ML20137X516

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Rev 1 to Project Engineering Procedure PEP-11, Reporting Design & Const Deficiencies to Nrc
ML20137X516
Person / Time
Site: South Texas, 05000000
Issue date: 03/27/1980
From: Jacobi L
HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20137X502 List:
References
FOIA-85-519 PEP-11-01, PEP-11-1, NUDOCS 8603100119
Download: ML20137X516 (16)
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, oyo ,y DEFl_CIENCIES TO NRC __ _ _ _ wa enauto HOUSTON LIGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROJECT ENGINEERING PROCEDURE PEP-il REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC 1.0 PURPOSE The purpose of this procedure is to describe the South Texas Project program for complying with the requirements of both 10 CFR 21 and 10 CFR 50.55(e).

2.0 SCOPE a This procedure esteblishes the requirements for review-ing, evaluating and reporting defects, non. compliances h . i4' and deficiencies which could potentially affect the s '. 3 safety functions of the South Texas Project as defined

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  1. by 10 CFR 21 or 10 CFR 50.5S(e).

I 3.0 REFERENCE DOCUMENTS 10 CFR 21 10 CFR 50.55(e) 4.0 RESPONSIBILITY 4.1 Project Quality Assurance Superviscr l

The Project QA Supervisor is responsible fCr per-feming a preliminary analysis of a reported in-cident to determine if further snelysis of the in-cident is required by the Incident Review Comittee, l

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  • REPORTING DESIGN AND CONSTRUCTION onn essuno 07/26/79 DEFICIENCIES TO NRC The Project QA Supervisor is responsible for notifying the Manager, South Texas Project and the Nuclear Regulatory Comission of in-cidents determined to be reportable pursuant to 10 CFR 21 or 10 CFR 50.55(e).

The Project QA Supervisor or his designee is responsible for preparing the minutes of all Incident Review Comittee meetings.

4.2 Manager, South Texas Project The Manager, South Texas Project is responsible for notifying the Vice President - Construction and Technical Services, of all incidents deter-mined by the Incident Review Comittee to be reportable under 10 CFR 50.55(e) or 10 CFR 21.

4.3 Team Leader, Nuclear Safety and Licensing The Team leader, NS&L is responsible for chair-ing all incident Review Comittee meetings.

l The Team Leader, NS&t, is responsible for pre-paring and submitting all written correspondence to the Nuclear Regulatory Comission as requimd by 10 CFR 21 or 10 CFR 50.55(e).

The Team Leader, NS&L is responsible for main-taining a file of all incidents considered by the Incident Review Comittee.

l 4.4 Incident Review Comittee l

1 The Incident Review Comittee is responsible for i determining reportability of deficiencies per

! 10 CFR 50.55(e) or defects and noncofnpliances l

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the citimate responsiblity for deteming(e) port-

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$U'd" REPORTING DESIGN AND CONSTAUCTION lDATR 111Ut 0 _ 07/26 ' 79 DEFICIENCIES TO NRC In order to improve the processing of incident reviews, convening of a joint session of the B&R and the HL&P Incident Review Congnittees is recorrrnended.

5.0 REQUIREMENTS 5.1 Initial Incident Notification Defects, noncogliances or deficiencies which could potentially affect the safety functions of the' nuclear power plant can be identified by numerous individuals and from various pro-cedures or interfaces. Regardless of the in.

dividual, organization or means of identifying such incidents, it is igerative that either the site Quality' Assurance Manager or the Project QA Supervisor be notified imediately so he can review the NCR (Jr ADR, if appropriate) and ini-tinte the evaluation process of the possibly reportable defect, noncomformance or deficiency.

5.2 Safety Evaluation Each incident trientified as being reportable to the NRC per 10 CFR 21 or 10 CFR 50.55(e) will receive both a technical evaluation and a safety i

evaluation to determine whether the incident cculd, if uncorrected, create a substantial safe-ty hazard. Technical evaluations are perfomed by the cognizant engineering organization and safety evaluations are performed by the Incident Review Consnittee.

l F'or the purpose of initial reportability determina.

, tion, the safety evaluation may be waived when an

! extensive safety evaluation is considered necessary

! and the dispositon of the incident will result in the retention of the original design configuration and safety criteria. In such cases, the incident shall be considered reportable. The final report A shall then consist of a technical evaluation.

safety evaluation shall be performed in all cases where the original design configuration or safety b criteria will not be retained,

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dei!CIENCIES T0 hRC For liformatis liilly 5.3 Deficienc.y Determination The following factors shall be considered in evaluating an incident to determine if it is a deficiency reportable to the NRC under the pro-visions of 10 CFR 50.55(e).

1. The deficiency shall be evaluated as af-fecting or have the potential to affect the safety of the operation of the plant at any time throughout its expected life.

This includes deficiencies which could affect the safety-related function of any structure, system or cowponent for which credit is taken in the FSAR in evaluating their capability to accomodate the effects of and to be concatible with environmental conditions associated with normal operation, maintenance, testing and postulated accidents. Careful considera-

-tion shall be given to the effects of the deficiency to assure that it does not in-directly affect the safety of operation of the plant.

2. The deficiency shall be related to the design or construction phases. This includes act-ivities of the Nuclear Steam System Supplier, l architect engineers, consultants, contractors, or suppliers.

l 3, The deficiency shall fall within one of the following four cate20 ries:

(a) A breakdown in the Quality Assurance Pro-

! gram related to any criterion in 10 CFR 50, Appendix B, applied to any design or construction activity affecting the safety

[ to plant operation.

(b) A deficiency in final design as approved l and released for construction such that the design does not comply to the design criteria and bases stated in the FSAR or Construction Permit. Final design denotes those drawings, specifications and other g engineering docements that have been rt-visived, approved and released for l

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No deficiency exists if a design stated in t'.e FSAR is changed by approved procedures after receiving prcper evaluation and review.

(c) A deficiency in construction of or damage to a structure, system or component which will require extensive evaluation, extensive repair to establish the adeq,:acy of the structure, system or cogonent.

( r A deviation from performance sptcifications defined in tne functional testing require-ments which will require extensive evalue-tion, extensive redesign, or extensive re-pair to establish the adequacy of the struc-ture, system or component.

4 The significance of the deficiency should be evaluated relative to operational safety. J!Le sienificance of a deficiency it a subjective .

_ evaluation and as such the_stanificance of a civen deficiency may not be close. Therefore, lf the significance of a defic < ency is in doubt, it should be treated as reportable to the NRC.

5.4 Defect Determination The following factors shall be considered in evalua-ting an incident to determine if it is defect report-able to the NRC under the provisions of 10 CFR 21.

1. The incident identified shall involve either the software or hardware requirements associated with a basic cogonent. A basic component is a safety Class 1, 2, or 3 Seismic Category I structure, system, cogenent or part thereof necessary to assure:

(a) The integrity of the reactor coolant pres-sure boundary, (b) The capability to shutdown the reactor and maintain it in a safe shutdown condition, or k+

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# REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC oAn insuro 07/26/79 5 'a (c) The capability to. prevent or mitigate the consequences of accidents which could re-suit in potential offsite exposures compar-able to those referred to in 10 CFR 100.11

2. The basic cogenent shall contain a defect which is defined by the following categories:

(a) A deviation in a basic component delivered to a purchaser or user where on the basis of an evaluation, the deviation could create a substantial safety hazard; or (b) The installation, use or operation of a basic component containing a defect as de-fined in paragraph 2 (a) above; or (c) A deviation in a portion of the nuclear power plant subject to the construction per-mit requirements of 10 CFR 50 provided the deviation could, on the basis of an evalua.

tion, create a substantial safety hazard and the portion of the factitty containing the deviation has been offered to the pur-chaser for acceptance; or (d) A condition or circumstance involving a basic component that could contribute to the ex-ceeding of a safety limit, as defined in the technical specifications of a license for operation issued pursuant to 10 CFR 50.

3. The defective basic component should be evaluated to determine whether the defect could, if uncor-rected, create a substantial safety hazard.
4. A cottynerical grade item is not part of a basic com-ponent untti after dedication which occurs after receipt when that item is designated for use as a basic coganent.

5.5 Noncompilance Determination The following factors shall be considered in evalua-ting an incident to determine if it is a noncompliance A+

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1. The incident identified shall involve either the software or hardware requirements associated with a basic component.
2. The basic component shall fail to comply with the Atomic Engergy Act of 1954. as amended, or any applicable rule, regulation, order or 11-cense of the NRC relating to substantial safety hazards. This includes failure to comply with design criteria and bases stated in the FSAR or Construction Pamit.
3. The basic component containing the noncompliance shall be. evaluated to detemine whether the non-compliance could, if uncorrected, create a sub-stantial safety hazard.

5.6 INCIDENT NOTIFICATIONS Five prir.ary notifications occur during the process of reporting defects, noncompliances and deficiencies in accordance with 10 CFR 21 or 10 CFR 50.55(e).

These notification are:

1. Any individual notifying the Project QA Super-visor of an expected incident requiring con-l sideration pursuant to' 10 CFR 50.55(e) or 10 CFR 21.
2. The Project QA Supervisor notifying the Team Leader, Nuclear Safety & Licensing of an in-cident requiring evaluation by the Incident Review Comittee.
3. The Project QA Supervisor notifying the Nuclear Regulatory Comission of an incident determined to be potentially reportable or reportable pur.

suant to 10 CFR 21 or 10 CFR 50.55(e).

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4. The Team Leader Nuclear Safety & Licensing notifying the cognizant engineering discipline and others required to call a meeting of the Incident Review Coernittee.
5. The Manager, South Texas Project notifying the Vice President . Power Plant Construction and Technical Services of an incident determined to be reportable or potentially reportable.

5.7 WRITTEN INCIDENT REPORT A written report is required to be submitted to the NRC Director of Regional Office and the NRC Director.

Office of Inspection and Enforcement, on each de-fact, noncompliance or deficiency reported to the NRC per 10 CFR .21 or 10 CFR 50.55(e). An outline for these written reports is provided in Attacrutent PEP-11-01 to this procedure. If information re.

quired for the written report is incomplete when the report is prepared, an interim report shall be prepared describing that information which is avail-able and a schedule for completing the remaining information.

5.8 INClotNT REVIEW COMMITTEE The incident Review Connittec shall consit of the following members, or their designees, as a minimum:

1. Engineering Team Leader, NS&L - Chairman
2. Project QA Supervisor
3. SJpervising Project Engineer, Design 5.9 OEADLINE REQUIREMENTS The following deadlines shall be observed.

A. The NRC shall be notified by telephone 1 Within 2 days pursuant to 10 CFR 21 2 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> pursuant to 10 CFR 50.55(e).

following determination by the Incident Review Comittee that incident is reportable, bY 0

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      • d" REPORTING DE$1GN AND CONSTRUCTION natr ennuno 07/26/79 DEFICIENCIES _TO NRC for Informatioil Only B. The NRC shall be sent a written report:

(1) Within 5 days pursuant to 10 CFR 21 (2) Within 30 days pursuant to 10 CFR 50.55 (e).

following determination by the Incident Review Comittee that the incident is reportable.

C. Brown & Root shall submit to HL&P for review a draf t written report:

(1) Within 2 days for Part 21 deficiencies (2) Within 17 days for Part 50.55(e) deficiencies, following determination by the Incident Review Comittee that the incident is reportable.

5.10 _PROCUREMENT DOCUMENT NOTIFICATION Attachment PEP-11-02 to this procedure provides a standard statement that must be included in all purchase orders and subcontracts for services and It equipment defined as being a basic component.

is the responsibility of the Purchasing Department to ensure this statement is included in all such purchase orders and subcontracts.

S.11 P0_$ TING REQUIREMENTS Attachment PEP-11-03 to this procedure provides a standard poster which must be displayed in conspic-uous locations at both the Houston home office and the construction site, it is the responsibility of the STP Quality Assurance Supervisor to ensure that adequate posters are displayed in appropriate 10-cations, This poster identifies the individual to whom initial notification of a defect noncompliance should be made.

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For Information 3sy 5.12 Procedure _

For a general flow chart of the incident review pro-cedure, see attachnent PEP-11-04.

Responsibility Action Any Individual 1. Reports to the Project QA Supervisor any inci-dent which he feels should be evaluated pursuant to 10 CFR 50.55(e) or 10 CFR 21.

Project Quality 1. Reviews the incident Assurance Supervisor report.

Project Quali.ty 2. Detemines whether it Assurance Supervisor is potentially report.

able.

Project Quality 3. If not potentially re-Assurance Supervisor portable, then handles incident through nor-mal QA channels Project Quality 4. If potentistly report.

Assurance Supervisor able then the Engi-neering Team Leader, Licensing is notified.

Engineering Team 5. Reviews the incident report and discusses Leader Licensing it with the Project QA Supervisor.

6. Arranges for review Engineering Team of the incident by Leader, Licensing the appropriate Engi-nearing discipline.
7. Evaluates the safety Engineering Team significance of the Leader, Licensing incident.

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nata anuan 67/96/79 for Mormation kily Engineering Team 8. If not potentially re-Leader, Licensing portable, then incident is resolved through nomal QA channels.

Engineering Team 9. If potentially report-Leader. Licensing able then incident is referred to the Inci-dont Review Comittee.

10 Whenever possible, the Incident Review Comittee HL&P Incident Review Cournittee shall be con-vened as a joint meet-ing with the 84R Inci-dont Review Comittee.

Incident Revlew 11. The Incident Review Comittee Consmittee considers the incidant.

Incident Review 12. If deemed not report-Comittee able, then the incident is resolved through nomal QA channels.

13. If deemed reportable.

Incident Review then the incident is Cnmittee reported to the NRC by the Project GA Super visor.

Project QA Super- 14. Notifies NRC Region visor IV within the time ,

frame noted in section 5.10.

Project QA Super-

15. Notifies the Manager, South Texas Project visor and the Manager Qual-ity Assurance.

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mara innuno 07/M /79 y N N nob b Engineering Team Leader. 16. Notifies the Super-Licensing vising Engineer. De-sign and the Super-vislieg Enginoer Nuclear 8

Safety & Licensing.

Engineering Team Leader,

17. Prepares a written re.

Licensing port to the NRC, Region IV within the time frame noted by section 5.40. 9.

Engineering Team Leader. 18. Prepares a documenta-Licensing tion package to be maintained by the Licensing group and RMS.

6.0 DOCUMENTATION

  • Each defect, noncompliance or deficiency evaluated by the Incident Review Corr.ittee shall be recorded in formal meeting minutes by the Project Quality Assurance Supervisor. A copy of these meeting min-utes, copies all telephone correspondence and copies of all NRC correspondence will be maintained by the Engineering Team Leader. Nuclear Safety & Li-censir.g; in addition to the permanent record copy to be maintained by RMS. It is the responsibility of each individual originating such documentation to en-sure that file copies are properly identified and transmitted to the Engineering Team Leader. NS&L and the Record Management System (RMS) File.

7.0 ATTACHMENTS A. PEP-11-01 " Incident Report Outline" B. PEP-11-02 " Procurement Document Statement" C. PEP-11-03 " Posting Notification" D. PEP-11-04 " Incident Review Flow Chart" A+

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SUMMARY

This section should provide a synopsis of the incident and its resolution. The following infomation should be contained in this section:

a. A synopsis of the incident
b. Postulated cause of incident
c. A synopsis of the corrective action taken
d. Synopsis of the results of the safety evaluation.

II. DESCRIPTION OF INCIDENT. t This section should provide a clear and corolete description of the incident and the circumstances surrounding it. The follow-ing information should be contained in the section:

a. Identification of the facility or activity or basic component (including vendor) supplied to such facility or activity in-volved in the incident
b. Source and extent of incident
c. The date and means by which the incident information was obtained
d. Unusual circumstances pertaining to the incident, such as weather conditions. test procedures undemay and/or abnormal conditions at site
e. Status of construction at time of incident f.

Procedures in effect.to avoid incident (if any)

!!!. CORRECTIVE ACTION This section should provide a clear description of the corrective action taken to rectify the incident and action taken to prevent recurrence. The following information should be contained in this section as applicable:

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a. The immediate response by Quality Assurance in response to the incident,
b. A complete description of all imediate actions taken to correct the incident.
c. A complete description of all long-range actions to be taken to correct the incident and innlementation schedule,
d. A delineation of the testing methods which will be utilized to ensure that repairs have been conducted properly.
e. Action taken to prevent the recurrence of the incident during the remaining construction phase of the facility.

IV.- SAFETY ANALYSIS This section should provide sufficient infomation to fully ana-lyze and evaluate all the possible safety implications of the incident. The following information should be contained in this ,

section as applicable: -

a. Nature of the incident and the safety hazard which is created or could be created,
b. Identification of applicable Quality Assurance documentation.
c. A record on all incidents noted in the Quality Assurance documentation and their resolution where applicable to the reported incident.
d. A complete record of the incident and the results of all investigations.
e. Postulated cause of incident.

l f. A complete description of all imediate actions taken to mitigate the consequences of the incident.

g. In the case of a basic comoonent which contains a defect or noncomplaince originated for evaluation by B&R, the number and location of all such components in use at. supplied for, being supplied for other facilities or activities with B&R as the engineer or constructor.

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PROCUREMENT DOCUMENI STATEM'.NT 10 CFR 21 " Reporting of Defects and Noncompliances" The work to be performed under this purchase order (subcontract) is con-sidered to involve a " basic component" as defined by Title 10 Code of Federal Regulations Part 21 (published 6/6/77 in Federal Register).

Therefore,10 CFR 21 is applicable.

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.. e e.,,,.

- .a eettt9tpet

-,-w,,--.--,,g,_,.,., - ,,.. ._. ,m n_ _ , , . , _ _ _ e ._,,-..,-mnn,-.. ,y , , . . , , - - - , , - - - - - , - , _ -

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