ML20138J037
| ML20138J037 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/09/1985 |
| From: | Perlis R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-A-077, OL-A-77, NUDOCS 8510290226 | |
| Download: ML20138J037 (44) | |
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August 24, 1984 UNITED STATES OF AMERICA C5
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NUCLEAR REGULATORY COMMISSION g7, ccr BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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HOUSTON LIGHTING AND POWER COMPANY, )
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50-499
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(South Texas Project, Units 1 & 2)
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NRC ST'AFF RESPONSE TO LICENSING BOARD MEMORANDUM AND ORDER REGARDING THE REPORTABILITY OF THE QUADREX REPORT I. INTRODUCTION
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The Licensing Board has requested the Staff to brief various ques-tions related to the reportability of the Quadrex Report.
In its respense herein, the Staff describes the applicability of the reporting requirements of 10 C.F.R. $ 50.55(e),10 C.F.R. Part 21, and the require-ments established for notification of adjudicatory boards of new and important information. The Board also requested that the Staff " define the construction status of each safety-related item dealt with by the Quadrex Report and explain the basis upon which it was determined that l
various items had or had not been released for construction." (Memorandum and Order of June 22,1983at7).
In response to this request, the Staff herein provides additional information concerning the " released l
for construction" finding and provides further infonnation on the i
reportability of the various Quedrex findings.
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II. 10 C.F.R. 6 50.55(e) REQUIREMENTS In its review of the Quadrex Report, the Sttff examined, inter alia, the question of how much of the report should have been reported to the NRC under the provisions of 10 C.F.R. 6 50.55(e). As stated in the Staff Review (huREG-0948), the Staff determined that the Applicants had reported all Quadrex-related items required to be reported pursuant to Section 50.55(e),
primarily because "the design had not been released for construction, with the exception of those items reported." NUREG-0948 at 2, 20.
In*Part V of thic brief, the Staff provides additional justification for its findings on reportability pursuant to that Section.
In this portion of the brief, the Staff will explain how Section 50.55(e) applies to the findings by Quadrex.
The NRC's Office of Inspection and Enforcement ("IE") has issued a
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document providing guidance on the reporting requirements of Section 50.55(e).1/ The NRC review of the reportability aspects of Quadrex was perfonred in accordance with this guidance. The guidance, and Section 50.55(e) itself, make clear that for the provisions of the section to be triggered, the following must occur:
1)
There must be a deficiency found in design or construction; and 2)
The deficiency found must have the potential, if uncorrected, to adversely affect the safe operation of the plant; and 3)
The deficiency must represent one of the following:
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A copy of the IE guidance is attached as an Appendix.
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a)
A significant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of Appendix B; or b)
A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit; or c)
A significant deficiency in construction of or sigrri-ficant damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the
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adequacy of the structure, system, or component to perform its intended safety function; or d)
A significant deviation from performance specifications which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of a structure, system, or component to 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.
The regulatiori plainly applies to deficiencies in either design or construction. However, to be reportable, the deficiency must also have the potential to adversely affect safe operation and it must representoneofthefollowing(listedinfullunder#3above): a signi-ficant quality assurance breakdown; a significant deficiency in final t
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design as approved and released for construction; a significant deficiency in construction; or a significant deviation from perfonnance specifications.
It is apparent that the Quadrex Report, which reviews Brown & Root's design performance, does not indicate deficiencies falling into the two latter categories. While significant quality assurance breakdowns could conceivably be indicated in a design effort review, such breakdowns would not have the potential to adversely affect the safe operation of the plant unless the designs had received approval to be released for construction! The Staff therefore found the critical issue raised by Quadrex in tenns of Section 50.55(e) to be whether significant deficiencies in final design were uncovered, and thus focused in its review on the'second criterion:
whether Quadrex revealed significant deficiencies in final design as
, approved and released for construction."
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Section 50.55(e) identifies the triggering point for. reporting design deficiencies as " final design as approved and released for construction." Of course, even if this point is reached, in order to be reportable the design must also meet the first two criteria of Section 50.55(e): the design must represent a deficiency and the deficiency, if uncorrected, must have the potential to adversely affect the safe operation of the plant. The determination as to when a design is considered final for purposes of Section 50.55(e) depends upon the design and construction practices of the particular facility. The practice followed at South Texas is described in Part V, infra.
III. PART 21 REQUIREMENTS The Comission adopted the additional reporting requirements in r
10 C.F.R. Part 21 in 1977 to implement Section 206 of the Energy Re-l
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t organization Act. See 42 Fed. Rg. 28893 (June 6, 1977). Section 206 (as does Part 21) applies to individual officers of permittees, licensees, and suppliers of components to nuclear facilities and authorizes the imposition of civil penalties against such individuals for a knowing and conscious failure to report certain information to the NRC. Section 21.21 provides that the NRC must be notified when infonnation is obtained reasonably indicating that a facility, or activity, or basic component, fails to comply with the Atomic Energy Act or the Comnission's regulations relating to a " substantial safety hazard" or contains a " defect."
A defect is defined in Section 21.3(d) as a " deviation" (a departure from the technical requirements included in a procurement document) in a basic component " delivered to a purchaser for use in a facility" if the defect could create a substantial safety hazard. As defined in Section
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21.3(a)(3), designs are considered basic components. " Substantial safety hazard" is defined in Section 21.3(k) as a loss of safety function to the extent that there is a major reduction in the degree of protection provided to the public health and safety. Insofar as Part 21 relates to construction l
permit holders, its coverage is similar, albeit somewhat narrower., than the coverageofSection50.55(e). SeeIEGuidanceonSection50.,5(e)at 10-11. NUREG-0302 Rev. 1 provides guidance on the applicability of Part
- 21. Both that document (at p.21.21(b)(1)-15) and the IE Guidance on Section 50.55(e) (at 10) make clear that items reported pursuant to Section 50.55(e) need not be reported again to satisfy Part 21. A design not yet released for construction could not constitute a " defect" because it has not yet been " delivered." Similarly, a preliminary design would not constitute a major reduction in the degree of protection provided to i
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6-the public health and safety and thus would not constitute a substantial safety hazard.
Inasmuch as Section 50.55(e) imposed at least as strict requirements as did Part 21 on the Applicants' reporting of the Quadrex It is the Staff's Report, the Staff focused on the former requirement.
position that Part 21 in fact imposed no requirement upon the Applicants (insofarasreportingofQuadrexisconcerned)notcoveredbySection 50.55(e) and that the question of whether Applicants adequately reported Quadrex-related matters to the NRC can be resolved by focusing on khether Applicants followed the requirements of Section 50.55(e).
IV. NOTIFICATION TO THE LICENSING BOARD PURSUANT TO THE McGUIRE AND BROWNS FERRY DECISIONS Section 50.55(e) and Part 21 impose reporting requirements on construction permit holders (and others) in order to ensure that the NRC Staff has sufficfent infomation to determine whether a nuclear facility has been constructed and will operate safely. In addition, all parties to licensing proceedings have an obligation under certain circumstances to report information to NRC adjudicatory tribunals. This obligation has been fleshed out by a number of Appeal Board decisions.
In McGuire,E he t
Appeal Board (and the Licensing Board) adjudicating the adequacy of the applicant's quality assurance organization were not notified of important changes in that organization. The Appeal Board wrote that " reasoned decision making" would suffer and adjudication would become meaningless if boards were not apprised of changes so that the evidence upon which the boards must rule accurately reflects existing facts. The Appeal Board has subsequently reaffirmed this principle a number of times. See, l
1
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Duke Power Compan (McGuire Station, Units 1 & 2), ALAB-143, 6 AEC i
623, 625-26 (1973.
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P g, Duke Power Company (Catawba Station, Units 1 and 2), ALAB-355, 4 NRC 397, 406 at n.26 (1976); Georgia Power Company (Vogtle Plant, Units 1and2),ALAB-291,2NRC404,408-12(1975).
In a later case in which the Appeal Board confronted the obligation to report information to adjudicatory bodies, the Appeal Board concluded that parties to pro-ceedings must notify adjudicatory bodies directly regarding "(1) new information that is relevant and material to the matters being adjudicated; (ii) modifications and rescissions of important evidentiary submis'sions; and(iii)[outdatedorincorrectinformationonwhichtheboardmight otherwise rely]." Tennessee Valley Authority (Browns Ferry Plant, Units 1, 2 and 3), ALAB-677, 15 NRC 1387, 1394 (1982).
In June of this year, the Appeal Board once again examined the issue of a party's obligation to report information to adjudicatory boards.
In Metropolitan Edison Company-(Three Mile Island Station, Unit 1), ALAB-774,19 NRC (SlipOp., June 19,1984), the Appeal Board faced a claim that a licensee's failure to submit certain reports earlier showed a lack of integrity on the part of licensee's management.
The Appeal Board noted (Slip Op. at 12) that whether the reports could be characterized as material evidence (and hence reportable) was open to question. The Appeal Board went on to say that "[i]n such cases of i
reasonable doubt... the information should be disclosed for the board l
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In Three Mile Island, the Board found that although the infonnation shoulc have been reporte'd to adjudicatory boards sooner, the l
licensee had voluntarily revealed the existence of the document to NRC personnel and that there was no basis to support an aturtion that the licensee had attempted to intentionally conceal infonnation from the NRC. Slip Op. at 14-15.
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... The Staff took the position when its counsel first learned of the Quadrex Report, and it continues to maintain, that under the principles cited above the Report should have been provided to the Licensing Board in May of 1981.
It is open to question whether the Report modifies specific information already presented to the Board. The Staff does however consider the Report relevant and material to the issues addressed in Phase I of While Phase I focused on management competence and specific the hearing.
construction defect issues, central underlying issues were qualitf as-surance and the safe construction of the South Texas Plant. The Quadrex Report, raising as it does important questions relative to the design work of Brown & Root and the quality control in that design, necessarily raised related questions on the adequacy of the coristruction work at the site.
_The Staff is of the view that under the circumstances the Report should have been provided to the Licensing Board when issued.
V.
REPORTABILITY OF INDIVIDUAL QUADREX ITEMS As noted above, the Board requested that the Staff " define the construction status of each safety-related item dealt with by the Quadrex Report and explain the basis upon which it was detennined that various items had or had not been released for construction." The Staff has examined the Quadrex Report, Bechtel's Assessment Report, and the earlier Staff review (NUREG) to review again the reportability of each Quadrex item under Section 50.55(e).
Each nonreportable item was assigned one of the following categories:
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An economic rather than a safety-related issue.
2.
A timeliness or scheduling concern rather than a safety issue.
3.
Design activities still in progress.
4.
No safety deficiency, as defined by 10 C.F.R. 50.55(e),
identified.
5.
No safety deficiency, as defined by 10 C.F.R. 50.55(e),
identified; however, Bechtel to perfonn additional calculations, examinations, or evaluations.
6.
Finding related to content of procedures; no safety deficiency identified.
7.
Finding questioned adequacy of documentation; no safety deficiency identified..
The 17 Generic Quadrex findings were not analyzed in this assessment in that these findings are based on an evaluation of the discipline
' firidings' and do not represent new findings.
As to the question of when an item can be considered as " released l
for construction," it should be pointed out that Brown & Root utilized a procedure (a copy of which is attached) that identified the status of design drawings. Thus a determination of whether items were released for construction at South Texas does not depend on subjective analysis or engineering judgment. As indicated in the attached procedure, designs were indicated as issued preliminary, issued for use, issued for con-I struction, or issued for review. The use of a drawing was dependent on its status; to be involved in construction, drawings must have been designated as " issued for construction." Thus there is a direct in-dication of items " released for construction."
The Staff had originally, in preparing NUREG-0948, examined each safety-related item dealt with by the Quadrex Report and had on an
individual basis determined whether the item was reportable. This determination was based on the safety significance of each item and, if an item were found to have safety significance, on whether the item had been released for construction. In attempting to respond to the Board's request by again subjectively determining whether an item had been released for construction, the Staff discovered that the information necessary for such a response is difficult to obtain and would require a reexamination of not only the Quadrex work packages, but a winnowing out from all South Texas drawings of those relevant to each work package.
Again, it should be stressed that to be reportable, an item must l
represent a deficiency, the deficiency must have the potential to adversely affect safe operation, and the deficiency (for these purposes).
must represent a significant deficiency in final design as released for construction. Both the Staff's more recent review and the original review discussed in NUREG-0948 reached the same conclusion: all The more recent reportable Quadrex-related items were in fact reported.
findings are not inconsistent with the earlier findings; if any of the three criteria are not met, an item would not be reportable. The Staff l
hopes this later review will be helpful to the Board in resolving any questions concerning the reportability of individual Quadrex items.
This analysis of the Quadrex findings is attached hereto.
VI. CONCLUSION Insum,theStaffsubmitsthatSection50.55(e)istheapplicable regulation with which to examine the reportability of various portions 4
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of the Quadrex Report; that Part 21 does not impose any additional l
requirements (as far as the Quadrex Report is concerned) not imposed by Section 50.55(e); and that under the Appeal Board decisions cited above, the Applicants should have provided the Report to the Licensing Board l
in May of 1981. The Staff also provides attached hereto a further analysis of the reportability of individual Quadrex items.
Respectfully submitted, Y / g-Robert G. Perlis Counsel for NRC Staff Dated at Bethesda, Maryland J
this 24th day of August, 1984 1
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l-UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
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In the Matter of
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Docket Nos. 50-498 l
HOUSTON LIGHTING AND POWER COMPANY, 50-499 j
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(South Texas Project, Units 1 & 2)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO LICENSING BOARD MEMORANDUM AND ORDER REGARDING THE REPORTABILITY OF THE QUADREX REPO
- j in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an l
asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this 24th day of August, 1984:
l Charles Bechhoefer, Esq., Chairman
- l Administrative Judge Brian Berwick, Esq.
Atomic Safety and Licensing Board Assistant Attorney General Environmental Protection Division Panel 4
U.S. Nuclear Regulatory Commission P.O. Box 12548 Capitol Station f
i Washington, DC 20555 Austin, TX 78711
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Dr. James C. Lamb III Administrative Judge Jack R. Newman, Esq.
313 Woodhaven Road Newman & Holtzinger, P.C.
j Chapel Hill, NC 27514 1025 Connecticut Avenue, N.W.
Washington, DC 20036 j
l Mr. Ernest E. Hill Administrative Judge Hill Associates Mrs. Peggy Buchorn r
l 210 Montego Drive Executive Director Danville, CA 94526 Citizens for Equitable Utilities, Inc.
Melbert Schwarz, Jr., Esq.
Route 1, Box 1664 1
j Brazoria, TX 77442 Baker and Botts l
One Shell Plaza i
Houston, TX 77002 Mr. Lanny Sinkin i
Citizens Concerned About l
William S. Jordan, III, Esq.-
Nuclear Power Hamon & Weiss 114 W. 7th, Suite 220 1725 I Street, N.W.
Austin, TX 78701 i
t Suite 506 Washington, D.C.
20006 i
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I Atomic Safety and Licensing Board Kim Eastman, Co-coordinator Panel
- Barbara A. Miller U.S. Nuclear Regulatory Comission Citizens Concerned About Nuclear Washington, DC 20555 Pat Coy Power Atomic Safety and Licensing Appeal 5106 Casa Oro Board Panel
- San Antonio, TX 78233 U.S. Nuclear Regulatory Comission Washington, DC 20555 Mr. David Prestemon*
Legal Counsel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Docketing and Service Section*
Office of the Secretary '
U.S. Nuclear Regulatory Comission Washington, D.C.
20555 d'
Rotiert G. Perlis
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5 E;uidance - 10 CFR 50.55{CCbnjtruction Deficie'nc33@rtinog 1.
PURPOSE _
i Deficiency reporting based on the requirements of Part 50.55(e) is designed to provide the fiRC -taff with prompt notification and timely information of deficiencies encountered during construction of nuclear power plants.
The intent of the Rule is to provide a basis for evaluation on the part of the tiRC with respect to potential safety consequences of deficiencies and the need for further action by NRC.
2.
DISCUSSION - GEtiERAL The conditions of construction permits are contained in 10 CFR 50.55.
Subpart 10 CFR 50.55(e) imposes a reporting requirement on construction permit (CP) holders to report each deficiency found in design and construction which if it were to have remain uncorrected could have adversely affected the safety of operations of the nuclear facility at any time throughout the expected lifetime of the plant.
Reporting is limited to deficiencies which meet certain other requirements as discussed below.
3.
RESTATE!4EfiT OF THE REGULATION The entire subsection of 10 CFR 50.55(e) is included here for conyanience.
50.55(e)(1)
If the pennit is for construction of a nt clear power plant, the holder of the permit shall notify the Connission 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:
i (i)
A significant breakdown in any portion of the quality assurance program conducted in accordance with the
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requirements of Appendix B; or i
(ii)
A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit; or (iii)
A significant deficiency in construction of or significant damage to a structure, system, or comp'onent which will i
require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, i
or component to perform its intended safety function; or
10 CTR 50.iMe)
Issue D ie:
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(iv)
A significant deviation from performance specifications which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of a structure, system, or component to 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 holder of a construction permit shall within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notify the appropriate Nuclear Regulatory Commis,sion Inspection and Enforcement Regional Office of each reportable deficiency.
(3)
The holder of a construction permit shall also submit a written report on a reportable deficiency within thirty (30) days to the appropriate NRC Regional Office shown in Appendix D of Part 20 of this chapter.
Copies of such i
report shall be sent to the Director of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, k'ashington, D.C. 20555. The report shall include a description of the deficiency, an analysis of the safety implications and the
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l corrective action taken, and sufficient information to l
permit analysis and evaluation of the deficiency and of 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.
J (4)
Remedial action may be taken both prior to and after notification of the Division of Inspection and Enforcement i
subject to the risk of subsequent disapproval of such j
action by the Comission.
I 4.
APPLICABILITY Subsection 10 CFR 50.55(e) applies to the CP holder and his contractors.
The CP holder is responsible for reporting each deficiency in accordance with the criteria and requirements of 10 CFR 50.55(e).
The regulation applies to design and construction and encompasses all of the activities inherent in design and construction even though they may be parformed by agents, contractors, subcontractors or consultants. The CP holder must establish and implement a system that assures all reportable deficiencies are identified and reported and the reporting requirement ~must be imposed on his agents, contractors and subcontractors.
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CRITERIA FOR REPORTING a.
Deficiency (1) must have been identified, i.e., found (2) related to activities conducted as authorized by a construction permit holder (design, construction or modification)
(3) could adversely affect the safe operation of a facility if it were not corrected, i.e., it is significant (4) significant deficiency relates to one or more of the following-(a) breakdown in QA program (b) design released for construction i
I (c) damage to a structure, system or component (d) construction of a structure, system, or component (e) deviation from performance specifications b.
Timeliness (1)
Initial report - within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (2) Written report - within 30 days (initial or final)
(3) Supplemental written report (s) as necessary to provide all information.
RepohtingOrganization
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c.
The CP holder is responsible for implementing instructions which will provide for licensee reporting of all reportable deficiencies identified by organizations authorized by him to conduct construction phase activities.
6.
CLARIFICATION OF 50.55(e) PHRASES
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a.
Could adversely affect l
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If a deficiency meets all the criteria and it could affect adversely safe operations of the facility, it is reportable.
"Could" does not imply that it would absolutely adversely affect safe operations.
It implies a probability that safe operations may be adversely affected if the proper conditions existed.
"At any tire" r.eans that all service and accident conditions of operation must be considered.
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10 CTP. K.EE(e)
Issue Date:
- /1/j0 1
The fact that a deficiency is obvious and couid not possible go uncorrected arid therefore could not adversely affect safe operation
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does not negate the requirement to formally report the deficiency if it meets the criteria of 50.55(e).
b.
Sionificance To be reportable under 10 CFR 50.55(e) a deficiency must be significant.
Significant is interpreted as having an effect or likely to h. ave an i
effect on, or influence, the safe operation of the facility in an adverse manner.
Although "significant" is not defined in 50.55(e), it is not the intent that trivia be reported. Significance primarily pertains to operational safety and not to the cost of the corrective action.
however, as indicated below, the cost to repair or redesign provides on indicator of the term " extensive." Trivial situations such as cosmetic defects are not reportable.
The test of significance includes but is not limited to safety related
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items / activities as discussed below.
i (1) It is important to note that the regulation does not specifically state that 50.55(e) applies only to safety related structures, systems and components although this may be inferred from the wording.
The 50.55(e) recuirement aoplies to any structure, system or component (SSCs) if it contains a deficiency which were it to have remained uncorrected could have affected adversely the l
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 r'esult of an adverse interaction with safety related SSCs.
Primary examples of this are undesirable conditions or failures in a nonsafety system, structure, or component which could impact or degrade safety systems or a safety function.
The inspector must use caution in applying 50.55(e). to nonsafety SSCs and must satisfy himself that the licensee has considered the interactions that a deficiency in a nonsafety SSC could create.
(2) If a deficiency involves inadequate management reviews, it may be significant.
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10 CTR 50.55(e)
Isst.e Date:
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c.
Extensive An item is reportable if it requires extensive evaluation to determine if it is adequate to perform its intended safety function or will not impair the accomplishment of a safety function through adverse interaction.
Extensive means the expenditure of resources (time, manpower, money) to a degree disproportionate with the original design, test or construction expenditure. The inspector should use caution - this requires judgement and experience.
For example, the lack of extensive evaluation may be used as a justification for not reporting.
But it also may indicate an inadequate evaluation due to expense involved or a failure to consider interactions and therefore should be considered suspect.
Redesign may appear to be not extensive; the inspector should verify that all interactions and interfaces have been considered and that sufficient design margin is available.
d.
Significant Breakdown in Quality Assurance A breakdown in the QA program related to any criteria in 10 CFR 50, Appendix B, may be a reportable deficiency depending upon its significance.
This applies to those design and construction activities affecting the safety of plant operations, including activities such as design verification, inspection, and auditing.
For example, QA program brea'kdown may result from an improper identification system for safety related materials. More specifically, the implementing procedures may be incomplete or otherwise inadequate, or the execution of adequate procedures may be incomplete, improper or completely ignored. In the latter case, not following established procedures to assure that specified quality related iequirements are met, for example,: may constitute a breakdown in the QA program that is reportable.
Similarly, an inadequate record keeping system that makes it impossible on a broad scale to detemine whether quality requirements have been met, is another example.
In such a case extensive evaluation and testing may be required to establish that applicable requirements have been met.
Conversely, occasional, incomplete or otherwise inadequate records i
that do not indicate a significant breakdown in the QA program nor an unsafe condition are not considered reportable.
Fo) example, if during site construction, delivery times (from mixing to placing) of a few of many truckloads of concrete are not recorded as required, and it can be shown by other records that requirements important to safety have been met, the matter would not be reportable.
These other records may be related concrete truck trip tickets, batch plant records or acceptable test results of concrete samples representing concrete from these trock.
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10 CTR E3.55(e)
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h tification and Reporting e
(1) fictification - Reportable Deficiency 10 CFR 50.55(e)(2) specifies that the CP' holder shall notify the appropriate fiRC Regional Office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of each reportable deficiency.
fictification means: (a) telephone report; (b) telegraphic report; and (c) verbal report to the fiRC Regional Office af ter becoming aware of a reportable A
deficiency, excluding holiday or weekend elapsed times.
notification to a fiRC representative ? resent at the CP holder's facilities does not satisfy the regulation.
The threshold for notification ('not reporting) is considered to be within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter licensee (CP holder) becomes aware of i
the reportable deficiency (or potentially reportable deficiency as clarified below).
Aware of the deficiency means that any cognizant licensee individual has knowledge of the deficiency as a result of:
(d) observation of condition (e) a formal submittal by any organization involved in the f'
design, construction, evaluations or inspection of the
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facility (f) an informal report, or allegation. by any organization or person.
(2) tiotificaElon - Potentially Reportable Deficiency 4
All of the reportability criteria of 50.55(e) may not be satisfied when a deficiency is initially discovered.
It is not always possible for the licensee to decide promptly during an evaluation However, in most wMether the identified deficiency is reportable.
cases, significance can be partially satisfied, or sound judgement
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will indicate potential significance.
In these cases, it should be considered 'that the deficiency is a potentially reportable deficiency, and the Regional Office should be notified.
The CP holder should specify that it is a potentially reportable deficiency.
The following IE position has been established to alleviate the apparent conflict between prompt notification and necessary evaluation time,for those cases where an extended period of time could lapse in completing a adequate evaluation of the identified i
deficiency:
flotification by telephone to the Regional Office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a cognizant licensee individual becomes aware of
[
a potentially reportable deficiency is considered acceptable.
(
A potentially reportable deficiency is considered to exist
10 Cri. 50.5E(e)
I:, ee S te:
4/'/I?
- when: (1) an intial prept review of available information indicates that the problem could be significant (i.e. -
partial significance is established),but, for various reasons, additional time is required to complete the evaluation; and (2) the deficiency may be considered significant, but neither a prompt review or full evaluation can be completed within 14 days due to lack of specific informa tion.
For example, an extensive evaluation period may exist when the licensee cannot determine without testing and analysis whether the physical properties relative to the material used for a section of reactor coolant piping were met, the licensee should promptly notify the Regional Office of this matter.
If the results of the above analysis indicates that the material is not acceptable, extensive evaluation and/or rework may be required.
If this is the case, it is clearly a reportable deficiency.
Conversely, if the analysis in the above example confirms acceptability of the material, the licensee should document these results in his records and notify the Regional Office that this deficiency was determined not to be significant based on the results of further analysis or investigation.
Consequently, some matters which require notification may not, subsequently, require a written report.
In surr.ary, the intent is to require a prompt notification in cases where a potentially reportable deficiency has been identified but the formal evaluation required to confirm whether the item is reportable can not be completed immediately.
(3)
Interim Report The CP holder may meet the 30 day written report requirement by submitting an interim report in lieu of the complete report if sufficient information is not available for a definitive report.
The int'erim report should specify:
(a) the potentia 1 problem and reference the notification (b) approach to resolution of the problem (c) status of proposed resolution (d) reasons why a finai report will be delayed (e) projected completion of corrective action and submittal date of the complete report.
l
i M Cir.
I. E 5 ( e)
- -*v M c:
4/1/g l.
(4)
Complete Report The regulation requires that the CP holder submit a written report to the appropriate Regional office within 30 days after initial notification.
If an interim report is submitted the final report shall be due on the date comitted in the interim report.
The complete report shall contain:
(a) description of the deficiency (b) analysis of the safety implications. This should include an identification of interfacing systems and possible inter-actions.
(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 1
explored and identified.
(d) sufficient inforrration to permit analysis and evaluation of the deficiency and of the corrective action.
7.
ENFORCEMENT
\\
If a CP holder is aware of a reportable deficiency and it can be shown by objective evidence that he' has not met the time reporting requirements, then he is in noncompliance with the reporting requirement of 50.55(e) and enforcement action should be taken.
The licensee should be encouraged to discuss "reportability" with the responsible IE inspector whenever he has a question or doubt regarding this mat.ter.
It is appropriate for the inspector to indicate his views r.
on whether a particular matter is reportable, but the licensee should understand that the ultimate responsibility remains with the licensee, and the inspector's judgement may change during a future inspection wherein he has an opportunity to fully review the circumstances asso-ciated with the matter.
l Another aspect of this Regulation related to reportability detennina-tion pertains to judgement--judgement used by the licensee in deter-mining whether a matter is teportable.
The licensee h,as to make a judgement based on his (or others) evaluation / analysis.
If the i
licensee decides, on the basis of the above, that a matter is not reportable, he may have satisfied the intent of this part of the 1
Regulation.
However, the inspector can exercise his option and
(,
challenge the licensee's decision of nonreportability.
A challenge may be valid if:
the evaluation is clearly faulty by way of omission of facts
!ssue ::te:
4 / L'I3
.g.
the evaluation is not supported by adaquate records i
the evaluation has not considered interactioni past IE experience (including that of the inspector) provide a basis l
as precedent.ur reportability the licensee has established a trend or pattern of habitually 1
evaluating deficiencies as non-reportable evaluation is performed by a person (s) or organization withou,t expertise in the subject.
The inspector has the right and the responsibility to examine the technical validity of the licensee evaluation and if an inappropriate or unsupported.
1 decision of nonreportability has been made by the licensee, enforcement action should be considered.
Regional management should review and, when valid, determine the appropriate enforcement action to take.
If there is evidence that superficial evaluations are being made to procedurally satisfy or bypass NRC requirements, strong escalated enforcement action should be considered.
(MC-0800 will be changed, accordingly) 8.
RELATION TO APP. B REQUIREMENTS i
10 CFR 50, Appendix B, requires procedures to be established and records maintained to handle required actions relative to resolution of identified I
deficiencies. Procedures and records (as in (1) and (2) below) are required to assure prompt notification and adequate reporting under 50.55(e). Means to do this should be an integral part of each licensee's QA program.
i (1)
Implementing procedures Althougfi the specific requirements of 50.55(e) are few (notify, evaluate, report), implementing procedures to assure that these
' requirements are met should be established by the CP holder.
For i
example, some means '(such as procedures or instructions) are required to assure that deficiencies found in design and construction activities 1
delegated by the licensee to others are handled properly and reported i
in a timely manner to the CP holder.
The procedures should assure that the evaluation of the significance of the deficiency to the safety of plant operations is performed by a person (s) with adequate expertise in the subject and that adequate management review is provided.
I (2) Records I
The licensee should maintain records to demonstrate that adequate evaluation / analysis of all defielencies was rnade regarding the irpact r
on safe operations.
It is appropriate for the IE inspector to inform the licensee that without such records the appropriate itcensee rara;crent cannot establish whether such evaluations were made or whether the NRC reoutrm* 'cociated with this activity were overlooked.
10 CFR SC.5E(e)
- n.e
- .e:
4 " J. 3
(
i '
l i
9.
RELATIONSHIP TO 10 CFR 21 REPORTING 4
)
Reporting of Defects and Noncompliances (10 CFR 21) inposes a reporting requirement on licensees and permit holders to immediately notify the Comission of defects, in basic cornponents or the facility which could create a substantial safety hazard.
There are certain situations which i
l can result in duplicate reporting of the same defect under 50.55(e) and Part 21 requirements.
Guidance that duplicate reporting is not the intent a
]
of the NRC regulations has been promulgated via NUREG-0302, Rev. I and t
i i
in correspondence supplied to the Atomic Industrial Forum.
This guidance l
is reproduced below:
(1) NUREG-0302 Rev.1 Guidance _
Must items reported as Significant Deficiencies (under Q.
50.55(e)) or Reportable Occurrences (under 50.36) also j
be reported as required in 10 CFR 217 j
A.
Duplicate reporting is not required.
Care should be exer-cised, however, to assure "that the Comission has been adequately infomed" (521.21b) and the infomation specified
(
in 521.21(b)(3) is provided should the reporting party's 2
evaluation show that a notification is required.
4 i
Q.
How do we determine when to report a " problem" under the provisions of 50.55(e) vs the provisions of Part 217 A.
550.55(,e) requires initial reporting in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,of the time licensee or his agent first identifies a significant defi-ciency.
A followup report is required in 30 days.
If evaluation requires substantial time to complete, interim l
i l
. report (s) are acceptable.
I l
121.21(b)(1) requires reporting within two days of when the j
director or responsible officer obtains information reasonably indicating a failure to comply cr a defect with a written report required within five days.
l In all cases, the exercise of reasonable judgement is expected in reporting potentially reportable problems to l
avoid the severe penalties, which could be imposed should j
the problem turn.out to be reportable.
i I
Q.
10 CFR 50.55(e), Conditions of Construction Pemits, requires f
I that the holder of a pemit notify the Comission of certain l
designs and construction deficiencies which are also the l
subject of 10 CFR 21. Why has not 10 CFR 50.55(e) been deleted?
i
\\
l
10 CFR D.55(c)
Issue N ie:
- 'O.
550.55(e) requires reporting that wou1d not be reported A.
under Part 21.
For example,1) significant damage to a basic component following delivery to the site is report-able under 50.55(e) and not under Part 21; and 2) a signifi-cant break down in quality assurance is reportable under 50.55(e) and not under Part 21.
Is the detemination of a " defect" based on the same cri-Q.
teria as provided in Part 50.55(e) and/or the requirements for technical specifications for operating plants?
In the case of the pemit holder, however, a defect No.
A.
reportable under Part 21 would also be reportable under In the case of the licensee some items 10 CFR 50.55(e).
could be reportable under Part 21 that are not reportable as LER.
For possible problems noted under 10 CFR 50.55(e) we report Q.
Will to the Comission "possible significant deficiencies."
we be allowed to report "possible defects and noncompliances" under the requirements of 10 CFR Part 217 Yes, a report may be rade during the evaluation before the A.
conclusion is reached that the deviation is a defect.
A report is not required, however, until 2 days after the responsible officer or. director is infomed of the conclu-sion reached as a result of the evaluation.
It appears to us that there will be more reports filed with Q.
the Comission under the requirements of 10 CFR Part 21 than under 10 CFR 50.55(e). Does the Comission have this same belief?
The majority of items subject to reporting unde r 50.55(e)
No.
A.
would not fit the definition in Part 21 for a " defect" involy-ing a " substantial safety hazard." For those c.7ses where both 50.55(e) and Part 21 reporting requirements may apply, it is expected that pemit holders will report only under 50.55(e) as long as they include the infomation required by Part 21 to adequately infom the Comission.
Supplemental Guidance Supplied to Atomic Industrial Forum on 0/A (2)
B and 16 Under 21.21(b)(1) of t;UREG 0302, Rev.1 The regions are authorized to use the enclosed staff positions on These positions 10 CFR Part 21 in ccmunications with licensees.
were pre;,ared in response to inquiries from AIF and supplement In particular, until pertinent those of fiUREG 0302, Rev. 1.
reporting regulations are amended, the staff position response to AIF should be used in answering licensee questions on he,w and when
..,s in lieu of dual reportinn uP en e-r s.--.<~.,,,,s
10 CFR 50.iE(e)
I:.ste Date:
a4 :3 i
When a combined 50.55(e)/Part 21 event,is reported by a licensee to the regional office by telephone, the region should use 150.55(e)(3) and 121.21(b)(3) information requirements for guidance to assure that the Comission is " adequately informed." Where an event is reported under 50.55(e) and it is (subsequently) established that the event is also reportable under Part 21 the licensee should be informed that it is acceptable for the licensee to provide the information required under 121.21(b)(3) via a supplement to the initial 50.55(e) report.
(From N. Moseley to Reg. Director memo of 5/8/79 forwarding 4/26/78 letter sent to AIF)
It is the staff's position that the licensee is not required to report I
under Part 21 an occurrence that falls within the scope of either Part 21 or 50.55(e) or Reg. Guide 1.16 if that occurrence is reported in accordance with 50.55(e) or Reg. Guide 1.16 requirements.
In such cases, it is also the staff's position that the time requirements (oral, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under 50.55(e) and R.G.1.16) of the reporting method used would be controlling and, for the licensee, the Part 21 reporting I.
times would not be applicable.
(Does not change prior staff position l
relative to information (21.21(b)(3)) requirements)
However, a director or responsible officer of a non-licensee.
organization upon receiving infomation of a reportable defect would be subject to Part 21 reporting time requirements unless j
he has actual knowledge the Commission has been adequately infomed.
Therefore, in those cases where a non-licensee has
~
provided the licensee, or licensees (i.e.. the defect is generic in nature) with the reportable infomation and that infomation i
is in fact reported by the licensee (s), the non-licensee is not required to duplicate the reporting.
In this instance it is also the staff's position that the non-licinsee must have actual knowledge that the reporting was exe-cuted prior to expiration of applicable Part 21 reporting time requirements before he would be relieved of reporting the defect.
i It should also be noted that non-licensees are not relieved of reporting until the Comission is " adequately infomed." Your attention is s'pecifically directed to $21.21(b)(3)(vi).
If licensee 50.55(e) report (s) do not adequately address the generic applicability, i.e., information on all such components, which the non-licensee may' be uniquely quaTified to provide, the Part 21 reporting responsibility would remain with the non-licensee for providing that part of the unreported infomation.
The reverse is not true because Section 50.55fe) does not have a
(
provision like that included under 521.21(b) f last sentence) to relieve the licensee of reporting under 50.55Le) where he had actual knowledge that the Comission has been adequately inferred via a Part 21 report. However, the staff has stated that where I
(
!srae Site:
'/1/50 the Part 21 report includes all information required for 50.55(e)_
reporting it would be acceptable for the li'censee's 50.55(e) report l
to simply reference the previously submitted Part 21 report.
(3) Additional Guidance - Information Notice 79-30 Recent IE experience (i.e., enforcement issued to S&W, B&W and 5 Region II licensees) clarifies "The staff position permitting i
alternate reporting via 50.55(e) or LER of a defect was intended to avoid duplicate reporting of the same event.
The use of alternate reporting methods by a licensee does not relievg him from assuring compliance with 10 CFR Part 21.
Therefore, each licensee must maintain a system which will assure compliance with all requirements of 10 CFR Part 21 and, in particular, in cases where the deficiency being reported under an alternate method is also a ' defect', to assure that all information required under Part 21 is forwarded to the NRC via the initial or a followup written report."
1 10.
10 CFR 50.55(e) EVENT FLOW DIAGRAMS The flow diagram on the following pages illustrate the sequence of steps and considerations relative to determining whether an identified construction deficiency is reportable.
Figure 1 is a duplication of the guidance previously made available to licensees via NUREG-0302, Rev. 1.
Figure 2, incorporates the IE position for assuring prompt reporting of l
reportable and potentially reportable deficiencies.
e*
1
(
i
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10 CFP. 50.5E (e) h ve Cate:
4 /' 'iD k.
F,1GURE 1 10 CFR 50.55(e)
IDENTIFIED PROBLEM I
i f i f
'r EREAKDOWN DEFICIENCY DEFICIENCY OEVI ATION FROM IN IN IN PERFORMANCE QAPRCGRAM FIN AL DESIGN CONSTRUCTION SPECIFICATIONS I
I I
I
(
l AND 3 r DEFICIENCY ADVERSELY AFFECTS SAFETY OF OPERATIONS I
AND 3
c-DEFICIENCY 15 Sl'GNIFIC ANT I
AND 9 r DEFICIENCY IS IN DESIGN OR CONSTRUCTION l
LICENSEE ACTIDN REQUIRED L
- st.e rate:
4/i/50 F::'JhE 2 10 CFR 50.55(e) - IE POSITION DEFICIENCY, PROBLEM OR POTENTIALLY.
SIGNIFICANT DEFICIENCY IDENTIFIED v
I I
EREAKDOWN DEFICIENCY DEFICIENCY DEVIATION FROM IN OR IN OR IN OR PERFORMANCE QA PROGRAM FINAL DESIGN CONSTRUCTION SPEClFICATIONS
~
v CONCLUSION OF'PR&".PT CONSIDERATION v
v
.s COULD ADVERSELY AFFEdT POTENTIAL FOR SIGNIFICANCE SAFE OPERATION - I.E.,
IS ESTABLISHED - ADDITIONAL A REPORTABLE DEFICIENCY INFORMATION IS REQUIRED MAKE NOTIFICATION OF N AL REPORTABLE NOT CATION DEFICIENCY T'
SUBMIT CONTINUE EVALUATION REPORT-l
.r REPORT SUBMIT WITHDRAWAL DEFICIENCY OF NOTIFICATION
i SOUTH 'IEX AS PROJECT ENGINffi.ING FROCEDURE FOR CR.*J.!!NG C0:CR01.
STP-DC-002-K
.El F__E.C i l.V.E. D.AT E.
OCTOBER 1, 1930
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CIGJrD DATE f
,N T.L. Porfilio 9f06'0 N,4.st,? ne. ten, / /
s v;
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.. B. F. ;'.i t 's.5..el l 0, ' '" 0 -
2 rf:.
- I. n cr R riew Pre: c Dc::;n F'.D.)_r.'.C:,,?_eme.ecn, 9/ ?O/.C0 D*cs s ; *-r e.-
E..jncting Rcvi:w
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STP 200 2G3 26-77
4 STT -DC-CC -K The s'tatus identificatien of the drawing nust be indicated by blacking in the appropriate block on the cylar strip located below the t'itle block on any original drawing prior to being h
copied for distribution.
Any portion of the drawing deviating from the indicated status will be address,-d in a note locat ed directly above the title bicek on the ri,ht side of the drawing.
t 2.4.3.2 Status Descriptions: The descriptions of the statuses used on STP drawings and the limitations of use for each status are contained in the following paragraphs:
2.4.3.2.1 Issued Trclicinary - Drawings irsued prelininary nuy be ured for dcsign infor ation, procurei..nt frquiry, and rLerling..A preliminary drawing cannot be used for detailing, design verification, ccustruction, fabrication,s,.:uiufacture, or purchase. Alpha designators are used for the issue segur.ncing of pielf inary drawings.
2.4.3.2.2 Is:ued For Use - A drawing issued for use is one that hs Lcen checked and si:bjected to the docement review process as described in 51?-DC-014, Engir.eering Procedure for Docu aent Fevicw C.;- wat Process. A use issue' drawing t ay be used for.* sign inforeation, procurement inquiry, checking, detailing, design erification, purchase, startup and turnover activities. A use issue drawing tiay be used for fabricatien and in.nufacture
- .ubject to the verification requirecents of Section 2.8.2.
A use issue dracing cannot be used for ccustruction.
Alpha designators are used for the issue sequencing of use issue drawings.
2.4.3.2.3 Issued for Construction - A drawing that is issued for construc-tion is one that has been checked and reviewed, and has received dr<ign verification, as applicable, in accord,nce with SIP DC-015,* Engineering Procedure for Design Verification. Use of a construction issue drawing is unrestricted. Construction issued dt: wings are issue sequenced begianing with : ero (0) r.cd sequentially numbered with arabic nu..crals for...ery approved revision thercafter.
2.4.3.2.4 Issued for Review - A drawing issued for review is processed in accordance with Section 2.6.1.
A draviig i:: rued for acview cannot be used for any purpose c> cept review and cct.:ent unless the drawing :;cets the requirements of Subsection 2.6.1.1.
A drawing previously issued for ccnstruction r y be issued for review subject to the following conditiens:
. ~
/'
t.i.j[
~
SOUIR TEXAS PROJECT ENGINEERING PROCEDURES MANUAL STP-DC-002-K/CN/2-24-81 4
i s.
A note above the title block of the drawing will contain g" l the word " Proposed."
b.
The drawing sequence and drawing status strip will not change for the review issue.
c.
A Document Review Form 200.40 will be attached.
d.
A Document Memorandum Acknowledgment (DMA) (Form 200.57) i is not required, b
2.5 DRAWING CONTROL AND DISTRIBUTION g
2.5.1 Design Representations CD TO While sketches and/or figures are not considered to be registered design documents, they may be used for information purposes, When any sketch is used as an attachment to a controlled S, Or document, the sketch must bear the control document number on NMm4 each page thereof.
(The sketch will not, under any circumstancea e.:.J r
carry a separate number.) If a sketch or figure is attached e,4 to correspondence, it must bear the correspondence number and gy3,'~.;
date.
r.x l.1 m 2.5.2 Registered Drawings I*a Cja:p All STP drawings (except as described in Section 2.5.3) shall E.O be registered and issued through EDCC.
All such drawings (including sepias and aperture cards) shall be stamped by EDCC C u @
with the validation stamp shown on Figure 5, which will show
{GW the date the drawing was processed.
.sJ,7y
=m w 2.5.3 Drawings for Information Only Irawing prints may be made for drafting or preliminary purposes without such prints being issued through EDCC.
In such cases, it shall be the responsibility of the discipline issuing the prints to stamp them as follows:
FOR INFORMATION ONLY THIS DRAWING MAY NOT BE USED FOR DESIGN OR i
CONSTRUCTION PURPOSES G
ENCLOSURE ANALYSIS OF QUADREX FINDINGS Quadrex Finding 10 CFR 50.55(e)
Basi's for Number Re?ortable Non-reportability Remarks Civil / Structural 4.1.2.1(a)
No 4
4.1.2.1(b)
No 3
4.1.2.1(c)
No 5
4.1.2.1(d)
No 4
i No 4
4.1.2.1(e) 4.1.2.1(f)
No 5
4.1.2.1(g)
No 5
4.1.2.1(h)
No 4
4.1.2.3(i)
No 4
4.1.2.3(j)
No 4
4.1.2.3(k)
No 1
4.1.2.3(1)
No 1
I 4.1.2.3(m)
No 4
4.1.2.4(n)
No 4
4.1.2.4(o)
No 5
No 5
4.1.2.4(p) 4.1.2.4(q)
No 5
4.1.2.4(r)
No 5
4.1.2.4(s)
No 3
4.1.2.4(t)
No 4
4.1.2.4(u)
No 5
4.1.2.4(v)
No 5
4.1.2.5(w)
No 4
4.1.2.5(x)
No 4
4.1.2.5(y)
No 4
4.1.2.5(z)
No 1
4.1.2.5(aa)
No 4
4.1.2.5(bb)
No 1
4.1.2.5(cc)
No 4
4.1.2.5(dd)
No 4
Page 2 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks Comouter Codes 4.2.2.1(a)
Yes Reported by licensee 5/8/81.
Final report 10/14/83.
4.2.2.1(b)
No 5
4.2.2.1(c)
No 5
4.2.2.1(d)
No 2
4.2.2.1(e)
No 6
4.2. 2.1( f)
No 6
4.2.2.4(g)
No 7
4.2.2.4(h)
No 4
4 4.2.2.4(1)
No 6
4.2.2.4(j)
No 6
- 4. 2.2.4( k)
No 6
4.2.2.5(1)
No 7
Electrical /I&C 4.3.2.1(a)
Reported as potential E0.55(e) item.
Later determined to be not reportable.
4.3.2.I(b)
No 4
4.3.2.1(c)
No 4
4.3.2.1(d)
No 5
4.3.2.1(e)
No 5
4.3.2.1(f)
No 5
4.3.2.1(g)
No 6
4.3.2.1(h)
No 6
4.3.2.1(1)
No 5
4.3.2.1(j)
No 5
4.3.2.1( k)
No 6
i--
Page 3 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks Electrical /C&I (cont.)
4.3.2.1(1)
No 2
4.3.2.1(m)
No 7
4.3.2.1(n)
No 3
4.3.2.1(o)
No 5
4.3.2.1(p)
No 5
4.3.2.3(q)
No 5
4.3.2.4(r)
No 5
4.3.2.4(s)
No 6
4.3.2.4(t)
No 6
4.3.2.4(u)
No 4
4.3.2.4(v)
No 6
4.3.2.4(w)
No 5
4.3.2.4(x)
No 5
4.3.2.4(y)
No 6
4.3.2.4(z)
No 4
4.3.2.4(aa)
No 5
4.3.2.4(bb)
No 3
4.3.2.5(cc)
No 5
HVAC 4.4.2.1(a)
Yes Reported 5/8/81 as a 50.55(e) item.
4.4.2.1(b)
Yes See 4.4.2.1(a).
4.4.2.1(c)
No 7
4.4.2.1(d)
No 5
Related to item 4.4.2.1(a).
4.4.2.1(e)
No 5
4.4.2.1(f)
No 7
4.4.2.1(g)
No 5
l i
Page 4 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks HVAC (cont.)
4.4.2.1(h)
No 5
Related to item 4.4.2.1(a) 4.4.2.1(1)
No 5
4.4.2.1(j)
No 6
4.4.2.1(k)
No 5
4.4.2.1(1)
No 4
4.4.2.1(m)
No 6
4.4.2.1(n)
No 5
4.4.2.4(o)
No 2
4.4.2.4(p)
No 2
4.4.2.4(q)
No 5
4.4.2.4(r)
No 5
4.4.2.4(s)
No 3
4.4.2.4(t)
No 3
4.4.2.4(u)
No 5
4.4.2.4(v)
No 5
4.4.2.4(w)
No 5
4.4.2.4(x)
No 5
4.4.2.4(y)
No 5
4.4.2.4(z)
No 5
4.4.2.5(aa)
No 7
4.4.2.5(bb)
No 4
Mechanical-Inside Containment 4.5.2.1(a)
No 5
4.5.2.1(b)
N,o 3
4.5.2.1(c)
No '
S 4.5.2.1(d)
No 4
4.5.2.2(e)
No 5
\\
\\
i Page 5 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks Mechanical-Inside Containment (cont.)
4.5.2.3(f)
No 1
4.5.2.3(g)
No 1
4.5.2.3(h)
No 1
4.5.2.3(i)
No 1
4.5.2.4(j)
No 4
- 4. 5. 2. 4( k)
No 2
4.5.2.4(1)
No 4
4.5.2.4(m)
No 4
4.5.2.5(n)
No 2
4.5.2.5(o)
No 5
4.5.2.5(p)
No 4
Mechanical-Outside Containment 4.5.3.1(a)
No 5
- 4. 5. 3.1( b)'
No 4
4.5.3.1(c)
No 2
4.5.3.1(d)
No 2
- 4. 5.3.1( e)
No 4
- 4. 5.3.1( f)
No 5
- 4. 5. 3.1( g.)
No 4
- 4. 5.3.1( h)
No 4
4.5.3.1(1)
No 4
- 4. 5. 3.1(j )
No 4
- 4. 5.3.1( K)
No 4
4.5.3.2(1)
No 2
4.5.3.3(m)
No 2
4.5.3.3(n)
No 1
4.5.3.3(o)
No 2
4.5.3.3(p)
No 1
1
Page 6 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks Mechanical-Outside Containment (cont.)
4.5.3.3(q)
No 2
4.5.3.3(r)
No 4
4.5.3.3(s)
No 1
4.5.3.4(t)
No 2
4.5.3.4(u)
No 4
4.5.3.4(v)
No 3
4.5.3.4(w)
No 2
4.5.2.4(x)
No 5
4.5.3.4(y)
No 5
4.5.3.4(z)
No 3
4.5.3.4(aa)
No 3
4.5.3.4(bb)
No 3
4.5.3.4(cc)
No 5
4.5.3.4(dd)
No 1
4.5.3.4(ee)
No 3
4.5.3.4(ff)
No 4
4.5.3.4(gg)
No 3
4.5.3.4(hh)
No 5
4.5.5.1(a)
No 5
4.5.5.1(b)
No 5
4.5.5.1(c.)
No 5
4.5.5.1(d)
No 5
4.5.5.1(e)
No 5
4.5.5.1(f)
No 5
4.5.5.1(g)
No 4
4.5.5.2(h)
No 1
l l
4.S.5.2(1)
N,o 1
l 4.5.5.3(j)
No '
5 4.5.5.3(k)
No 1
4.5.5.4(1)
No 4
l
Page 7 of 12 j
Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable' Non-reportability Remarks Mechanical-Outside Containment (cont.)
4.5.5.4(m)
No 4
4.5.5.4(n)
No 5
4.5.5.4(o)
No 5
4.5.5.4(p)
No 5
4.5.5.4(q)
No 4
4.5.5.4(r)
No 3
4.5.5.4(s)
No 5
4.5.5.5(t)
No 1
Nuclear Analysis 4.6.2.1(a)
No 5
4.6.2.1(b)
No 5
4.6.2.1(c)
No 2
4.6.2.1(d)
No 4
4.6.2.1(e)
No 2
4.6.2.1(f)
No 4
4.6.2.1(g)
No 5
4.6.2.1(h)
No 5
4.6.2.1(1)
No 5
- 4. 6.2.1(j.)
No 5
- 4. 6.2.1( k)
No 2
- 4. 6. 2.1(1 )
No 5
4.6.2.1(m)
No 5
4.6.2.1(n)
No 3
4.6.2.1(o)
No 5
4.6.2.2(p)
No 1
4.6.2.2(q)
No 5
4.6.2.2(r)
No 1
Page 8 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks Nuclear Analysis (cont.)
4.6.2.2(s)
No 2
4.6.2.4(t)
No 4
4.6.2.4(u)
No 4
4.6.2.4(v)
No 5
4.6.4.1(a)
No 5
4.6.4.1( b)
No 5
4.6.4.1(c)
No 5
4.6.4.3(d)
No 2
4.6.4.4(e)
No 4
4.6.4.4(f)
No 5
4.6.4.4(g)
No 5
4.6.4.4(h)
No 3
4.6.4.4(1)
No 5
4.6.4.4(j)
No 5
4.6.4.5(k)
No 3
4.6.4.5(1)
No 5
Pipine and Support 4.7.2.1(a)
No 4
- 4. 7. 2.1( b.)
No 4
4.7.2.1(c)
No 5
4.7.2.1(d)
No 5
4.7.2.1(e)
No 5
4.7.2.1( f)
No 4
4.7.2.3(g)
No 5
4.7.2.3(h)
No 5
4.7.2.3(1)
Ko 4
4.7.2.3(j)
No 4
Page 9 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks
~
Piping and Support 4.7.2.3(k)
No 5
4.7.2.4(1)
No 4
4.7.2.4(m)
No 4
4.7.2.4(n)
No 5
4.7.2.4(o)
No 5
4.7.2.5(p)
No 5
4.7.3.1(a)
No 3
4.7.3.1(b)
No 3
4.7.3.1(c)
No 4
4.7.3.1(d)
No 6
4.7.3.1(e)
No 5
4.7.3.1(f)
No 5
4.7.3.1(g)
No 4
4.7.3.1(h)
No 5
4.7.3.1(i)
No 5
4.7.3.1(j)
No 4
4.7.3.1(k)
No 3
4.7.3.2(1)
No 5
4.7.3.2(m)
No 3
j 4.7.3.2(n)
No 2
4.7.3.2( o.)
No 5
4.7.3.3(p)
No 4
4.7.3.3(q)
No 5
4.7.3.4(r)
No 3
4.7.3.4(s)
No 4
4.7.3.4(t)
No 5
4.7.3.4(u)
No 7
4.7.3.4(v)
No,
4 4.7.3.4(w)
No 7
4.7.3.4(x)
No 4
4.7.3.4(y)
No 5
l
Page 10 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks Radiological Control 4.8.2.1(a)
Reported as potential 50.55(e) subsequently evaluated as not reportable 4.8.2.1(b)
No 5
4.8.2.1(c)
No 5
4.8.2.1(d)
Reported as potential 50.55(e),subsequ'ently evaluated as not reportable.
4.8.2.1(e)
No 5
4.8.2.1(f)
No 5
4.8.2.1(g)
No 6
4.8.2.2(h)
No 6
4.8.2.2(i)
No 5
4.8.2.2(j)
No 5
4.8.2.2(k)
No 4
4.8.2.2(1)
No 5
4.8.2.2(m)
No 5
4.8.2.2(n)
No 5
- 4. 8. 2. 2( o-)
No 5
4.8.2.3(p)
No 5
4.8.2.4(q)
No 3
4.8.2.4(r)
No 5
4.8.2.4(s)
No 5
4.8.2.4(t)
No 5
4.8.2.4(u)
N.o 5
4.8.2.4(v)
No 4
4.8.2.4(w)
No 5
4.8.2.4(x)
No 4
P W
Page 11 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-recortability Remarks Radiological Control (cont.)
4.8.2.4(y)
No 7
4.8.2.4(z)
No 5
4.8.2.4(aa)
No 5
4.8.2.4(bb)
No 5
4.8.2.4(cc)
No 5
4.8.2.4(dd)
No 5
4.8.2.4(ee)
No 5
4.8.2.4(ff)
No 3
4.8.2.4(gg)
No 5
4.8.2.4(hh)
No 3
4.8.2.4(11)
No 5
4.8.2.4(jj)
No 5
4.8.2.4(kk)
No 5
4.8.2.4(11)
No 5
In-Service Inspection and Maintenance 4.9.1(a)
No 3
4.9.1(b)
No 3
4.9.1(c)
No 4
4.9.1(d).
No 5
4.9.2 No 5
4.9.2(a)
No 5
l 4.9.2(b)
No 5
4.9.2(c)
No 4
4.9.2(d)
No 4
4.9.2(e)
No 5
4.9.2(f)
No 4
4.9.2(g)
No 5
.. =
t,.
~
Page 12 of 12 Quadrex Finding 10 CFR 50.55(e)
Basis for Number Reportable Non-reportability Remarks In-Service Inspection and Maintenance (cont.)
4.9.2(h)
No 5
4.9.2(1)
No 5
4.9.2(j)
No 5
4.9.2(k)
No 5
4.9.2(1)
No 5
4.9.2(m)
No 5
4.9.2(n)
No 4
4.9.2(o)
No 5
4.9.2(p)
No 4
l 4.9.2(q)
No 5
4.9.2(r)
No 4
4.9.2(s)
No 4
i L
k 2
I i
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