Resolution of Discrepancies

DOESTD107393

control program, the number and nature of reportable events, and deficiencies and conflicts uncovered

in using design documents.

Completeness reviews should be conducted by system or topic. For each system or topic, the full set

of extracted, verified, and validated design requirements or design basis should be collected and

evaluated as a unit. Evaluation of these sets of information is a direct precursor to DIS preparation.

Several different approaches are possible for determining the completeness of design information, as

described in Section 2.2.1.3. The technical management review is the recommended approach to

completing evaluation of the extracted information because of the breadth and depth of experience that

can be applied and because of the independence of the review from the initial extraction, verification,

and technical validation. The review process should be procedurally established, taking into

consideration any lessons learned from the initial technical management review employed for the CM

program design requirements element.

The technical management review of design requirements may begin upon the completion of the smart

search, which concentrates on the source documents most likely to contain design requirements, and

may proceed in parallel with the comprehensive search, which focuses on documents containing

design basis information and, thus, is not expected to yield many new design requirements. This review

is conducted before the design basis review so that the initial DISs can be issued and candidate design

requirements for regeneration can be determined as promptly as possible. Technical management

review of design basis information should be initiated following completion of the comprehensive

search. The processes for the design requirements and design basis reviews should be essentially the

same, even though the reviews can occur at different times.

Following the management review and completion and approval of any additional actions,, the design

information is ready for formatting and initial DIS issuance. The final validation activity, field validation,

occurs following the regeneration of critical missing design information and the preparation of DISs.

3.4 RESOLUTION OF DISCREPANCIES

The program criteria establish that a formal discrepancy resolution process should be defined and

used to support the DR program. The discrepancy resolution process interfaces with existing facility

programs, as indicated in Figure 35. Open items should be identified to expose unanswered technical

questions, concerns, and cases of missing or inaccurate information. Open items will arise from

documentation conflicts; undocumented verifications and validations; and undocumented design inputs,

constraints, calculations, and analyses. The validity of items should be confirmed; if an open item is not

valid, it should be closed.

Open items may be identified at any point in the design reconstitution process, from information

retrieval to field validation. Strong interaction is to be expected between the design information

evaluation function (i.e., verification, validation, and technical management review) and the discrepancy

resolution function, because the evaluation function concentrates on the accuracy and completeness of

the extracted design information.

Open items with safety significance should be identified as discrepancies. Preliminary safety--

significance screening of discrepancies includes an assessment of TSR, SAR, and DOE commitment

impacts. If any such impacts are identified, the discrepancy should be evaluated for operability and

reportability impacts. Safety-significant discrepancies are to be promptly transferred to existing problem

resolution programs, such as those for nonconformance reporting, to determine if any immediate action

is necessary. Existing programs are appropriate for operability and reportability reviews because they

are specifically designed to accommodate such reviews and they command the necessary experience

II-74