ML20138J264
| ML20138J264 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/12/1985 |
| From: | Barker D HOUSTON LIGHTING & POWER CO. |
| To: | Robertson C HOUSTON LIGHTING & POWER CO. |
| References | |
| OL-I-CCANP-071, OL-I-CCANP-71, NUDOCS 8510290299 | |
| Download: ML20138J264 (27) | |
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OFFICE MEMORANDUM
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To ST-HL-lbMQED C. G. Robertson June 12 1981 D. G. Barker SFN: V-0530' I
Erom 4
gy PROCEDURE DEVI ATIONS CONCERNING REPORTABLE DEFICIENC$8$ pg g g i
j The intent of this memorandum is to outline those specific areas in j
which current practice deviates from PEP 11. Rev.1 "Reportingi Design: and Constructicn Deficiencies to NRC" due to instructions from either Mr.
I Goldberg, yourself or I.
It is our understanding that a corporate procedure i
is being prepared and the project procedure will be revised. During the interim this memo, with your written concurrence, will justify the use of the j,
deviations. Note that all of the deviations are considered minor in that they i
j typically involve a change in the HL&P responsible individual or the elimination of preliminary reviews prior to a full review.
' provides a list of the deviations. Attachment 2 is a copy of Rev. 2 of PEP 11. Attachment 3 is a copy of your memo of May 11, 1981 i
discussing some of the deviations.
4 Your written concurrence of these deviations is reouested by June 22, 1981.
i JW/fij cc:
J. G. White L. R. Jacobi t
M. E. Powell R. R. Hernandez STP RMS I
I CcRMP V huCLEAR REGULATORT COMul584em I
.s.,,.MK6-4Hohnu,,s. a._ deMW In the matter of
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ATTACHMENT 1 i
PEP 11 REY. 1 SECTION CURRENT PRACTICE l
4.1 Project Manager Site related incidents are being referred to the IRC chairman through i
several sources as opposed to only the Project QA Manaoer. Thus, the
" preliminary analysis" and " preliminary notice" are not occurring for each j
incident.
In addition, the Project 0A Manaoer is not notifying the Project Manager nor Region IV office. The IRC chairwan is doina this. The IRC chairman assigns the notification of the RRI to the 0A representative at the IRC meeting.
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l 4.2 Team Leader, Nuclear As with site related items, there is no l
Safety and Licensing lonner a " preliminary analysis".
Instead all of the incidents are being referred to the IRC. As noted above, the RRI notification is assigned to the OA representative at the IRC meeting.
Initial report preparation is the responsibility of the Engineering i
Coordinator. The Team Leader, NS8L reviews and submits these reports to i
manaoement for approval.
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4.3 Manager, STP The IRC chairman notifies the Manager, Licensing who is responsible for keeping the HLAP executives informed.
5.1 Initial Incident Per the May 11, 1981 memo (ST-HL-19074) i Notification the Supervising Project Engineer is the site contact point. Again the notifica-
!i tion of the RRI is the responsibility of l
the QA representative at the IRC i
meeting.
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PEP 11 REV. 1 SECTION CURRENT PRACTICE 5.6 Incident Notifications The current practice for these notifications that are different are:
a.
Team Leader, NS+L contacts Region IV office b.
QA representative at IRC meeting is responsible for notification of the RRI c.
SPE at the site is a contact point d.
The Manager Licensing informs the executive management af ter notification from the IRC chairman.
5.8 Incident Review Committees A site IRC has not been implemented.
Site problems are handled by the home office IRC.
5.9 Deadline Requirements The IRC is now meeting and making determinations to comply with the deadlines as opposed to depending on the Proj. QA Manager or Team Leader, NS+L 5.11 Posting Requirements The Manager, Licensing is responsible for ensuring that posters and other written notifications are implemented.
l 5.12 Procedure Relative to 10CFR 21, the Supervising Project Engineer's office at the site is the site contact point that an individual may utilize to express a concern relative to defects a non-conpliances. The procedure for implementing this is outlined in j
ST-HL-1907 (5/11/81); a copy of which is provided as Attachment # 3.
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F,-h e k 1
PEP-ll REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC
SUMMARY
OF REVISIONS i
REVISION SUMM ARY n rvision etsemierson nu een 0
Initial Issuance 1
This procedure formalizes the process of notifying the NRC of potentially reportable items.
Initial notification for site deficiencies is by the Project QA Manager.
Initial notification for all other deficiencies is by the Team Leader of Nuclear Safety & Licensing. A site Incident Review Comittee has been established to handle site deficiencies. This procedure will re:;uire additional revision once a Licensing engineer is assigned to the site.
REVISION AUTHORIZATION atvision nuvsta 0
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L HOUSTON LIGHTING & POWER C0"PANY SOUTH TEXAS PROJECT 4
i PROJECT ENGINEERING PROCEDURE PEP-11 i
REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO fRC 1.0 PURPOSE The purpose of this procedure is to describe the Soeth Texas Project program for complying with the requirements of both 10 CFR 21 and 10 CFR 50.55(e).
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2.0 SCOPE l
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This procedure establishes the requirements for reviewing, I.
evaluating and reporting defects, non-compliances and deficiencies which could potentially affect the safety i
functions of the South Texas Project as de'ined by 10 CFR 21 or 10 CFR Sn.55(e).
j 3.0 REFERENCE DOCUVENTS e
NRC ISE Inspection Manual, " Guidance - 10 CFR 50.55(e) 4 1
Deficiency Reporting *, 7-1-76.
4.0 RESPONSIBILITY I
4.1 Project 0A Manager l
l The Project GA Manager is responsible for perfarning 1
a preliminary analysis of a site identified incident to determine if it is possibly reportable.
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? OF ?1 EECT REPORTIN3 DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC D ATE l$$UED nE M6 /7n The Project 0A Manager is responsible for perfor-ing a prelininary analysis of a site identified in:ident to cetemine if further analysis of the incident is reovired by the Incident Review Con-ittee.
The Project GA Manager 's resconsible for providing prelirinary notice tc f ne Resident Reactor inspector of each possibly reportable deficiency identified on site.
The Project GA Panager is responsible for notifying t' r Manager, South Texas Project and the N:C Region 1, office of incidents detemined to be reportable ru-suant to 10 CFR 21 or 10 CFR 50.55 (e).
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4.2 Team Leader, huclear Safety and Licensing i
The Tee, Leader, NS&L is responsible for perfoming a prelirirary analysis of a here office identified incident to detemine if it is possibly reportable.
l The Team Leader, f:58L is resporsible for perfomino a prelirinary analysis of a here office identified incident to detemine if further analysis of the incident is required by the in:ident Review Comittee.
The Team Leader, NS&L is responsible for providing preliminary notice to the Resident Reactor Insrector of ea:h possibly reportable deficiency identified by the ho e office.
The Tean Leader, NSAL is resporsible for n0tifying the Panager, South Texas Project and the fM. Region
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l IV office of incidents deternined to be reportable pursuant to 10 CFR 21 or 10 CFR 50.55(e).
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The Tean Leader, NS&L or his designee is responsible l
l for chairing all Incident Review Connittee reetings.
The Tean Leader, NS&L or his designee is responsible l
for preparing the ninutes of all incident Review i
Tonnittee reetings.
The Tean Leader, NS&L is responsible for preparing j
and subnitting all written correspondence to the j
Nuclear Regulatory Comission as recuired by 10 CFR 21 or 10 CFR 50.55(e).
The Team Leader, NS&L is responsible for naintaining I
a file of all incidents censidered by the Incident Peview Connittee.
4.3 Manager, South Texas Project l
The Manager, South Texas Project is responsible for notifying the Vice President - Construction and l
Technical Services, of all incidents determined by the Incident Review Comittee to be reportable under 10 CFR 50.55(e) or 10 CFR 21.
4.4 incident Review Con-ittee j
The incident Review Connittee is responsible for detemining reportability of de'iciencies per 10 CFR i
50.55(e) or defects and noncompliances per 10 CFP 21, 5
Houston Lighting 1. Power has the ultinate f
responsibility for determining reportability o' deficiencies per 10 CFR 50.55(e).
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HOU$ TON LIGHTING & POWER COMPANY SOUTH TEX AS PROJECT PEP-ll i
PROCEDURE MANUAL PROC NO.
REV NO I TITLE PROJECT ENGINEERING PROCEDURE smtT REPORTING DESIG?i AND C0!iSTRUCTIO!4 0 riCIENCIES TO NRC DATE ISSUED 05/16/80 5.0 REQUIREMENTS 5.1 Initial Incident Notification Defects, noncompliances or deficiencies which could potentially affect the safety functions of the nuclear power plant can be identified by numerous individuals and fron various procedures or interfaces.
Regardless of the individual, organization or neans of identifying such incidents, i
it is inperative that either the Project GA Manager I
or the Teai Leader, NSAL be notified innediately so he can review the f;CR (or ADR, if ap;:ropriate) and initiate the evaluation process of the possibly reportable defect, nonconfomance or deficiency.
The Project GA Manager or Team Leader, NS&L shall notify the Resident Reactor Inscector within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or receipt of each incident considered to be possibly reportable.
5.2 Safety Evaluation Each incident identified as being reportable to the f;RC per 10 CFR 21 or 10 CFR 50.55(e) will receive bcth a technical evaluation and a safety evaluation
.to detemine whether the incident could, if uncorrected, create a substantial safety hazard.
Technical evaluations are cerfomed by the cognizant engineering organization and safety evaluations are perfomed by the incident Review Comittee.
For the purpose of initial reportability deterrina-tion, the safety evaluation nay be waived when an extensive safety evaluation is corsidered necessary and the disposition of the incident will result in the retention of the original design configuration
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sumatcT REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC oaTt issuto ns/1c/en and safety criteria.
In such cases, the incident shall be considered reportable.
The final report shall then consist of a technical evaluation. A safety evaluation shall be perforned in all cases where the original design configuration or safety criteria will not be retained.
5.3 Deficiency Determination The following factors shall be considered in evaluating an incident to deternine if it is a deficiency reportable to the NRC under the provisions of 10 CFR 50.55(e).
1.
The deficiency shall be evaluated as affecting or
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have the potential to affect the safety of the operation of the plant at any time throughout its expected life. This includes deficiencies which could affect the safety-related function of any structure, systen or component for which credit is taken in the FSAR in evaluating their capability to acconnodate the effects of and to be compatible with environnental conditions associated with nomal operation, naintenance, testing and postulated accidents. Careful consideration shall be given to the effects of the deficiency to assure that it does not indirectly affect the safety of operation of the plant.
2.
The deficiency shall be related to the design or construction phases.
This includes activities of the Nuclear Stean Systen Supplier, architect engineers, consultants, contractors, or suppliers.
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Tne deficiency shall fall within one of the following four categories:
(a) A breakdown in the Ouality Assurance Progran related to any criterion in 10 CFR 50, Appendix it, applied to any design or construction activity affecting the safety to plant operation.
(b) A deficiency in final design as approved and released for construction such that the design does not comply to the design criteria and bases stated in the FSAR or Construction Permit. Final design denotes those drawings, specifications and other I
engineering documents that have been reviewed, approved and released for fabrication, installation or construction.
No deficiency exists if a design stated in the FSAR is changed by approved procedures after receiving proper evaluation and review.
(c) A deficiency in construction of or damage to a structure, systen or component which will require extensive evaluation, extensive repair to establish the adecuacy of the structure, systen or conponent.
(d) A deviation from perfomance specifications defined in the functional testing require-nents which will require extensive evalua-tion, extensive redesign, or extensive re-pair to establish the adequacy of the struc-ture, systen nr component.
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suancT REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC o4Ts issuto 05/16/80 4.
The significance of the deficiency should be evaluated relative to operational safety. The significance of a deficiency is a subjective evaluation and as such the significance of a given deficiency may not be clear. Therefore, if the significance of deficiency is in doubt, it should be treated as reportable to the fGC.
5.4 Defect Determination The following factors shall be considered in evalua-i ting an incident to determine if it is defect report-L able to the NRC under the provisions of 10 CFR 21.
1.
The incident identified shall involve either the I.
software or hardware requirements associated with a basic component. A basic conponent is a Safety Class 1, 2, or 3 Seismic Category I structure, systen, component or part thereof necessary to assure:
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(a) The integrity of the reactor coolant pres-sure boundary, (b) The capability to shutdown the reactor and maintain it in a safe shutdown condition, or (c) The capability to prevent or mi'.igate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 100.11 2.
The basic component shall contain a defect which is defined by the following categories:
(a) A deviation in a basic component delivered to a purchaser or user where on the basis of
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,,ct 8 or 21 S'8JEC' REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC oave issueo 05/16/80 an evaluation, the deviation could create a substantial safety hazard; or (b) The installation, use or operation of a basic component containing a defect as defined in paragraph 2 (a) above; or (c) A deviation in a portion of the nuclear power plcnt subject to the construction pemit requirements of 10 CFR 50 provided the deviation co? Id, on the basis of an evaluatior.. create a substantial safety hazard and the portion of the facility containing the deviation has been offered to the purchaser for acceptance; or I
(d) A condition or circumstance involving a basic component that could contribute to the exceeding of a safety limit, as defined in the technical specifications of a license for operation issued pursuant to 10 CFR 50.
3.
The defective basic component should be evaluated to detemine whether the defect could, if uncorrected, create a substantial safety hazard.
4.
A comercial grade iten is not part of a basic component until after dedication which occurs after receipt when that item is designated for use as a basic conponent.
5.5 Noncompliance Detemination The following factors should be considered in evaluating an incident to determine if it is a noncompliance reportable to the fGC under the provisions of 10 CFR 21.
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The incident identified should involve either the software or hardware requirements associated with a basic component.
2.
The basic component shall fail to comply with the Atomic Energy Act of 1954, as anended, or any applicable rule, regulation, order or license of the NRC relating to substantial safety hazards.
This includes failure to comply with design criteria and bases stated in the FSAR or Construction Pemit.
3.
The basic component containing the noncompliance should be evaluated to determine whether the noncompliance could, if uncorrected, create a substantial safety hazard.
5.6 Incident Motifications Five primary notifications occur during the process of reporting defects, noncompliances and deficiencies in accordance with 10 CFR 21 or 10 CFR 50.55(e).
These notifications are:
1.
Project 0A Manager or the Team Leader, NSAL notifying the Resident Reactor Inspector of an incident determined to be potentially reportable pursuant to 10 CFR 50.55 (e) or 10 CFR 21.
2.
Any individual notifying the Project QA Manager or the Team Leader, NS&L of an expected incident requiring consideration pursuant to 10 CFR 50.55 (e) or 10 CFR 21.
3.
The Project GA Manager notifying the Tean Leader, Nuclear Safety & Licensing of an incident
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l' Houston LIGHTING O POWER COMPANY SOUTH TEXAS PROJECT PEP-ll PROCEDURE MANUAL Proc.NO.
REV.NO.
I TITLE PROJECT ENGINEERING PROCEDURE s m ect REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC oATE issuto 05/16/80 requiring evaluation by the Incident Review Committee.
4.
The Team Leader, Nuclear Safety & Licensing notifying the cognizant engineering discipline and others required to call a meeting of the Incident Review Committee.
5.
The Manager, South Texas Project notifying the Vice President - Power Plant Construction and Technical Services of an incident determined to be reportable er potentially reportable.
5.7 Written Incident Report
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A written report is required to be submitted to the NRC Director of Regional Office and the NRC Director, Office of Inspection and Enforcement, on each defect, noncompliance or deficiency reported to the NRC per 10 CFR 21 or 10 CFR 50.55(e). An outline for these written reports is provided in Attachment PEP-11-01 to this procedure.
If information required for the written report is incomplete when the report is prepared, an interim report shall be prepared describing that information which is available and a schedule for completing the remaining information.
5.8 Incfdent Review Conriittee A.
The Incident Review Committee for home office identified incidents shall consist of the following members, or their designees, as a minimum:
1.
Engineering Team Leader, NSSL - Chairman 2.
Project QA Supervisor 3.
Supervising Project Engineer, Design l
Engineering l
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- C' REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC oave issuto 05/16/80 B.
The Incident Review Comittee for site identified incidents shall consist of the following members, or their designees, as a minimun:
1.
Engineering Team Leader, NS&L - Chaiman 2.
Project QA Manager 3.
Supervising Project Engineer, Site Engineering Support 5.9 Deadline Requirements The following deadlines shall be observed.
A.
The NRC shall be notified by telephone:
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(1) Within 2 days pursuant to 10 CFR 21 (2) Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> pursuant to 10 CFR 50.55(e).
following detemination by the Project GA Manager i
or the Team Leader, NSAL that the incident is l
possibly reportable.
B.
The NRC shall be sent a written repnrt:
I (1) Within 5 days pursuant to 10 CFR 21 l
(2) Within 30 days pursuant to 10 CFR 50.55(e).
following detemination by the Incident Review Connittee that the incident is reportable or detemination by the Project GA Manager or Team Leader, NSAL that an iten is potentially reportable. Should a potentially reportable item i
be subsequently detemined to be not reportable then the NCR Region IV office shall be notified in writing of this disposition.
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'I PROCEDURE MANUAL Proc. No.
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5.10 Procurement Document Notification Attachment PEP-11-02 to this procedure provides a standard statement that must be included in all purchase orders and subcontracts for services and equipment defined as being a basic component.
It is the responsibility of the Purchasing Department to ensure this statenent is included in all such
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purchase orders and subcontracts.
5.11 Posting Requirements i
Attachment PEP-11-03 to this procedure provides a standard poster which must be displayed in conspicuous locations at both the Houston home office I
and the construction site.
It is the responsibility of the STP Team Leader, Nuclear Safety and Licensing
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to ensure that adequate posters are displayed in appropriate locations. This poster identifies the individual to whom initial notification of a defect or noncompliance which would potentially affect the safety functions of the STP.
5.12 Procedure Responsibility Action Any Individual 1.
Reports to the Project QA Manager any incident which he i
feels should be evaluated pursuant to 10 CFR Sn.55(e) or 10 CFR 21.
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Project QA Manager 2.
Reviews the incident or Team Leader, report.
Nuclear Safety &
Licensing Project QA Manager 3.
Determines whether it or Team Leader, is potentially Nuclear Safety &
reportable.
Licensing Project QA Manager 4.
If not potentially or Project Quality reportable, then
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Assurance Supervisor handles incident through normal QA channels.
Project QA Manager 5.
If potentially report-or Team Leader, able, then the Nuclear Safety Resident Reactor
& Licensing Inspector and the Team Leader, Nuclear Safety & Licensing is notified.
Team Leader, 6.
Reviews the incident Nuclear Safety report and discusses
& Licensing it with the Project QA Supervisor.
Team Leader, 7.
Arranges for review Nuclear Safety of the incident by the
& Licensing appropriate Engineer-ing discipline.
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PAGE 14 OF 21 REPORTING DESIGN AND CONSTRUCTION nericityctre To Npc DATEISSUED 05/16/80 Responsibility Action Tean Leader, 8.
Evaluates the safety Nuclear Safety significance of the A Licensing incident.
Tean Leader, 9.
If potentially report-Nuclear Safety able then incident is
& Licensing referred to the Incident Review Connittee.
Incident Review
- 10. The Incident Review Connittee Cm7mittee considers the incident.
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Engineering Nuclear
- 11. If deened not Safety A Licensing reportable, prepares a written report notifying NRC Region IV.
Incident Review
- 12. If deemed not Connittee reportable, then the incident is resolved through nornal OA channels.
Incident Review
- 13. If deemed report-Connittee able, then the incident is reported to the NRC by the Team Leader, Nuclear Safety A Licensing.
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susa:T REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC carr issut o 05/16/80 Responsibility Action Team Leader, Nuclear
- 14. Notifies NRC Region IV Safety & Licensing within the time frane noted in section 5.9.
Project 0A Manager or
- 15. Notifies the Manager, Team Leader, Nuclear South Texas Project Safety & Licensing and the Manager, Quality Assurance.
Team Leader, Nuclear
- 16. Notifies the Super-Safety & Licensing vising Engineer, Design and the Supervising Engineer
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Nuclear Safety &
Licensing.
Team Leader, Nuclear
- 17. Prepares a written Safety & Licensing report to the f.9C, Region IV within the time frame noted by section 5.9.
Team Leader, Nuclear
- 18. Prepares a docunenta-Safety & Licensing tion package to be maintained by the Licensing group and RMS.
6.0 DOCUMENTATION Each defect, noncompliance or deficien:y evaluated by the Incident Review Con 91ttee shall he recorded in fornal f
meeting ninutes by the T?an Leader, Nuclear Safety &
Licensing. A copy of these nectirg ninutes, copies all telephone correspondence and cop'es of all NRC
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correpondence will be maintained by the Team Leader, Nuclear Safety & Licensing; in addition to the pemanent record copy to be maintained by R"S.
It is the responsiblity of each individual originating such documentation to ensure that file copies are properly identified and transmitted to the Tean Leader, NSAL and the Record Panagement System (RMS) File.
7.0 ATTACH"E NTS
, PEP-11-01 Incident Report Outline
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PEP-11-02 Procurement Document Statement PEP-11-03 Posting Notification I
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p1 REPORTING DESIGN A'O CONSTRUCTION nrrtetre tre Tn nor oav r ' swr o 05/16/80 ATTACHMENT PEP-11-01 INCIDENT REPORT OUTLINE SUK4ADY This section should provide a synopsis of the incident and its resolution.
The following infomation should be contained in this section:
a.
A synopsis of the incident b.
Postulated cause of incident I
c.
A synopsis of the corrective action taken d.
Synopsis of the results of the safety evaluation.
II. DESCRIPTION OF INCIDEf T This section should provide a clear and complete description of the in:1 dent and the circumstances surrounding it.
The following infomation shnuld be contained in the sectinn:
Identification of the facilit a.
component (including vendor) y or activity or basic supplied to such facility or activity involved in the incident.
b.
Source and extent of incident.
c.
The date and means by viich the incident information was obtained.
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PAGe 18 of 21 susact REPORTING DESIGN A'4D CONSTRUCTION DEFICIENCIES TO NRC oats essuso 05/16/80 d.
Unusual circunstances pertaining to the incident, such as weather conditions, test procedures underway and/or abnomal conditions at site.
e.
Status of construction at time of incident 3
f.
Procedures in effect to avoid incident (if any)
!!!. COPRECTIVE ACTION This section should provide a clear description of the ccrrective action taken to rectify the incident and action taken to prevent recurrence. The following infomation should he contained in this section as applicable:
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a.
The imediate response by Quality Assurance in response to the incident.
b.
A complete description of all imediate actions taken to correct the incident.
c.
A complete description of all long range actions te be taken to correct the incident and inplementation schedule.
d.
A delineation of the testing methods which will be utilized to ensure that repairs have been corducted
- properly, e.
Action taken to prevent the recurrence of the incident during the remaining construction phase of the facility.
IV.
5ffETY ANA'.Y$l$
This section should provide sufficient information to fully analyse and evaluate all the possibly safety I
HOUSTON LIGHTING & Font n COMPL4Y SOUTH TEXAS PROJECT PEP-11 PROCEDURE MANUAL Paoc =o a rv. No 1
TifLE PROJECT ENGINEERING PROCEDURE g
9 g
susact REPORTING DESIGN AND CONSTRUCTION 05/16/80 DEFICIENCIES TO NRC oatt issuto implications of the incident. The following infomation should be contained in this section as applicable:
a.
Nature of the incident and the safety hazard which is created or could be created.
b.
Identification of applicable Ouality Assurance documentation.
c.
A record on all incidents noted in the Ouality Assurance documentation and their resolution where applicable to the reported incident.
d.
A complete record of the incident and the results of all investigations.
e.
Postulated cause of incident.
f.
A corolete description of all imediate actions tanen to mitigate the consequences of the incident.
g.
In the case of a basic component which contains a defect or noncompliance originated for evaluation by fl8R, the number and location of all such components in use at, supplied for, being supplied for other facilities or activities with BAR as the engineer or constructor.
L-
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HOUSTON Li'HTING & POWE3 COMPANY SOUTH TEX AS PROJECT PEP-11 PROCEDURE MANUAL Paoc NO.
arv NO I TIT LE PROJECT ENGINEERING PROCEDURE g
susstcT REPORTING DESIGN AND CONSTRUCTION DEFICIENCIES TO NRC OAfr issuto 05 /16/P3 ATTACHMENT PEP-11-02 PROCUREMENT DOCUPENT STATEMENT 10 CFR 21
" Reporting of Defects and Noncompliances" The work to be perfomed under this purchase order (subcontract) is considered to involve a " basic component" as defined by Title 10 Code of Federal Regulations Part 21 (published 6/6/77 in Federal Register). Therefore,10 CFR 21 is applicable.
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mass 3s poste Mg 1
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10 CFR Part 21 c m os Reporting of Safety-Related Defects and Non-Compliances
,,,3c. no.
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, AGE 21 0F 21 DATE ISSUED 05/16/80 The Nuclear Regulatory Commission requires directors and responsible officers of certain firms and j
organisations to report defects in components and failures to comply with regulatory requirements that may reeutt in a substantial safety hazard. The new regulations are identified as: Title 10 Chapter 1 Code of Federst Megulations - Energy - Port 21. They appty to fstms that:
- Build, operste. or own NRC licensed facilities or conduct NRC. licensed or regulated activities.
- Suppfy safety related components for NRC heensed facilities.
e Supply safety.retated desi n. testing, inspecting or consutting services for NRC licensed facihties.
0 l
i The following documents provide information relative to the reporting of safety.related defects and non.
conformance 3
A COP'Y OF 10 CFR PART 21 is LOCATED l
i A COPY OF THE PROCEDURE FOR IMPLEMENTING 10 CFR PART 2115 LOCATED ANY DEFECTS OR NONCOMPLtANCES WHICH I
COULD POTENT 1At LY AFFECT THE SAFETY FUNCTIONS OF THE NUCLEAR POWER PLANT SHOULD SE REPORTED TO Perie et he fase,si tem one reeviei.en eencem.as in.e toownement t
se e pori w'ee,.ee:eite e feen ene rea.cometence e,o i
l Pusu: LAW e3 43e j
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ases 30s ist An, nie,ewei s.,ece,,,,s,ane.e,e
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10 CFR PARt 21 - JUNE 10.1977 n
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sus" se'en er fedure to esage, l'e'p Art of IDH es ems'iees e ea, aeste.eese 'wto regwican e
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feat', see'ed em We Pepa ses of eso, forde, tassess er sehrence e
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$$i The C-.- -- : 7 e tW'sterises to seriense auch Peteertebse 6 erie said ePer tagf ergenesit artarges a pienemg gg 8Fiew's W48tes e8,h We Persere W Wie Wesen
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- * *3 llouston Lighting. & Power. Company r..
OFFICE MEMOR ANDUM ro G.L. Parkey 19'l Ib Uti Itay 11, 1901
/,)[fC ST-HL-19074 from C.G. P.obertson W M l SFli: V-0100 10 CFR Part 21 Interim Impfenent'ing Procedures '
[N. s,,
l Sajcer j
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HLLP is rcorganizing the updating its posting and poi,ER.. ige office at the STP site is being identified as the site contact pliin,e.r,'sL3*
contact relative to 10 CFR Part 21. The Supervising Project /
employees may utilize to express any concern relative to defects or
-dkQ, non-coTpliances.
A separate point of contact for the Houston metropolitan area is also being identified. New procedures for evaluating items under 10 CFR Part 21 are being developed and will be issued in the near future.
In the interin the following procedure is to be implemented relative to any report to your office from an individual.
A.
The Supervising Project Engineer (SPE) shall notify the 11anager of Licensing's office and the fianager of Quality Assurance's office by telephone as soon as practical after receiving a contact, i
B.
If possible the SPE shall arrange for a face-to-face meeting with the individus1 expressing the concern and will prepare a written formulation 4
of his concern, with copies forwarded to the fianager of Licensing and the l'anager of Quality Assurance immediately.
C.
The individual will be infor.:cd that he may express his r.oncern without fear of any retaliatory action, penalty,or discriminatory act being taken against him.
D.
The indivic'ual will be informed by the SPE that the matter will be irrediately evaluated and that he will be notified in writing as to the result of that evaluation.-
E.
The llenager of Licensing will indicate upon tele hone notification the evalution procedure that will be utilized, e.g. A Site evaluation or a Project evaluation at the Houston location.
In any event, such evaluaticn nust be completed and a preliminary determination made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receipt of information.
As a separate matter relative to this process any new e-ployces of j
HLLP scheduled to work in the nuclear area shall receive a briefing concerning 10 CFR Part 21 reporting requirements and mechanisms including the IP.C Region IV telephone number under which he may express any concerns relative to defects or non-compliances.
)
CGR/dmh Attachment 1
l cc:
G.U. Oprea J.H. Goldberg R. A. Frazar l
R.P. Iturphy R.I. lioles i
D.G. Di:rter i
L.R. Jacobi l
H.J. Overstreet
{
lI.J. Su n e v
HSpOri.Hru 07 UOtety-Halated DEiacts end Non-Compliances HO' STON LIGHTING & POWER J
The Nue:est f:.gu*rtery Co rMarian requires $roctors and esspor.s% c*ft:e oessn: stions to espe =t defects In components and f a*fw'st to crrnp'r
- ,*.S es;s'ator of ce t:5 r. r.s s o eesw*: in a swh'a'tW ta'et, harr'd. The fisw to:s ations tre identif.ed as: Tibe 70 CA.=prer ! Ccte r vt:s*'e"**'s that me y t
Fec'. rs! Reps.'.ptic s. incrgy. Part 21.1 hey spply to intms 1F.st.
- Bst!d. operste oe own NRO ficeased fe:
93wppir safety refated components for fiRO Iconsed fetiMiss1'. ties or conds t f4404:ensed or ts;ufs 95wpply efe:r re'ated design. testies. Inspottin; or consufting servi:es for NRO ficansed f ell t:
a. es The fo30eria;( :vm:nts prow:ve ir.forw:fon ts'ative to the r gatiac of safaty-refstc? dafsets and
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non<enforrne.%;e A COPY Or 10 CTR PART 21 h LOOATED
.6I.IN.I.'41'i.[fE!f}II.DIII.'iM.{N.fl.....
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. im9ti!. tM U!'i. 9BM e.1 ?h ii. ??H},. ITC -
A CO?Y OF T::173DOEDU:'I FOR IMPLEMst?Ti'd3 10 CF3 PART 2113 LOOATED 1).!fy:'iQ,[}@M}9,(MjMRl5,9((}g/SP,$]}f 2),tigy!9,gn3Iy;yI,,t433gg,'s,pir;g,,,,,,
.... !*!E 5 ??f. E'r'i!9!5. kwn d..............
A!AY DIFECTS 03 ft0N007.TLt* NOES WH!OH COULD PDiE :TIALLY MFECT TH SAFETY FUNOTIO!iS OF Ti;I NUOLEAR FO'dIR f *.J.NT csDuto ct nEn,aTru TO
- 1) JJiim 51 %.HNiCT. iM 15 ?i flSii. 517i........
(512)572-5456.x22c7 2).f4HM58.W;!H5.!!ClM!9(MIH??5.e ao!9.
g (Heuston) (713)425-3335 PmMa e8 the fede-P anw e*4 ret,". tea aumeeme th am useert se'e sn: asea wem em re u;-c.e es: @er et r. vs PLSLIC LAW 93-0B ENERGY REDRGr.'d2AT10's 1. 7 CT 1974 "Sec 2Di(e) b constru: tin;, y individual dire:te. or res;:7.sible ef ficer c' a fi--
ceir:;. c;eratina, or su;;,1yir; the cc ;;r.tr.ts of any fe:ility er activity which is $1censet er etterwise ra slat:' purssent to the At:-it Ert ;y A:t of 1$54, es t cr. fed. or pw* sus;r.t t; this A:t s,+.o citeir.s info-.: tion resa:r.nbly irdi:ntin; that su:h facility or activity or basic co. ::e.:.ts sup, lief to su:h fe:ility or a:tivity l
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