ML17290B066
| ML17290B066 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/22/1994 |
| From: | Baranowsky P NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Quay T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9403310204 | |
| Download: ML17290B066 (2) | |
Text
March 22, 1994 MEMORANDUM FOR:
Theodore R. quay, Director Project Directorate V
Office of Nuclear Reactor Regulation FROM:
SUBJECT:
Patrick W. Baranowsky, Chief Trends and Patterns Analysis Branch Division of Safety Programs Office for Analysis and Evaluation of Operational Data REPORTING MULTIPLE FAILURES AND RELATED EVENTS AT WNP-2 UNDER 10 CFR 50.73 This memo is in response to a note from Jim Clifford, NRR/PDV, concerning questionable reporting practices under 10 CFR 50.73 at WNP-2.
In LER 397/93-010, Revisions 0 through 5, the licensee is assuming a
flexibilityin reporting that is not appropriate.
Over an extended period of time (two years),
the licensee has utilized LER revisions to report events, such as conditions prohibited by.Technical Specifications, which were discovered as a result of discovering inadequate test procedures in a "surveillance improvement program".
The WNP-2 practice is based on the guidance in NUREG-1022, Supplement 1,
Answers to questions
- 14. 13 and
- 14. 14.
This guidance was intended to cover an activity such as an outage or test program lasting on the order of several weeks (Answer 14.13) or 60 days (Answer 14.14).
The guidance was not intended to cover activities lasting for extended
- periods, such as two years.
(The current (second) draft of NUREG-1022, Rev.
1, which was noticed for comment on February 7, 1994, essentially repeats the guidance of questions
- 14. 13 and 14.14~on pages ll and 12, with additional discussion on page 109.)
Furthermore, the licensee, in a letter submitted on November 9, 1993, stated its intention of reporting on an approximately quarterly basis.
There is no provision in the-LER rule or in NRC event reporting guidance that allows delaying reportable events until the end of a quarter.
280038 9403310204.94032Z I
PDR ADOCK 05000397 P
PDR As stated in NUREG-1022, revisions should not be used to report new events months after the original event.
Events of this type should be reported as new LERs, not as revisions to previous LERs.
The flexibilityprovided by NUREG-1022, Supplement 1, should not be used as a mechanism to avoid submitting separate reports.
/s/
Patrick W. Baranowsky, Chief Trends and Patterns Analysis Branch Division of Safety Programs Office for Analysis and Evaluation of Operational Data Distribution:
TPAB R/F EJordan DRoss PBaranowsky HHarper
- GNizuno, OGC
WJones SIsrael JHacKinnon
- STreby, OGC
- Tguay, NRR
- HPoore, ORNL TPAB ~a,X HHarper 03/y /94 SC/P PAB DHic man 03/)( /94 C TPAB+
PBarako s y 03+/94
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