ML18227B835
| ML18227B835 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/01/1977 |
| From: | Robert E. Uhrig Florida Power & Light Co |
| To: | Lear G Office of Nuclear Reactor Regulation |
| References | |
| NUREG-0161 | |
| Download: ML18227B835 (6) | |
Text
DISTRIBUTION AFTER ISSUANCE OF OPERATING LICENSE
.'JRC FORM 195 U S NUCI.EAR REGULATORY COMMISS N'-76 I
N<C DISTRIBUTION FoR PART 50 DOCKET MATERIAL OOCKET NUMBER FILE NUMEER jfJ ETTER ORIGINAL Q COPY DESCRIPTION C1NOTORIZEO JUNC LASS IF IE O Mr. George Lear PROP INPUT FORM ENCLOSURE FRQMI~~
Miami, Fl.
33101 Robert E. Uhrig OATE OF OOCUMENT 09/01/77 OATE RE CEI V E 0 09/06/77 NUMSER OF COPIES RECEIVEO 3 Dg e'urnishing comments in response to NRC's ltr dated 07/29/77 which forwarded new "instructions for Preparation 6f Data Entry She for Licensee Event Report File", NUREG-0161, Ju ts 1977.
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rygggQ ItLgDQE93 DO NOT REMOVFI PLAiIT NAhIE'URKEY POlNT UNITS 3 Q 4 Jcm 09/08/77 SAFETY BRANCH CHIEF' FOR ACTION/INFORMATION IIREG. FILE DR I GE (2)
OELD HANAUER CHECK STELLO EISENHUT SHAO BAER BUTLER GRDIES J. COLLINS INTERNALDISTRl BUTION LPDR:
TIC NSIC 16 CYS ACRS SENT CATE EXTERNALOISTRIBUTION 0 Y CONTROL NUMBER
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P. O. BOX 013100, MIAMI, FL 33101 y6 l(z I)
FLORIDAPOWER & LIGHTCOMPANY September 1,
1977 L-77-275 Office of Nuclear Reactor Regulation Attention:
Mr. George Lear, Chief Operating Reactors Branch 53 Division of Operating Reactors U. S. Nuclear Regulatory Commission Washin'gton, D. C.
20555
Dear M):
. Lear:
"', j ~eN@~~v gfgg 1
Re:
Turkey Point. Units 3 and 4
Docket Nos.
50-250 and 50-251 NUREG-0161 S
')
/ ~tk Your letter of July 29, 1977 forwarded new'"Inst'iuctions for-Preparation of Data Entry Sheets for Licensee Event Report (LER)
File", NUREG-0161, July 1977.
Your letter also requested that we review the instructions and notify you if we did not anticipate being able to use the revised form.
We have reviewed NUREG-0161 and have the following comments:
(1)
NUREG-0161 states that background and any other supplementary information required for a full an attachment to the LER form.
This, being a
non-specific open-ended requirement, is subject to interpretation.
"Sufficient information for full understanding" depends on the reader's back-ground.
(2)
The main purpo"e of the LER form is tc pro:ide in-formation on off-normal events to a computer data bank.
Since attached information is not. used for this purpose, the attachment becomes of secondary importance and need not be the subject, of special instructions.
(3)
Compatibility with the Nuclear Plant Reliability Data System (NPRDS) does not necessarily make the new LER form less burdensome, as claimed in the Introduction to NUREG-0161.
The responsibilities for compiling NPRDS reports and LER's reside with different. groups within Florida Power 6 Light, Company.
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Office of Nuclear Reactor Regulation Page Two Increased coordination of these responsibilities would actually increase the work load.
In addition, the new LER forms are longer and more detailed.,
and will not be easier to complete than the current forms.
(4)
The "PROCEDURES" section on page 3 of NURFG- 0161 claims that "the procedures described herein do not impose any additional reporting requirements'".
This will be true as long as NUREG-0161 instructions are interpreted as "guidelines",and not "requirements".
(5)
One effect of NUREG-,0161 will be to expand one report.
into two reports, i.e., the LHR abstract"which is intended to stand alone, and the separate 'narrative attachment.
This considerably increases the work needed to file a Reportable Occurrence report.
Technical Specification 6.9.2 specifies the reports required to describe Reportable Occurrences.
Specifications 6.9.2.a (prompt reports) and 6.9.2.b (30-day reports)
- state, in part, that written followup reports shall include, as a minimum a completed copy of a licensee event report form, to be supplemented, by additional narrative material to provide complete explanation of the circum-stances surrounding the event.
Our current practice of conti:nuing the Event Description and Cause Description on a separate page whenever more space is needed satisfies the Technical Specification requirements.
A separate narrative attachment that restates the LER form in greater detail is not necessary.
Although we have objections to NUREG-0161 as described
- above, do intend to implement the new LER form, wit:h the understanding that our Reportable Occurrence reports will maintain th="ir present overall format, and that NUREG-0161 will not become an auditable requirement.
Also, rather than change our reporting-p actices in mid-year, it.,",would be simpler for us to continue, using the
- current, LER form for the remainder of 1977.
Tnus,'we plan to use NUREG-0161 for general guidance in implementi:ng,the new LER forms after January lp 1978.
Very truly, yours, Robert E. Uhrig Vice President REU/MAS/cpc cc:
Mr. James P. O'Reilly, Region II Robert Lowenstej.n, Esquire
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