Information Notice 2011-19, Licensee Event Reports Containing Information Pertaining to Defects to Basic Components
| ML111800524 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/26/2011 |
| From: | Laura Dudes, Mcginty T Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| Beaulieu, D P, NRR/DPR, 415-3243 | |
| References | |
| IN-11-019 | |
| Download: ML111800524 (4) | |
ML111800524 UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
WASHINGTON, DC 20555-0001
September 26, 2011
NRC INFORMATION NOTICE 2011-19:
LICENSEE EVENT REPORTS CONTAINING
INFORMATION PERTAINING TO DEFECTS IN
ADDRESSEES
All holders of an operating license or construction permit for a nuclear power reactor under
Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of
Production and Utilization Facilities, except those who have permanently ceased operations
and have certified that fuel has been permanently removed from the reactor vessel.
All holders of or applicants for an early site permit, standard design certification, standard
design approval, manufacturing license, or combined license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
All individuals, corporations, partnerships, or other entities for which the regulations of
10 CFR Part 21, Reporting of Defects and Noncompliance, apply (see 10 CFR 21.2, Scope).
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform
addressees of recent events that were reported under 10 CFR 50.73, Licensee Event Report
[LER] System, that discussed defects1 to basic components2 and the new NRC practice of
posting such LERs to the 10 CFR Part 21 report page of the NRC public website. Although
there is no explicit NRC requirement for licensees to do so, the NRC encourages licensees
reporting 10 CFR Part 21 defects under 10 CFR 50.73 to note 10 CFR Part 21 applicability on
the LER form (NRC Form 366) and within the text of the LER. The NRC expects that recipients
will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. Suggestions contained in this IN are not NRC requirements;
therefore, no specific action or written response is required.
1 NRC regulations in 10 CFR 21.3, Definitions, state that a defect is a deviation in a basic component
delivered to a purchaser for use in a facility or an activity subject to the regulations in 10 CFR Part 21 if, on
the basis of an evaluation, the deviation could create a substantial safety hazard.
2 NRC regulations in 10 CFR 21.3 state that a basic component is a structure, system, or component that
ensures the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and
maintain it in a safe-shutdown condition, or the capability to prevent or mitigate the consequences of
accidents. In all cases, a basic component includes safety-related design, analysis, inspection, testing, fabrication, replacement of parts, or consulting services that are associated with the component hardware, design certification, design approval, or information in support of an early site permit application under
10 CFR Part 52, whether these services are performed by the component supplier or others.
BACKGROUND
The regulations in 10 CFR Part 21 establish procedures and requirements for the
implementation of Section 206 of the Energy Reorganization Act of 1974. Section 206 requires
any individual director or responsible officer of a firm constructing, owning, operating, or
supplying the components of any facility or activity that is licensed or otherwise regulated
pursuant to the Atomic Energy Act of 1954, as amended, or the Energy Reorganization Act of
1974, who obtains information reasonably indicating (1) that the facility, activity, or basic
component supplied to such facility or activity fails to comply with the Atomic Energy Act of
1954, as amended, or any applicable rule, regulation, order, or license of the Commission
relating to substantial safety hazards3, or (2) that the facility, activity, or basic component
supplied to such facility or activity contains defects that could create a substantial safety hazard, to immediately notify the Commission of such failure to comply or such defect, unless he has
actual knowledge that the Commission has been adequately informed of such defect or failure
to comply.
Regulation 10 CFR 21.2 states that for persons licensed to operate a nuclear power plant under
10 CFR Part 50 or 10 CFR Part 52, evaluation of potential defects and appropriate reporting of
defects under 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear
Power Reactors, 10 CFR 50.73, or 10 CFR 73.71, Reporting of Safeguards Events, satisfy
each persons evaluation, notification, and reporting obligation to report defects under
DESCRIPTION OF CIRCUMSTANCES
The NRC reviews all LERs for safety significance and generic applicability. The NRC
occasionally identifies LERs containing information related to defects in basic components
(which satisfies the reporting obligation to report defects under 10 CFR Part 21) where the LER
does not specifically mention 10 CFR Part 21. The following LER provides a specific example
of this situation.
H.B. Robinson Steam Electric Plant, Unit 2
On February 22, 2010, the licensee at H.B. Robinson Unit 2 removed the B emergency diesel
generator (EDG) from service for planned maintenance. During post-maintenance testing, the
output breaker for the B EDG failed to close. The breakers failure to close was unrelated to
the maintenance activity. The licensees analysis determined that the cause of the EDG output
breaker failure was a vendor workmanship error related to a defective shunt trip attachment
movable core in the breaker control circuit. The licensee determined that the B EDG had been
inoperable for a period of 27 days and reported the condition under 10 CFR 50.73(a)(2)(i)(B) as
any operation or condition that was prohibited by the plants technical specifications. Additional
3 NRC regulations in 10 CFR 21.3 state that a substantial safety hazard means a loss of safety function to the
extent that there is a major reduction in the degree of protection provided to public health and safety for any
facility or activity licensed or otherwise approved or regulated by the NRC, other than for export, under
10 CFR Part 30, 40, 50, 52, 60, 61, 63, 70, 71, or 72. information appears in H.B. Robinson Steam Electric Plant, Unit 2, LER 05000261/2010-001-01, Emergency Diesel Generator Inoperable in Excess of Technical Specifications Completion
Time due to Output Breaker Failure, dated June 1, 2010, on the NRCs public Web site in the
Agencywide Documents Access and Management System, Accession No. ML101590222.
DISCUSSION
Regulation 10 CFR 21.2 specifies that a nuclear power plant licensees evaluation of potential
defects and appropriate reporting of defects under 10 CFR 50.73 satisfies the evaluation, notification, and obligation to report defects under 10 CFR Part 21. Because of the potential
generic nature of defects to basic components reported in some LERs, the NRC staff will now
post all LERs containing information pertaining to defects to basic components to the Part 21 Reports page on the NRC public website. The intent of this effort is to raise licensee awareness
of defects to basic components by rapidly disseminating this information to the industry via the
NRC public website. Although there is no explicit NRC requirement for licensees to do so, the
NRC encourages licensees reporting 10 CFR Part 21 defects under 10 CFR 50.73 to note
10 CFR Part 21 applicability on the LER form (NRC Form 366) and within the text of the LER.
CONTACT
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contacts listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
/RA/
/RA/
Laura A. Dudes, Director
Timothy J. McGinty, Director
Division of Construction Inspection
Division of Policy and Rulemaking
and Operational Programs
Office of Nuclear Reactor Regulation
Office of New Reactors
Technical Contacts: Stephen J. Pannier, NRR
301-415-4083
301-415-3026 E-mail: stephen.pannier@nrc.gov
E-mail: paul.prescott@nrc.gov
301-415-6616 E-mail: omid.tabatabai@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under NRC Library.
ML111800524 TAC ME5927 OFFICE
IOEB/DIRS
Tech Editor
BC:IOEB/DIRS
BC:EQVB/DE
NAME
SPannier
KAzariah-Kribbs
JThorp
MMurphy
DATE
8/16/11
7/29/11 e-mail
8/16/11 e-mail
8/31/11 OFFICE
BC:CQVB/DCIP
BC:IRIB/DIRS
D:DIRS
LA:PGCB/NRR
NAME
RRasmussen
TKobetz
FBrown JAnderson for
CHawes
DATE
8/1/11 e-mail
9/14/11
9/19/11
9/21/11 OFFICE
PM:PGCB/NRR
BC:PGCB/NRR
D:DCIP:NRO
D:DPR:NRR
NAME
DBeaulieu
SRosenberg TAlexion for LDudes
TMcGinty
OFFICE
9/20/11
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