ML20210T712
| ML20210T712 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 09/04/1997 |
| From: | Mccollum W DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9709160042 | |
| Download: ML20210T712 (8) | |
Text
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Duke Power Com A tu,wy compny pany
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Oconce Nudear Site d '* #*"p CP-P.O. Box 1439 Seneca, SC 29679 W. R. McCollum, Jr.
(861) 885-3107 omcr
% hidas (864) 885-3564 Mx September 4, 1997 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555
Subject:
Oconee Nuclear Station Docket Nos. 50-269, -270, -287 Licensee Event Report Submittal Evaluation for.-
Oconee Nuclear Station Gentlemen:
Oconee Nuclear Station received NRC letter, dated fune 19, 1997, which identified a number of concerns related to the quality of certain Oconee Licensee Event Reports (LERs).
It is Oconee's intention to take the appropriate measures to address these specific concerns.
Furthermore, to= assure that we understgnd your needs and are in full-conformance with the guidance and requirements set forth in NUREG-1022
/
and 10 CFR 50.73, Oconee would like.to reach a common.
understanding on interpretation and application of this guidance.
To--facilitate that process, representatives from I
Oconee who compose the LERs, would like to meet with-the staff and NRC Office for Analysic and Evaluation of
. Operational Data (AEOD) at a time and place convenient to you to clarify.this matter. 'Once again, it is Oconee's intention-and desire to assure that the NRC staff has-all the information needed to' perform their work.
Oconee'has reviewed this letter and would like to address the goncerns-in Attachment 1.
. y,.. n_ m j_C OCl 9709160042 970904ADOCK 05000269:
PDR S
PDR g
4 Document Control Desk
' September 4, 1997 Page 2 Item a.: Restatement of concern Oconee submits many more abstract-only Licensee Event Reports (LERs) than are submitted by other licensees. In addition, the abstracts frequently do not contain the information required by 10 CFR 50.73 (b) (2) through (b) (6) for LER content, such as event root cause and proposed corrective actions. For example, the abstract-only LER 269/96-06-did not describe why the procedure change process allowed the situation to occur, and what steps were taken to prevent recurrence. Also, abstract-only LER 269/97-02 did not specify root causes or corrective actions.
Response
Oconee submitted one abstract-only LER in 1996 (LER 269/96-
- 06) and submitted one abstract-only LER in 1997 (LER 269/97-05).
It has not been the normal practice to submit abstract-only LERs and these are the only ones that Oconee has submitted in the past five years.
These two events were considered to be simplistic in nature whereby the entire event could be described in the abstract as allowed by NUREG-1022.
We do, however, understand your concern with the procedure change process issue associated with LER 269/96-06.
Oconee's philosophy has been to report events when the weight of the evidence indicates that a reporting criterion may be satisfied.
This approach assures that the staff receives'potentially relevant reporting information in a
. timely manner.
However, some of these 50.72 and 50.73 reports are later retracted.when the completion of the engineering analysis concludes a report was not required.
Since January 1, 1996, Oconee has submitted ten LERs
Document Control Desk September 4, 1997 Page 3 initially as abstracts, with the intention of submitting supplemental reports when the analysis of the safety significance was completed.
This was the case with LER 269/97-02.
In four cases, completion of the safety significance revealed that the event was not reportable and the LER was withdrawn.
To minimize *.he number of LERs initially submitted as abstracts, Oconee is placing additional emphasis on completing the past operability evaluation, or safety significance, in a time frame commensurate with the potential significance of the issue.
If the issue is complex and the analyses necessary to support the safety significance cannot be completed in a I
reasonable time frame, Oconee will submit an LER with available information and provide a supplement when the safety significance is complete.
It is expected that'the number of LERs initially submitted as abstracts will be minimized in the future.
Item b.: Restatement of concern The 10.CFR paragraph, stated as the basis for the LER, has not always been-consistent with the event description. For example, LER 269/96-06 was submitted under 10 CFR 50.73 (a) (2) (v) (D), which is any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. However, the report describes what appears to be a section (a) (2) (I) technical specification deviation. This observation is based on.the report statements that the "[ filters) had not been tested in exact accordance with TS requirements," and
" Functional operability of the filters was not in question; therefore, this event had no safety impact."
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Document Control Desk September 4, 1997 Page 4
Response
The above noted statements concerning LER 269/96-06 are correct. This'LER was submitted under 10 CFR 50.73 (a) (2)
(v) (D) because the event was initially conservatively reported under the equivalent section of 10 CFR 72.
At the time of the 10 CFR 72 notification, Oconee used a " worst case", conservative interpretation that the filters may not have been capable of performing their intended function.
Oconee agrees that it would have been more appropriate to report the LER as an operation prohibited under Technical Specifications (10 CFR 50.73 (a) (2) (i) (B) as you have indicated.
Item c.: Restatement of concern In a number of cases, supplemental event information was not submitted in accordance with NUREG-1022 guidance.
Supplemental event information should be submitted as a revision to the original LER,-such that the revised LER is complete and contains all of the-information,Enot just the revised or supplemental information. For example, the supplemental information for abstract-only LER 269/96-10 was submitted in a revision to a' unrelated event described in LER 269/ 96-08. In addition, LER 269/96-08 had been retracted prior to the' time that the supplemental information was added. Also, the supplemental information for abstract-only LER 270/96-06 was supplied in-separate letters, rather than in the LER.
4
s Document Control Denk September 4, 1997 Page 5
Response
Oconeeagreesthatsuphlementaleventinformationshouldbe submitted as a revision to the original LER in accordance with NUREG-1022.
In the specific situations noted, the following discussion may help clarify the confusion concerning the various LER numbers-LER 269/96-08, LER 269/96-09, and LER 269/96-10 were issued as abstracts with expectations of providing supplements when additional l
information concerning the events was determined.
Prior to l
any supplements being provided, operability evaluations j
concluded that LER 269/96-08 and LER 269/96-09 were not j
reportable and these LERs were withdrawn. LER 269/96-10 was revised to LER 269/96-08 as specified in the cover letter to the supplement.
This renumbering methodology follows the guidance specified in NUREG-1022 which states, in part, "The NRC would prefer that-. licensees reuse a sequential number rather than leave holes in the sequence."
If an alternate LER numbering approach is preferred by the staff, Oconee will revise its administrative procedures as appropriate.
LER 270/96-06 was submitted initially as an abstract only, then supplemented (Revision 1) to include the pertinent information and later supplemented (Revision 2) to indicate that two of the three valves were operable.
Item d.: Restatement of concern occasionally, pertinent event-information has not been included in LERs, which resulted in failure to report many of the details of the events in a timely manner. For example, the root causes and corrective actions are sometimes deferred to a supplemental report.
- Thus, information pertinent to the effect of the event on the system, post-maintenance or surveillance testing, or length
4 4
Document Control Desk September 4, 1997 Page 6 of time the conditions existed, may be missing (see LER 270/96-07).
Thus, all of the pertinent information is not available to the staff in a timely manner for such LERs.
All reasonable effort should be expended to include all pertinent information in an LER and submit it in a timely manner, in accordance with the guidelines of NUREG-1022.
Response
As noted in the above comments, Oconee's intention is to comply with the requirement of 10 CFR 50.73 and the guidance of NUREG-1022.
This includes all pertinent information, provided in a timely manner, including the root causes and corrective actions.
We further intend to assure that the NRC staff is in possession of any and all information needed to support any further analysis, coding, or other work that they may need to perform.
If you have any questions, please call R. T. Bond at 864-885-3043.
v.
Very truly yours,
,- f
- W. R. McCollum,
__o
Document Control Desk September 4, 1997 Page 7 cc:
Mr. Luis A. Reyes Administrator, Region II U.S. Nuclear Regulatory Commission 61 Forsyth Street, S. W., Suite 23T85 L
Atlanta, GA 30303 y
Mr.
D.
E. LaBarge l
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C.
20555 Mr. M. A.
Scott NRC Resident Inspector Oconee Nuclear Station
(
Document Control Desk September 4, 1997 Page 8 B.
L.
Peele M. K. Nazar W. W.
Foster R.-L.
Gill J.
E.
Burchfield ELL NSRB e
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