ML20050B611
| ML20050B611 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/08/1981 |
| From: | TELEDYNE ENGINEERING SERVICES |
| To: | |
| Shared Package | |
| ML20050B607 | List: |
| References | |
| TEP-1-004, TEP-1-4, NUDOCS 8204060128 | |
| Download: ML20050B611 (11) | |
Text
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f UNCONTROLLED COPY ATTACHMENT A TES TECHNICAL ENGINEERING PROCEDURE TEP-1-004 REPORTING 0F 10 CFR 21 0FFENSES WTELEDYNE ENGINEERING SERVICES 130 SECOND AVENUE WALTHAM, MASSACHUSETTS 02254 617-890-3350 hok l
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1.0 SCOPE This procedure provides the method for the investigating, anal-ysis, review and reporting of possible defects or noncompli-ances as defined by 10 CFR 21 for NRC-Licensed nuclear power facilities for which TES is performing work.
2.0 APPLICATION 2.1 This procedure applies to the following instances:
l (a) possible existence of a safety hazard that may violate the Atomic Energy Act, Atomic Reorganization Act, or any ap-plicable rule, regulation, order, or license of the Nuc-lear Regulatory Commission (NRC), or l
(b) possible existence of a defect that may create a safety hazard as defined by NRC regulations.
2.2 The following documents formed the basis for this procedure:
Title 10, Part 21 Reporting of Defects and Code of Federal Noncompliance Regulations 2/81
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TES Policy Reporting of Safety-Related No. 4.13 Defects and Noncompliance in NRC-l.icensed Facilities 2.3 The following terms and definitions apply:
(a) Reporting Person - the TES employee who identifies the possible defect or noncompliance (b) Project Manager - the TES employee who is responsible for the management of the project for which the possible defect or noncompliance is reported (c) Review Committee - a committee, as a minimum composed of the Manager of Engineering Analysis, a TES Consulting i
Engineer, and a member of the TES staff with applicable expertise, assigned the task of evaluating reported de-fects or noncompliances (d)
Defect or Noncompliance Form (DNF) -
the form used for recording and reporting a possible defect or noncompliance (Enclosure (1))
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(e) Responsible Officers - TES President and Senior Vice Pres-ident l
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SECTION 2.4 The following personnel responsibilities apply:
(a) Reporting Person - preparation and submittal of the DNF (b) Project Manager _- responding within the first twenty-four (24) hours to the Reporting Person and forwarding DNF to Manager of Engineering Analysis when possible defect or noncompliance exists (c) Manager of Engineering Analysis - convenirg and chairing a Review Committee within twenty-four (24) hours when a DNF is forwarded reflecting a possible defect or noncompliance exists; reporting of results of Review Committee action to the Project Manager, to the Reporting Person, and, if the defect or noncompliance is suspect, to the Responsible Officers in writing within twenty-four (24) hours after the Review Committee has completed the required evaluation and preparation of report (d) Responsible Officer - final evaluation of Review Commit-I tee actions, if the defect or noncompliance is suspected; reporting of defect or noncompliance to NRC, if deemed necessary, verbally within forty-eight (48) hours after receipt of the written report from the Review Committee o-esp.
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and in writing within five (5) working days from receipt of the report.
(e) Manager, Quality Assurance - assuring that the time re-
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quirements of this procedure are met; assuring that the records and reports are 1:: sued as required.
m 3.0 METHOD 3.1 Initial Re;:orting Any person employed by TES who believes that a possible defect or noncompliance as defined by 10CFR Part 21 exists on work being performed by TES'shall report this to the responsible Project Manager using the form in Enclosure (1).
An informa-tion copy of this form shall go to the QA Manager and the
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Manager of Engineering Analysis.
T-3.2 Project Manager Response 3
3.?.1 The Project Manager must respond in twenty-four (24) hours, l~
using the DNF.
This response can be in two forms:
(1) the possible defect or noncompliance is not reportable and po fur-ther action will be taken by the Project Manager, or (2) the Project Manager agrees that the possible defect or ncncompli-ance could be reportable under Part 21 and the DNF with his
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coments will be forwarded to the Quality Assurance Manager and the Manager of Engineering Analysis.
3.2.2 If the Reporting Person does not concur with the Project Mana-ger's finding that the reported defect or noncompliance is not reportable to the NRC, the Reporting Person shall annotate his copy of the DNF with any additional supporting information and forward it to the Manager of Engineering Analysis for further review.
3.3 Engineering Review 3.3.1 When a possible defect or noncompliance is reported to the Manager of Engineering Analysis by the Project Manager or Re-porting Person, he shall establish a Review Committee within twenty-four (24) hours.
The Review Committee shall determine i
whether the possible defect or deviation should be categorized as a suspected defect or suspected noncompliance, as defined in 10CFR Part 21, or categorized as not being suspect.
3.3.2 Within 5 working days the Review Committee shall prepare a written report which includes a summary of their findings. The report and referenced documents shall be sufficiently detailed to allow independent review and shall comply with Section 3.6 of the TES QAM.
Copies of the report shall be transmitted to O
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the Project Manager, the Reporting Person, and, if the nas,1ble defect or noncompliance is suspect, to both Responsih P ffi-Cers.
3.4 Reporting to NRC 3.4.1 Upon receipt of the Review Comnittee report, a Responsible Of-ficer shall make the final evaluation as to whether or not the y
condition is reportable under 10CFR Part 21.
3.4.2 When a Responsible Officer determines that a suspected defect or nonccmpliance is reportable, the report to the NRC shall be made verbally within forty-eight (48) hours and in writing within five (5) days.
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3.5 Enclosure (2) is a flowchart that depicts the method to be followed.
1 4.0 RECORDS The report and copies of all referenced documents shall become controlled documents as defined by the TES Quality Assurance Manual.
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Enclosure (1)
Defect or Noncompliance Form O
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'itTELEU(NE ENGINEERING SERVICES UNCONTROLLED COPY Report of Possible Defects or fioncompliance as Defined by 10CFR Part 21 Date Person Preparing Report TES Project fiumber Client Project Manager Project QAE fluclear Facility /Fac'ilities Involved Description of Possible Defect or fiancompliance:
Signature cc:
Q.A. Manager Manager of Engineering Analysis Project Manager Response:
Date Signature cc:
QA Manager Manager of Engineering Analysis 3/81
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Enclosure (2)
Flow Chart 4
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j TES FLOW CHART i,i UNCONTROLLED COPY y
->feporting Person ;q
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Q.A. Manager y (DNF
,4 Agree l
Yes "> Stop 9
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Project Manager Mgr.
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24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> r
No Sus ert No i
r Yes 5
h y
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Manager, Engineering Analysis ;<.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Form Review Com;aittee f
5 working days 3r Prepare Report i
i Legend l
l Decision NO l
Stopl#
Suspect Solid line = action
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Dashed = information l
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1 Yes j
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j-TES President and g
Senior Vice President
',i 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Decision Verbal Written Stop <.-
fio ReportabTe Yes -+ Report to
>keportt R
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NRC NRC 5
days