ML20091A632
| ML20091A632 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 09/27/1977 |
| From: | Mayer L NORTHERN STATES POWER CO. |
| To: | Desiree Davis Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9105160420 | |
| Download: ML20091A632 (4) | |
Text
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M SIsga_.......... _ ~ ~'3 7c gy NORT.'ERN STATES POWER COMPANY
.....m.._~........o, Septczaber 27, 1977 30 1.,
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Mr D K Davis, Acting 011ef Y"
Operating Reactors, Branch #2
, J' c/o Distribution Services Branch, DDC, ADM
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U S Nuclear Regulatory Cocunission Washington, DC 20555
Dear Mr Davis:
WNTICELIA NUCLEAR GENERATING PIANT PRAIRIE ISIAND LEAR GENERATING PIANT Docket No License No. DPR-22 Docket No.
282 License No. DPR-42 Docket No. 50-306 License No. DPR-60 Licensee Event Reporting Your letter dated August 12, 1977 requested that we use a "slightly modified fomat" for reporting those non-routine occurrences that are required by our technical specifications. Your letter further requested that we review the revised instruction manual for preparation of the Licensee Event Report foms and make plans to use the revised form and instructions starting with the first reportable occurrence af ter September 30, 1977.
We find it impracticable to implement the revised reporting by October 1,1977.
Your August 12, 1977 letter was not received until September 9,1977 and it did not include supplies of the Licensee Event Report fom.
(Additional instruction manuals and LER forms have been ordered from MIPC.) The Monticello Nuclear Generating Plant is currently in the midst of a refueling outage and this will be followed by a similar outage for Prairie Island Unit No. 2 later this fall. Addi-tional time is needed for us to procure the necessary instruction booklets and foms, allow the plant to review them and establish new reporting routines during a period r
I of time when they are not involved in a heavy outage work load and to establish a unifom impicmentation date between the two plant organizations. We will impicment t
use of the revised Licensee Eveut Report form, following the instructions contained in NUREG-0161 to the maximum extent practicable, starting with the first reportable l
occurrence after January 1,1978.
t We are most disturbed by your request that we provide a ecxnplete narrative report of the event for all 14-day Licensee Event Reports. The revised instruction manual further expands your reporting request by stating that most events which require i
reporting on a 30-day basis will generally require an attachment as described above.
This is a new and separate reporting requirement which will add to the already
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burdensome reporting requirements and extensive requests for infomation from the NRC.
l 9105160420 770927 PDR ADOCK 05000263 Q&YfN
NORTH,. RN OTATEO POWER COMPA NY Mr D K Davis Page 2 Sept aber 27, 1977 In Septaber,1974, the AEC published Revision 2 of Regulatory Guide 1.16 for consnent by pcwer reactor licensees. his was fo11 cued by Regional meetings to secure input from these licensees and to explain the proposed reporting under the computerized Licensee Event Report concept. Prior to that time, most of these licensees had been submitting narrative type reporte on occurrences at the nuclear plants. At the meeting on November 7, 1974 in Re81on III at Chicago, the utility representatives took strong exception to what appeared to be an increasing reporting burden under Regulatory Guide 1.16.
It was explained to us that the reporting burden should be somewhat reduced by adoption of Regulatory Guide 1.16 and the Licensee Event Report fom; in most cases, the report would be a J0-day written report as opposed to the prmpt notification with written follcu-up report 14 days later. he NRC representatives stated that the number of itms to be reported had been reduced. When the utility representatives again expressed concern over having to supply not only a ccrapleted LER fom, but also a narrative summary, they were infomed that in 90% of the cases, the LER fom would suffice.
NSP has filed narrative sur:naries to supp1 ment the LER foms on occasions where additional infomation was needed to explain an event that might have significant interest or safety impact; we have also filed supplemental information at the re-quest of the NRC inspector. In addition, for every reportable occurrence and certain other non-reportable occurrences, a thoroudt iaventigation is conducted, an investi-gative report is prepared which contaiha reccx:rnendations for corrective actions, and these are reviewed by plant management and the sppropriate review groups. Wese internal investigative reports cont: tin very detailed infomation and preliminary reconsnendations, canrot usually be ccuple'ed in the 14-day or 30-day time frame, and may contain inforstion that 11 pro. ietary, personal, or otherwise unsuitable for docketing. However, these investiga..ve reports are made availabic to the NRC inspector during his visits, and can be utilized in that manner to perfom a safety assessment of the event. We intend to continue our past practice of submitting supplemental infomation with the LER foms en those occasions where we believe it is appropriate, or on those occasions where we agree with the inspector's evaluation that a supplemental report is indi.cated.
We ask that the NRC reconsider their request for the production of a narrative report for each '.icensee Event Report submitted. We believe it would be appropriate for the NRC to demonstrate 1ow this additional reporting would result in a cct:rnensurate increase to the bealth and safety of the public, the regulatory basis for making such a request, and make provision for industry-wide review and coment on this proposal, similar to the opportunity provided in 1974 when the accurrence reporting policy was substantially revised.
As a Licensee for two nuclear plants, we transmitted about 315 separate reports to the NRC in 1976, almost all of which consisted of 4n copies of multi-page reports.
On the basis of about 75 Licensee Event Reports having been submitted for Monticello and Prairie Island in 1976, the NRC request means that an additional 75 separate narrative sumary reports would have to be prepared, reviewed, printed and included for submittal with the Licensee Event Report. h is large number of Licensee Event Reports stems, in part, frcxn the NRC policy of over-reporting as expressed in the
NORTHR.sN OTATKO POWER COMPANY Mr D K Davis Page 3 September 27, 1977 introduction to one of the Reports to Congress on Abnormal Occurrences, as folicva:
"The NRC reviewed events reported at the 62 nuclear power plants licensed to operate during.....
None affected the public health and safety; ade-quate levels of protection were available in each event to assure no adverse impact on the public health and safety.....
Becauss of the broad scope of reRuistion and the conservative attitude toward safety. there are a large number of events reported to the NRC..... (Emphasis added) Most of the reports received from licensed nuclear power facilities describe events that did not directly involve the nuclear reactor itself, but involved equipment and ccs:rponents which are peripheral aspects of the nuclear steam supply systesn, and are minor in nature with respect to the impact to the p.iblic health and safety. Ihe majority are discovered during routine inspection and surveillance testing and are corrected upon discovery.
Typically they concern single malfunctions of components or parts of systems with redun-dant operable cogonents or systems continuing to be available to perfom the design function."
Ihe above reinforces our belief that the Licen4ee Event Reports are used mostly for data collection in an attesept to determine equipment reliability, but also to indi-cate areas where further acchn might be warranted through the issuance of I&E Circulars and Bulletina or further investigation through the I&E inspection process.
We believe that the present process provides ample infomation to permit safety asscesment of events through I&E/ Licensee on-site or verbal contacts.
We ask your cooperation in an attempt to halt the ever-increasing reporting burden being thrust upon reactor licensees. Should the NRC wish to convene scoe type of meeting with reactor licensees to discuss this, and other reporting requirements, we would be pleased to attend, explain our position and provide consnent on proposed igrovements in the reporting process.
Yours very truly, W Q.
L 0 Mayer, PE Manager of Nuclear Support Services IDM/ak cc: J G Keppler
'-Sirector, MIPC, USNRC G Charnoff HPCA - Attn: J W Feman l
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NRC OnM 195 NRC DISTRIBUTION ron PART 50 DOCKET MATERIAL INCIDENT REPORT oATE or occt,u t NT FROM: NSP TO:
gp, D. K. Davis Minneapolis, Minnesota 55401 09/27/77 L. O. Mayer oATE RECrivto 09/30/77
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L otSCRIPTiON Advising that NSP finds it impract-able to implement the revised format for reporting non-routine occurrences that are required by tech specs, and furnishing comments therefor...
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