ML20151U483

Advises That Encl Revised Comanche Peak Review Team (Cprt) Procedure for Classification,Evaluation & Tracking of Specific Design Const Discrepancies Identified by Cprt Delivered to Vs Noonan.Related Correspondence

ML20151U483
Person / Time
Site:	Comanche Peak
Issue date:	02/07/1986
From:	Woolridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
To:	Bloch P, Jordon W, Mccollom K Atomic Safety and Licensing Board Panel
References
CON-#186-033, CON-#186-33 OL, NUDOCS 8602110028
Download: ML20151U483 (18)

Text

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KELATED CORRESPONDENCE 03 9 WORSIIAM, FORSYTIIE, SAMPELS 8: WOOLDRIDGE TMimiv.Two MuNDRED. OOi eRvAN TOwE,0L M E i L D ROh*J"AI".'OOLOR DOE DAW.As. Tr.xAS 75201 ,,,,$,",*,"*"

NEIL O. AN DERSON SPENCER C. RELTEA RONALD M. MANSON TELEPHONE (1 sale 79 3OOQq J. DAN BOM ANNAN CU gj s I -

or COUNSEL JOS. lRION WORSHAM TRAVIS E. VANDERPOOL EARL A. FOR$VTHE JUDaTM M.JOMNSON RfCM ARD L. ADAMS DAvio C.LONERGAN GFF l. . T E LEcOPiER1ri A> seO. OQie JOMN W. MC REYNOLDS THOMAS F. LILLARD

{Q[K{ f ROBERTm.wsSE "

TIMOTMY A.M ACK wM. STEPH EN SOYD MARKR.WASEM CMRISTOPMER R. MtLTEN BERO ER ROBERT P. OLivCR p.4R A SCMWART1 RCHARD G. MOORE NA CTEt..ETMuRE" CECELIA J. BRUN ER February 7,1986 JOE A. DAveS EnsC M. PETERSON Peter B. Bloch, Esq. Dr. Kenneth A. McCollom Chairman Dean Atomic Safety and Licensing Board Division of Engineering, U.S. Nuclear Regulatory Commission Architecture and Technology Washington, D.C. 20555 Oklahoma State University Stillwater, Oklahoma 74074 Dr. Walter H. Jordan 881 West Outer Drive Elizabeth B. Johnson Oak Ridge, Tennessee 34830 Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 34830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50-445 and 50-446dL--

Dear Administrative Judges:

Applicants have this date delivered to Mr. Vincent S. Noonan Appendix E, entitled "CPRT Procedure for the Classification, Evaluation and Tracking of Specific Design or Construction Discrepancies identified by CPRT," developed by .

the Comanche Peak Response Team.

As a part of our continuing effort to keep the Board apprised of matters which relate to the licensing of Comanche Peak, we are enclosing four copies of such revision. This revision is not being offered into evidence at this time, and is provided for information only.

Respectively, ,.

lIfj fjMf'

/

9602110000 860207 ' '/

PDR ADOCK OGOOOA45 G PDR N Robert A. Wooldrid e RAW /kiw Enclosures cc: Ser vice List

\ 303

SERVICE LIST Mr. Peter B. Bloch, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom Dean, Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074 Elizabeth B. Johnson Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Mrs. Juanita Ellis President, CASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks, Esq.

Assistant Attorney General Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 Nicholas S. Reynolds, Esq.

William A. Horin, Esq.

Bishop, Liberman, Cook, Purcell & Reynolds

~1200 Seventeenth Street, N.W.

Suite 700 Washington, D.C. 20036 Mr. W. G. Counsil

. Executive Vice President Texas Utilities Generating Company Skyway Tower,25th Floor 400 N. Olive Street Dallas, Texas 75201 Mr. Thomas G. Dignan, Jr.

Mr. R. . Gad, III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Mr. Roy P. Lessy, Jr.

Morgan, Lewis & Bockius 1800 M Street, N.W.

Washington, D.C. 20036 4

. .l -A Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission

- 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

' Lanny A. Sinkin Christie Institute 1324 North Capitol Street Washington, D.C. 20002 Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. William L. Clements Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stuart A. Treby, Esq.

' Office of the Executive Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

. Chairman Atomic Safety and Licensing Appeal Panel

. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Ellen Ginsberg, Esq.

U.S. Nuclear Regulatory Commission 4350 East / West Highway,4th Floor' Bethesda, Maryland 20814 Billie Pirner Garde Citizens Clinic Director

' Government Accountability Project 1555 Connecticut Avenue, N.W.

Suite 202 Washington, D.C. 20036 Nancy Williams Cygna Energy Services, Inc.

101 California Street Seite 1000 San Francisco, California 94111 David R. Pigot Orrick, Herrington & Sutcliffe 600 Montgomery Street

. San Francisco, California 94111 Mr. Shannon Phillips Resident inspector Comanche Peak SES c/o U.S. Nuclear Regulatory Commission P. O. Box 38

{ Glen Dnea_ Tavse 74nh1

~

Anthony Roisman, Esq.

Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W., Suite 611 Washington, D.C. 20036 Joseph Gallo, Esq.

Isham, Lincoln & Beale 1120 Connecticut Ave., N.W.

Suite 840 Washington, D.C. 20036 7

TXX-4695-q CORRES @ D M gg .

File No. 10068 TEXAS UTILITIES GENERATING COMPANY axvwar rowen . 4oo xonin ouvn =rnerT, s..n. ai uau.4 , rmx4= ,seon CQk)[., >-

February 7, 1986 yggcougg '86 FEB 10 mo:26 CFFM .

00ChU m - J11 CPRT-236 Bute Mr. Vincent S. Noonan-Director, Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20599

SUBJECT:

Comanche Peak Steam Electric Station Submittal of Appendix E of the Comanche Peak Response Team (CPRT)

Program Plan

Dear Mr. Noonan:

Transmitted herewith is Revision 1 of Appendix E "CPRT Procedure for the Classification, Evaluation, and Tracking of Specific Design or Construction Discrepancies Identified by the CPRT" of the CPRT Program. Plan. Recipients are asked to insert this Appendix after the tab " Appendix E Classifi-cation Discrepancies" which was. included in our submittal of Revision 3 of the Program Plan on January 27, 1986.

We still intend to submit the~ testing issue-specific action plans by March 1. Should you have any questions please do not hesitate to call either John Beck or myself.

Yours very truly, l

W. G. Counsil

'WGC:tj Enclosure A IslVENinN ED9' TEXAN l'TILITIEn KLECTMit' COMi'ANY

ED CORRNE

,g R. vision: 1. ,

, Page 1 of 13

') APPENDIX E f

Q DOCKErre CPRT PROCEDURE FOR THE CLASSIFICATION AND 'NNPC EVALUATION OF SPECIFIC DESIGN OR CONSTRUCTION DISCREPANCIES IDENTIFIED BY THE cpg Y I0. [A0 Qfi A. PURPOSE f, The purposes of this procedure are to:

- Provide' criteria for classifying discrepancies, and

- Establish a process and criteria for evaluating discrepancies.

The classification and evaluation processes described in this Appendix were primarily developed and designed to address design and construction discrepancies identified by the CPRT during the .

implementation of the ISAPs and DSAPs developed for the CPRT self-initiated investigatory efforts. In order to ensure consistency throughout the CPRT program, similar processes will also be applied in the reporting of the results of the CPRT investigatory efforts for ISAPs and portions of DSA?s that were.

n developed to respond to concerns specifically identified by

(. External Sources.

Additional information related to the development, approval and documentation of corrective actions for all deviations or deficiencies (both specific and programmatic) identified by the CPRT is provided in Appendix H to the CPRT Program Plan.

B. CLASSIFICATION The following definitions have been established for use in classifying and evaluating identified discrepancies. t'

l. DESIGN ADEQUACY All design discrepancies'are classified as observations, deviations or deficiencies, depending upon whether the design error resulted in a failure to meet design criteria and depending on the safety significanca of any failures to meet design criteria. The definitions employed in this area by the CPRT are as follows:

(a) Design Discrepancy

Any identified error related to design inputs, implementing documents and outputs for safety-related

\ structures, systems or components that could have an adverse impact on the adequacy of their design.

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R1 vision: 1

-. Page 2 of 13

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APPENDIX E (Cont'd)

B. CLASSIFICATION (Cont'd)

(b) Design Observation Any identified design discrepancy that has been determined to not constitute a design deviation. l (c) Design Deviation Any identified design discrepancy.that has been determined to constitute a verified failure to meet a design commitment or specification. In this regard, design commitments include regulatory requirements, FSAR commitments, other licensing commitments, code commitments or other project-specific design criteria or commitments. .

(d) Design Deficiency Any identified design deviation that has been determined to be safety-significant.

.D' Q (e) Safety-Significant

" Safety 7significant", for purposes of the CPRT Program , is defined to mean that the identified discrepancy, if uncorrected, would result in the loss of capability of the affected system, structure or component to perform its intended safety function. For purposes of the CPRT Program, credit is not allowed for redundancy at the component, system, train or structure level.

(f) Programmatic Design Deficiency A set of related design discrepancies that have been determined to constitute an adverse trend that is-progra:nmatic in nature.

This definition, which is employed in the CPRT Program for purposes of sample expansion, is more restrictive than that usually applied to the term " safety-significant" for regulatory purposes or in common parlance, in that it ignores redundancies that do exist in real' life. [ Compare 10CFR50, Appendix A (Introduction, " Single Failure"); 10CFR50.55(e)(1) . ] Identification of a deficiency as O " safety-significant" for purposes of the CPRT Program, therefore, b is not equivalent to a statement that, in fact, the deficiency, if uncorrected, would have resulted in unsafe operation.

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. .Page 3 of 13 m

/ i APPENDIX E (Cont'd)

B. CLASSIFICATION (Cont'd)

2. CONSTRUCTION ADEQUACY All construction discrepancies are classified either as deviations or deficiencies, depend'ing upon the safety significance of the discrepancy. The definitions employed by the CPRT in this area are as follows:

(a) Construction Deviation Any identified error related to construction or installation of safety-related hardware that has been determined to constitute a verified failure to construct or install a safety-related structure, system or component in accordance with safety-significant .

attributes and criteria contained in design drawings and specifications or installation procedures /

requirements.

(b) Construction Deficiency

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'qj .Any identified construction deviation that has been determined to be safety-significant.

(c) Safety-Significant See B.I.(e) and associated footnote for definition. l (d) Programmatic Construction Deficiency A set of related construction deviations that has been determined to constitute an adverse trend that is programmatic in nature.

3. TESTING PROGRAM ADEQUACY All testing discrepancies are classified either as deviations or deficiencies, depending upon the significance of the discrepancy. The definitions employed by the CPRT in this area are as follows:

(a) Testing Deviation Any verified failure to meet a testing program commitment, regulatary requirement or a project specific testing comliitment. In this regard, (gL') commitments include FSAR commitments.and other licensing commitmente.

1 Rsvision: 1 4

Page 4 of 13 l

APPENDIX E

()k N,_ (Cont'd)

B. CLASSIFICATION (Cont'd)

(b) Testing Deficiency Any identified testing deviation that is determined to have resulted in a failure to meet a testing program objective such that retesting is required to demonstrate that the affected structure, system or component is capable of performing its intended safety function.

(c) Programmatic Testing Deficiency A set of related testing deviations that has been determined to constitute an adverse trend that is programmatic in nature. ..

4. QA/QC PROGRAM ADEQUACY All QA/QC Program discrepancies are classified either as deviations or deficiencies, depending upon the significance of

,s) the discrepancy. The definitions employed by the CPRT in this area are as follows:

%J (a) QA/QC Program Deviation Any verified failure of the QA/QC Program to meet regulatory requirements (i.e., 10CFR50 Appendix B),

FSAR commitments or other licensing commitments.

(b) QA/QC Program Deficiency Any identified QA/QC Program deviation that is determined to have resulted in a failure that is reportable in accordance with 10CFR50.55(e).

(c) Programmatic QA/QC Program Deficiency A set of related QA/QC deviations that has been determined to constitute an adverse trend that is programmatic in nature.

C. EVALUATION PROCESS

1. DESIGN ADEQUACY

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The decision logic used in the evaluation of identified design discrepancies is as follows:

e' Rsvicion: 1

,. Page 5 of 13 j APPENDIX E

\s,/ (Cont'd)

C. EVALUATION PROCESS (Cont'd)

(a) Design Observations Each design discrepancy that is determined not to constitute a verified failure to meet a design commitment or specification will be classified as a design ~ observation.

The evaluation of each design observation will be considered to be complete when the basis for the above-mentioned determination is documented.

-Design observations and design deviations will be collectively evaluated for the purpose of identifying adverse trends. (See Section 5 below.) .

(b) Design Deviations l

~

Each design discrepancy that is determined to constitute a verified failure to meet a design f- s commitment or specification will be evaluated further L( ) -

for safety significance. If it is determined that such a discrepancy is not safety-significant, it will be classified as a design deviation.

The evaluation of each design deviation will be considered to be complete when:

The CPRT has determined-(to the extent required by Appen' dix H) that appropriate corrective action has been accomplished for the nonconformance associated with the design deviation (i.e., hardware changes, approval for an exemption or deviation from the commitment or requirement from the governing-body, or both); and The bases for the above-mentioned determinations have been documented.

Design observations and design deviations will be collectively evaluated'for the purpose of identifying adverse trends. (See Section 5 below.)

(c) Design Deficiencies

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m Each design deviation that is determined to constitute a safety-significant failure to meet a design commitment or specification will be classified as a design deficiency.

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, Pags 6 of 13 APPENDIX E

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L(,,/ (Cont'd)

C. EVALUATION PROCESS (Cont'd)

The evaluation of each design deficiency will be considered to be complete when:

The root cause and/or contributing causes for the deficiency have been identified; The generic implications of the deficiency have been evaluated. This evaluation must be of sufficient scope to provide reasonable assurance that there are no remaining undetected deficiencies within the affected area, population, or stratum; The CPRT has determined.(to the extent ,

required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the design deficiency; and gs -

The bases for the above-mentioned f j' ~ determinations have been documented.

Any additional discrepancies that may be identified as a result of the above-mentioned generic implications evaluation will each be classified and dispositioned in accordance with this Appendix. In addition, the associated set of such discrepancies will be further evaluated for commonalities that may be indicative of an adverse trend. (See Section 5 below.)

(d) Programmatic Design Deficiency The evaluation of each programmatic design deficiency will be considered to be complete when the required ,

actions set forth in Section 5 for identified adverse trends have been completed.

I

2. CONSTRUCTION ADEQUACY (a) Construction Deviations i Each verified failure to meet a design or installation I

specification will be evaluated further for safety significance. If it is determined that such a

/"'T deviation is not safety-significant~, it will be j (m,/. classified as a construction deviation.

L _ _ . . _

R2 vision: 1

, , Pags 7 of 13 l 7 #~N~ APPENDIX E (s_,I (Cont'd)

C. EVALUATION PROCESS (Cont'd)

The evaluation of each construction deviation will be considered to be complete when:

l I

The CPRT has determined (to the extent required by Appendix H) that appropriate corrective a'ction has been accomplished for the nonconformance associated with the construction deviation (i.e., hardware changes); and the bases for the above-mentioned determinations have been documented.

Construction deviations will be collectively evaluated ,

for the purpose of identifying adverse trends.-(See Section 5 below.)

(b) Construction Deficiencies

.f--( Each safety-significant failure to meet a design or j ~) installation specification will be classified as a construction deficiency and will be evaluated further for root cause and generic implications.

The evaluation of each construction deficiency will be considered to be complete when:

The root cause and/or contributing causes for the deficiency have been' identified; The generic implication of the deficiency have been evaluated. This evaluation must be of sufficient scope to provide reasonable assurance that there are no remaining undetected deficiencies within the affected area, population, or stratum; The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for l' the nonconformance associated with the construction deficiency; and The bases for the above-mentioned determinations are documented.

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4 Rsvision: 1 t

v ,

Page 8 of 13

(('

APPENDIX E (Cont'd) j C. EVALUATION PROCESS (Cont'd)

Any additional deviations that may be identified as a result of the above-mentioned generic implications evaluation will each be classified'and dispositioned in-accordance with this. Appendix. In addition, the ,

associated set of such deviations will be further evaluated for commonalities that may be indicative of -

an adverse trend. (See Section 5 below.). ,

(c) . Programmatic Construction Deficiency The evaluation of each programmatic construction deficiency will be considered to be complete when the

, required actions set forth in Section 5 for identified i . adverse trends have been complete. .

3. TESTING PROGRAM ADEQUACY

, (a) Testing Deviation Each verified failure to meet a testing program commitment, regulatory requirement or a projtet

<- specific commitment will be classified as a testing l deviation. The deviation will be evaluated to i determine whether it resulted in a failure to meet a testing program objective such that retesting is required to demonstrate that the affected structure,

system or component is capable of performing its intended safety function.

' The evaluation of each testing deviation will be considered to be complete when:

The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the testing deviation (i.e., retesting, approval for an exemption or deviation from the commitment or requirement from the governing

, body, lor both); and 1

The bases for the above-mentioned

, determinations have been documented.

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RIvision -l' Pags 9.of 13

! (T . APPENDIX E

\/ (Cont'd)

C. EVALUATION PROCESS (Cont'd)

Testing deviations will be collectively evaluated for the purpose of identifying adverse trends. (See Section 5 below.)

(b) Testing Deficiency-Each testing deviation that is determined to have.

resulted in a failure to meet a testing program objective such that retesting is required to demonstrate that the affected structure, system or component is capable of performing its intended safety function will be classified as a testing deficiency.

1 . .

The evaluation of each testing deficiency will be ,

considered to complete when:

The root cause and/or contributing causes for

• the deficiency have been identified;

.fs The generic implications of the deficiency

.(') have been evaluated. This evaluation must be of sufficient scope to provide reasonable assurance that there are no remaining undetected deficiencies within the affected 4 area, population, or stratum; The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated with the testing deficiency; and The bases for the above-mentioned determinations are d.ocumented.

Any additional deviations that may be identified as a-results of the above-mentioned generic implications evaluation will each be classified and dispositioned in accordance with this Appendix. In addition, the associated set of such deviations will be further evaluated for commonalities'that may be indicative of an adverse trend. (See Section 5 below.).

(c) Programmatic Testing Deficiency

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The evaluation of each programmatic testing deficiency will be considered to be complete when the required actions set forth in Section 5 for identified adverse

,- trends have been completed.

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t Rsvision: 1-Page 10 of 13 APPENDIX E

('\_-'} (Cont'd)

C. EVALUATION PROCESS (Cont'd)

4. QA/QC PROGRAM ADEQUACY (a) QA/QC Program Deviation Any. verified failure of the QA/QC Program to meet regulatory requirements, FSAR commitments or other licensing commitments will be evaluated for reportability in accordance with 10CFR50.55(e). If it is determined that such a failure.is not reportable, it will classified as a QA/QC Program deviation.

The evaluation of each QA/QC Program deviation will be considered to be ccmplete when:

The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for ,

the nonconformance associated with the QA/QC Program deviation (i.e., program changes, f- s approval for an exemption or deviation from

(

) the commitment or requirement from the governing body, or both); and The bases for the above-mentioned determinations ~have been documented.

QA/QC Program deviations will be collectively evaluated for the purpose of identifying adverse trends. (See Section 5 below.)

(b) QA/QC Program Deficiency Each QA/QC Program discrepancy that determined to be reportable in accordance with 10CFR50.55(e) will be classified as a QA/QC Program deficiency.

The evaluation of each QA/QC Program deficiency will be considered to complete when:

- The root cause and/or contributing causes for the deficiency have been identified; The generic implications of the deficiency have been evaluated. This evaluation must be of sufficient scope to provide reasonable

['N assurance that there are no remaining

\_s undetected deficiencies within the affected area, population, or stratum; 9

Rsvision 1 g- Page 11 of 13 APPENDIX E 5

(Cont'd)

C.- EVALUATION ~ PROCESS (Cont'd)

The CPRT has determined (to the extent required by Appendix H) that appropriate corrective action has been accomplished for the nonconformance associated'with the QA/QC Program deficiency; and The bases for the above-mentioned determinations are documented.

Any additional deviations that may be identified as a result of the above-mentioned generic implications evaluation will each be classified and dispositioned in accordance with this Appendix. In addition, the associated set of such deviations will be further .

evaluated for commonalities that may be indicative of an adverse trend. (See Section 5 below.)

(c) Programmatic QA/QC Program Deficiency-The evaluation of each programmatic QA/QC Program O- deficiency will be considered to be complete when the required actions set forth in Section 5 for identified adverse trends have been completed.

5. ADVERSE TRENDS A trend is a set of related discrepancies (observations and/or deviations) having attributes that reflect a discernible commonality. Examples of possible commonalities include:

The individual, group of individuals or organization performing the safety-related activity; and The program requirements, procedures or controls governing the performance of the safety-related activity.

A trend is considered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected' safety-significant deficiency in the affected area . population or stratum.

Adverse trends are also referred to as programmatic deficiencies.

O Each trend identified by the CPRT will be evaluated to determine whether it is adverse. CPRT Review Team Leaders are responsible for performing such evaluations and for making such determinations within their areas of responsibility.

Rivision 1

<o Page 12 of 13

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-V APPENDIX E (Cont'd)

C. EVALUATION PROCESS (Cont'd)

The nature and extent of these evaluations will vary depending upon the nature of the identified trend and the information already available regarding the implications of the trend.

Considerations in this regard include the extent to which:

- The boundaries of the trend have been identified;

- The underlying cause and/or contributing causes of the trend have been identified; The area, population or stratum affected by the trend has been investigated; The potential safety significance of the trend has been identified; and .

- Corrective action has already been taken to address the trend.

The results of these evaluations will be documented and retained in the CPRT working files.

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\

If an adverse trend is determined to exist, the following actions are required:

- The root cause and/or contributing causes must be assessed;

- The generic implications of the trend must be evaluated. This evaluation must be of sufficient scope to provide reasonable assurance that there are no remaining undetected deficiencies within the affected area, population or stratum;

- Appropriate corrective actions for any additional deviations or deficiencies identified during the evaluation of generic implications must be defined; and Appropriate corrective action to preclude recurrence in

, the future must be defined.

The results of these activities will be documented and retained in the CPRT working files.

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,; .Paga 13 of 13

/~ APPENDIX E (s_,)/ - (Cont'd)

C. EVALUATION PROCESS (Cont'd)

.6. SPECIAL CASES As indicated above, unless an adverse trend is identified, root cause and generic implications evaluations will not be performed for individual design deviations or construction deviations. It is recognized, however, that special cases may be identified where a-root cause and generic implications assessment'are warranted for certain individual construction or design deviations.

Review Team Leaders are responsible for identifying any such potential special cases to the Senior Review Team. The Senior Review Team in conjunction with the Review Team Leader will determine what additional action is required in such cases. >

Such determinations, including the associated bases, will be ,

documented and retained in the CPRT working files.

7. UNCLASSIFIED DEVIATIONS As noted in the Program Plan (e.g., Program Plan, Section

/

( ~s) IV(A), p.14), it may be determined that it is more practical or expeditious, with respect to a given deviation or set of '

deviations, to proceed directly to analysis of root cause and generic implications and to specification of corrective actions. Where such a determination has been made, performing a safety significance evaluation in respect of the unclassified deviation (s) would aerve no purpose and will not be done. Such unclassified deviations will be. tracked as deficiencies for purposes of root cause and generic implications analysis and for the purpose of corrective actions.

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