ML20076G252

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Rev 1 to ATP-9-Q, 10CFR21-Procedure for Reporting of Defects & Noncompliance
ML20076G252
Person / Time
Site: Midland
Issue date: 05/26/1983
From:
MARK G. JONES ENGINEERING CONSULTANTS, INC.
To:
Shared Package
ML20076G013 List:
References
ATP-9-Q, NUDOCS 8306140592
Download: ML20076G252 (7)
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Q 4 10CFR21 - PROCEDURE FOR REPORTING 5' k. OF DEFECTS AND NONCOMPLIANCE Y

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ATP-9-Q Revision 1 Page 2 of 7 TABLE OF REVISIONS

  • Revision 0, Date April 15, 1983 Original Issue.

Revision 1, Date Ma y 26, 1983 Revised to clarif y paragraphs II A and IIIB.

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ATP-9-Q Revision 1 Page 3 of 7 10CFR21 - Procedure for Reporting of Defects and Noncompliance I. SCOPE This procedure establishes responsibilities and methods for identifying, evaluating, and reporting safety-related defects or instances of noncompliance as required by federal regulations.

II. DEFINITIONS AND RESPONSIBILITY A. Responsible Officer The President of MGJEC shall be the officer responsible for notifying the Nuclear Regulatory Commission of defects or noncompliance as defined and required by,10CFR21.

B. Safety Review Committee The committee responsible for conducting preliminary evaluations and safety evaluations, if a p p r o p'r i a t e , of potential defects or noncompliances. The Safety Review Committee shall be designated by the Responsible Officer.

Each committee shall consist of a Chairman and two other members.

C. Safety Evaluation An evaluation to determine if a deviation or noncompliance could create a substantial safety hazard and would therefore be reportable in accordance with 10CFR21.

D. Other terms used in this procedure are defined in 10CFR21.

III. PROCEDURE AND REQUIRED DOCUMENTATION A. GENERAL The Code of Federal Regulations, Title 10, Part 21 -

Reporting of Defects.and Noncompliance (10CFR21), requires that the NRC be notified in certain cases where a nuclear ,

facility, or activity associated with the facility, or a l

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ATP-9-Q Revision 1 Page 4 of 7 component delivered for use in the facility, fails to comply with NRC regulatory requirements or c6ntains a defect which could create a substantial safety hazard.

The provisions of 10CFR21 apply to those safety-re3ated design and engineering services provided by MGJEC. The intent of this procedure is to assure that any potential cases of defects or noncompliance in work performed are promptly identified, investigated, and, if appropriate, reported as prescribed by the regulations. ,

B. IDENTIFICATION Any employee who identifies a situation which he or she believes represents a failure to comply or a defect (See Attachment A for definition), shall promptly report all pertinent information to the Responsible Officer by memorandum. The subject of the memorandum'shall be "10CFR21

- Report of Potential Defect or Noncompliance."

C. PRELIMINARY EVALUATION Upon notification of a potential defect or noncompliance, the Responsible Officer shall direct that a Preliminary Evaluation of the defect be performed under the direction of the Safety Review Committee, which shall call upon the nece,ssary technical personnel to perform the evaluation. The Responsible Officer shall establish a schedule for this evaluation, not greater than one month. The purpose of the Preliminary Evaluation is to:

1. Verify that the reported condition does, in fact, exist and does represent a deviation from technical requirements or a noncompliance with regulatory requirements.
2. Determine if the provisions of 10CFR21 apply to the reported condition.
3. Determine whether a substantial safety hazard might exist.
4. Determine whether a safety evaluation is warranted and if the capability exists within the Company to perform that evaluation.

The Preliminary Evaluation shall be documented in a formal report and submitted to the Responsible Officer. This report shall include:

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.o ATP-9-Q Revision 1 Page 5 of 7

1. Results of its review.
2. Recomcended action, including which organization should perform the safety evaluation, if warranted.

If the preliminary evaluation indicates that the condition is potentially rep'ortable under 10CFR21, the President shall notify the client. This notification shall include all pertinent information and shall indicate whether MGJEC can perform the Safety Evaluation as specified in 10CFR21.

D. SAFETY EVALU ATION When it has been determined that a Safety Ivaluation is required, agreement of the client shall be obtained regarding which organization shall perform the evaluation.

Safety Ersluations performed within MGJEC shall be performed under the direction of the Safety Review Committed. Upen completion of the Safety Evaluation, a written report shall be submitted to the President stating whether the subject deviation or noncompliance could create a substantial safety hazard and is therefore reportable under 10CFR21.

E. NOTIFICATION When advised by the Safety Review Committee that a defect or noncompliance exists in work for which MGJEC is responsible, and is such that a substantial safety hazard could result, the President shall notify the client.

The President, shall notify the NRC of the defect or noncompliance which was found to exist. This notification shall be made within two days after advising the President that a reportable condition exists. The President shall also submit a written report to the NRC within five days as prescribed by 10CFR21.

F. RECORDS The Chairman of the Safety Review Committee shall establish and maintain a file for each case of a potential defect or noncompliance. The file shall include:

1. I ni t,i al memorandum report of potential defect or noncompliance. .
2. Report of Preliminary Evaluation by the Committee.

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ATP-9-Q Revision 1 Page 6 of 7

3. Report of Safety Evaluation with supporting documentation.
4. Records of notification provided to the client and the NRC.
5. Written report of defect or noncompliance submitted to the NRC.

Upon final resolution of a case of potential defect or noncompliance, the file shall be retained in the Corporate Files.

G. POSTING The Responsible Officer shall be responsible for posting the appropriate documents as required by 10CFR21. The standard posting is shown in Attachment A.

IV. REFERENCES A. Code of Federal Regulations, Title 10, Part 21 -

Reporting of Defects and Noncompliance.

B.- MGJEC Quality Assurance Manual, latest revision.

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ATP-9-Q Revision 1 l Page 7 of 7 '

ATTACHMENT A ALL MGJEC EMPLOYEES Section 206 of the EnerEy Reorganization Act of 1974, as amended, requires that the Nuclear Regulatory Commission be notified in certain cases where a defect or instance of noncompliance with NRC regulatory requirements exists that could create a substantial safety hazard to a nuclear facility. Specific requirements regarding the e val u ation and reporting of such defects or instances of noncompliance have been promulgated un d er Title 10, Code of Federal Regulations, Part 21.

Since our work is performed in support of systems and structures which are important to the safety of nuclear power plants, MGJEC is subject to these requirements. We have established a procedure for identifying, evaluating and reporting to the NRC, if approprate, any potential defects or. instances of noncompliance in our work. As specified in the 10CFR21 Procedure s any employee who identifi,es a condition which he or she believes represents a potential defect or noncompliance should repcrt it by memorandum to the President of MGJEC.

A copy of Section 206 of the Energy Reorganization Act is shown below.

Mark G. Jones Pr e si d ent DIERGY REORGANIZATION ACT OT 1974 Section 206 NONCOMPLIANCE

-gn) Astr landistesa3 diverter, or re r---8W adiseer of e (trm esastrwettag, swalso, opersnag, or mapplytag he ammponeets af ese Basilary or assetty which to bewased er otherwtse ropteerd pursweat ta the Atomic "Reargy Art ed 39H as summeded. se perrummat to mJa Act, weie ebnatas trJerusettee reasernab)y indiceung Shal gaseb $nethfy or Deogey or baac . ana Wppbed to afth ISCIIlty or SegTtty-

@) talls to emach with he Atositic EarrEv Act of 19M. as armended, or may appbcable Tels, swsulmana, e= der. er beense e' the Ceramasanen relang as onbesanua3 salery basards er p) ematataa e dudect ehlsh am.14 evoet, e e batanuaJ eatety hasard, as afetased by resv-lenene etteh me Counnamanas shat preensitosa, shaU tramediately soufy the Commise6en of meet tauses en emumply, or of mseh driect. saleas meet persee has acasal knowledge that due htaatendhee been admupestely talerused el mech Eteleft er falhare to swmply.

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Aemmate EamrEr Act af 1994. as emmended.

gel "yhe requirwooeta of als meanse shaB be pewscamently posted me the presslees of may tacther beensed se otherwlso regislated pereumat to to Aamene E.mergy Art of 19M. se aumended.

gd "Das Ossimlestes sa mathertsed to ammeert a,ch rensenaue taspersons and asher enforewment meetsitses as emeded to sumsvre seenphasse etah the yrwynstees at mas secues.

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