ML20154R326
| ML20154R326 | |
| Person / Time | |
|---|---|
| Issue date: | 01/14/1982 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154R302 | List: |
| References | |
| FOIA-85-836 RI-1600.21, NUDOCS 8603280308 | |
| Download: ML20154R326 (4) | |
Text
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.q - en u.nx avenue xino or mussia. ec~~svevania n.o. jg RI 1600.21 REGIONAL INSTRUCTION No. 1600.21 PROCESSING OF 50.55(e) REPORTS PURPOSE To prescribe the processing of Construction Deficiency Reports (COR's) required by 10 CFR 50.55(e).
BACKGROUND Deficiency reporting b'ased on 10 CFR 50.55(e) is designed to provide timely information on nuclear power plant construction-deficiencies.
The intent is to provide a basis for NRC evaluation of potential safety consequences and the need for further action. COR's are required from Construction Permit (CP) holders for each deficiency found in design and construction which, if uncorrected, could adversely affect the safety of operations anytime during the expected lifetime of the plant. The regulation prescribes the following:
Initial report - within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Written report - within 30 days (interim or final) 1 Supplemental written reports - as necessary to provide information.
Further guidance is contained in IE Manual. Interpretation / Guidance Section 10 CFR 50.55(e), issued 4/1/80.
ACTION
'1. Initial Report
- a. When initial notification of a CDR (potentially reportable item) is received, an identification number will be assigned for all documents pertaining to the notiff:ation 'and report (s).
.That identification number is obtained from the Docket Room where the master record is maintained by the Supervisor, Files, Mail and Records. The number will be in the form "CDR 82-00-01" (which would be the first notification received for a' docket number in calendar year 1982).
CONTACT: R. M. Gallo
- b. The CDR identification number is to be written prominently on all notification and report records as "COR 82-00-01".
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- c. The person receiving the notification of a 10 CFR 50.55(e)
(potentially) reportable item is to prepare a Telephone Report and Daily Report.
- d. A Form #6 (OIL input) will be prepared by the person who~
receives the initial notification after receiving the written report. The following apply:
The " Item Number" is the CDR number obtained from the Docket Room.
" Type" is "CDR".
" Module" is "92700".
" Resp" is the Resident / Project Inspector code.
The " Descriptive Title" will state the original description of the item and identify other significant related correspondence.
- e. Copies (when prepared) of the Form #6 and the. Teleghone Report will be provided to the Supervisor, Files, Mail and Records -
and to the Project / Resident Inspector.
- f. The original Form #6 will be submitted to the. MIS Coordinator for entry into the Outstanding Items File System.
- g. As stated in 10 CFR 50.55(e) and IE Information Notice 80-28, CDR's are made' to the Regional Office. If the Resident Inspector is informed of the deficiency by the licensee, he should prepare appropriate documentation and verify that the licensee has contacted the appropriate Region I representative (normally the responsible Section Chief).
- 2. Written Roorts
- a. The Supervisor, Files, Mail and Records is responsible for routine distribution of written CDR's. Copies are to be forwarded to the following:
(1) IE Document Management Section, via NRC Form 208 prepared by the Supervisor, Files, Mail and Records.
(2) The responsible Section Chief, DRPI, for further review.
(3) 'T'he responsible Resident / Project inspector, if not included on the licer.see's distribution.
- b. Routine CDR acknowledgement letters are not issued. Region I i Form 123 may be used to acknowledge reports or document additional itcensee commitments, as necessary.
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- 3. General
- a. An Outstanding Items File printout of all CDR's for Region I dockets will be prov_ided by the MIS Coordinator upon reques_t.
- b. All telephone and written CDR's are to be reviewed by the responsible Project / Resident ~ inspector in accordance with the following:
(1) IE Manual Procedure 90712, Inoffice Review of Event Reports.
(2) Regional Office Instruction 1100.1, Preliminary Notifications (Manual Chapter 1120)'
(3) Temporary Instruction 2500/3, Potentially Generic Events
- c. For final CDR's, the Resioent/ Project Inspector will conduct '
site followup and closecut, where possible, in a routine inspection report. Requests for technical inspection by DETI or for vendor inspection by Region IV may be made. Requests for vendor inspection by Region IV should be made for instances where the deficiency directly relates to off-site activities and verification of the activities at the vendor facility is-needed to closecut the CDR.
- d. Feedback to the docket room regarding withdrawn reports will be by copy of the telephone or other report withdrawing the potential CDR. The Supervisor, Files, Mail and Records will update and close out the master record based on that feedback.
- e. Periodically (at least annually), Resident / Project Inspectors will review licensee programs relative to the evaluation and reporting of construction deficiencies. Particular emphasis should be placed on the licensee's (and its contragtors) threshold for determining reportability and the tiseliness of notification to the NRC. Results of~this review will be documented in a routine inspection report. Discrepancies such as superficial, inappropriate or unsupported evaluations and excessive delays in reporting are to be brought to the attention of regional management, Approved: . s onald C. Ha. # T Director Date: _ j g 198 h
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4 Distribution List Regional Administrators Office Division Directors Branch Chiefs Section Chiefs Director, EI Staff PA0 .
- i. Sto Supervisor, Files, Mail and Records Supervisor, Word Processing Center Resident Offices i
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, U. ry March 29, 1985 MEMORANDUM FOR: James M. Taylor, Director Office of Inspection .and Enforcement FROM: James Lieberman, Director and Chief Counsel Regional Operations and Enforcement Office of the Executive Legal Director
SUBJECT:
INTERPRETATION OF 10 CFR 50.55(e)
In a recent Memorandum and Order issued by the Licensing Board in the South Texas initial licensing proceeding, the Board had occasion to interpret elements of the reporting requirements of 10 CFR 50.55(e). The Licensing Board interpreted 10 CFR 6 50.55(e)(1)(i) to create a duty on applicants to report " deficiencies found in design" which represent a "significant breakdown in any portion of a quality assurance program" whether or not the drawings generated by that design process had been released for construction. It found that this duty to report ~ deficiencies in the quality assurance program was in addition to the duty under 10 CFR 50.55(e)(.1)(ii) -
to report deficiencies in the final design of the project "as approved and released for construction". In reaching its decision, the Board rejected the Staff's argument which was based on the Region IV practice, that the triggering point for reporting design deficiencies is when the final design is approved and released for construction.
The Board's decision is now the law of the case for the South Texas project. I do not ' disagree with the Board's interpretation of 10 CFR 50.55(e).
Because this interpretation differs from that praviously followed by Region IV, and possibly other regions as well, I wanted to draw this interpretation to your attention so that you can take any necessary steps to assure consistency in our inspection efforts and licensee's reporting threshholds. I would be
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' pleased.to discuss this matter with you at your convenience.
N James Lieb'erman Director and Chief Counsel Ig/y/ Regional Operations and Enforcement
$gy Office of the Executive Legal Director cc- DISTRIBUTION B.' Grimes, IE }- ELD Rdr Reading J. Partlow, IE NRC Central Subject J. Axelrad, IE Lieberman chron Burns info E. Peis, OELD Cyr chron CunninghamlMurray 44 :0EhD p_____:._
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