ML20211N534

From kanterella
Jump to navigation Jump to search
Discusses Mutual Concerns Re Reportability of Incidents to Nrc.Methods to Improve Candor & Forthrightness Also Discussed,Per Recent Notice of Violation Concerning Rod Pull Error.Related Info Encl
ML20211N534
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 02/17/1987
From: Sylvia B
DETROIT EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
GP-87-0008, GP-87-8, NUDOCS 8703020103
Download: ML20211N534 (5)


Text

%6 B. Ralph Sylvia I..k. Group Vic3 Pradent PRIORITYROUTINd f_irst Seennd i D Mbd 6"#E

~

=

  • 6400 North Dixie Highway CN$

h~

n n Newport, Mchigan 48166

{FC ~ [

(313) 586 4150 DR d i _

l;~~

February 17, 1987 FILQfc GP-87-0008 Mr. James G. Keppler Regional Administrator Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137

Dear Mr. Keppler:

One of the first items I put emphasis on when I came to Detroit Edison was the concern that the NRC had regarding the candor and forthrightness of the people at Detroit Edison. I took another opportunity to read the Notice of Violation and Proposed Imposition of Civil Penalty for the rod pull error and saw some very strong

-language regarding Detroit Edison's candor and forthrightness. To address this concern. I have directed that we report everything to the NRC if it appears that the item has the opportunity for generating regulatory or public interest. I hope that such a change in reporting has been obvious to the NRC.

In addition. I have had my staff working for the past few months to develop ways for improving the method that we review and approve outgoing correspondence. Finally, I have, along with Frank Agosti, directed the Chairman of our Oasite Review Organization and Corrective Action Review Board, to err on the side of conservatism when deciding the issue of reportability. Even when an issue is deemed to be not reportable but there are differences of opinion, we intend to keep the NRC informed of such considerations. The attached memo should be self-explanatory.

I feel the results of these actions will demonstrate that Detroit Edison is aggressively pursuing the issue of candor and forthrightness just as we have rEcent technical concems.

Sincerely, Attachment . . [J cc Mr. W. G. Rogers 0*

Mr. J. J. Stefano Mr. A. B. Davis

\\

8703020103 070217

[DR ADoCn o3000341 FEB 181987 PDR Z6e/

-[

Detroit Edison 0801.02 Date: February 13, 1987 GP-87-0006 To: OSR0 Chairman CARB Chairman From: 8. R. Sylvia Group Vice Pres gyt.n [ident F. E. Agosti Vice President Y

Nuclear Operations

Subject:

Reportabil.ity Determinations Recently we encountered situations where there were conflicting opinions on the reportability of an incident to the NRC. It is our expressed desire that we err on the side of conservatism whenever there are differences of opinion as to reportability. Over-reporting is seldom criticized. Unfortunately, we are well aware of the impact of under-reporting.

We recognize that there are legitimate differences of opinion regarding the interpretation of Tech Specs or other regulations, sequence of events, and failure mechanisms. As Chairmen of your respective committees, you have the authority to make the final reportability decision.

To assure that the differences of opinion present in such a decision are recognized, the attached letter is provided as a sample of one to be sent when the situation warrants it.

This letter is our means of sharing with the NRC why non-reportability was determin.d and what arguments for reportability were expressed.

We want to express that no one sholilif be penalized for voicing differences of opinion. Quite the contrary; such a process is encour-aged before a decision is made so that all relevant and conflicting differences are heard and explored. It is vital, however, that the process be managed. The final decision is yours; the additional letter is for information sharing, not reportability.

.. ~~

d OSR0/CARB Chairmen 2/13/87 VP-87-0006 Page 2

This policy is consistent with our recently announced Business Plan in that we want to be characterized as an' organization that is candid,

~

- accurate, and complete in its communications. To that end, we would expect immediate implementation of this position.

RBS/FEA/TR/pir i

Attach.

cc: W. S. Orser i T. Randazzo -

i I

l

c

.. *+ s. nmen sywa

, Group Vic3 President l

g' u aNIE February 13, 1987 '

GP-87-0000 0801.02 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-432

Subject:

Reportability Determination for This letter is to advise you as to the reportability determination which was recently made on the subject noted above.

In meetings held to review the matter in both the Onsite Review Organization and the Corrective Action Review Board, the reportability of the item was determined. While the final determination was made that the item was not reportable, the purpose of this letter is to inform you that there were contrary opinions expressed regarding the reportability.

The reason that the item was determined to be not reportable is based on the following information:

. Opinions which expressed a contrary review on reportability were based on the following facts and circumstances:

i i

i

,... *s NRC GP-87-0000 2/13/87 Page 2 Given this information, the Plant Manager made the final determination that the subject was in fact not reportable. However, in an effort to keep you fully informed, we are providing this information.

If you have any questions, please do not hesitate to contact Mr. Tom Randazzo at (313) 586-4320.

Sincerely, B. R. Sylvia Group Vice President s

4 I

-. . . . . . , _ . _ . . . _ . , , , _ _ _ _ _ . _ _ , , . , . - . . , , , _ _ _ . . . _ _ _ , _ _ . _ . , _ _ _ _ . _ _ _ _ _ _ . _ . . _ _ _ . _ _ _