ML20236N975

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Rev 0 to Design Adequacy Procedure Discipline Instruction DI-PM-001, Trending & Root Cause Evaluations
ML20236N975
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/03/1987
From:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20236N530 List: ... further results
References
DI-PM-001, DI-PM-1, NUDOCS 8708120175
Download: ML20236N975 (25)


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Rev. 0:.

April'6, 1987

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PROJECT MANAGEMENT /MULTIDISCIPLINE INSTRUCTIONS

-Table of contents Instruction No.

Title Revision Date DI-FM-001 Trending and Root Cause o

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Trending and Root,Cause Evaluations NUMBER 2 DI-PM-001 Revision Prepared Date Reviewed Date -

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COMANCHE PEAK RESPONSE TE AM - DAP DISCIPLitE INSTRUCTION 0-Nemse<= 01-en-001 Titie: Treme4ne ene Root Ceese Evelue14 ems sevisiee:o

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1 TABLE OF CONTENTS Section Paae Cover Sheet......................

i Table of. Contents...................

11

'l.0 PURPOSE....................

1 2.0 SCOPE 1

3.0 DEFINITIONS AND RESPONSIBILITIES 2

4.0-INSTRUCTION 3

5.0 DOCUMENTATION 9

Attachments

.O-A.

Trending and Root Cause Evaluation Flowchart.

A-1 B.

Trend Identification Codes..........

B-1 through B-3 C.

Completion of DAP Form 7-1A C-1 through C-4 D.

Root Cause Codes...............

D-1 through D-3 E.

Format and Content for Trending E-1 through E-2 Engineering Evaluation Reports O

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COMANCHE PE AK RESPONSE TE AM - DAP DISCIPLitE INSTRUCTION l

b-Number:

DI-PM-001

Title:

Trending and Root Cause Evaluations Revision:0 i

l l

1.0 PURPOSE I

J The purpose of this instruction is to supplement and i

amplify the requirements of Design Adequacy Program (DAP) procedure DAP-7, " Trending and Generic Implications Evaluations," by providing detailed, working-level directions for trending and root cause evaluations.

This instruction is not intended to conflict with any DAP-7 requirements; DAP 7 is the governing procedure should any conflicts be identified.

This instruction provides the direction necessary to identify trends and postulate root causes for the issues identified during the DAP review.

The focus of this effort will be in identifying programmatic root causes

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and improvement areas for the Texas Utilities (TV)

Electric Company. Contractor discrepancies will only be evaluated for root causes where it is apparent that a programmatic utility improvement ma'y prevent recurrence of the discrepancies.

2.0 SCOPE This is a Project Management /Multidiscipline Instruction (PM) applicable to all DAP self-initiated activities and Disciplines for the performance of the subject activity.

l This instruction applies to Discrepancy / Issue Resolution Reports (DIRs) which are types "D,"

"T," "R,"

and "E."

"C" type DIRs are outside the scope of this instruction.

Unsubstantiated discrepancies will not be trended or evaluated for root cause. Type "T" DIRs will only be O

Page I of 9

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COMANCHE PE AK RESPONSE TE AM - DAP DISCIPLitE INSTRUCTION

' Number:

DI.pg.001

Title:

Trending and Root Cause Evaluations Revision: 0 used by the Programmatic and Generic Implications (PGI)

Discipline to assess.multidiscipline trends.

3.0 DEFINITIONS'AND RESPONSIBILITIES

3.1 Definitions

See Section 3.1 of DAP-7 3.2 Responsibilities 3.2.1 Discioline Coordinators l

The Discipline Coordinators (or designees) are responsible for performing the following:

O-1 1.

Assigning personnel to perform trend identification j

and root cause evaluations.

2.

Approving DAP Forms 7-1A and Engineering Evaluation Reports (EERs) which are generated in accordance with this instruction.

3.

Notifying the PGI Discipline Coordinator of any new trend categories, trend descriptions, and postulated root causes, as identified.

O I

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COMANCHE PE AK RESPONSE TE AM - DAP DISCIPLitt INSTRUCTION Number:

DI-PM-001

Title:

Trending and Root Cause Evaluations Revision:0 3'. 2. 2 -

PGI Coordinator The PGI Coordinator (or designee) is responsible for performing the following:

1.

Assigning identification codes to any new identified trend categories, trend descriptions and postulated root causes.

2.

Establishing and maintaining the trend and root cause data base.

3.2.3 DAP Reviewers The DAP Reviewers are responsible for the following:

1.

Performing trend identification and root cause evaluations.

2.

Preparing DAP Forms 7-1A and EERs.

3.

Informing the Discipline Coordinator of any new potential trend categories, trend descriptions or postulated root causes which are identified.

l 4.0 INSTRUCTION The overall process of trend identification and root cause I

evaluation will be performed as shown in Attachment A (Trending and Root Cause Evaluation Flow Chart).

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COMANCHE PE AK RESPONSE TE AM - DAP DISCIPLitt INSTRUCTION Nurnber: DI-FM-001

Title:

Trending and Root Cause Evaluations Revision: 0 4.1 Trend Identification

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4.1.1 General i

The initial list of trend categories and trend descriptions (Attachment B) has been developed through a I

multidiscipline effort.

The actual descriptions of the conditions and the Design Activities described on the DIRs were used as a basis. While the list is intended to incorporate known trend descriptions, trends are not limited to the items on Attachment B.

Additional trend O..

categories and descriptions may be added as they are ideatified-4.1. 2.

Trend Ccde Assianment Process DAP Reviewers will review each DIR generated within a specific Discipline. Where several duplicate or related issues have been consolidated into one primary issue (in accordance with DAP-2, " Documentation and Tracking of Issues and Discrepancies") only the primary DIRs need be reviewed.

Each issue documented on a DIR will be assigned a document type (1 - Calculation, 2 - Drawing, 3 - Speci-fication, or 4 - Other), and at least one Trend Category and trend description using Attachment B.

For example, when a specification is not in compliance with the SAR, the appropriate trend identification code is 3.A.I.

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i COMANCHE PEAK RESPONSE TEAM - DAP DISCIPLitE INSTRUCTION O

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Dt-m-x1 we Tren44ng ene aoot Ceuse eve,uetions a visie":o When the document in question is a Vendor Document, it will be assigned the document type code'of the design document requiring the vendor submittal.

(For example, where a DIR documents a problem with vendor drawing submittals that were required by a specification, the appropriate. document type is 3 - Specification.)

If the DIR topic is a Design Change Authorization (DCA), it is identified with the document type code which is the I

cubject of the DCA.

When two or more different issues are identified on a DIR, the DIR will be assigned a document type, trend category and trend description for each issue identified. Multiple examples of the same issue on one DIR will be assigned only one trend identification code identifier for that 1

issue.

Trend Category H ("0ther") is assigned to DIRs when the issue documented on the DIR cannot be categorized in any of the other available trend categories.

When the trend code assignment process is complete within any Discipline, the DAP Reviewers shall evaluate the DIRs assigned to Trend Category H for any discernable commonality and recommend new Trend Categories be established (reference Section 4.1.3) as appropriate.

The designated trend identification code will be entered in the PGI data base.

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COMANCHE PE AK RESPONSE TE AM. DAP DISCIPLitE INSTRUCTION Number:

DI.pM. col

Title:

Trending and Root Cause Evaluations Revision:0 4.1.3.

Identification of New Trend Cateaories or Descriptions l

New Trend Categories or descriptions will be approved by the Discipline Coordinator and assigned a trend identification code identifier by the PGI Coordinator or his designee. The PGI Coordinator / designee shall incorporate the new code into this instruction by revision or addendum (in accordance with DAP-10, " Development and Use of DAP Procedures and Discipline Instructions").

4.1.4 Trend Identification Process

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DAP Rev.iewers will review and evaluate the distribution of DIRs for each trend identification code.

Based on the number and nature of DIRs assigned to each trend identification code, the DAP Reviewer will determine whether a trend exists.

Both the number and the nature of the DIRs assigned shall be considered.

4.1.5 Documenting Trends A Trend Evaluation Form (DAP Form 7-1A) will be generated for each of the Trend Categories by each Discipline.

Attachment C of this instruction provides detailed instructions for completing the form.

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COMANCHE PE AK RESPONSE TE AM - DAP DISCIPLitE INSTRUCTION Numbers - DI-PM-001

Title:

Trending and Root Cause Evaluations Revision:0 1

4.2 Root Cause Evaluation 4.2.1 General 1

i The list of postulated root.causes (Attachment D) was developed from known types of root causes which have been identified in the nuclear industry. Additional root causes may be added to Attachment D as they are identified.

Root cause evaluations may be performed concurrently with the trend identification process detailed in Section 4.1 0

4.2.2 Root Cause Identification Process l

DAP Reviewers will review each trend identified within the Discipline (Section 4.1.4) and assign one or more postulated root causes (from the list in Attachment D) to each of the associated DIRs. The assignment should be J

specific, however, if the specific root cause cannot be identified, then the general root cause should be recorded.

(For example, the code "P0" should be assigned if the postulated root cause is procedural inadequacies, and a more specific determination cannot be made.)

The postulated root cause code (s) for each DIR comprising a trend shall be entered into the PGI data base. Root cause codes need not be assigned to DIRs which do not constitute a trend.

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' COMANCHE PEAK RESPONSE TEAM - DAP DISCIPLitE INSTRUCTION

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1rene4n, ano Root Cause Eva,uat4 ens R isioe:o 4.2.3 Identification of New Root Causes New postulated root causes will be approved by the Discipline Coordinator and assigned a root cause code identifier by the PGI Coordinator or his designee.

The PGI Coordinator / designee shall incorporate the new code into thiS instruction by revision or addendum (in accordance with DAP-10).

4.2.4 Documenting Root Causefs)

Postulated root causes will be documented on the DAP Form 7-1A generated per Section 4.1.5.

Root causes will be identified for each of the DIRs documented on the Form.

4.3 Multidiscipline Trending and Root Cause Evaluations 4.3.1 Multidiscioline Trend Identification The PGI Group will review the Trend Evaluation Forms prepared by the other Disciplines and identify multidiscioline trends; i.e., trends clearly appearing in more than one discipline that indicate that the root cause evaluations should be integrated and evaluated at a multidiscipline level. The results of the evaluation will be documented on an EER in accordance with Section 5.0.

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1 COMANCHE PEAK RESPONSE TEAM - DAP DISCIPLitE INSTRUCTION O

Number:

DI.PM-001

Title:

Trending and Root Cause Evaluations Revision:0 i

l 4.3.2 Multidiscioline Root Cause Evaluation For each multidiscipline trend identified in Section 4.3.1, the PGI Group will postulate one or more multidiscipline root causes, using the list in Attachment D.

4.3.3 Documenting Multidiscioline Trends and Root Causes The PGI Group will generate one DAP form 7-1A for each Trend Category to document multidiscipline trends and postulated root causes.

Q 5.0 DOCUMENTATION Trends and root causes will be documented in accordance with Sections 4.1.5 and 4.2.4, respectively. One EER will be prepared by each Discipline to summarize the results of the trending and root cause evaluation process within that Discipline.

The PGI Group shall prepare one EER to summarize the results of the multidiscipline trending and root cause evaluation process.

The EERs shall be prepared in accordance with DAP-8,

" Preparation of Engineering Evaluations," as clarified by Attachment E, " Format and Content for Trending Engineering Evaluation Reports."

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DI-PM-001 Revision 0 Attachment A

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ATTACHMENT A TRENDING AND ROOT CAUSE EVALUATION FLOW CHART l

P, E, M, C/S: DOCUMENT DIRs, USE DESIGN ACTIVITY DATA BASE TO IDENTIFY PRELIMINARY LIST. OF TRENDS.'

IDENTIFY PRELIMINARY LIST OF ROOT CAUSES I

P, E, M. C/S: EVALUATE "D", *R", AND *E" DIRs FOR TRENDS i

i r P, E, M, C/S: INITIATE DAP FORM 71A i

(ONE FOR EACH TREND CATEGORY) 4 P. E, M, C/S: DOCUMENT IDENTIFIED TRENDS ON DAP FORM 71A ENTER TRENDS IN PGl DATA BASE h

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PGI: EVALUATE P E, M C/S: IDENTIFY ROOT MULTlDISCIPLINE TRENDS CAUSES FOR ALL DIRs THAT (INCLUDE "P' DIRs)

COMPRISE TRENDS A

l PGl: EVALUATE COMMON ROOT P, E, M C/S: DOCUMENT

' CAUSES FOR IDENDRED ROOT CAUSES MULTIDISCIPLINE TRENDS ON DAP FORM 71A, ENTER h

ROOT CAUSES IN PGl CATA E'ASE PGl: DOCUMENT MULTI.

DISCIPLINE TRENDS AND ROOT CAUSES ON DAP FORM 71A P, E, M, C/S: PREPARE DISCIPLINE EER ON IDENTIFIED TRENDS, ROOT PGl: PREPARE EER ON CAUSES AND "NO TRENDS" e MULTIDISCIPLINE TRENDS AND ROOT CAUSES-e REPETITIVE ROOT CAUSES P = PIPING e "NO TRENDS" E - ELECTRICAL M = MECHANICAL C/S - CIVIL / STRUCTURAL A-1

DI-PM-001 Revision 0 Attachment B

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ATTACHMENT B q

TREND IDENTIFICATION CODES A. Inadeauate Control of Desian Inouts or lesian Outout Documents 1.

Conflicts exist between design documents and SAR.

2.

Design document is not in compliance with applicable code / standard /

regulatory requirement.

3.

Design documents differ from data supplied by manufacturer.

4.

Design documents do not contain required information to assure compliance with design.

5.

Conflicts exist with other design documents (i.e., drawings, calculations, specifications) or standard references.

6.

Design documents do not meet design criteria.

7.

Design documents do not reference applicable code / standard / regulatory requirements.

O 8.

Design documents reference incorrect source of input (includes wrong revision).

9.

Design documents have uncontrolled or undocumented source.

B. Desian Verification Was Inadeauate 1.

Design verification lacking in original design.

2.

Design verification lacking for design changes.

3.

Process of final load verification was inadequate or was not performed.

4.

Verification did not identify errors.

C. Document Control Was inadeauate For Documents Controlling the Desian Process or Containina Desian Information 1.

Use of unapproved procedures.

2.

Document not reviewed and/or approved.

3.

Control of document (e.g., issue control, unavailable calculations, revision control, superseded document control, etc.) not as required or not available, such that document is incomplete, untraceable, or irretrievable.

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B-1

DI-PM-001 Revision 0 Attachment B

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4.

Document does'not comply with established preparation and control requirements.

5.

Error in the FSAR.

D. Desian Chances were Inadequately Controlled 1.

Design requirement changes (test results, new/ revised commitments, etc.) did not result in appropriate design changes.

2.

Corrective action resulting from identified design errors has not been performed.

3.

Inadequate justification for design change authorization.

4.

Changes have not been incorporated into all affected design documents.

5.

No review and approval is available for changes to documents.

6.

Issue control and distribution of DCAs are not as required.

E. Inadeouate Control or~ Reconciliation Between Desian Requirements and Vendor Documents 1.

Specification does not address documentation required to be submitted

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by vendor.

2.

Document submitted by the vendor is not consistent with the design commitments.

3.

Vendor document required to be submitted for review and. approval has not been reviewed and approved.

4.

Vendor document required by specification is not available.

5.

Vendor document contains unresolved comments.

6.

No documentation to substantiate that the equipment qualified is the same as supplied.

7.

TNE/G&H vendor document control not in compliance with 10CFR50, Appendix B.

F. Errors Were Made in the Process of Performino Desian Activities 1.

Assumptions incorrect /not verified / inappropriate / oversimplified /

unjustified.

2.

Methodology incorrect (i.e., wrong formulas, inappropriate use of computer code, modeling error, etc.).

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'l DI-PM 001.-

Revision 0 i

Attachment B C'

.3.

Human errors (e.g., typo, transposition of data, mathematical, drafting).

l 4.

Design. process.is not performed or incomplete.

5.

Inconsistencies exist within a document or a design process.

6.

Design documentation does not contain necessary-information to reconstruct the process or verify compliance of process.

7.

Document shows equipment in locations'not consistent with design commitments.

8.

Document omitted, equipment required by design requirements.

9.

Document shows equipment different than what is required by design.

10.

Incorrect procedure used or referenced for performing design process.

11.. Objective / output purpose not stated.

12.

Computer code (lack of documentation or verification).

13. Administrative processing error (e.g., missing signatures / revision numbers).

O o te eeou te co"tro' or oes4a" '" terr ces 1.

Internal (to discipline) interface failure (design inputs / outputs

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improperly communicated /used).

2.

Internal (to A/E organization) interface failure (design inputs / outputs improperly communicated /used).

3.

External interface failure (design inputs / outputs improperly communicated /used).

H. Q.thgr 1.

DIRs which identify items that can not be categorized in A, B, C, D, E, F, or G, above.

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B-3

DI-PM-001 Revision 0 Attachment C V.

ATTACHMENT C COMPLETION OF DAP FORM 7-IA The trends identified will be documented on Form 7-1A, " Trend Evaluation."

The numbers have been assigned to the applicable blocks of the attached example Form for clarification. The unique Form number (Block 10) will be assigned as detailed in DAP-7.

o Block No. 1

" Attribute or Technical Issue Trended" Enter the title of the Trend Category identified.

For example, Inputs / Outputs, Design Verification, etc.

o Block No. 2 "Other Attributes Selected (constrained)"

Next to the applicable utributes, enter the appropriate information.

For example, next to " Discipline," enter Electrical / Instrumentation and Control, This is to identify the constraints within the Trend Category identified. The only line required to be filled in is

" Discipline."

o Block No. 3 " Number of DIRs in this Subset" Q

Enter number of DIRs identified in the Trend Category.

Block No. 4 "Name of Each Subattribute in Trendgd o

Attribute./No. of DIRs/DIR Nos."

This block will identify (1) each Trend Description code within the Trend Category, (2) the DIRs assigned to each description code, (3) whether or not the number and nature of DIRs constitute a trend, and (4) for each identified trend, who the responsible design organization was (TUGC0 or OTHER).

Justification shall be provided where DIRs are allocated to a particular trend identification code, but no trend is identified (e.g., insufficient number of DIRs having reasonable discernable commonality are assigned).

This information may be attached on a separate page as necessary and referenced in Block No. 4.

o Block No. 5 " Trend Description" Provide a summary description of the trends identified within the applicable Trend Category.

If no trend was identified, within the Trend Category, Block No. 5 should be noted "No Trend."

Sub-block Within Block No. 5 C-1

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4 DI-PM-001 Revision 0 Attachment C v

The sub-block is divided into six (6) statements to be checked "yes" or "no" as applicable.

l I.

Trend Identified-If a trend is identified, check "yes" and continue completing the information as applicable in the sub-block.

If no trend is identified, check "no" and go to Block No. 6.

l 2.

Deviation Included-If one or more DIRs addressed by the form is identified as a deviation, check the "yes" column.

3.

Additional Reviews Required-If additional reviews are requirec to identify a trend which may exist within the identified DIRs, check the "yes" column.

If no additional reviews are required, check the "no" column.

4.

Additional Reviews Completed-If additional reviews are required,

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indicate when they are completed by checking the "yes" column and describe the additional reviews on an attachment.

If no additional reviews are required, mark the column "N/A."

l 5.

Discipline Specific-Check the "yes" co~umn for technical disciplines and "no" for the PGI discipline.

p 6.

Multidisciplinary-Check the "no" column for technical d

disciplines and "yes" for the PGI discipline.

o Block No. 6-

"Procrams Affected" Enter the progrsms, processes, procedures, work' activities or other programmatic aspects that are potentially associated with thi trends.

o Block Naa 7, '" Potential for Safety-Sianificent deficiency" a

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Enter "not required" (N/R) urless a Safety Significant Evaluation has beer.f performed (in accordance with DAP-22) to substantiate that the s

trend does not have a potentici for Safety Signific.]nt Deficiencies.

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If m Safety Significant EvaluatMon> has been performed, eater "See

., Attacid6 Evaluation" and attach the evaluation performed id ac:ordance with DAP-22.

o Blqr): No. 8-

"Descripti6n Ud Bases of Evaluation" L

Listithepostulatedrohtcande(s)foreachDIRwithineachidentified trend.

Provide:the frequ w.) of occurrence of root cw ses for each trend.

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L o, Block No', 9-

" Conclusion" If a Safety Significant Evaluation has been performed, mark either

" Adverse Trend" or, "Nonadverse Trend" as indicated by the.results of the Safety Significant Evaluation.

If n'o Safety.Significant Evaluation has been performed and a trend has been. identified, mark " Unclassified."-

If no trend has been identified, mark "No Trend."

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DI-PM-001 Revision 0 Attachment C j

Evolvation Number: DAP-TE-1 COMANCtf PEAK ADEQUACY PROGRAM Rev:

l TREND EVALUATION Number of Sheeis:

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.O (DAP Form 7-1A)

DAP Discipline:

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TREND EVALUATION - LEVEL 11 Attribute or Technical Issue Trended:

Date:

Other Attributes Selected (constrained). List as appropriate:

Discipline Classification Generic Implication

(

Design Organization Status Problem

)

Des;gn Activity Type Review Topic Activity Attribute Sofety Significance HDA S rstem/5 tructure/ Comp.

Root Covee DlR Nos.

Number of DIRs in This Subset:

Ncme of Eoch Subottribute in Trended Attribute / No. of DIRs / DIR Nos.

TREND DESCRIPTION g

Dcte:

O Yes No TreM fdentif;ed Oeviction included A dditionel Reviews Regvited Aceitional Reviews Completed (Describe In A ttachment)

Discipline Soecific Y wit; disc IDlinofy TREND EVALUATION h

Programs Affected:

Octe:

Potential for Sofety-Significant Deficiency:

Description and Bases of Evolvation:

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Conclusion:==

D Advers trene Ovn=2...ir4.e tr.no O won.ever.. Trena O x. trens b

Prepored Br/ Dote

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DAP Monoger/ Dote

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Discipline Coordinator /Date

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Approved Br RTL/ Dote

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DC-87-48 g,4 l

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DI-PM-001 Revision 0 Attachment D O

ROOT CAUSE CODES SQQE

. DESCRIPTION' P0 Procedures P1 Ambiguous P2 Incorrect Application P3 Incomplete P4 Missed Technical Requirements-P5 Misunderstood Regulatory Requirements P6 Missed Regulatory Requirements P7 Inadequate Review for Requirements / Commitments P8

.0ut of Date P9 Nonexistent PL1 Contradictory Procedures PL2 Conflicting Technical Requirements PL3 No Configuration Control System 10 Procedure Implementation 11 Inconsistent 12 Error-in Judgment 13 Knowing Violation 14 Unknown Violation

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15 Inadequate Review that Req. Met.

16' Simple Mistake 17 Procedure Requirement not Understood 18 Inadequate Input Information 19 Wrong Codes / Standards Used IEl Disregarded Procedure i

IE2 Failed to get Inputs l

CO Communications Cl Failure Within Group C2 Failure Between Groups-C3 Inadequate Between Companies

- A0 Inspection / Audit Al Inadequate Checklists A2 Inadequate Training / Qualification A3 Inadequate Surveillance of Inspections A4 Inadequate Analysis of Findings

'i A5 Inadequate Distribution of Findings A6 Not Done A7 Excessive Deferral / Backlog I

I O.

D-1

DI-PM-001 Revision 0 Attachment.D Ol I

ROOT CAUSE CODES (2Q{

DESCRIPTIO3 TO Timeliness TI Inadequate Time. allowed for Task i

T2 Insufficient Engineering Done q

T3 Inadequate to Check Changes Against Requirements / Commitments T4 Untimely Incorporation-of Change's -in Requirements / Commitments T5 Failure:to Incorporate Changes in Requirements / Commitments.

. T6 -

Untimely Audits / Inspections T7 Severe Schedule Pressure D0 Documentation DI Failure to Demonstrate Compliance D2 Inadequate Access to Information D3-Illegible D4 Missing ry D5 Incomplete L (_/

D6 Misfiled D7 Inaccurate D8 Ambiguous D9 Not Reviewed and/or Approved 00 Training / Qualification Q1'

' Inadequate for Tasks Performed Q2 Nonexistent Q3 Failure to Retrain After Errors Q4 Inadequate Qualification Standards Q5 Lack of Experience Q6 Lack of Training Q7 Lack of Education X0 Transfer of Information XI Correct Information Used Improperly l

X2 Incorrect Information Transferred j

X3' Improper Interface X4 Nonexistent Interface X5 Information Not Transferred O

D-2 A

DI-PM-001 Revision 0 Attachment D g..O.

ROOT CAUSE CODES QQQg DESCRIPTION Xb Correct Information Not Used X7 Incorrect' Information Used Improperly K

Planned Management Risk V

Post-Inspection / Turnover Controls F0 Corrective Action F1 Failure to Recognize. Program Breakdown F2 Failure to Identify Root Caus.e F3 Failure to-Prevent Recurrence F4 Failure to Trend F5 Failure to Recognize Recurrence F6 Inadequate to Correct Problem F7 Not Implemented M0 Management Attention M1 Lack of Goals / Objectives M2 Lack of Interest / Indifference M3 Inadequate for Trends

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M4 Inadequate Staffing M5 Failure to Supervise M6-Inadequate Analysis of Findings M7 Lack of Performance / Effectiveness Measure M8 Inadequate Policy for Performance of Work M9 Failure to Implement Policies MN1 Failure to Assess Policies MN2 No Feedback on Policies-MN3 No Action on Feedback Received MN4 Oversite R

Random Error (Root Cause Indeterminate)

B0 Design Basis B1 No Design Basis. Document Generated O

D-3

DI-PM-001 Revision 0 Attachment E h'

ATTACHMENT E FORMAT AND CONTENT FOR TRENDING ENGINEERING EVALUATION REPORTS DAP-8, " Preparation of Engineering Evaluations," provides instructions for the format and content of EERs.

DAP-8 also includes provisions for alternate formats / content for particular types of EERs. This instruction implements.

those DAP-8 provisions.

The trending EERs generated in accordance with Section 5.0 will include, as a minimum, the following elements:

1. Cover Paae-A format similar to DAP-8,. Attachment A shall be used. A brief statement of the purpose and scope shall be included. The Table of Contents block shall list the key elements of the EER, as described below.
2. Abstract-The abstract shall be a one to two page summary of the EER.

Each paragraph of the abstract should address one of the major EER sections.

3. Main Body-The main body of the EER shall be comprised of the following:

Background-The background section should. discuss the overall DAP a.

review process; including, especially, the process for identifying

'h' and documenting design discrepancies. Associated Comanche Peak Response Team Program Plan commitments for trending and root cause evaluations should also be described.

b.

Methodology-This section shall discuss the process for trending and root cause evaluations including:

o assigning trend identification codes to DIRs, o

evaluating the number and nature of DIRs for each trend code and identifying trends, determining postulated root causes for those DIRs that comprise o

trends, documenting identified trends (and "no trends") and postulated o

root causes on DAP Forms 7-1A, and o

capturing information in the PGI trending and root cause data base.

The PGI EER on multidiscipline trends shall also address the process used to identify these trends and their associated postulated root Causes.

E-1 1

i

DI-PM-001 Revision 0 Attachment E

/]

Findin's-This section shall describe the findinas of the trending.

c.

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\\-

and root cause evaluation process. This shall include:

a description of trends which were identified in the Discipline,

.o and how these trends were distributed among the Trend Categories, a discussion of DIRs which were assigned to a particular, trend o

identification code but (because of the number and nature of the DIRs) were not identified as a trend, a discussion of the frequency of occurrence of root cause codes o

within each identified trend, and any other findings which became apparent during the trending / root o

.cause evaluation process and may be of benefit to Texas Utilities Electric Company.

The PGI, multidiscipline EER shall describe all the multidiscipline trends which were identified and their associated postulated root causes.

d.

Conclusions-This section shall ' provide the conclusions of the trending / root cause evaluation process.

The emphasis of this section should be in providing conclusions which are useful to TV and will allow them to eliminate identified root

/'

- causes (and thereby prevent recurrence of the patterns of discrepancies identified during the DAP review).

4. Attachments-A copy of all DAP Forms 7-1A generated by the Discipline shall be attached. Other attachments / appendices should be attached if they provide information that supports or clarifies the EER.

The mechanisms for EER numbering, logging, review, approval, revision, and retention shall be in accordance with DAP-8.

4 E-2

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TITE: Documentation of the Bases for Selection of Systems, Scructures, Components, and Documents for. Review b

NUMBER:

DI-EIC-002 Revision Prepared Date Reviewed Date Approved Date Y

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1 UNCONT!i0iiED f-UE ![l[$jl]nTjQJj Qjyj,,y r V 699

~ I COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE /m Documentation of the Bases for Selection Number: DI-EIC-002

Title:

of Systems, Structures, Components, Revision: 0 and Documents for Review l TABLE OF CONTENTS SECTION PAGE C OV E R S HE E T....................................... 1 T ABLE O F C O NTE NTS................................ 11 1.0 PURPOSE............................................ I 2.0 SCOPE.............................................. I, t 3.0 DEFINITIONS AND RESPONSIBILITIES.................. 1 4.0 I NST RU CT I O N....................................... 2 S.0 D O C U ME NT ATI O N.................................... 4 Page ii of 4 (3 V

i 1 l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Documentation of the Bases for Selection { Number:DI-EIC-002

Title:

of Systems, Structures, Components, Revision: 0 and Documents for Review 1.0 PURPOSE This discipline instruction defines the requirements for documentation of the bases for selection of systems, structures, components, or.d documents for review. 2.0 SCOPE This discipline instruction supplements the instructions contained in DAP-21 and hence has the some scope. 3.0 DEFINITIONS AND RESPONSIBILITIES bv 3.1 Definitions None. 3.2 Responsibilities 3.2.1 D'iscipline Coordinator The Discipline Coordinator or his designee shall ensure that the bases for selection of systems, structures, components, and documents for review are documented in accordance with this discipline instruction and shall review and approve the bases for selection. Poge 1 of 4 l O t

l O COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Documentation of the Bases for Number: DI-EIC-002

Title:

Selection of Systems, Structures, Revision: 0 Components, and Documents for Review 3.2.2 Reviewers - Reviewers shall prepare bases for selection documentation in accordance with this discipline instruction and DAP-21. 1 4.0 INSTRUCTION 4.1 Determination of Populations for Systems and Structures Relative to Attachment C of DAP-21, for those Homogeneous Design Activities (HDAs) whose Primary Selection Basis was "Other," the Reviewer shall define the total population of systems and/or structures that are selectable for review and shall document in on engineering evoluotion how that population was determined. 4.2 Determination of Populations for Components and Documents Relative to Attachment D of DAP-21, for components or documents which are not " unique" per DAP-21, the Reviewer shall define the total population of components and/or documents that are selectable for review and shall docu-j ment in on engineering evoluotion how that populo. ion was determined. 1 I J Pope 2 of 4 OV

COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Documentation of the Bases for- \\ Number: DI-EIC- 002

Title:

Selection of Systems, Structures, Revision: 0 Components, and Documents for Review ^3 Bases for Selection The Reviewer shall explain in on engineering evaluation the bases for selections made from the populations defined in Section 4.! and Section 4.2. The explanation shall include a brief discussion of each Secondary Selection Factor for Attachment C of DAP-21 and of each Selection Factor for Attachment D of DAP-21. Attachments C and D shall be completed by each Reviewer to summarize the selections made and shall be attached to the engineering evaluation. The Reviewer shall factor into the selection process input, where appropriate, from the current revision of the opplicable CPRT DAP Action Plan (specific selection commitments, etc.) and from the current revision of the oppi,1 cable discipline Phase 3 Scope Validation engineering evaluation (HDA numbers and descriptions, organizations, documents, etc.). For any selection that is determined to be " arbitrary" per DAP-21, the Reviewer shall explain in the engineering evoluotion why no significant differ-ences exist among the items available for selection and why any selection serves as an equally valid test of the Homogeneous Design Activity. Comments may be entered in the " Comments" column of Attachments C or D, or the Reviewer may refer to the engineering evaluation for comments. Pope 3 of 4

COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l I Documentation of the Bases for Number: DI-EIC-002

Title:

Selection of Systems, Structures, Revision: O Components, and Documents for Review 5.0 DOCUMENTATION Each Reviewer shall document the total population and the bases for selection of systems, structures, components, and documents for review in an engineering evaluation per DAP-8, except that only the following is required to be included: o Cover Sheet with Purpose, Scope, and Contents completed; o Reference Documents identified; Population Determinations per Sections 4.1 and 4.2; o Bases for Selection discussion per Section 4.3; o DAP-21 Attachments C and D completed. o i j Poge 4 of 4 O !}}