ML20138H616

Staff Exhibit S-142,consisting of Undated STP-DC-021D, Engineering Procedure for Engineering Design Deficiencies. App a Re Requirements for Reporting Deficiencies as Specified in 10CFR50.55(e) Encl

ML20138H616
Person / Time
Site:	South Texas
Issue date:	08/13/1985
From:	HOUSTON LIGHTING & POWER CO.
To:
References
S-142, NUDOCS 8510290101
Download: ML20138H616 (15)

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SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MAhTAL

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ENGINEE, RING DESIGN DEFICIENCIES Q-%

1.0 Ih'"RODUCTION 1.1 PURPOSE The purpose of this procedure is to provide Engineering personnel and/or otherwise resolve South with methods to identify, report,(STP) Engineering Design Deficiencies (EDD This procedure satisfies the requirements of ANSI N452.11, Texas Project Section 9 (Ref. 1).

1.2 SCOPE M

This procedure applies to Engineering personnel when identifying e.-C and dispositioning design deficiencies and the reporting of these Q It also deficiencies to appropriate levels of management.

includes instructions for the handling of reportable deficiencies as defined in 10CFR50.55(e) and 10CTR21 (Ref. 2 and 3).

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,, (,,f Not included in this procedure are the handling of deficiencies

@y detected during the Document Review Cortment process.

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2.0 REQUIREMENTS

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2.1 Design deficiencies are generally detected:

snM During the design proceas, F>,

a.

Q When resolving Supplier Deviation Requests (SDRs)(see Q

b.

STP-DC-024), or During the document approval cycle.

c.

Engineering Design Deficiency reports should not be written' for minor administrative or technical matters, for deficiencies l

already documen'ted as Quality Assurance Nonconformance Reports, (NCRs) (see STP-DC-022), or as demurrers.

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SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MANUAL STP-DC-021-D 2.2 REPORTING RESPONSIBILITY Engineering Design Deficiency reports may be written (using Form 200.108) by all STP Engineering personnel who have the technical proficiency to do so.

Instructions for completing Form 200.108 are contained in A040GM010, STP Forms Manual.

2.3 MANAGEMENT VISIBILITY To assure appropriate visibility by Engineering Management, all EDDs and their responses shall be sent using General Memoranda (GM) (see STP-DC-006), to the affected Assistant Engineering Project Manager (s) (AEPM) as a minimura. Any significant EDD's will be brought to the Engineering Project Manater (EPM) by Design Quality Engineering (DQE.)

2.3.1 Closecut of Engineering Design Deficiencies All EDDs shall be closed *out, and the Closecut documented by entry of the signature and date of the AEPM-Special Services,

'or his designee.

2.3.2 Recourse for Engineering Design Deficiency Resolutions Should the originator of an EDD fail to concur with the accepted resolution of an identifie'd deficiency, he should address his comment to the AEPM-Special Services for resolution.

If the resolution is still unacceptable to the originator, he should then bring the resolution of the EDD, together with his comments and those of the AEPM-Special Services to the Senior Group Vice President-Engineering, Power Group whose decision is considered " final" for disposition of EDDs in these cases.

It should be clearly understood that such action on the part of the originator is acceptable and within the authorized line of communication, j

2.4 POTENTIALLY REPORTABLE DEFICIENCIES Pursuant to 10CFR50.55(e) and 10CFR21, Project personnel are required to report deficiencies that could affect the safety of Project operations. Reporting requirements for a deficiency under 10CFR50.55(e) are summarized in Figure 3 and are more fully described in Appendix A.

Reporting requirements for deficiencies under 10CFR21 are shown in Figures 4 and 5.

Evaluation processes are described in STP-PM-022 (see Ref. 4).

I 2 or 12 L

e SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MANUAE STP-DC-021-D Potentially reportable deficiencies shall be promptly documented and the Design Quality Engineering (DQE) Group and AEP Services notified.for assuring that notifications are further given (in seq The AEPM-Special Services, EPM, Houston Quality Assurance to:

(QA) Coordinator, and Eicensing.

The Incident Review Committee (IRC), upon notifi vbether the condition is reportabic.

perform a safety evaluation and any other requested evaluation, EPM.

p the extent and nature of which shall be detersined by the Notification of the Client under these conditions is theO responsibility of the IRC.

@O 3.0 PROCEDURE

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3.1 PROCESS FLOW

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The process The process flow for EDDs is shown in Figure 1. flow for h

ENGINEERING DESIGN DEFICIENCIES m :en 3.2 s:=*O rg.*

3.2.1 Originating Discipline how the deficiency was detected, b

200.108 Identifies on Formsuch as during systems review, etc., and gives a d O

a.

Liessa 200.108.

Enters date detected and reported on Form b.

Indicates on Form 200.108 the total plant numbering system (TPNS) of the document describing or specifying the e.

requirements, title, and originator's name.

d.

Forwards Form 200.108 to DQE for action.

Design Quality Engineering 3.2.2 200.108. Identifies Reviews the deficiency reported on Form If whether the deficiency is design-based or proce a.

If a who determines the course of action required.

procedural requirement has been violated, may DPE.

. O 3 of 12

Et*d EC:1I S0/82/90 3 d1S old 38N Sn WOMd SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MANUAL STP-DC-021-D b.

Assigns EDD to responsible discipline with a due date and transmits via General Memorandum (GM) with GH number (orginal) entered on the form.

Checks to see if the EDD was sent to the IRC or reported c.

to the Nuclear Regulatory Commisaicu (NRC).

d.

Reviews responses to the deficiency reported on Form 200.108.

If in the judgment of the DQE the cited psoblem has not been resolved satisfactorily, confers with the EPM who determines whether further action is required.

Upon resolution and, if required, recurrence control approval, completes Form 200.108.

Provides trending and status reports to ensure that due e.

dates are met. Ensures that EDDs related to other deficien-cies (ADRs, NCRs, NRC citations, etc.) are correlated to that document.

f.

Assists the EPM in the analysis of recurring deficiencies.

3 Monitors for deficiencies that are reportable under 10CFR50.55(e) or 10CFR21, or are significant and/or recurring. Notifies AIPM-Special Services in accordance with Section 2.4 herein.

h.

Reviews closeout of all EDDs to ensure completeness and compliance with regulatory requirements and project procedures.

1.

Obtains AEPM-Special Services or designee signature and date for closeout, and transmits completed Form 200.108 via GM with GM number entered on the form.

3.2.3 Cognizant Discipline Project Engineer Respends to EDDs by required date, using Form 200.106.

a.

Sends response to DQE via GM with GM number (response) entered on the form (Ref. File A730G2),

t b.

Consults with DQE and EPM, as required. Provides any l

docuenented evidence or reference thereto to support l

response.

Initiates necessary documentation to correct deficiency, if required.

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SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MANUAL STP-DC-021-D b

Resolves the identified deficiency and provides plan to c.

preclude recurrence, if required.

d.

Provides followup responses where actions cannot be completed by the due date.

Monitors for deficiencies that are reportable under e.

10CFR50.55(e) or 10CFR21. Confers with DQE as necessary, f.

Marks the "Sent to IRC" block of Form 200.106 at such time that it is determined that the subject should be considered by the IRC for reportability.

g.

Signs and dates Tom 200.108 and forwards to AEPM-Special Services.

3.2.4 Assistant Engineering Project Manager-Special Services Signs and dates Form 200.J08 to close-out the EDD, when complete. W 3.2.5 Engineering Project Manager "h

Consults with DQE on EDDs, as required, to determine action co ensure prompt resolution and closecut.

3.2.6 Engineering Document Centrol Center M

[W Files EDDs in file A730GZ.

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3.3.1 Discipline Detecting the Deficiency O

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Obtains all available supporting information.

hy a.

b.

Notifies DQE promptly of a potentially reportable deficiency.

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3.3.2 Design Quality Engineering Notifies the AEPM-Special Services of the existence of the potentially reportable deficiency.

3.3.3 Assistant Engineering Project Manager-Special Services Notifies the Houston QA Coordinator, through the IRC a.

.. committee meeting of t.he potentially reportable deficiency

-- within four business hours after the EPM has been notified.

b.

Provides for direction of all safety and technical evaluation activities as specified by the EPM.

Coordinates activities between Engineering and interfacing internal and external organizations.

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P!'d 1C:11 58/82/90 3 d15 A18 OMN 50 WOdd SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MANUAL STP-DC-021-D 3.3.4 Cognizant Discipline Project Engineer Assists DQE in the preliminary assessment of the potentially a.

reportable deficiency.

b.

Provides resources for the safety and technical evaluation and reporting as directed from the EPM through DQE.

3.3.5 Engineering Project Manager a.

Participates in IRC meetings.

b.

Provides direction to Engineering personnel to accomplish necessary safety and technical evaluation (s) and reporting, as applicable.

4.0 SUPPORTING MATERIAL

4.1 REFERENCES

-Reference 1 ANSI N45.2.li-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants Reference 2 10CFR50, Licensing of Production and Utilization Fucilities,

Reference 3 10CFR21, Reporting of Safety-Related Defects and Noncompliances Reference 4 STP-PM-022, Procedure for the Evaluating and Reporting for Defects, Nonconformances, and Noncompliances 4.2 PROCEDURES CITED STP-DC-006 Engineering Procedure for Correspondence and Communication Control STP-DC-022 Engineering Procedure for Processing Nonconfor-mance Reports STP-DC-023 Engineering Procedure for Processing Field Change Requests STP-DC-024 Engineering P'rocedure for Supplier Deviation Requests 4.3 70Pns CITED Form 200.108 Engineering Design Deficiency Report 6 of 12 1

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SOUTH TEXAS PROJECT ENGINEERING PROC 2DURES MANUAL STP-DC-021-D DESIGN ENGINEERING ENG. DOCUMENT OBSE RVING COGNIZANT QUALITY PROJECT CONTROL DISCIPLINE DISCIPLINE ENGINEER MANAGER CENTER l

DS$ERVE8 DEFICIENCY COMPLETES F O RM 200.108 REVIEWS. APPROVES CONSULTS I

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FIGURE 1 ENGINEERING DESIGN DEFICIENCY FLOW CHART 7 of 12

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REPORT REVIEW REVIEW AND APPROVE COMPLETE APPROVE SUBMIT PER STPM4422 PROVID E CORRECTIVE ACTION AS REQ't FIGURE 2 PROCESS FLOW FOR REPORTABLE DEFICIENCIES 8 ef 12

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SOLTd TEXAS PROJECT ENGINEERING PROCEDURIS MANUAL STP-DC-021-D Reportable to NRC Per 10 CFR 50.85(e) o Deficiency is Significant a

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11*d 00:11 58/82/90 3 d15 AIM OMN SG WOMd SOUTH TEXAS PROJECT ENGINEERING PR00EDURES MAhTAL STP-DC-021-D 10 CFR Part 21 Reporting of Safety-Related Defects and Non-Compliances me Esseer pagwlaterv Cornemee.en recueres steerere one ressere.bse off%ere of ennem Arme one organavi ene to reeert esfese en serasenente ear fedures is comoey.ci regi.fstory roewromenu tosi mov resuft in a si.hetermai ester, ratera The new toewiscono are seerivnes as: r,pe to C9eerer r case streseret Aervdee ens - Enern - port 21. They seery er., Nrme inet e $wns. os.reta er som hAC i'ceasse fecihtee er tenswet NRC4ceeses or retvisted esernt es.

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s.0 SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MANUAL STP-DC-021-D i

APPENDIX A REQUIRE!!7,NTS FOR REPORTING DEFICIENCIES AS SPECIFIED IN 10CFR50.55(e)

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(1) If the permit is for construction of a nuclear plant, the holder of the permit shall notify the Commission of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant, and which represents:

M (i)

A significant(1) breakdown in any portion of the quality assurance program conducted in accordance with the require E,M ments of Appendix B; or (ii)

A significant deficiency in final design as approved and C

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releases for construction such that the design does not Q

conform to the criteria and bases stated in the safety "y

analysis report or construction permit; or g

c,m (iii)

A significant deficiency in construction of or significant y

damage to a structure, system or component which will N

require extensive evaluation, extensive redssign, or (3

extensive repair to meet the criteria and bases stated in 47,r me the safety analysis report or construction permit or to M

otherwise establish the adequacy of the structure, system, n"

or component to perform its intended safety function, or

,.. we (iv)

A significant deviation from perfcrmance specifications O

which will require extensive evaluation, extensive redesign,l M or extensive repair to es.tablish the adequacy of a structure, system, or component te meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function.

(2)

The term "significant" is not specifically defined and, as such, requires the use of judgement in each case. Thus, each deficiency that cannot be resolved by the routine application of engineering procedures must be reported to DQE, which will then report it in accordsnce with Section 2.2 of this procedure. This process should then ensure that its significance can properly be judged by those individuals charged with this responsibility.

A-1 of 2

01*d 62:11 58/02/90 3 d15 Als dan Sn WOWd SOUTH TEXAS PROJECT ENGINEERING PROCEDURES MANUAL STP-DC-021-D (2) The holder of a construction permit shall notify the appropriate Nuclear Regulatory Commission Inspection and Enforcement Regional Offfr2 of each reportable deficiencv within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.(2)

(3) The holder of a construction permit shall also submit a written report on a reportable deficiency within 30 days to the Division of Inspection and Enforcement with a copy to the Inspection and Enforcement Regional Office. The report shall include a description of the deficiency, an analysis of the safety implications and the corrective action.

If sufficient information is not available for a definitive report to be submitted within 30 days, an interim report containing all available information shall be filed, together with a statement as to when a complete report will be filed.

(4) Remedial action may be taken both prior to and after notification of the Division of Inspection and Enforcement, subject to the risk of subsequent disapproval of such action by the Commission."

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For ~the purposes of this procedure and all others related to the reporting of deficiencies to the NRC, "24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" shall mean 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time HL&P determines that a deficiency should be reported to the NRC.

A-2 of 2