ML20117F137
| ML20117F137 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/23/1983 |
| From: | Pertuit J EBASCO SERVICES, INC. |
| To: | |
| Shared Package | |
| ML20117F125 | List: |
| References | |
| FOIA-84-205 ASP-IV-122, NUDOCS 8505130144 | |
| Download: ML20117F137 (15) | |
Text
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SITE CCNrROL AND PPOCESSING OF Dt2tG5/tKN-CCMPLIANCE
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CCEDITICNS TO LP&L asp _pf_177 l
l ISSUI SC0!ARY
^??R0"U E' ' U NME Iss;I/"A-I "A" Draft 11-22-82 J. Gutierrez A
"A" Issue (I
2-23-83 J. R. Pertuit R. J. Milhiser New "B" Draft 3/22/83 J. R. Pertuit b
"B" Issue
~Ws 3-23-83 J. R. Pertuit R.
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,vATERFORO STEAM CLECTRIC STATICN - UNIT NO. 3 PACE:, ' OF
,,t 1.0 PURPOSE
,1 To provide direction and guidance to Waterford Project personnel in the implementation of Ebasco company procedure N-23, Reporting a
. Defect /._Non-compliance to the NRC, for assuring prompt notification and tiimely submittal of information to LP&L regarding significant f
deficiencies found during design and construction at the Waterford Steam Electric Station - Unit No. 3 and to delineate the interface and lines of communication between the applicable Ebasco department. LP&L Construction Q.A. and LP&L Licensing.
i 2.0 SCOPE This procedure applies to Waterford Project Ebasco Site personnel as delineated herein and is intended to complement company procedure N-23 by addressing the overall coordination effort associated with:
1,
i a)
Identification and Reporting of Defect (s)/ Noncompliance Condition (s) b)
Evaluation requirements 1
c)
Preparation of Reports l
l d)
Corrective Action and Follow-Up l
This procedure shall be used in conjunction with the references listed below.
3.0 REFERENCES
a 3.1 Guidance - 10CFR50.55(e), Construction Deficiency Reporting Issue
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date: 4/1/80 l
l 3.2 10CFR21 - Reporting of Defects and Noncompliance 3.3 Ebasco Company Procedure N-23, Reporting a Defect /Norcompliance to the NRC 3.4 ASP-III-7. Processing of Nonconformances and Audits 3.5 ASP-IV-36, Control of Technical Bulletins e
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PACE: 2 OF m
'#ATERFORD STEAM E1.fCTRIC STATION - UNIT NO. 3 153tJE:,
4.0 DEFINITIONS 4.1 Defect or Noncompliance - A defect is a deviation in a delivered or installed safety-related item which, upon evaluation, could create a substantial safety hazard. Noncompliance means failure to comply with the Atomic Energy Act of 1954, as amended, or any applicable rule, regulation, order or license of the Commission which could create a substantial safety hazard.
4.2 Deviation - A departure from the technical requirements of a procurement and/or design document or SAR design bases and criteria for a safety-related item as released for final design and construction or as a delivered item or service. The term "devi Aatio " is meant to g ompass "defig_iency" as used in i
ID WR50.55Ce).~ Note that rev1Tions to drawings already released for
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constructT8n are not to be automatically considered as deviations since changes of this nature are part of the normal design evolution process.
4.3 Delivered - Acceptance of a saf ety-related item by the purchaser at the point of delivery.
If a safety-related item is rejected during
-J any receipt inspection and returned, the item is not considered a
delivered. Conditional acceptance clauses, i.e., acceptance of a safety-related item dependent upon satisfactory performance for a specified p'eriod of time, are not applicable when determining whether or not a item is considered delivered.
4.4 Interim Report - A report where sufficient information is not available f or a final report.
4.5 Final Report - A report whose content will permit the Nuclear Regulatory Commission (NRC) to evaluate the defect or noncompliance and corrective action taken.
4.6 Safety-Related Item - A plant ' structure, system, component or part thereof necessary to assure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could result j
As used in this in significant off-site radiation exposures.
procedure only, safety-related items are also defined to include services such as design, manufacture, fabrication, placement, erection, installation, modification, inspection, testing, analyses or other consulting services supplied for a nuclear power plant.
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WATERFORD STEAM ELECTRIC STATION - UNIT NO. 3l PACE:
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ISSUE: a 4.7 Substantial Safety Hazard - A loss of a safety function to the extent that there is a asjor reduction in the degree of protection provided to public health and safety when considered in the content of the plant safety analyses and design basis.
Additional criteria include:
a)
Moderate exposure to, or release of, licensed material (radiologically this results in doses of 25 rem to the thyroid and 0.5 rem to the whole body to persons in unrestricted l
areas).
l b)
Major degradation of essential safety-related equipment, c)
Major deficiencies involving design, construction, inspection, test or use.
5.0 RESPONSIBILITIES 5.1 The Quality Program Site Manager is responsible for monitoring i
compliance to Company Procedure N-23 and assuring the' completion of
-J deviation evaluations and finalizing reports which result from discovery / reporting of a defect / noncompliance which are a result of construction activities.
5.2 Ebasco Site Support Engineering (ESSE)
The Engineering Discipline Supervisors or their designees are responsible for determining whether a deviation is or is not significant and to provide substantiation thereto, as well as for
, providing engineering analyses which are necessary to allow the i
Project Licensing Engineer (PLE) to perform a safety evaluation.
The Engineering Discipline Supervisors or their designees are responsible for gathering information and preparing a draf t of the g
report for design-related deviations and corrective action (s) taken.
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PACE: 4 OF to_
WAT3 FORD STEAM ELECTRIC STATICN - UNIT NO. 3 IS3UE: B 5.3 Construction The Senior Resident Engineer or his designee (s) is responsible for gathering information and preparing a draft of the report for construction-related deviations and corrective action (s) taken.
5.4 Licensing The PLE, based on analyses performed by engineering disciplines as required, shall perform a documented safety evaluation to determine if a substantial safety hazard exists. He shall then notify the Q.A. Site Supervisor via telecon within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> f rom the time a request is made for a licensing evaluation by the Q.A.S.S. or his designees.
In addition, the PLE shall forward to the Q.A. Site Supervisor a copy of the safety evaluation.
l 6.0 PROCEDURE General -
A nonconformance or condition that requires evaluation as to reportability under 10CFR50.55(e) requirements may be identified by either Ebasco
-J (Engineering cr Construction) LP&L or an outside supplier.
Overall responsibility for assuring compliance, implementation and maintenance of this procedure rests with the Quality Program Site Manager Implementation and coordination of the activities delineated herein is accomplished through the organizational Matrix structure depicted in (Attachment 7.1).
6.1 Criteria for Identification and Reporting of " Deficiencies" by Ebasco N
6.1.1 Any Ebasco employee obtaining information that a deviation exists in a safety-related item, and which meets or could conceivable meet the reporting requirements of 10CFR50.55(e), shall immediately report it to his supe rvisor. This supervisor shall review the information, determine concurrence and thereupon immediately inform the Q. A. Site Supervisor, f ollowing it up by a memo or by filing a nonconformance report (NCR) in accordance with procedure ASP-III-7.
6.1.2 A nonconformance or condition that requires evaluation as to reportability under 10CFR50.55(e) requirements may be identified as a result of:
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5 10 ISSUE:
B A)
Quality Assurance and/or Engineering Review of NCR's, observation of a condition or activity, be it Design, Construction, Inspection or Testing, not conducted in accordance with procedural requirements.
B)
A formal submittal (letter) by a vendor supplying material, components, and/or services and any organization involved in the design, construction, evaluations, or inspection of the Waterford facility.
Employees should be alert for project documents be they: material reports, test reports, inspection reports, drawings. (i.e., info bulletins) which may reflect data or information in noncompliance with project requirements.
Conflicting requirements as may be reflected in procedures and specifications which result in re-evaluation or rework shall be brought to the attention of the Q.A. Site Supervisor.
C)
An informal report, or allegation, by any organization or person having knowledge of project requirements and activities.
Significant non-safety items are to be included if the structure, system or component involved could cause or contribute to degradation or integral plant safety as a result of an adverse interaction with safety related structures, systems or components.
6.1.3 The QASS or designee (s) shall review nonconformance reports and notifications received, applying the guidance of Company Procedure No. N-23 and the requirements of 10CFR50.55 (e) or 10CFR21, as appropriate and shall initiate Form 1352 (Attachment 7.2) if there exists sufficient documented evidence to determine potential reportability with respect to a j
breakdown in the Quality Assurance Program requirments.
6.1.4 When such a determination cannot be reached by Quality Assurance, additional input shall be obtained from ESSE, and Licensing as described in par 6.1.5.
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153UE:' 8 WATERFORD ST M ELECTRIC STATION - UNIT NO. 3 PAC 5:
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6.1.5 In instances where information is required for determining whether the deviation is significiant with respect to f'inal design, construction or performance criteria requirements. the QASS shall'obtain required technical information from the applicable ESSE engineer.
Evidence shall be provided by ESSE supporting their determination of significance (i.e. function of item, consequences of failure, etc).
When ESSE determines an item is significant Licensing is required to perform a safety evaluation of the condition identified.
If Licensing's review determines the condition identified to conscitute a substantial safety hazard, the QASS shall be notified within 24 hrs.
The QASS shall then proceed with reporting the incident in accordance with par. 6.1.6.
6.1.6 If this initial review determines that the reported condition meets the criteria established in 10CFR50.55(e),
the LP&L Project Licensing Engineer shall be notified via (Attachmen*c 7.3) and the deficiency classified as Potentially Reportable Incident (PRI) or Significant Construction Deficiency (SCD) as appropriate.
Assignment of numbers shall be by Ebasco Quality Assurance, Quality Analysis Group.
This action " starts the clock" on the 21 calendar day report submission date to LP&L.
6.1. 'l If within the subsequent 14 calendar day period the evaluation confirms acceptability (non-reportability) of the deficiency / condition, Q.A. shall submit these results to file and notify LP&L that the deficiency was determined not to be significant based on the results of further analysis or investigation. Conversely, if reportability is established LP&L shall again be notified via
,.3 and the deficiency upgrr.ded to Reportable.
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6.2 Identification of " Deficiencies" by u When LP&L discovers a condition related to Design or Construction and which requires evaluation in accordance with 10CTR50.55(e),
wrir.r.an notification shall be submitted toJ.hae n qua utY Assurance
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with the following information provided for processing as delineaced above:
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WAT!3J0'AD STI.ui EL C3 C STATION - UNIT No. 3 FACE: 7 0F 10
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A)
When the condition was detected B)
Where it was detected or suspected C)
Items, components, structures or systems affected D)
How it was detected E)
Nature of the condition rendering the item (s) unacceptable or suspect.
Ebasco shall be given the information above to the extent known prior to the initial notification to the NRC.
Conditions identified by LP&L will be evaluated and processed by LP&L in accordance with NAP-il7, unless otherwise requested.
Ebasco will be notified verbally and by memo of conditions identified by LP&L that will require Ebasco input / assistance in accordance with the N-23 procedure.
Assignment of all numbers shall be through Ebasco Quality Assurance.
All information and correspondence relating to significant deficiencies shall be communicated / transmitted between the following, as a minimum:
Quality Program Site Manager Q. A. Site Supervisor Project Site Manager l
Project Superintendent l
Senior Resident Engineer Project Engineer (ESSE)
Licensing
,1 Project Q. A. Engineer LP&L, Project Q. A. Engineer LP&L, Licensing Engineer
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Ebasco Planning & Schedulin's Department 6.3 Evaluation l
6.3.1 Personnel / Departments assigned resp'onsibility for
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j providing an evaluation shall allocate. all necessary resources and time to assure that a prompt and complete i
analysis of the deficiency identified is submitted to the
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Q. A. Site Supervisor within the time f rame stipulated.
6.3.2 The evaluation shall be conducted and significance of the deficiency established through application of the criteria presented in regulation 50.55(e) and company procedure N-23.
6.3.3 The test of significance includes, but is not limited to, safety-related items / activities.
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"B"
'JATIRTORD STI.ui ELICTRIC STATION - UNIT No. 3 PAGE: 8 0F 10 The 50.55(e) requirement applies to any structure, system or component (SSC's) if it contains a deficiency which, were it to have remained uncorrected, could have adversely affected the safety of operation of the facility. This includes those SSCs that, even if not classified as safety related, could cause or contribute to the degradation of integral plant safety as a result of an adverse interaction with safety related SSCs. Primary examples of this are undesirable conditions or failures in a non-safety system, structure, or component which could impact or degrade safety systems or a safety function.
6.3.4 Evaluations pertaining to a Potentially Reportable incident (PRI) shall as a minimum address the following:
a)
The potential problem and indicate manner of notification / identification b)
Approach to resolution of the problem c)
Status of proposed resolution d)
Reasons why a final evaluation will be delayed (when applicable) e)
Analysis of safety implications f)
Projected completion of corrective action and submittal date of the complete evaluation.
6.3.5 A complete and final evaluation shall containt a) description'of the deficiency b) analysis of the safety implications. This should include an identification of interfacing systems and possible interactions, c) corrective actions taken.
Corrective actions should be sufficient to correct the deficiency and prevent future identical or similar occurrences. To prevent future occurrences the causes of the deficiency must be fully explored and identified.
d) suf ficient information to permit analysis and evaluation of the deficiency and of the corrective action.
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6.3.6 The cognizant engineer responsible for the evaluation 1
shall forward his signed and dated evaluation to the Q. A.
Site Supervisor.
Concurrent with this, a copy of the evaluation shall be submitted to the assigned Project Licensing Engineer via telecon and celecopy.
The Licensing Engineer after receiving Engineering's evaluation from the Q.A.S.S. or his designee shall, within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, provide the Q.A. Site Supervisor with a Safety Analysis Report via telecon with follow-up through telecop.
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If the evalu.64va 1. considered repurcable this starts the 21 day clock for Ebasco's interim report to LP&L.
Upon receipt of all necessary information, Form 1352 (Attachment 7.2) sh-ll be completed by QASS.
6.4 Preparation of Reports 6.4.1 It is the assigned responsibility of the Senior Resident Engineer or his designee to prepare and submit evaluations in the form of a draft initial Interim Report. Interim Status Report and a Final Report to the Q. A. Site Supervisor within the requested time period for deficiencies related to Construction activities.
6.4.2 The Project Engineer (ESSE) shall prepare and submit similar reports on evaluations pertaining to design deficiencies to the Q.A. Site Supervisor within the time frame requested.
6.4.3 Format and content of the reports shall be in accordance with the guidelines provided on attachment 7.3.
6.4.4 The Q. A. Site Supervisor or designee will compile the j
of ficial report (s) utilizing the information submitted by Engineering and Construction, as appropriate, along with Licensing's evaluation.
6.4.5 Planning and Scheduling will maintain, update and revise schedules, as well as the issuance of new schedules whenever a new problem report is opened.
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PACE:
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WATER *CRO STEAM ELECTRIC STATION - UNIT NO. 3 in ISSUE: a l
6.5 Corrective Action Follow-Up and Completion 6.5.1 It is encumbent upon Construction. Engineering and/or Quality Assurance, as appropriate, to accomplish corrective action a outlined in the reports.
6.5.2 Coordination and follow-up shall be accomplished through the collective participation of individuals assigned to the Matrix organization group depicted on attachment 7.1.
6.5.3 The Senior Resident Engineer will issue semi-monthly, and submit to the Site Manager with a copy to Quality Assurance, a report with the status of progress and identification of hard spots, if any, in closing out action, I
items.
7.0 ATTACHMENTS l
7.1 Flow Matrix.
7.2 Form 1352.
7.3 Significant Report Form.
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EsAsCo ss: VICES INCORPOR ATED OEM 1352 Report N;.
DEVI ATION/ NONCOMPLIANCE EVALUATION ATTACHMENT 7.2 Date f
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NERAL:
Project Client Deviation Title Date of Oc.currence Date of Discovery DEVI ATION EVALUATION:
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OEVIATION REPRESENTS A SIGNIFICANT:
Affects Safety.Related item or Part
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Breakdown of QA Program Thereof and or Defif ency in Final Design item is Delivered and or Defirency in Construction Could Create a Substantial S. ety Hazard C]
sficency in Performance Re
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Reportable
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and Advenely Affects Safety of Plant if Left Uncorrected Has Been Evaluated for Appi.. ability with Respect to Other Ebesco Clie its.
b Reportable I
Report Required NOTIFICATION:
- 1. Client Notlfied on:
- 5. Client Notified on:
- 2. Report Due Cient ty:
- 3. Report Due NRC
- 6. NRC Notified on: _
- 7. Report Due NRC by:
interim by:
Finel by:
PGAE/QP9A PQAE/QPSM SloNAfume eioNATURe COMMENT 31 A--.----.
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- .3 GUTDE SIGNIFICANT CONSTRUCTION DEFICIENCY REPORT GUTLINE
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(1) This report is submitted pursuant to 10CFR50.55(d).
(2) One or two sentence problem description.
Identification of the facility, the cctivity or the safety-related component supplied for such facility or such cctivity which fails to comply or contains a defect.
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This problem is considered (reportshic/potentially reportebic/nen-reportativ) under the requirements of 10CFR50.55(e)
(4)
This problem has been identified to the Nuclear Regulatory Commission by under 10CFR21 (or) to the best of our knowledge, this problem has not been identified to the Nuclear Regulatory Commission pursuant to 10CFR21.
DESCRIPTION:
(1)
The date on which the information of such defect or failure to comply was obtained and how the deficiency was detected.
(2)
Nature of defect or failure to comply.
ga)
Organisation responsible for defect or p'rogram deficiency.
(4)
The number, location, and identification of all safety-related components, systema affected by the defect.
(S)
General status of the installation containing the defect.
SAFETY IMPLICATION $t (1)
An evaluation of the safety hasard which is created or could be created by such defect or failure to comply.
(By N.Y. Licensing)
CORRECTIVE ACTION:
(1)
The corrective action which has been, is being, or will be taken.
(2)
The name of the organisation responsible for the action.
(3)
The length of ties that has been or will be taken to complete the action including the corrective action completion date.
(4)
Include a delineation of the testing methods which will be utilised to ensure that repairs have been, or will be, properly conducted.
'*4 Specify any actions taken to prevent recurrence of the incident to the entant feasible.
(4)
If necessary er applicable, any fellowup actions er advice related to the defect er failure to comply about the facility, activity, er safety-related component that has been, is being, er will be given to venders, contractors, purchasers, l
er lisensees.
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QUALITT ASSURANCE COMPANY PROCEDURE NO.
N-23 vie 6s useamo
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A.INDIC A TEs REPORTING A DEFECT / NONCOMPLIANCE TO THE NRC navisio" June 20, 1983 a
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TABLE OF CONTENTS Section M
1.0 PURPOSE' 3
2.0 SCOPE 3
3.0 MAINTENANCE 3
.0 DEFINITIONS 3
5.0 REPORTING REQUIREMENTS 6
5.1 Jurisdiction of 10CFR50.55(e) and 10CFR21 6
5.2 Responsibility for Filing a 10CFR50.55(e) Report 6
5.3 Responsibility for Filing a 10CFR21 Report 7
5.4 Disagreement with Client's Opinion 7
6.0 EBASCO RESPONSIBILITIES 7
6.1 Quality Assurance 7
6.2 Nuclear Licensing 8
6.3 Engineering 9
6.4 Ebasco Constructors Inc 9
6.5 Reference Plants and Engineering Standards 10 6.6 All Ebasco Employees 10 6.7 Special Cases 10 7.0 EVALUATION AND REPORIINC (Refer to Attachnent 5) 10 7.1 Discovery of a Deviation 10 7.2 Evaluation by Engineering 11 RJN 2028q Cocynet @ 1983, 1979 Ebasco $mical lacemmted 110034 / be t