ML20040C909

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Compliance W/10CFR21
ML20040C909
Person / Time
Site: Satsop
Issue date: 02/27/1981
From:
WALLACE/SUPERIOR CONSTRUCTION CO.
To:
Shared Package
ML20040C890 List:
References
IOP-1.0, NUDOCS 8201290363
Download: ML20040C909 (8)


Text

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9 WALLAT/ SUER 10R, A J31hT VdfPJE lOJSTCO 72R washinnton Public' Power D3CIMtTT Ib.

TOP 1.0 Supply System TITtp: cow 11ance with locra Part 21 S0 JECT UNP ?&5

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REVISION DATA: Rev. 0 - New Procedure UNCONTROLLED FOR INFORMATION ONLY

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Y THIS DRAWING / DOCUMENT IS NOT TO EE USED FOR ANY OJAliTY EFFECT-ING ACTIVITY. MISUSE OF.THIS DR AW-ING/DOCUN>ENT SHALL CAUSE THE

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RESPONSIBLE PARTY [S] TO BE DISCl-4 PLINED AS DEEMED APPROPRIATE.

APPROVAL DkTES, SIG!MTU?ls PeV.

((0/ECT){V!AGER DATE LEVELIII" DATE~

QAI'NMGER DATE L

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Proc. No.

101 1.0 WALL.ACEE / SUPE AlO A - A loint Ventur e Page 1

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' GU ALITY AS S U A AN C E CERDEm5 PROCE D URE Revision O

W NUCLEAR FACILITIES CONSTAUCTION Date 2-25-81 Project WNP 3 & 5 t

TITLE:

COMPLIANCE WITH 10CFR PART 21 1.0 PURPOfE

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Wallace/ Superior's (U/S) policy is to assure that all segments of the Company mc fully cogniz2=t of the requirements of Title 10, Chapter 1, Code of Fedt ral Regulatic=s - Energy, Part 21, Reporting of Defects and Noncom-pliance, and that appropriate information and guidance materials 'are pro-vided to assure that all staff are aware of their responsibilities in neering the requi ements of Part 21.

2.0 S' COPE This policy applies to work efforts on facilities regulated pursuant to the Atomic Energy Act of 1954 as amended or the Energy Reorganization Act of 1974

'3.0 PROCEDURE 3.1 This procedure has been developed to meet the requirements of Part 21.

It has been established to deal with the actions required of

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employees verking at nuclear facilnie:; or on nuclear facility compc ents or dealing with procurement of components for nuclear f acilities.

It also deals with actions by W/S management lihat are recui-ed for reporting.

3.2 General

3. 2.1 Any i.ndividual, director or Eanager of W/S who obtains infor-mation reasonably indicating:
3. 2.1.1 That the facility, activity, or basic component l

supplied to such facility or activity fails to comply with the Atenic Energy Act, as amended, or any applicable rule, regulation, order, br license of the Commission relating to substantial safety hazards; or

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.r.q 3.2.1.2 That the facility, activity, or basic component supplied to such facility or activity contains defects, which could create a substantial safety hazard; and 3.2.1.3 shall notify the Cc=.ission of such failure to com-i ply or such def ect, unless he has actual 1:2owledge that the Jo=21ssion br_s been adequately informed of such defect or failure to comply.

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[W4s GUALITY ASSU AANCE D:fm PROC.EDURE

. Revision 0

NU CLEAA FACILITIES CONSTAUCTION Date 2-25-61 L.l Project W365 3.0 PROCEDURE (cont'd)

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3.3 Specific 1.;tions 3.3.1 The following applies to e=ployees remotely located at the Clearfield facility and those performing activities at the WNP 3/5 construction site and those at any location uhile performing, an activity directly related to the scope of the 232 Contract.

a 3.3.2 Any employee who obtains information that meets the require-

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ments for reporting of defects and nonco=pliance.as defined in 10CFR, Part 21, shall ir=ediately notify the appropriate, responsible W/S manager.

These managers are defined as follows:

.,. 3 3.3.2.1 For the WNP 3/5 construction site, the managers are as follows:

a.

Project Director b.

Project Manager c.

Quality Assurance Manager d.

Operations Manager e.

Construction Manager f.

Proj ect Control Manager 3.3.2.2 For the Cla.arfield facility, the canagers are the i

President of the facility ind the Quality Assurance i

Manager.

3.3.3 The responsible W/S manager vill have the e=ployee immediately fill out a written report which shall include, but need not be limited to, the following information, to the extent known:

3.3.3.1 Name and address of the reporting individual or indi-5 viduals.

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3.3.3.2 IGentification of the activity or the basic component -

Ey which fails to comply or co".tcins a defect.

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3.3.3.3 Identification of the firm constructing the component or performing the activity which f ails to comply or contains a defect.

3.3.3.4 Nature of the defect or failure to co= ply and the

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safety hazcrd which is created or could be created by such defect or failure to comply. T-23217 2 6

..~~. 3.3.3.5 The date on which the information of such defect or -*a-

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_ faildre to co: ply w^ as obtained.

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,It2U ALITY ASSU AAN CE N PROCEDURE Revision O

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' NUCLEAA 3:ACILITIES CONSTAUCTION Date 2-25-81 Proj ect WNP 3 6 5 3.0 PROCEDURE (cont'd) 3.3.3.6 In the case of a co:ponent which contain,s a defect. :

or fails to comply, the number and location of all such co=ponents in use or being supplied for the WNP 3/5 project.

3.3.3.7 The corrective action which has been, is being, or will be taken; the name of the individual or organi-

, casible for the action; and the anticipated.

zation re length of time that has been or will be taken to com-plete the action.

~ i 3.3.3,8 Any advice related to the defect or fai2ure to comply about the activity.or basic component that has been, is being, or will be given to the Owner / Engineer (0/E).

.3.4 Standard form, provided with this procedure, shall be used whenever possible.

3.4.1 The responcible manager shall i= mediately convene a committee of the reporting employee, himself, and one other W/S employee, where possible, for the purpose of evaluating the deviation.

3.4.2 If the deviation is determined to be included in the reporting require:ents of lOCEF, Part 21,. the responsible canager shall:

i 3.4.2.1 Immediately notify the W/S Proj ect Director, to whom f

he is ulticately responsible, of all actions and circumstances.

3.4.2.2 The Proj ect Director shall i= mediately notify the 0/E of the deviation in order that the 0/E may cause the deviation to, be evaluated, unless the deviation has been corrected.

3.4.3 The Project Director shall prepare a c)py of the Standard 10CFR, Part 21, Reporting Form, from information received from the

-O respcasible manager. He shall contact the following:

Sam P.

1 Wallace Company, Inc., Senier Vice President and Corporate i

Legal Counsel to notify ther of his actions.

i 3.4.4 Within two (2) days from receipt of information, a designated person shall notify the Dire ter, Office of Inspection and t

Enforcement, or the Director of the appropriate Regional office.

If the initial notification is by means other than written communication, a written r eport shall be submitted to the appropriate office within five (5) days af ter' the information is obtained.

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Proc. No.IOP 1.0

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. WALLACE / SUPERIOR - A loint Venturn Page 4

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NUCLEAR FACILITIES CONSTAU CTIOM Date 2-25-81

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, Froject WP 3 6 5 J

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3.0 PROCEDUPI (cont'di

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3.4.5 The 0/E of the WNP 3/5 project shall be nrified,of the actions of W/S.

3.5 Other Considerations 3.5.1 Each procurement for a basic component issued by W/S will specify, when applicable, that provisions of,10CFR, Part 21, apply.

3.5.2 Copies of this procedure or a reference thereto,10CFR, Part 21, and Section 206 of the Energy Reorganization Act of 1974, shall be posted at prominent locations where W/S employees

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are located.

3.6 Record Keeping 3.6.1 Records shall be prepared in connection with repertable defects or noncompliances as defined in 10CFE, Part 21,' detected during fabrication, assembly, installat'on, inspection, or testing of any basic co=ponent supplied cr to be. 'ised for the WP 3/5 pro-ject, that cre suf ficient. to shew, ampliance to 10CFR, Part 21, upon inspection by duly authorired repree.cr.tatives 'of the Nuclear Regulatory Commission.

3.6.1.1 These recotds will be slpplied to the 0/E at the j

coapleti n of the task.

3.6.1.2 1: the 0/E determines the records are not necessary for him to meet the requirements of 10CFR, Part 21, they will be destroyed.

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r-WALLACE/ SUPERIOR, - A JOINT VENTURE ~

10CFR PART 21 REPORTING FORM FOR-REPORTING OF DEFECTS & NONCOMPLIANCE -

1.

Name(s). and address (es) o'f " reporting individual (s).

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Facility or component which us under noncompliance.

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Supplying firm identification (name, add,ress).

4.

Describe the nature of the defect and the safety hazard.

5.

If a basic componcnt, number and location of all such components (strach an extra sheet or continue of' back, if necessary)..

6.

Describe the corrective action which has been, is being, or should be taken, including responsible parties and an estimate of time involved.

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10CFR Part 21 Reporting; Form for Reporting of Defects & Noncompliance Page 2 of 2 7'

Coh=ents or adviste that should be given :,, other purchases or licensees t 4

SIGNED:

DATE :

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-- NOTICE T

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~.I-10 CFR PART 21.- REPORTING OF DEFECTS AND NONCOMPLIANCE u

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~.3 It ic part of Wallace/ Superior's policies and procedures to meed com-

.I pletely the requirements of Section 206 of the Energy Reorganization l'

Act of 1974. That Section deals with reporting defects and noncom-pliance in facilities regulated pursuant to the Atomic Energy Act of g

1954, or the Energy Reorganization Act of 1974.

Briefly stated:

l "Any Vallace/ Superior employee who obtains information concerning the

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-l UN'. 3/5 project which reasonably indicates:

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(1) That the facility, activity, or any basic component is not meeting the proper requirements, or (2) That the f acility, activity, or any basic component has a j

defect,

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-1 SHALL IMMEDIATELY NOTIFY THE PROPER WALLACE/ SUPERIOR MASAGER."

1 Complete instructions, detailed procedures, and eppropriate reference material are available for review.

Please' contact the following indi '

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Q TD..j NAME-Jc j

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LOCATION.

Pii0SE SUMDER:

i UALLACE/ SUPERIOR, A JOINT VENTURE

'232} 726 P.O. BOX 575 f'

.ELMA, MASHINGTON 98541

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