ML20138H680
| ML20138H680 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/13/1985 |
| From: | Powell M HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| OL-S-145, NUDOCS 8510290120 | |
| Download: ML20138H680 (13) | |
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HOUSTON Ll2HTIN3 0 POWEQ COMPANY SOUTH TEXAS PROJECT
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PROCEDURE MANUAL
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MCkETfD
SUMMARY
OF REVISIONS UO.A I
race so susatcT REPORTING DESIGN AhD CONSTRUCTION
'85 PLP-02 DEFICIENCIES TO NRC OCI 17 A o.eq
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Changed procedure number from PEP-4.01 to PLP-02.
In additio',.n,:
changed the lead responsiblity for initial notification of all deficiencies solely to the Team Leader, Nuclear Licensing; removed distinction between site and home office handling of deficiencies and clarified engineering's role in the evaluations.
1 Complete revision to procedure.
2 Change to Section 5.6 changing Project Manager to Manager, South Texas Project.
Editorial changes to Attachment 9.3.
Revision to Attachment 9.5.
3 Changed " incident" to deficiency. Added new sections 4.2.10, 5.4, 6.5, 6.6 and re-renumbered existing Sections. Added new Attachments 9.8 and 9.9.
Attachments 9.5 and 9.7 were revised.
4 Changed Manager, STP Site to Deputy Project Manager in.8 on Page 23. Added Deputy Project Manager.9, page 24.
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5 Changed Executive Vice President, Nuclear to Group Vice President, Nuclear in Sections 4.2.9, 4.3.4 and 5.8.
Deleted reference to Vice President, Nuclear Engineering and Construction in Section 5.8 since this position no longer exists. Added the word boundary to attachment 9.5, item 8.1 to identify "the integrity of the reactor coolant pressure boundary." These changesareeditorialinn,agrj.
oee,ne30w W Nfi-SLomeieiEn. 9E/ELmf la the saatter of Staff V
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MEV.NO.
HOUSTcN Ll3HTING O POWE3 COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL
' AGE OF 1
24 TITLE PROJECT LICENSING PROCEDURE
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REPORTING DESIGN AND CONSTRUCTION 05-21-85 DEFICIENCIES TO NRC 1.0 PURPOSE To establish the procedure for identifying and evaluating conditions 1.1 which could potentially affect the safety functions of STP and for reporting deficiencies, defects and noncompliance to NRC in accordance with 10 CFR 50.55(e) and 10 CFR 21.
2.0 SCOPE This procedure applies to conditions identified during the design, 2.1 engineering, and construction phases of each unit of the STP, prior to the issuance of the operating license for each respective unit.
This procedure also applies to conditions reported to STP by its 2,2 architect-engineers, constructors, suppliers and any other contractors or consultants.
3.0 REFERENCE DOCUMENTS NRC I&E Information Notices 80-28. " Prompt Reporting of Information in 3.1 Accordance with 50.55(e)." 79-30, " Reporting of Defects and Noncompliance, 10 CFR Part 21."
3.2 10 CFR 50.55(e) - Attachment 9.1 10 CFR 21 3.3 3.4 NRC I&E Inspection Manual, " Guidance - 10 CFR 50.55(e) Construction Deficiency Reporting", 4-01-80.
Corporate Procedure, Handling of Conditions Potentially Reportable 3.5 under 10CFR21 3.6 Reporting of Safety-Related Defects and Non-Compliancies -.2 4.0 DEFINITIONS 4.1 10CFR50.55(e) Definitions-Asusedinthisprocedure Significant - Having an effect or likely to have an effect on, 4.1.1 or influence, the safe operation of the facility in an adverse manner.
Extensive - Expenditure of resources (tine, manpower, or money) 4.1.2 to a degree disproportionate with the original design, test or construction expenditure.
Final Design - Denotes those drawings, specifications, or other 4.1.3 engineering documents that have been reviewed, approved and released for fabrication, installation or construction.
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ST7 59 A it 83)
PROC. NO.
MEV.NO.
HOUSTON LIGHTIN3 6 POWER COMPANY SOUTH TEXAS PXOJECT PLP-02 5
PROCEDURE MANUAL Pact or 3
24 TITLE PROJECT LICENSING PROCEDURE s
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REPORTING DESIGN AND CONSTRUCTION 05-21-85 DEFICIENCIES TO NRC i
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(3) The capability to prevent or mitigate the conscquences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 100.11.
In all cases, the term " basic component" includes design, inspection, testing, or consulting services, important to safety, that are associated with the component hardware, whether these services are performed by the component supplier or others.
Those plant structures, systems, or components, or parts thereof, at a minimum, which are identified as either Safety Class 1, 2, or 3 or Seismic Category I, are basic components.
4.2.2 Commercial Grade Item - An item that is (1) not subject to design or specification requirements that are unique to facilities or activities licensed by NRC, and (2) used in applications other than facilities or activities licensed by NRC, and (3) able to be ordered from a manufacturer / supplier on the basis of specifications set forth in his published product description (e.g., a catalog).
A comercial grade item becomes a basic component after receipt when it is dedicated (designated for use as a basic component) by the recipient.
4.2.3 Deviation - A departure from the technical requirements of a procurement document for a basic component.
I Procurement Document - A contract which defines the l
4.2.4 requirements which the facility or basic component must meet in a
This order to be considered acceptable by the purchaser.
includes specifications, purchase orders and other documents that establish the requirements for purchaser acceptance and includes code requirements, drawings and procedures that are referenced as part of the procurement document I
4.2.5 Delivery - Transfer of control of a basic component. Delivery occurs upon acceptance of a basic component made subsequent to a test or inspection which takes place within a reasonable time after receipt. If no test or inspection is performed within a l
reasonable time, the basic component will be deemed to have been delivered.
If a component is rejected on the basis of a deviation identified during a receipt test or inspection.
l delivery has not occurred.
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STP 59 A (1[831 PXOC. No.
AEv.N3.
HOUSTON L12HTIN3 O POWED COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL PAGE op 5
24 TITLE PROJECT LICENSING PROCEDURE
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REPORTING DESIGN AND CONSTRUCTION 05-21-85 DEFICIENCIES TO NRC 1
contractors or consultants. See Attachment 9.8 for a listing of STP responsible individuals.
4.2.11 Constructing or Construction - The design, manufacture, fabrication, placement, erection, installation, modification, inspection, or testing of a facility or activity, and consult-ing services related to the facility or activity that are im-portant to safety.
4.3 Procedure Definitions Significant Deficiency - An event or condition which has an 4.3.1 effect or is likely to have an effect on, or influence, the safe operation of the facility in an adverse manner.
Initial Evaluation - Evaluation of a significant deficiency to 4.3.2 determine if it is a reportable or potentially reportable deficiency under 10 CFR 50.55(e) or if there is a need to consider it further under 10 CFR Part 21.
Technical Evaluation - The technical, including safety, evalua-4.3.3 tion of a significant incident to determine if the criteria for reportable deficiency under 10 CFR 50.55(e) or a defect or non-The technical evaluation compliance under 10 CFR 21 are met.
is performed subsequent to the initial evaluation.
Incident Review Committee (IRC) - The project comittee respons-4.3.4 ible for conducting the initici evaluation and subsequent tech-nical evaluation of significant deficiencies. Unless an incident review is conducted by a comittee under the direction and supervision of the Group Vice President Nuclear as a minimum, the IRC shall consist of the following members or i
their designees:
1.
ProjectLicensingEngineer(Chairman) 2.
Project QA Supervisor 1
l 3.
Cognizant Supervising Project Engineer, Houston Engineering 4.
Other cognizant individual (s) as designated by the Chairman.
4.3.5 Notification - A telephone, telegraphic or verbal report.
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STP % A (183)
PAOC.NO.
RE V. NO.
HOUSTON LIGHTING G POWE3 COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL PAGE OF 7
24 TITLE PROJECT LICENSING PROCEDURE f
REPORTING DESIGN AND CONSTRUCTION
^jf5-21-85 DEFICIENCIES TO NRC 5.5 Incident Review Committee (IRC)
The IRC is responsible for conducting the initial evaluation of 5.5.1 significant deficiencies and, if applicable, for initiating and reviewing the technical evaluation.
5.5.2 The IRC Chairman is responsible for drafting the written reports to NRC.
5.5.3 The IRC Chairman is responsible f'or publishing minutes of each IRC meeting. Minutes shall include, as a minimum, identification of participants, listing of deficiencies conside ed, and an explanation of findings, as applicable.
5.5.4 The IRC ' Chairman is responsible for notifying the NRC of potentially reportable deficiencies and reportable deficiencies. The initial notification (if appropriate) shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the time that the IRC Chairman is informed that there exists a significant deficiency.
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5.5.5 The IRC Chairman is responsible for maintaining files pertaining to 10 CFR 50.55(e) and 10 CFR 21 evaluations.
5.5.6 The IRC Chairman is responsible for notifying the originator of the disposition of those items referred to the IRC.
This may be accomplished by sending the originator a copy of the IRC meeting minutes.
5.6 Manager, Nuclear Licensing 5.6.1 The Manager, Nuclear Licensing is responsible for reviewing the IRC's completed evaluations and the written reports before submission to the NRC.
5.7 Manager, South Texas Project 5.7.1 The Manager, South Texas Project ensures that appropriate resources are made available to assure that evaluations and reports are completed in a timely manner.
5.8 Group Vice-President, Nuclear 5.8.1 The Group Vice-President, Nuclear is responsible for submitting the written reports to the NRC.
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STP 59 A (1-R3)
PROC. NO.
TJE V. N1 HOUSTON UGHTIN3 0 POWEn COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL PAGE OF 9
24 TITLE PROJECT LICENSING PROCEDURE REPORTING DESIGN AND CONSTRUCTION
^j'5-21-85 1
DEFICIENCIES TO NRC If the DEF is to be reviewed by IRC, it is so noted on the DEF 6.4.1 and imediately forwarded (hand-carried) to the IRC Chairman.
6.4.2 If the DEF is not to be reviewed by IRC, it is so noted on the form along with an appropriate explanation and copies sent to:
1 Originator 2
IRC Chairman
- 3) Responsible SPE In the event that a responsible individual (see attachment 9.8) 6.5 becomes aware that any STP supplier, contractor or consultant has notified the NRC of a 10CFR21 item that may be applicable to STP, he shall imediately so inform the IRC Chairman.
6.6 In the event that any of those individuals responsible for the interface with the STP architect-engineer and/or NSSS supplier becomes aware that the STP architect-engineer and/or NSSS supplier has notified the NRC, or HL&P, of a potentially reportable deficiency, he shall imediately so inform the IRC Chairman.
6.7 The IRC Chaiman, upon notification by the Manager, Engineering, of a significant deficiency; or by a responsible individual becoming aware of a 10CFR21 item reported by a vendor (per Section 6.5); or after being informed of a potentially reportable deficiency as required by Section 6.6; shall initiate an IRC meeting.
6.7.1 The IRC shall conduct an initial evaluation to determine if the significant deficiency is a potentially reportable deficiency, a reportable deficiency, or not reportable, under provisions of 10 CFR 50.55(e) and to determine if there is a need to further consider the deficiency under the provisions of 10 CFR 21.
6.7.2 The determination of the IRC shall be documented on an IRC Evaluation Form (Attachment 9.4). Minutes of the IRC meeting shall be available as soon as practicable. A copy of the IRC Evaluation Fom shall be sent to the originator.
6.7.3 If the IRC determines that a reportable or potentially reportable deficiency exists the IRC Chaiman shall notify the NRC. The initial evaluation and notification to NRC shall be accomplished within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time that the IRC Chairman was informed that a significant deficiency exists.
The notification to NRC must be documented in telephone minutes.
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I ST8 wa stam PRCC. NO.
KEV.NO.
HOUSTON UGHTIN3 6 POWEQ COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL 11 24 TITLE PROJECT LICENSING PROCEDURE REPORTING DESIGN AND CONSTRUCTION
^ 'f5-21-85
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i DEFICIENCIES TO NRC 4
for reportable or potentially reportable deficiencies that are also 6.9 determined to be reportable under 10 CFR 21, NRC shall be notified by including the appropriate information in the report described in Sec-f tion 7.0.
However, the Notification process and other subsequent requirements of this procedure shall be invoked as if the defect or noncompliance were a reportable deficiency under 10 CFR 50.55(e).
For deficiencies determined reportable under 10 CFR 21 but not otherwise reportable under 10 CFR 50.55(e), the NRC shall be notified in 10 CFR 21 requires initial notification accordance with 10 CFR 21.
within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of completion of IRC's determination that 10 CFR 21 1
applies.
6.10 The IRC shall also be convened from time to time by the IRC Chairman l
to review those DEF's that Engineering determined were not The purpose of this review is to provide added assurance 1
significant.
Meeting that all significant items are being considered by the IRC.
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minutes should include a listing of those DEF's considered and conclusions reached.
I' 7.0 REPORTS TO NRC For those deficiencies determined to be reportable under 10 CFR
'l 7.1 50.55(e) the written report will be submitted to NRC within 30 calendar days of the initial notification to NRC. This report shall For contain the pertinent elements identified in Attachment 9.6.
those items called into the NRC as potentially reportable but subsequently determined not to be reportable, verbal notification must be made to the NRC within 30 calendar days followed by written confirmation.
For those deficiencies determined to be reportable under 10 CFR 21 but i
7.2 not under 10 CFR 50.55(e), the written report shall be submitted to 1
NRC within 5 days of the completion of IRC's determination that 10 CFR l
21 applies.
i 8.0 MAINTENANCE OF RECORDS In addition to any other files maintained by applicable procedures, a 8.1 file of each deficiency evaluated by an IRC subsequent to the effective date of this procedure shall be maintained under the l
cognizance of the IRC Chairman.
Each file shall contain the documentation associated with the 8.2 deficiency including the IRC Evaluation Form with all supporting documentation, copies of minutes of IRC meetings, and all copies of written reports to NRC.
1 g
A copy of those items described in 8.2 shall be forwarded to Records 8.3 l
Management.
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STs59A (1 831 FnOC. NO.
- E v. No.
HOUSTON UGHTING O POWED COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL PAGE OF PROJECT LICENSING PROCEDURE 13 24 TITLE
^ '5$5. 21-85 PEPORTING DESIGN AND CCNSTRUCTION 0
DEFICIENCIES TO NRC Page 1 of 1 ATTACHMENT 9.1 - 10 CFR 50.55(e) te) 11) If the permit is for construc-(2) The holder of a construction tion of a nuclear poser plant, the permit shall with!n 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notify holder of the permit shall nottfy the the appropriate Nuerear Regulatory Commission of each defletency found Commission Inspection and Enforce-in design and construction, which, ment Regional Office of each reporta-sete it to hase remained uncortected, ble defici e
Id r 0f [cohructfon 7
could have affected adversely the (3) The permit shall also submit a written p s r plant a t e oughou MpoM on a Mportable defle.lency the expected lifetime of the plant. and within thirty (30) days to the-appro-which representa:
priate NRC Regional Office shown in (1) A signifleant breakdosTt in any Append 1s D of Part 20 of this chapter.
portion of the quality assurance pro.
Copies of such report shall be sent to gram conducted in accordance sith
- the Director of Inspection and En.
the requirements of Appendix B to forcement. U.8 Nuclear Regulatory this part; or Commission. Washington, D.C. 2035L (11) A significant defleiency in final The report shall include a desertation design as approved and released for of the deficiency, an analysts of the construction such that the design does safety implications and the corrective not conform to the critetta and bases action taken. and sufficient informa.
stated in the safety analysm report or Lion to permit analnis and evaluation construction permit; or of the deficiency and of the corrective (t!!) A significant deficiency in con-action. If sufficient infermation is not struction of or significant damage to a avaHable for a definitive report to be structure, system. or component which submitted withirt 30 days, an intenm will require extensive evaluation. ex.
tenstre redesten. or extensive repair to report containing a11 available infor.
meet the criterta and bases stated in mation shall be filed, together with a the safety analysis report or construc-statement as to when a complete tion permit or to otherwise estab1Lah report stU be fUed, the adequacy of the strveture, system.
(4) Remedial action may be taken or component to perform its intended both prior to and after notification of safety function; or the Division of Inspection and En.
tiv) A significant deviation from per*
forcement subject to the risk of subse-formance specifications which will M-quent disapproval of such action by quire extensive evaluation, extensive the Commission.
redesign. or extensive repair to estab-lish the adequacy of a structure.
system, or component to meet the erl.
terts and bases stated in the safety analy:La report or construction permit or to otherwise estabitsh the adequacy of the structure. system, or cotagonent to perforta lla,tratended safety func.
Lion.
I W2/F002/a
STP 59 A (183)
PT40C. NO.
GE v. NO.
HOUSTON LIGHTING & POWER COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDUHE MANUAL PAGE OF TITLE PROJECT LICENSING PROCEDURE 15 24 OATE ISSUED
$U BJE CT REPORTING DESIGN AND CONSTRUCTION 05-21-84 DEFICIENCIES TO NRC
- Reporting of Safety Refsted Defects and.2 Non Compliances Page 15 of 24
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STP57A (1 83)
FROC. N3.
KEV. N 2 HOUSTON UOHTING T POWE A COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL PAGE OF 17 24 TsTLE PROJECT LICENSING PROCCDURE
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^5$"
REPORTING DESIGN AND CONSTRUCTION 05-21-85 5"
DEFICIENCIES TO NRC ATTACHMENT 9.3 Page 2 of 2 INSTRUCTION FOR COMPLETING A DEFICIENCY EVALUATION FORM INSTRUCTION LINE NO.
The responsi5le SPE should assign and record form and revision 1
number; enter date report received.
Record the unit number (s) affected. Record the safety class 2
and seismic category of the system, structure, or component.
Give a brief description of how the deficiency was discovered.
3 Reference any deficiency related documents.
Record the title of the governing documents.
4 Record the requirement stated in the governing documents.
5 Describe the deviation and hazard as accurately and completely 6
as possible.
Signature of the initiator and the date the form was prepared.
7 The SPE marks the appropriate "yes" or "no" block, signs and dates 8
the DEF. Provide a short discussion of the basis for the determination. Distribution is made in accordance with Section 6.2.
The Manager, Engineering, marks the appropriate "yes" or "no" 9
block, signs and dates the DEF. Provide a short discussion of the basis for the determination. The Manager, Engineering may simply concur with the reason provided by the SPE.
Distribution is made in accordance with Section 6.4.
Steps 2 through 7 apply to DEF originator, f
M2/F002/a
e-STS 59 A (183I PLOC. N3 r,E v. N3 t
HOUSTON LI2HTIN3 0 POWE3 COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUA?.
PAGE OF PROJECT LICENSING PROCEDURE 19 24 TITLE e
I REPORTING DESIGN AND CONSTRUCTION 05-21-85 DEFICIENCIES TO NRC ATTACHMENT 9.4 Page 2 of 2 not noffritATI0g Cate Tine ledivid.a1 notified at MEL CI "
Notified oy F1 MAL ttFCR'A8!LITY Citita!4ATION (10CF#50.55fe)):
if5 no There esists a deficitacy in design or coestruction b
Deficieacy represents a significant (1) Breakdown in any portion of the CA Program (Per 10CFR50 Acceadia 8)
OR (11) Deficieecy7n final design as approved a*d released for construction (does not comfom to $AR ce CP)
Da (iii) Deficiency 7n ccestruction or construction damage which required estersive evaluation, redesign or repair CR (iv) Deviation From perfomance specifications which requires esteative evaluation, redesign or repair AC Weet it to remin uaTorrected could have adversely affected the safety of operations Teere esists a reportante deficiency:
. Attach all eecessary supportirg docume*tation -
Corewets:
htC notification (if required by step 6.6.6)
Date Tise ledividval notified at haC hetified by im6 kne t rNn Date Reviewed manager, nuclear Licensteg Este
STP 59 A (1 *3)
P ROC. N3.
9EV.N3, HOUSTON Lt2HTIN3 O POWE2 COMPANY SOUTH TEXAS PROJECT PLP-02 5
PROCEDURE MANUAL PAGE OF 21 24 TITLE PROJECT LICENSING PROCEDURE
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REPORTING DESIGN AND CONSTRUCTION
^{5-21-85 DEFICIENCIES TO NRC ATTACHMENT 9.6 Page 1 of I CONTENTS OF WRITTEN REPORT TO NRC If it is determined that the deficiency is reportable under 10CFR50.55(e), the written report will contain all of the inforrration, to the extent known, required The report shall include a description of the deficiency, an by regulation.
analysis of the safety implications and the corrective action taken, and suffi-cient information to permit analysis and evaluation of the deficiency and of the If sufficient information is not available for a definitive corrective action.
report to be submitted within 30 days, an interim report containing all available infomation shall be filed, together with a statement as to when a complete report will be filed.
If it is determined that Part 21 is applicable, then the report shall contain the following information to the extent known:
(1)
Name and address of individual infoming the Commission.
(ii)
Identification of the facility and the basic component which contains a defect or fails to comply.
(iii)
Identification of the fim supplying the basic component which contains a defect or fails to comply.
(iv)
Nature of the defect or failure to comply and the safety hazard which could be created.
Date on which infomation on the defect or failure to comply (v) was obtained. (i.e., date the determination of reportability pursuant to 10CFR Part 21 was completed.)
(vi)
Number and location of all such components (includes other HL&P nuclearplants).
Corrective action taken/to be taken, including responsibility foi (vii) corrective action, schedule for corrective action or length of time taken to correct.
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POCC. N 3.
CEV.ND.
HOUSTON Ll2HTIN2 G POWER COMPANY SOUTH TEXAS PROJECT PLP-02 5
i PROCEDURE MANUAL PAGE OF 23 24 TITLE PROJECT LICENSING PROCEDURE 7
ATE issuEo REPORTING DESIGN AND CONSTRUCTION 05-21-85 DEFICIENCIES TO NRC ATTACHMENT 9.8 List of Responsible Individuals Manager, STP Deputy Project Manager General Manager, Nuclear Engineering Manager Engineering (STP)
Manager, Nuclear Purchasing Manager, QA Manager, Project QA Manager, Nuclear Services Manager, Nuclear Fuel Manager, Nuclear Licensing Principal Engineer, STP Special Coordinator Supervising Project Engineer (Systems)
Supervising Project Engineer (Physical Design)
Supervising Engineer, STP Licensing Supervisor, Project Design / Procurement QA IRC Chairman I
M2/F002/a
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