Part 21
Jump to navigation
Jump to search
Part 21 refers to the reporting of defects to the NRC and the industry.
The term "part 21" tends to refer to 2 different perspectives:
- Outgoing: Discovery of a new defect and the need to report.
- Incoming: Outside information (Operating Experience) applies to a site. The potential defect should be evaluated or corrected.
Incoming Part 21 OE
Outgoing Part 21 Reporting
- Discovery -> Evaluation -> Notification -> Written Report
- Discovery -> Evaluation-> Interim -> Notification -> Written Report
- Discovery (CR written): Implies a Deviation or failure to Comply. Reportability evaluation becomes indeterminate and a CA initiated to Engineering to perform an Evaluation per CC-AA-309-1012 Att 9.1
- Evaluation started to determine “substantial Safety Hazard”
- 5 days = 10 CFR 21.21(a)(3) "(3) Ensure that a director or responsible officer subject to the regulations of this part is informed as soon as practicable, and, in all cases, within the 5 working days after completion of the evaluation described in paragraphs (a)(1) or (a)(2)". The nuance is "working days" not days, and its from Evaluation complete date not the whole evaluation period. So, technically, if it is done early, then you may be short-cycled to do the next step (notification).
- Interim Report: A DDE extension for the Evaluation beyond 60 days of discovery date is allowed but an Interim report is needed.
- Notification: The initial ENS report after the evaluation
- Written report: A letter after the notification with a little more detail
Notification: 10 CFR 21.21(d)(3)(i)
The initial Part 21 notification is via ENS, at the ~60 day after discovery. It is followed up by a written letter.
- (d)(3)(i) Initial notification by facsimile, which is the preferred method of notification, to the NRC Operations Center at (301) 816 - 5151 or by telephone at (301) 816 - 5100 within two days following receipt of information by the director or responsible corporate officer under paragraph (a)(1) of this section, on the identification of a defect or a failure to comply. Verification that the facsimile has been received should be made by calling the NRC Operations Center. This paragraph does not apply to interim reports described in § 21.21(a)(2).
Written Report: 10 CFR 21.21(d)(3)(ii)
- (d)(3)(ii) Written notification to the NRC at the address specified in § 21.5 within 30 days following receipt of information by the director or responsible corporate officer under paragraph (a)(3) of this section, on the identification of a defect or a failure to comply.
Format for written report is found in 10 CFR 21.21(d)(4).
Interim Report: 10 CFR 21.21(a)(2)
An interim report is an option within the CFR to report the part 21 when you need more time to assess. If you have discovery but don't want to confirm the issue meets the reporting criteria, the interim report is a possible solution.
- (2) Ensure that if an evaluation of an identified deviation or failure to comply potentially associated with a substantial safety hazard cannot be completed within 60 days from discovery of the deviation or failure to comply, an interim report is prepared and submitted to the Commission through a director or responsible officer or designated person as discussed in § 21.21(d)(5). The interim report should describe the deviation or failure to comply that is being evaluated and should also state when the evaluation will be completed. This interim report must be submitted in writing within 60 days of discovery of the deviation or failure to comply.
- Warning: the interim report is due in 60 days where the normal notification can technically have 5 days added.