Letter Sequence Other |
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MONTHYEARML20058M4021993-12-0808 December 1993 Forwards TIA,93TIA006,interpretation of Reporting Requirements Re Multiple Failures of safety-related Components Project stage: Other ML20058L6931993-12-0808 December 1993 Forwards TIA 93TIA006,interpretation of Reporting Requirements Re Multiple Failures of safety-related Components Project stage: Other ML20058L0091993-12-0808 December 1993 Forwards NRR 931102 Response to Region IV 930413 Request for Interpretation of Reporting Requirements Re Multiple Failures of safety-related Components Identified During Performance of Surveillance Testing Project stage: Other ML20058K9811993-12-0808 December 1993 Forwards NRR 931102 Response to Region IV Request for Interpretation of Reporting Requirements Re Multiple Failures of safety-related Components Identified During Performance of Surveillance Testing for Info Project stage: Other ML20058K6001993-12-0808 December 1993 Forwards Tia,Interpretation of Reporting Requirements, 93TIA006 Re Multiple Failures of safety-related Components Project stage: Other ML20058K5961993-12-0808 December 1993 Forwards Tia,Interpretation of Reporting Requirements - 93TIA006,re Multiple Failures of safety-related Components Project stage: Other ML20058K5801993-12-0808 December 1993 Forwards Tia,Interpretation of Reporting Requirements - 93TIA006,re Multiple Failures of safety-related Components Project stage: Other ML20058K5611993-12-0808 December 1993 Forwards Tia:Interpretation of Reporting Requirements, 93TIA006.Guidance Provided in Response to Region 5 Request for Interpretation of Reporting Requirements for safety- Related Components Project stage: Other 1993-12-08
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217G7401999-10-14014 October 1999 Forwards MOR for Sept 1999 for Cooper Nuclear Station. Rept Includes Documentation of Challenges to Safety/Relief Valves,Iaw TS 5.6.4 ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20216J8061999-09-20020 September 1999 Forwards Rev 37 to Safeguards Plan,Iaw Provisions of 10CFR50.(p).Rev Withheld,Per 10CFR73.21 ML20212C4921999-09-15015 September 1999 Forwards Monthly Operating Rept for Aug 1999 for Cooper Nuclear Station.Rept Includes Operating Data Rept,Unit SD Rept & Documentation of Challenges to Safety/Relief Valves ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211N5271999-09-0202 September 1999 Responds to NRC 990823 RAI Re Y2K Readiness at Cooper Nuclear Station,Per GL 98-01,Suppl 1 05000298/LER-1999-006, Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl1999-08-26026 August 1999 Forwards LER 99-006-00 for Cns.Commitments Made by Util Encl ML20211F1311999-08-24024 August 1999 Forwards Rev 1 to Calculation Nedc 97-044, NPSH Margins for RHR & CS Pumps, in Support of 990615 Proposed Amend to DPR-46 Re Containment Overpressure Contribution to ECCS Pumps NPSH Requirements 05000298/LER-1999-003, Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel1999-08-23023 August 1999 Informs That Commitment Re Insp Rept 50-298/98-15 & LER 99-003,to Bound Extent of Condition & Take Appropriate C/As Is Now Complete.Addl Time Is Required to Accommodate Training of Engineering Support Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20210R0301999-08-12012 August 1999 Forwards Monthly Operating Rept for July 1999 for Cooper Nuclear Station,Iaw Guidance Provided by GL 97-02.Rept Also Includes Documentation of Challenges to Srvs,Per TS 5.6.4 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6761999-08-10010 August 1999 Requests That Following Changes Be Made to Distribution on NRC Correspondence ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210K6071999-08-0202 August 1999 Submits Withdrawal of Proposed License Amend Re Secondary Containment Isolation Description & Refueling Accident Analysis Results ML20210K3811999-08-0202 August 1999 Forwards Listed Info,Which NPPD Believes Demonstrates Ability to Obtain Funds in Amount of $10 Million for Payment of Such Premiums within Specified Three Month Period,Iaw 10CFR140.21 ML20210G5101999-07-28028 July 1999 Forwards fitness-for-duty Program semi-annual Performance Rept for Period of 990101-0630,per Provisions of 10CFR26.71(d) ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20209B7851999-07-0101 July 1999 Forwards Corrected Occupational Radiation Exposure Repts, for Cys 1996 & 1997.Util Stated That Repts Did Not Properly Tabulate Number of Personnel Receiving Exposures Less than 100 Mrem by Work & Job Functions in CY96 & CY97 05000298/LER-1999-005, Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl1999-07-0101 July 1999 Forwards LER 99-005-00 for Cns.Commitments Made by Util Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, 05000298/LER-1999-004, Forwards LER 99-004-01.Commitments Made by Util Are Encl1999-06-28028 June 1999 Forwards LER 99-004-01.Commitments Made by Util Are Encl ML20209B5451999-06-28028 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl ML20196H0331999-06-24024 June 1999 Informs NRC of Deletion of 1991 Commitment Contained in Ltr Re Feedwater Nozzle Bypass Leakage Monitoring at Plant ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20209A7221999-06-23023 June 1999 Submits Revised Pages to Proposed Change to Plant TS Previously Submitted in ,Per 990615 Telcon with NRC ML20196F5331999-06-22022 June 1999 Forwards Examination Summary Rept for FW Nozzle Examinations Performed During 1998 Fall Refueling Outage at Cooper Nuclear Station.Rept Covers Past Examinations Up to & Including 1998 Fall Refueling Outage ML20196B4681999-06-17017 June 1999 Forwards TS Bases Changes Made at Plant Subsequent to Receipt of License Amend 178,dtd 980731,for Conversion to Its,Through 990610.List of Effective Pages for TS Bases, Encl ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195H8891999-06-14014 June 1999 Forwards Response to NRC 990315 RAI Re GL 95-07, Pressure Locking & Thermal-Binding of SR Power-Operated Gate Valves, 180-day Response Submitted by District on 960213 ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20195E2351999-06-0808 June 1999 Forwards Response to NRC 990517 RAI Re Util Proposed Change to TS Re Calibr Frequency of Reactor Recirculation Flow Transmitters Associated with APRM ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations 1999-09-30
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217N1931999-10-22022 October 1999 Forwards Insp Rept 50-298/99-12 on 990927-30.No Violations Noted.Insp Exam of Activities Under License as They Relate to Emergency Preparedness & to Compliance with Commission Rules & Regulations & with Conditions of License ML20217G8771999-10-14014 October 1999 Forwards Insp Rept 50-298/99-10 on 990920-24.No Violations Noted ML20217C2671999-10-0808 October 1999 Forwards Insp Rept 50-298/99-03 on 990823-27 & 0907-10.No Violations Noted.Purpose of Insp to Ensure That Licensee Had Effective Programs for Identifying,Evaluating & Correcting Problems Which Could Impact Safe Plant Operations ML20212K9661999-09-30030 September 1999 Forwards Safety Evaluation Accepting plant-specific Safety Evaluation Rept for USI A-46 Program Implementation at Cooper Nuclear Station ML20216J1081999-09-28028 September 1999 Ltr Contract:Task Order 048, Cooper Safety Sys Design & Performance Capability Insp, Under Contract NRC-03-98-021 ML20212J5061999-09-27027 September 1999 Forwards Insp Rept 50-298/99-07 on 990718-0828.No Violations Noted.Inspectors Focused on Implementation of Licensee Reactor Safety & Emergency Preparedness Programs ML20212F3641999-09-22022 September 1999 Forwards Insp Rept 50-298/99-09 on 990823-26.No Violations Noted ML20212A6061999-09-14014 September 1999 Forwards Insp Rept 50-298/99-08 on 9900816-20.No Violations Noted.Insp Focused on Implementation & Effective Performance of Access Authorization/Fitness-for-Duty (Behavior Observation) Program & Access Control of Personnel ML20211F4661999-08-23023 August 1999 Discusses GL 98-01 Issued by NRC on 980511 & NPPD Responses for Cooper Nuclear Station & 990628 & Results of Visit to Plant on 990811-12.Staff Determined That Integrated Contigency Plan Incomplete & CNS Not Y2K Ready ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210P6861999-08-0909 August 1999 Forwards Insp Rept 50-298/99-06 on 990530-0717.No Violations Noted.During Insp,Inspectors Identified Two Issues Categorized as Being Low Risk Significance & within Licensee Response Band ML20210N1331999-08-0606 August 1999 Forwards Notice of Withdrawal of Application for Amend to FOL DPR-46.By Ltr Licensee Withdrew Amend Request Which Would Have Revised Usfar to Reflect as-built Configuration of Reactor Bldg Isolation Dampers ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D2541999-07-21021 July 1999 Forwards Insp Rept 50-298/99-02 on 990628-0702.Purpose of Insp Was Primarily to Evaluate Effectiveness of Licensed Operator Requalification Program.No Violations Were Identified ML20210C2041999-07-20020 July 1999 Discusses 990715 Mgt Meeting with Midamerican Energy Co Re risk-informed Baseline Insp Program Recently Implemented at Cooper & Fort Calhoun Stations ML20209H8191999-07-15015 July 1999 Forwards Safety Evaluation on GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20209E6951999-07-12012 July 1999 Discusses Response to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Recommends Review of New Database Diskettes on Listed Website.Comments Due by 990901 or Data Entered Into Rvid for Plant Will Be Acceptable ML20209D8731999-07-0808 July 1999 Refers to 990707 Meeting Re Licensee Recent Maintenance Program self-assessment.Also Discussed How Licensee Incorporated Assessment Findings Into Rev of Maintenance Performance Improvement Plan.List of Attendees Encl ML20196J2471999-06-29029 June 1999 Discusses Completion of Licensing Action for GL 97-04, Assurance of Sufficient Net Positive Suction Head for ECC & Containment Heat Removal Pumps, ML20196F7511999-06-24024 June 1999 Discusses 990622 Meeting with Public at Arbor Manor, Alburn,Ne to Provide Overview of Pilot Insp Program ML20196E1411999-06-16016 June 1999 Forwards Insp Rept 50-298/99-05 on 990502-29.Noncited Violations Identified ML20195F6171999-06-0909 June 1999 Informs That GE Rept, Matl Presented by GE 970709 Meeting at Cooper Nuclear Power Station Re Replacement of ECCS Pump Suction Strainers Between Nppd,Ge & NRC Staff, Will Be Withheld from Public Disclosure as Requested ML20207G3031999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Rev 24,under 10CFR50,App E,Section V Provisions.No Violations Identified ML20207G4481999-06-0808 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure,Epip 5.7.1, Emergency Classification,Rev 23 C2,under Provisions of 10CFR50,App E,Section V ML20207G4531999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station EP Implementing Procedure EPIP 5.7.1, Emergency Classification,Revision 25,under Provisions of 10CFR50,App E,Section V ML20207G3001999-06-0707 June 1999 Ack Receipt of Which Transmitted Changes to Cooper Nuclear Station Ep,Rev 33,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required Based on Determination That EP Effectiveness Not Affected by Changes ML20207D3811999-05-27027 May 1999 Informs That During Next 6 to 12 Months,Starting 990530,NRC Plans to Conduct Insps Shown in Attached Insp Plan.Insps Include Both Planned Baseline & Supplemental Insps (Formerly Core & Regional Initiative Insps) ML20207A5191999-05-19019 May 1999 Forwards Insp Rept 50-298/99-04 on 990321-0501.Four Violations Identified & Being Treated as non-cited Violations ML20206Q6171999-05-17017 May 1999 Forwards RAI Re 990301 & 10 Ltrs Re Proposed TS Changes to Calibr Frequency of Recirculation Flow Transmitters from Once Every 184 Days to Once Every 18 Months.Util Responses Should Be Provided within 30 Days of Ltr Date ML20206P0171999-05-12012 May 1999 Discusses GL 96-05 Issued on 960918 & NPPD Responses Submitted on 961118,970317,980504 & 990222 for Cooper Nuclear Station.Forwards Safety Evaluation Concluding That NPPD Adequately Addressed Actions Requested in GL 96-05 IR 05000298/19980091999-05-12012 May 1999 Refers to Insp Rept 50-298/98-09 Conducted Between 981227-990130.During Insp,Apparent Violation of 10CFR50.50 Identified & Being Treated as non-cited ML20206M1791999-05-11011 May 1999 Informs That NRC Ofc of NRR Reorganized Effective 990328. Reorganization Chart Encl ML20206H4191999-05-0707 May 1999 Informs That on 990407,NRC Administered Gfes of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However,Copy of Master Exam with Answer Key,Encl for Info.Without Encl ML20206P8961999-05-0707 May 1999 Refers to Meeting Conducted at Region IV Office on 990506 Re Licensee Upcoming Rev to Strategy for Achieving Engineering Excellence & Plans to Achieve Performance Improvements.List of Attendees & Util Presentation,Encl ML20206H7541999-05-0505 May 1999 Forwards Insp Rept 50-298/99-01 on 990207-0320.Violations Being Treated as non-cited Violations ML20205R5541999-04-16016 April 1999 Submits Summary of 990330 Public Meeting in Brownville,Ne to Discuss Results of PPR Completed on 990211,which Allowed for Exchange on New Assessment Process,Current Performance Review & Upcoming Actions Taken in Response to Y2K Concerns IR 05000298/19980221999-03-19019 March 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-298/98-22 on 990107.Finds Reply Responsive to Concerns Raised in NOV ML20205E8991999-03-19019 March 1999 Advises of Completion of Plant Performance Review on 990209 to Develop Integrated Understanding of Safety Performance. Overall Performance Was Acceptable.Problems with Communication in CR Resulted in Several Minor Events ML20204D9451999-03-18018 March 1999 Forwards Insp Rept 50-298/98-09 on 981227-990206.Three Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20207M9591999-03-15015 March 1999 Forwards Request for Addl Info Re Licensee Response to GL 95-07, Pressure-Locking & Thermal-Binding of Safety-Related Power-Operated Gate Valves, for Cooper Nuclear Station ML20204B6771999-03-15015 March 1999 Submits Withdrawal of Amend Request for Operating License DPR-46.Proposed Change Would Have Modified Facility TSs Pertaining to Neutron Monitoring Neutron Detectors ML20207M9811999-03-15015 March 1999 Advises That Which Withdrew 980415 Amend Request, Being Treated as Withdrawal.Proposed Change Would Have Modified Facility TSs Pertaining to Neutron Monitoring,Flow Biased Rod Block Monitor ML20204B3301999-03-11011 March 1999 Forwards SE Accepting Third 10-year Interval Inservice Insp Program Plan Requests for Relief Numbers RI-13,RI-17 & RI-25 for Plant ML20204B7061999-03-11011 March 1999 Requests Approval of Proposed Operability Criteria for Use in Evaluation & Interim Resolution of Degraded & Nonconforming Conditions with Piping & Pipe Supports at Facility ML20205A5811999-03-0909 March 1999 Forwards Exam Rept 50-298/99-301 for Exam Administered on 990212.Exam Included Evaluation of Four Applicants for Reactor Operator License ML20207K3231999-03-0808 March 1999 Discusses 990224 Meeting Re Staff Critique of Refueling & Equipment Outage RE-18 & Implementation Status of Improvement Strategy for Engineering.List of Attendees & Matl Used in Presentation Encl ML20202G1701999-02-0202 February 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam at Util Facility on 990407.Authorized Representative from Facility Must Submit Ltr Listing Names of Candidates ML20202E3121999-01-22022 January 1999 Forwards Insp Rept 50-298/98-08 on 981115-1226 & Notice of Violation.First Violation Re Staff Failure to Follow Procedures (Two in Operations,One in Maint & One in Plant Support) ML20199G6041999-01-19019 January 1999 Informs That Effective 990118,JN Donohew Has Assumed NRC Project Mgt Responsibility for Cooper Nuclear Station ML20199E1521999-01-0707 January 1999 Forwards Insp Rept 50-298/98-22 on 981116-1208 & Notice of Violation Re Lack of Effective Oversight by Plant Mgt 1999-09-30
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UNITE D S7 AVES 49 QEGug
,7, f NUCLEAR REGULATORY COMMISSION
' /j'.j ' REGION IV o 8 611 RY AN PLAZA DRIVE', SUIT E 400 Y, AR LINGTON, T E XAS 760118064
- "* DEC 8 1993 Docket: 50-298 License: DPR-46 Nebraska Public Power District ATTN: Guy R. Horn, Vice President - Nuclear P.O. Box 98 Brownville, Nebraska 68321
SUBJECT:
TASK INTERFACE AGREEMENT: INTERPRETATION OF REPORTING REQUIREMENTS - 93TIA006 (TAC NO. M86339)
The purpose of this letter is to provide for your information a copy of the guidance recently issued by the Office of Nuclear Reactor Regulation in their Memorandum of November 2, 1993, to Region IV (see enclosed). This guidance was provided in response to a Region IV request for interpretation of reporting requirements related to multiple failures of safety-related components that are identified during the performance of surveillance testing. '
We plan to implement this guidance during out future inspections at your [
facility. Should you have questions regarding this matter, please contact Tom ;
Westerman of my staff at 817-860-8145.
I
.J j$ mue . Collins, Director Division of Reactor Safety i
Enclosure:
(as noted) cc w/ enclosure:
Nebraska Public Power District ATTN: G. D. Watson, General Counsel P.O. Box 499 '
Columbus, Nebraska 68602-0499 Nebraska Public Power District ATTN: Mr. David A. Whitman P.O. Box 499 .
Columbus, Nebraska 68602-0499 Nebraska Department of Environmental '
Control ATIN: Randolph Wood, Director i P.O. Box 98922 Lincoln, Nebraska 68509-8922 i
9312160086 931208 E PDR ADOCK 05000298 P PDR ;L [
Nebraska Public Power District :
Nemaha County Board of Commissioners ATTN: Larry Bohlken, Chairman i Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 i i
Nebraska Department of Health ATTN: Harold Borchert, Director Division of Radiological Health i 301 Centennial Mall, South l P.O. Box 95007 ,
Lincoln, Nebraska 68509-5007 ;
Department of Natural Resources ;
ATTN: Ronald A. Kucera, Department Director l of Intergovernmental Cooperation i P.O. Box 176 Jefferson City, Missouri 65102 ;
Kansas Radiation Control Program Director ;
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. lMi5tA001
%, ' d / November 2, 1993 MEMORANDUM FOR: Samuel J. Collins, Directt.
Division of Reactor Safety i Region IV iROM: Elinor G. Adenram, Assistant Director for Regions IV and V Jivision of Reactor Projects Ill/IV/V i Office of Nuclear Reactor Regulation
SUBJECT:
TASK INTERFACE AGREEMENT: INTERPRETATION OF REPORTING ',
REQUIREMENTS - 93TIA006 (TAC NO. MB6339)
In response to your request dated April 13,199.i. we have reviewed the av&ilable guidance associated with the reporting requirements related to :
multiple failures of safety-related components that are identified during the '
performance of surveillance procedures. The specific examples cited in your questions regarded the outage surveillances related to primary or secondary '
rafety relief valves and the discovery that the as-found setpoints were outside the allowable technical specification setpoint tolerances. Please note that the Public Document Room (PDR) has been included on the distribution ;
for this response.
Licensees were stated to have presented interpretations of the reporting rules ;
(10 CFR 50.72/50.73) and the related guidance provided in NUREG-1022, which supported the conclusion that the discovery of safety valve setpoint drift was not reportahle. Specifically, question 2.3 of NUREG-1022, Supplement 1, had !
been used to argue that the condition was not reportable, because the condition could be assumed to have occurred at the time of discovery. Another l argument presented by licensees was stated to involve analyses or evaluations which determined thac the degraded setpoints did not result in the plant operating outside its design basis, and therefore supported a conclusion that '
the condition was not reportable.
t A review of 50.72 and 50.73 identifies several reporting criteria which might be relevant to the discovery of safety valves outside the setpoint tolerances given in the Technical Specifications. These criteria and a dScussion of their applicabiii:j is provided in Enclosure 1. ,
I The t assment can be summarized as follows:
- The use of question 2.3 to NUREG-1022, Supplement 1, is not appropriate to justify a decision to not report many conditions found during refueling outage surveillances. Other guidance in Supplement 1 is clear ;
that if onditions are discovered during an outage, but are believed to have existed during operation, they are reportable so long as an '
applicable threshold for reporting is reached. >
b
~, i Samuel J. Collins November 2, 1993
- A licensee may determine that a condition such as safety valve setpoint drift, does not constitute operation outside the design basis of the plant, and therefore not report such events in accordance with those criteria in 50.72 and 50.73. However, as discussed below, the condition i may be reportable as a result of other criteria. !
- 50.73(a)(2)(vii) is deemed the most relevant criterion for the reporting of primary or secondary safety valves found to be outside the acceptable setpoint tolerance. This is due to the fact that this criterion is based on the train or channel level and does not require the loss of a safety function but only the inoperability of multiple channels of a safety system. Some latitude i .qht be given in light of the number of. secondary safety valves; but, for most instances of setpoint drift, this criterion i would result in the conditions being reportable.
- Note that we currently expect to include guidance along these lines in .
the forthcoming Revision I to NUREG-1022; if so, that specific guidance should be consulted in the future in determining reportability.
. v3 e Elinor G. Adensam, Assistant Director for Regions IV and V Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation .
Enclosure:
Criteria ,
cc w/ enclosure: !
W. Hodges, Region I A. Gibson, Region II '
G. Grant, Region III K. Perkins, Region V l
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ASSESSMENT OF VARIOUS REPORTING REQUIREMENTS FOR APPLICABILITY TO PRIMARY OR SECONDARY SAFETY VALVES FOUND OUTSIDE TECHNICAL SPECIFICATION ,
ACCEPTABLE SETPOINT TOLERANCE BAND !
50.72(b)(1)(ii) Any event or condition during operation that results in the 50.73(a)(2)(ii) condition of the nuclear power plant, including its :
principal safety barriers, being seriously degraded; or results in the nuclear power plant being:
(A) In an unanalyzed condition that significantly >
compromises plant safety; (B) In a condition that is outside the design basis of ,
the plant; or (C) In a condition not covered by the plant's operating l and emergency procedures.
Discussian: The applicability of these criteria is determined by an evaluation of the situation by the licensee. Upon determining that the setpoints were outside the allowable range of the technical specifications, the licensee would be expected to follow the required actions of the technical specifications and assess the plant condition in regards to-equipment operability and required corrective actions.
Guidance related to the evaluation of degraded and nonconforming conditions is provided by Generic Letter 91-18. As stated in the second draft of NUREG-1022, :
Revision 1, it is expected that licensees may use !
engineering judgement and experience in determining whether a condition meets these reporting criteria. The ability of a licensee to justify that a given condition is neither unanalyzed nor outside the design basis is dependent on the as-found condition of the equipment and the degree of analyses performed. i 50.72(b)(2)(i) Any event, found while the reactor is shut down, that, had -!
it been found while the reactor was in operation, would have resulted in the nuclear power plant, including its principal ,
safety barriers, being seriously degraded or being in an !
unanalyzed condition that significantly compromises plant !
safety.
Discussion: The arguments are very similar to those above and again can [
support either a reportable or non-reportable conclusion :
based on the licensee's assessment of the significance of ,
the condition. However, this criterion was intended to :
capture potential problems which might be discovered only during refueling outage surveillances. Question 7.10 in NUREG-1022, Supplement 1, is considered relevant guidance in '
regard to the reportability of equipment found to be inoperable during outage surveillances. ,
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Question 2.3 of NUREG-1022, Supplement 1, and the second draft of NUREG-1022, Revision 1, state that failures should be assumed to occur at the time of discovery unless there is firm evidence to believe otherwise. It seems appropriate to classify setpoint drift as a mechanism which would occur t some time (usually indeterminable) during the period between ,
calibration and subsequent surveillance unless some factor, such as an extended outage or testing. conditions, could be identified as a likely cause. If testing conditions or ;
other causes are identified such that reporting is deemed unnecessary, the licensee would still be expected, under other programs and regulatory requirements, to evaluate the adequacy of the surveillance program to ensure that the ,
activity is ensuring the operability of the safety valves or other components. A voluntary report may still be useful as a means of distributing the information related to the problem and its cause to the industry. Please note that ;
although question 2.3 may be deemed an insufficient reason to determine safety valve drift is not reportable, the licensee may determine that the significance (see above) of l the condition does not satisfy the reporting threshold. -
50.72(b)(2)(iii) Any event or condition that alone could have prevented the ;
50.73(a)(2)(v) fulfillment of a safety function of . structures or systems that are needed to:
(A) Shut down the reactor and maintain it in a safe !
shutdown condition, j (B) . Remove residual heat, (C) Control the release of radioactive _ material, or .
(D) Mitigate the consequences of an accident. !
Discussion: The second draft of NUREG-1022, Revision 1, provides safety valve drift as' an example of a common mode problem which may ,
be reportable under this criterion. The example was added i to the case described in Information Netice 85-27 which ;
dealt with multiple inoperable control rods. Although ;
certain occurrences of multiple safety valve drift problems :
should be determined to be reportable under this criterion, it should not be assumed that all cases of one or more ;
safety valves exceeding the technical specification i tolerance band need be- reportable in accordance with this ;
criterion. As in the previously discussed reporting i criteria, the licensee's engineering judgement should ,
determine if the condition could have prevented the' )
fulfillment of a safety function. Candidates for reporting include those cases in which the setpoints of multiple safety valves could have resulted in exceeding the associated system's design pressure. If experience or engineering judgement can reasonably estimate the maximum
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i drift which might occur and detemine that the safety function would be maintained, the licenree can determine that the condition is not reportable.
Although discussed in the various drafts and revisions of i NUREG-1022, it warrants repeating that the primary motivation behind evaluating plant conditions such as safety t valve drift should be to ensure safety and only secondarily '
to determine reportability. If engineering assessments !
identify a problem and determine that plant equipment was not and reasonably could not be rendered inoperable by a :
phenomenon such as setpoint drift, the licensee can then also justify a determination that the condition is not reportable. Voluntary reports are appreciated if the '
licensee feels the information might be helpful to others.
The staff should, as always, be cautious in recommending :
that a licensee make a " voluntary" report.
50.73(a)(2)(vi) Events covered in paragraph (a)(2)(v) of this section may '
include one or more procedural errors, equipment failures, and/or discovery of design. analysis, fabrication, i construction. and/or procedural inadequacies. -However, indivtdual component failures need not be reported pursuant a to this paragraph if redundant equipment in the same system was operable and available to perform the re ,uired safety function. :
I Discussion: (See above) :
50.73(a)(2)(vii) Any event where a single cause or condition caused at least i one independent train or channel to become inoperable in ;
multiple systems or two independent trains or channels to ,
become inoperable in a single system designed to: (
(A) Shut down the reactor and maintain it in_a safe shutdown condition, (B) Remove residual heat, !
(C) Control the release of radioactive material, or !
(D) Mitigate the consequences of an accident.
Discussion: This criterion may be the most. relevant to the specific u example of safety valves found outside the technical . '
i specification tolerance band. As stated in the second draft j of NUREG-1022, Revision 1, the reporting threshold for this
- part of 10 CFR 50.73 is lower than for other parts since it ;
is at the train or channel level rather than the system and ;
function levels. Valves found outside the technical !
specification setpoint tolerance band can reasonably be considered to have been inoperable during operation unless a ,
licensee determines that testing is not representative of -!
conditions during operation (see item 50.72(b)(2)(1)). This ;
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i criterion was developed with general. consideration given to the normal two train design level of redundancy. Given that most plants can satisfy pres;ure relief requirements with several main steam safety valves unavailable, a rigid interpretation of this criterion regarding the secondary 3 safety valves (i.e., any case with more than one safety valve outside the tolerance band) may be overly conservative. However, the licensees are considered to have the weakest argument if they determine that this criterion !
is not applicable, and therefore the condition is not- .
reportable, when finding multiple safety valves outside the acceptable range.
50.73(a)(2)(i.8) Any operation or condition prohibited by the plant's technical specifications.
Discussion: Available guidance regarding operability and technical specification requirements generally have licensees enter the allowed outage time and associated action statements upon discovery of equipment inoperability unless a definite !
time of inoperability can be established. Technical specifications are considered satisfied provided the allowed outage time and associated action statements are satisfied.
Therefore, provided that licensees restore compliance prirt ,
to returning to power operation, reporting of safety valve drift in accordance with this criterion would not be i necessary. However, it is expected that upon identification of a problem such as safety valve setpoint drift, licensees shoeld take actions to prevent recurrence or pursue a change :
in the technical specification requirements (such as t increasing the acceptable tolerance range of the setpoints).
If a licensee determines, through industry experience, information from a vendor, or self assessments, that a component may be inoperable during operation, appropriate L actions should be taken in accordance with the technical i specifications (reduce power or shutdown). . This reporting r criterion may be applicable if a licensee fails to satisfy the required action or can determine that a limiting ,
condition of operation had not been satisfied for longer !
.than the allowed outage time following a specific cause for a component becoming inoperable. !
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