacy of 300 previously issued NCRs that were selected for a sampling program conducted by the Project, o A review of the newly issued Project procedures for NCRs as well as the current NCR training program, and o A review of the Project's NCR verification effort.
This
]
includes both the Project's verification of all previously issued NCRs for technical adequacy and the Project's activities for NCRs issued under the new CPSES procedure.
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions 3.1.1 Nonconformances (ANSI N45.2, Criterion 16)
A deficiency in characteristics, documentation or procedures that renders the quality of an item unacceptable or indeterminate.
Examples of nonconformances include: physical l
defects, test failures, incorrect or inadequate documentation, or deviation from prescribed processing, inspection or test procedures.
Nonconforming items may be disposed of by acceptance as is, by
}
scrapping or repairing the defective item, or by rework to complete or correct to a drawing or specification.
Such measures shall provide assurance that the item is identified as nonconforming and controlled.
The measures shall require Page 1 of 12 6
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V COMANCHE PE AK RESPONSE TE AM - DAP DISCIPl.ltC INSTRUCTION Numben DI-M-003
Title:
Technical Adequacy Review of NCRs Revisiom _3 documentation verifying the acceptability of nonconforming items which have the disposition of repair or use as is.-
A description of the change, waiver or deviation that has been 1
accepted shall be documented to record the change and denote the as-built condition.
j 3
3.1.2 Scrap Disposition i
j Assigned when it is determined that an item is unsuitable for its intended purpose and cannot be feasibly or economically reworked or repaired.
3.1.3 Rework Disposition 1
Assigned when actions are required to correct the nonconforming conditions and bring the affected items into compliance with the specified design requirements.
3.1.4 Repair Disposition n
Assigned when actions are required to repair the nonconforming V
conditions to an acceptable
- state, not necessarily in compliance with the existing design.
Repair dispositions shall include apprc9riate technical justification for acceptance of the it em with characteristics that do not comply with the specified design requirements.
3.1.5 Use-As-Is Disposition Assigned when sufficient technical ju::tification can be established such that the nonconforming characteristics do not result in adverse conditions, and when the affected item will continue to meet all functional requirements including performance, maintainability, fit, and safety.
3.2 Responsibilities 3.2.1 Reviewer The Reviewers are responsible for performing a technical adequacy review of selected NCRs in accordance with this instruction.
Page 2 of 12
4 COMANCHE PE AK RESPONSE iE AM - DAP DISCIPLitE INSTRUCTION Numbers DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 3 3.2.2 Program Reviewer The Program Reviewer is responsible for performing an evaluation of the training and procedural modifications instituted as a result of programmatic weaknesses identified by the Project during a review of the technical adequacy of NCR dispositions The Program Reviewer will evaluate the new NCR procedures e.g., NEO 3.05,
" Reporting and Control of Nonconformances" and the content of the training program to determine if programmatic weaknesses have been adequately addressed.
3.2.3 Group Leader The Group Leader is responsible for implementing this instruction.
This includes providing training for the reviewers, evaluating reviewer comments, facilitating document transfer, and summarizing review results.
3.2.4 Discipline Coordinator O.
The Mechanical Discipline Coordinator, or his designee, is
~ l responsible.for reviewing this instruction, recommending its approval to the DAP Manager, and approving the resulting engineering evaluations.
3.2.5 DAP Manager The DAP Manager is responsible for approval of this Q instruction.
4.0 INS 1RUCTION 4.1 Proiect NCR Review The Project NCR Review Team randomly selected 300 NCRs and subjected them to as many as three levels of review, depending upon the effort required to determine adequacy the third level required a determination of safety significant (e).
This NCR technical adequacy review will include a.ninimum of 10% of the Project's sample, with selection based upon an engineering review of the sample NCRs.
Page 3 of 12 0
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i hb.'.tANCHE PEAK RESPONSE TE AM - DAP DISCIPLitE INSTRU l
Nueer: DI.M.003
Title:
Technical tidequacy Review of NCRs Revisiom 3 The Group Leader, or his designee, will select at least 30 NCRs from the sample of 300.
These will then be sorted according to the responsible discipline in preparation for the Ib technical adequacy review. Obtaining a reasonable number of NCRs from each discipline will be considered by the Group Leader in the NCR selection process. Additional NCRs may be selected if necessary so that a reasonable number of NCRs from each discipline can be subjected to review.
The technical adequacy review will be conducted by a team of engineers with at least one representative from each of the following disciplines: Mechanical, Electrical /I&C, Civil / lG A
Structural, and Pising.
The review will be considered a I
preliminary review aased on the Project's decision to include the 300 sample NCRs in the NCR verification effort conducted under SWEC Project Procedure PP-041, "Nonconformance Evaluation Procedure."
gd Reviewers will evaluate each NCR and the Project's assessment of the NCR using an NCR Review Worksheet for initial q
documentation purposes. The Reviewer will fill out the NCR V
Review Worksheet (Attachments A and B) for each NCR evaluated, recording the :NCR number in the spcce in item 1 on the worksheet. The second item on the worksheet asks the Reviewer to determine if the NCR adequately describes the nonconforming condition.
The third item on the worksheet asks the Reviewer to determine if the disposition provided on the NCR fully addresses the statement of nonconformance.
This check is not of technical adequacy but determines if the disposition accounts for each nonconforming item identified on the NCR, and if the disposition is a complete solution. The fourth item calls for the Reviewer to assess the technical adequacy of the NCR disposition, independent of the assessment made by the Project NCR Review Team. The first part of item 5 asks the Reviewer to record the Project's technical adequacy conclusion shown on the Project "NCR Evaluation Worksheet").(as 4
If the Project NCR Review Team concurred with the NCR disposition, the Reviewer can proceed to item 6 on the i
Worksheet.
Otherwise, the Reviewer should evaluate the supplemental documentation cases, etc.) supplied by the (e.g.,
calculations, ASME code Project NCR Review Team used in making an adequacy determination.
Any discrepancies Page 4 of 12 l
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COMANCHE PE AK RESPOt4E 'fE AM - DAP DISCIPLiff itGTRUCTION Number D2-M-003
Title:
Technical Adequacy Review of NCRs Revision: 3 identified b the Reviewer in evaluating the Project NCR Review Team'ys adequacy assessment shall be documented on the IA Worksheet.
IL3_\\
After reviewing the NCR and any supporting documentation assembled by the Project NCR Review Team, the Reviewer should state whether or not he/she concurs with the adequacy determination made by the Project NCR Review Team (i.e.,
is the nonconformance resolved?).
The basis for the Reviewer's decision should be
- cited, usin Continuation Sheet") as needed. g Attachment B
Reviewer ("Worksheet If the disagrees with the final disposition reached by the Project NCR Review Team, this shall be recorded on the Worksheet.
Upon completion, the Reviewer will sign the Worksheet, attach any continuation sheets and the NCR package, and return this to the Group Leader. Also, any discrepancies identified by the Reviewer will be brought to the attention of the Group Leader.
The NCR technical adequacy review may draw upon the criteria lists developed as part of the previous Design Adequacy Program effort to assess compliance with design requirements.
(
)
If any of the selected samples include a Project Safety Significance determination, the Project's definition for safety significance i.e.,
reviewers to assess a(dequacy.10 CFR 50.55(e)) will be used by d Upon completion of the initial review, the Group Leader will decide if a reasonable assurance 4
conclusion can be drawn regarding the adequacy of the Project's NCR review effort.
If not, additional NCRs within the Project's sample population may be selected for review, up to a complete review of the 300 NCRs.
Upon completion of the Project NCR Review, each Reviewer will retrieve their NCR Review Worksheets from the Group Leader, and summarize results on Attachment C, the NCR Review Record.
After signing the NCR Review Record, Reviewers will return it, along with other review documentation, to the Group Leader.
[d 4.2 Review of Procedure and Trainino Procram This phase of the NCR technical adequacy review will evaluate lb both the NCR training program instituted as a result of the findings of the Project's NCR review as well as the procedural I
Page 5 of 12
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COMANCHE PE AK RESPONSE TE AM - DAP DISCIPLitE INSTRUCTION i
Number DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 3 modifications made in light of these same findings.
The Program Reviewer will conduct this review in accordance with this section.
The Program Reviewer will evaluate the Project's NCR training ld program to assess its adequacy in addressing programmatic weaknesses related to the technical adequacy of NCR dispositions previously identified in Project or third-party evaluations. The Program Reviewer will first collect and review these evaluations of the historical CPSES NCR programs for findings to the technical adequacy of NCR dispositions. pertaining Sources include:
1
- 1. Project report related to the resolution of Project 1
Corrective Action Report (CAR) number 62.
- 2. CPRT ISAP VII.a.2 Results Report, "Nonconformance and Corrective Action Systems."
- 3. Findings resulting from Section 4.1 of this instruction.
,O Th4s review wili be decemented ex 14stins the decements 4
reviewed along with the prograrunatic weaknesses identified in each document.
The content of the Project NCR training program will then be evaluated to determine if the identified programmatic weaknesses have been addressed. Documentation of this evaluation may be appended to the listing discussed above.
In addition to assessing the training program, the Program Reviewer will evaluate new Project procedures for NCRs Nonconformances"(e.g.,
NE0 3.05,
" Reporting and Control of
) to determine if the programmatic weaknesses related to the technical adequacy of NCR dispositions have been adequately addressed.
Documentation of t11s step of the review can also i
be appended to the listing discussed above.
ld Upon completion of this review, the Program Reviewer will summarize his findings in an Engineering Evaluation using the lA i
requirements of DAP-8 as a guide.
The evaluation will include E d.B as an attachment the listing containing the programmatic weaknesses identified in the documents reviewed by the Program j
Page 6 of 12 l
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N&rs DI.M.003
Title:
Technical Adequacy Review of NCRs Revisiom 3 Reviewer, as well as the results of his evaluation of the training program and new procedure in addressing these weaknesses.
4.3 Overview of Proiect NCR Procram As a result of the conclusions reached by the Project from the Project NCR review CPSES has committed to technical adequacy r,eview of all previously issued NCRs. conducting a The Project has defined their review effort within the SWEC Project Procedure PP-041, Rev. O, "Nonconformance Evaluation Procedure." This procedure describes four distinct tasks to be completed by the Project, each to be overviewed by DAP:
- 1. Screening Review--Identifies those NCRs which require a technical review.
- 2. Technical Review--Evaluates the technical adequacy of those NCRs passing the screening review.
dr^
- 3. NCR Revision and Deportability Assessment--NCR dispositions determined to be technically inadequate will be revised and, if necessary, a deportability assn.sment will be made.
- 4. NEO 3.05 Surveillance Review--kCRs issued under the new arocedure will be subject to surveillance on a periodic
) asis to assest technical adequacy.
Revisions made to the Project procedure during the course of the overview will be addressed as described in Section 4.3.5.
4.3.1 Screening Review The objective of the DAP overview of the Project's screening effort will be to establish reasonable assurance that NCRs that require a technical justification (i.e.,
use-as-is or repair dispositions) enter the Technical Review phase described in PP-041.
The Group Leader, or designee, will select completed lBg screenings from the NCR Evaluation Screening Log (see PP-041, Attachment PP-041-A) and assign them to the Reviewers.
In l
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O COMANCHE PEAK RESPONSE TEAM - DAP DISCIPLitE INSTRUCTION Numbers. D].M.003
Title:
Technical Adequacy Review of NCRs Revisiom 3 making his selection, the Group Leader will consider factors which include the discipline affected by the NCR and when the NCR was evaluated by the Project. The overview will focus on A
those NCRs that have not been recommended for a technical review.
A minimum of 1,000 NCRs which have not been recommended for the technical review will be selected and evaluated.
The Reviewer will retrieve the selected NCRs (from the Project O NCR Review Team or CPSES records center and evaluate the Project's decision to exclude those NCRs )from the technical review. As a minimum, NCRs which have a use-as-is or repair disposition should be included in the Project technical review.
This evaluation will be documented using Attachment D,
the Screening Review Record.
As indicated on this Attachment, the Reviewer will record the NCR numbers from the NCR Evaluation Screening Log which he/she has identified as not being advanced to the technical review. The Reviewer will also record the affected engineering discipline [ Mechanical (M), Civil / Structural (C/5), Piping (P),and Electrical /I&C Q,6
- engineer, and the last name of the Project person who lA (E/I)),the date the NCR was approved by the responsible performed the screening of the NCRs.
Em The Reviewer will then determine whether the Project's decision to not perform a technical review on the NCR in question is valid. The reviewer may wish to contact Project personnel to obtain additional information and/or clarification.
Sheuld the Reviewer disagree with the Project d
decision to not include a particular NCR in the technical review, he/she would so indicate on Attachment D and provide justification for this position.
Upon completion of a Screening Review Record, the Reviewer will sign and submit the form (along with any associated documents such as Contact Log Sheets and DIRs) to the Group Leader. When a minimum of 1,000 screening reviews have been completed by the Reviewers, the Group Leader will compile and evaluate the results. Upon completion, an interim evaluation l/.\\
report wil1 be prepared.
ElU Page 8 of 12 0
th COMANCHE PE AK RESPONSE TE AM - DAP DISCIPLitE INSTRUCTION Number: DI.M.003 Tit!c: Technical Adequacy Review of NCRs Revision: 3 1
'4.3.2 Techn'ical Review and Deportability Assessment l
Reviewers will evaluate each NCR, and the Project's assessment of technical adequacy, using the NCR Technical Review l
Worksheet (Attachment E) as a guide.
The reviewer will initiate an NCR Technical Review Worksheet for each NCR evaluated. ' Item I identifies the NCR being reviewed.
The questions of Section 2 on the Worksheet guides the Reviewer in performing an independent review of the NCR.
Item 2.a asks the reviewer to determine if the stated nonconformance is adequately described.
In doing this, the reviewer shall make a comparison of the violated document (stated on the NCR), and the description of.the nonconforming condition.
Item 2.b asks the reviewer if hiconcurs with the disposition classification (i.e., rework, repair, use-as-is or scrap).
In Item 2.c.
the reviewer will d&tcrmine if the disposition addresses all aspects of the stated nonconformance.
In this regard, the reviewer is checking to ensure that if multiple items are identified in the statement of nonconfermance, each are g
respectively addressed in the corresponding In
()
the final question of Section 2 (Item 2.d),g disposition.
the reviewer shall.
make a judgement on both' thi correctness of the disposition, and the technical adequacy.
Regarding this item, it should be emphasized that the disposition may be correct, but not necessarily adequate in that a sound basis for the disposition was not provided. The reviewer s %11 ensure that his response addresses both aspects.
Section 3 of the NCR Technical Review Worksheet is a series of questions addressing the assessment of the Project's technical review of NCRs.
Item 3.a asks if the Project reviewer agreed with the NCR disposition (i.e.,
is the NCR classification correct?)
In Item 3.b the Project reviewer evaluates the technical justification provided on the NCR and any supporting documentation, and makes a determination as to accepta sility.
The reviewer will state his/her agreement or disagreement.
If the Project reviewer was not satisfied with the technical justification and/or the supporting documentation, he/she is directed to assemble documentation necessary to support either A
the original NCR dispovtion, or the disposition ae feels is G.1 appropriate.
Item 3.c asks the reviewer if he/she concurs with the conclusions reached by the Project reviewer on this Page 9 of 12
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O ' COMANCHE PE AK RESPOtEE TE AM - DAP DISCIPU&. INSTRUCTION y
N&rs DI-M-003
Title:
Technical Adequacy Reviyu of NCRs Revision: 3 m --
item.'!!P the reviewer does not concur, he/she shall clearly
?
indicat? this on the worksheet and state his/her reasons on a
conifonation sheet.
The final item on the worksheet, Item 3.d, asks the reviewer if he/she cc,ncurs with the Project Riview Team's decision regarding the technical adequacy of the disposition.
Technically adequte implies the.
affected d
hardware, will fuifill its des'gn requirements.
If the reviewer'does not concur, he/she shall clearly indicate this on the worksheet and state his/her reasons on a continuation sheet.
The Group Leader, or designee, will select samples ?. om those
~
NCRs which have undergone the PP-041 Technical Review and assign them to the reviewers. A minimum of 60 NCRs will be selected in the first 1,000 technical reviews conducted by the d
Project. An additional 60 NCRs will be selected in each of the next two blocks of 1,000 technical reviews conducted by the Project.
Should the number of NCRs requiring a technical review be relatively small in any particular discipline, the Group Leader may decide to increase-the discipline i
n subpopulation in subsequent selections (e.g.,
instead of c15 A
Cl Electrical /I&C NCRs in the first 1,000, the Group Leader may O_\\
choose tc extena thi: to 15 Electrica?/I&C NCRs in the first 2,500).
4.3.3 NEO 3.05 Surveillance Review The reviewers will conduct a surveillance of a select sample of flCRs iciued under the new NE0 procedure to determine if programmatic weaknesses associated with the previous NCR system have been corrected.
Sixty (60) Nr.f!s that have been issued and closed since the NEO went into effect (December 22, 1986 will be selected.
The selection will contain a reasonable ) number of NCRs from each discipline affech.d by the completed NCRs.
specific review areas will be categorization of the nonconformance and Page 10 of 12
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O com^sese re Ax neSeowSe Team - o^r oiSciei irt ireTaueTios Naher: DI-M-003
Title:
Technical Adequacy Review of NCRs Revision: 3 technical justification for dispositions in the "use-as-is" and " repair" categories.
Factors to be considered are:
complete coverage of stated nnconformance o
o recurrence measures, if applicable o scope of technical justification d
The results of the evaluation of each NCR selected will be documented on the NCR Surveillance Form (Attachment G).
Reviewer comments will be numbered on the Surveillance Forms and written out on a confirmation sheet (Attachment B) to be attached to the Surveillance Form.
At the completion of the surveillance, the Group Leader will prepare an interim evaluation report.
4.3.4 Engineering Evaluation Upon conclusion of the surveillance overview Section 4.3.3), the Group Leader will coordinate the effor(see O'
ar, Engineering Evaluation using the requirements of DAP-8 as a
/L t to prepare A
guide. The evaluation will address the adequacy o' the PP-041 review tasks
'(1.e.,
Screening Review
-Technical Review / Deportability Assessment, and Surveillance Review).
s This evaluation will document the conclusion of the overview ld i
of the technical adequacy of CPSES NCR dispositions.
4.3.5 Revisions to Project Procedure The Group Leader may provide more specific direction to personnel assigned the overview of the Project NRC review in the event that there are revisions to the Project procedure (i.e., PP-041) that da not have a substantive impact on the validity of this instruction.
The Engineering Evaluation ld described in Section 4.3.4 shall discuss the impact of any such changes on the validity of the overview.
If the revisions to the Project procedure are determined to be substantive, the Discipline Coordinator will determine the need for changes to the overview program.
Prje 11 of 12
COMANCHE PE AK RESPON5E TE AM - DAP DISCIPLitE INSTR Number D].M-003
Title:
Technical Adequacy Review of NCRs Revision: 3 5.0 DOCUMENTATION 5.1 Review Worksheets The review worksheets will be retained by the Group Leader until the review results are transferred onto the Review Records and incorporated into an Engineering Evaluation.
ld 5.2 Review Records The review records will be signed by the responsible Reviewer.
Upon com Leader, pletion, the review records will be given to the Group who will include the forms in an Engineering A
Evaluation.
LL 5.3 Enoineerino Evaluations The results of the DAP review (Sections 4.2 and 4.3) using the requirements of DAP-8 as Engineering Evaluations.
a guide, will be summarized in retained as records.
The engineering Evaluations will be lLu A
O s
Page 12 of 12
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p.U ATTACHMENT A NCR Review Worksheet 1.
NCR Number 2.
Does the NCR adequately describe the nonconforming condition?
3.
Does the NCR disposition address the, stated nonconforming condition?
4.
Does the NCR disposition adequately and correctly resolve the stated nonconforming condition?
5.
O Does the Project NCR Review concur with the NCR disposition?
V If not, does supplemental documentation assembled by the Project NCR Review Team adequately support the NCR disposition (including 50.55(e) evaluations completed by the NCR Review Team)?
e lA 6.
Do you concur with the Project NCR Review Team's final disposition of the NCR?
Attachment.B as necessary)(State basis for your answer,using A
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ATTACHMENT E NCR Technical Review Worksheet 1.
NCR Number 2.
Review of historical NCR:
2.a Does the NCR adequately describe the nonconforming condition?
2.b Is the disposition classification correct?
2.c Does the NCR. disposition address all aspects of the stated nonconforming condition?
2.d Does the NCR disposition adequately and correctly O
resolve the stated nonconforming condition?
3.
Assessment of SWEC Technical Review:
3.a Does the SWEC NCR Reviewer concur with the NCR disposition?
3.b Does the SWEC NCR Reviewer concur with the technical justification and supporting documentation?
3c.
If not, does supplemental documentation assembled by the SWEC NCR Review Team adequately support either the original NCR disposition or the proposed revised disposition?
(Explain disagreements fully on continuation sheet.)
3.d Do you concur with the SWEC NCR Review Team's decision regarding technical adequacy of the' disposition (i.e.
hardware functionality)?
(Explain disagreements fully on continuation sheet.)
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