ML16141B215
| ML16141B215 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/19/1997 |
| From: | Labarge D NRC (Affiliation Not Assigned) |
| To: | Hampton J DUKE POWER CO. |
| References | |
| NUDOCS 9706230269 | |
| Download: ML16141B215 (4) | |
Text
June 19, 1997 Mr. J. W. Hampton Vice President, Oconf'Site Duke Power Company P. 0. Box 1439 Seneca, SC 29679
SUBJECT:
LICENSEE EVENT REPORT SUBMITTAL EVALUATION FOR THE OCONEE NUCLEAR STATION UNITS 1, 2, AND 3
Dear Mr. Hampton:
In response to a concern related to the quality of some Licensee Event Reports (LERs) that have been submitted by the Duke Power Company for the Oconee Nuclear Station, the NRC Office for Analysis and Evaluation of Operational Data (AEOD) has conducted a review of recent LERs. The purpose of the review was to identify weaknesses in the.submittals and inconsistencies with NUREG-1022 guidance. A summary of the specific problem areas identified by AEOD is enclosed. We request that you review these comments and consider steps to upgrade your program as necessary. In addition, we request that you review the guidance in NUREG-1022 and 10 CFR Part 50.73 to ensure all weaknesses have been identified and corrected.
It is important to recognize that incomplete or incorrectly reported LER information adversely affects the staff's ability to accurately code LERs for the Performance Indicator Program, perform accident sequence precursor analyses, and perform other long-term.evaluations of operational experience.
Sincerely, ORIGINAL SIGNED BY:
David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects -
I/II Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Examples of LER Reporting Weaknesses cc w/encl:
See next page Distribution:
Docket File OGC PUBLIC ACRS PD 11-2 Rdg.
JJohnson, RII SVarga CCasto, RII JRosenthal LPadovan MScott.
To receive a copy of this document, Indicate In the box:
"C" = Copy without attachment/enclosure "E" = Copy with attachment/
enclosure "N" = No copy OFFICE PDII-2/
I PDII-2/
,A NAME DLaBarg LBerry Be DATE e /1q/97
/
97 DOCUMENT NAME: G:\\OCONEE\\PPL R\\LTR OFFICIA D COPY 9706230269 970619 PDR ADOCK 05000269 S
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 19, 1997 Mr. J. W. Hampton Vice President, Oconee Site Duke Power Company P. 0. Box 1439 Seneca, SC 29679
SUBJECT:
LICENSEE EVENT REPORT SUBMITTAL EVALUATION FOR THE OCONEE NUCLEAR STATION UNITS 1, 2, AND 3
Dear Mr. Hampton:
In response to a concern related to the quality of some Licensee Event Reports (LERs) that have been submitted by the Duke Power Company for the Oconee Nuclear Station, the NRC Office for Analysis and Evaluation of Operational.
Data (AEOD) has conducted a review of recent LERs. The purpose of the review was to identify weaknesses in the submittals and inconsistencies with NUREG-1022 guidance. A summary of the specific problem areas identified by AEOD is enclosed. We request that you review these comments and consider steps to upgrade your program as necessary. In addition, we request that you review the guidance in NUREG-1022 and 10 CFR 50.73 to ensure all weaknesses have been identified and corrected.
It is important to recognize that incomplete or incorrectly reported LER information adversely affects the staff's ability to accurately code LERs for the Performance Indicator Program, perform accident sequence precursor analyses, and perform other long-term evaluations of operational experience.
Sincerely, David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects -
I/II Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Examples of LER Reporting Weaknesses cc w/encl: See next page
Oconee Nuclear Station Units 1, 2, and 3 cc:
Mr. Paul R. Newton Mr. J. E. Burchfield Legal Department (PB05E)
Compliance Manager Duke Power Company Duke Power Company 422 South Church Street Oconee Nuclear Site Charlotte, North Carolina 28242-0001 P. 0. Box 1439 Seneca, South Carolina 29679 J. Michael McGarry, III, Esquire Winston and Strawn Ms. Karen E. Long 1400 L Street, NW.
Assistant Attorney General Washington, DC 20005 North Carolina Department of Justice Mr. Robert B. Borsum P. 0. Box 629 Framatome Technologies Raleigh, North Carolina 21602 Suite 525 1700 Rockville Pike Mr. G. A. Copp Rockville, Maryland 20852-1631 Licensing -
ECO50 Duke Power Company Manager, LIS 526 South Church Street NUS Corporation Charlotte, North Carolina 28242-0001 2650 McCormick Drive, 3rd Floor Clearwater, Florida 34619-1035 Senior Resident Inspector U. S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, South Carolina 29678 Regional Administrator, Region II U. S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, Georgia 30303 Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 County Supervisor of Oconee County Walhalla, South Carolina 29621 Mr. Dayne H. Brown, Director Division of Radiation Protection North Carolina Department of Environment, Health and Natural Resources P. 0. Box 27687 Raleigh, North Carolina 27611-7687
Examples of Licensee Event Report ReDorting Weaknesses Oconee Nuclear Station The following summarizes the problems identified in reporting LERs:
- a.
Oconee submits many more abstract-only Licensee Event Reports (LERs) than are submitted by other licensees. In addition, the abstracts frequently do not contain the information required by 10 CFR 50.73(b)(2) through (b)(6) for LER content, such as event root cause and proposed corrective actions. For example, the abstract-only LER 269/96-06 did not describe why the procedure change process allowed the situation to occur, and what steps were taken to prevent recurrence. Also, abstract-only LER 269/97-02 did not specify root causes or corrective actions.
- b.
The 10 CFR paragraph, stated as the basis for the LER, has not always been consistent with the event description. For example, LER 269/96-06 was submitted under 10 CFR 50.73(a)(2)(v)(D), which is any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. However, the report describes what appears to be a section (a)(2)(i) technical specification deviation. This observation is based on the report statements that the "[filters] had not been tested in exact accordance with TS requirements," and "Functional operability of the filters was not in question; therefore this event had no safety impact."
- c.
In a number of cases, supplemental event information was not submitted in accordance with NUREG-1022 guidance. Supplemental event information should be submitted as a revision to the original LER, such that the revised LER is complete and contains all of the information, not just the revised or supplemental information. For example, the supplemental information for abstract-only LER 269/96-10 was submitted in a revision to an unrelated event described in LER 269/96-08. In addition, LER 269/96-08 had been retracted prior to the time that the supplemental information was added. Also, the supplemental information for abstract only LER 270/96-06 was supplied in separate letters, rather than in the LER.
- d.
Occasionally, pertinent event information has not been included in LERs, which resulted in failure to report many of the details of the events in a timely manner. For example, the root causes and corrective actions are sometimes deferred to a supplemental report. Thus, information pertinent to the effect of the event on the system, post-maintenance or surveillance testing, or length of time the conditions existed, may be missing (see LER 270/96-07). Thus, all of the pertinent information is not available to the staff in a timely manner for such LERs. All reasonable effort should be expended to include all pertinent information in an LER and submit it in a timely manner, in accordance with the guidelines of NUREG-1022.
Enclosure