ML20112H321
| ML20112H321 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/27/1984 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| IEB-82-02, IEB-82-2, LIC-84-434, NUDOCS 8504020218 | |
| Download: ML20112H321 (2) | |
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Omaha PubHC Power District 1623 Harney Omaha, Nebraska 68102 402/536-4000 December 27, 1984 LIC-84 434 i
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Mr. Robert D. Martin g3 lg i
Administrator-Region IV U.S. Nuclear Regulatory Commission D
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611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011
Dear Mr. Martin:
During a meeting on December 20, 1984, the Omaha Public Power District appreciated the opportunity to provide Mr. Paul Check and other members of your staff with additional information regarding measures which have been or will be taken to provide additional assurance that responses to the Nuclear Regulatory Commission are complete. The District is confident that the measures discussed during the December 20, 1984 meeting will be effective in increasing the accuracy and completeness of responses to the Nuclear Regulatory Commission.
One issue briefly discussed during the December 20, 1984 meeting was whether the District's initial response to IE Bulletin 82-02 caused or prevented the NRC or the District to take action different than that taken as a result of the incomplete response.
It is the District's fim belief, which is supported by detailed reviews, that acceptable lubricants were l
being used at the time of the District's response. The District continued I
to use these lubricants af ter a detailed review was completed in 1984 which confirmed acceptability. The District is also unaware of any action by the NRC regarding the lubricants which were being used once it became known that the District's initial response was incomplete and revised lubrication data was submitted.
Supplement VII to 10 CFR, Part 2, Appendix C provides that:
A false statement caused by an inadvertent clerical or similar error involving information which, had it been available to NRC and accurate at the time the infomation should have been submitted, would probably not have resulted in regulatory action or NRC seeking additional information is a Severity IV violation.
Since you acknowledge that the District's incomplete response was not intentional and was not intended to conceal or mislead, we believe it is appropriate to classify it as " inadvertent." As 8504020218 841227 PDR ADOCK 05000285 l&
G PDR 4551?4 Employme th qual Opportunity Ih 9/-25 T
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Mr. Robert D. Martin December 27, 1984
-Page Two shown above, a complete and accurate response "would probably not have re-sulted in regulatory action or NRC seeking additional information." In addition, the Commission has suggested that " materiality" should be contingent upon the safety significance of the information (47 Fed. Reg. 8584 (1984)). Based upon the above-described review, the District has concluded that the incomplete response has no safety significance. For all of these reasons, the District submits that escalated enforcement action is not warranted.
Sincerely,
$t/b R. L. Andrews Division Manager.
Nuclear Production RLA/KJM/lp cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, DC 20036 Mr. E.
G.
Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Inspector