ML20234E954
| ML20234E954 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/18/1987 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8709220578 | |
| Download: ML20234E954 (2) | |
See also: IR 05000298/1987018
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SEP181997
In Reply Refer To:
Docket:
50-298/87-18
Nebraska Public Power District
!
ATTN: George A. Trevors
Division Manager - Nuclear Support
P. O. Box 499
Columbus, NE
68601
Gentlemen:
Thank you for your letter of September 2,1987, in response to our letter
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and the attached Notice of Violation dated August 4, 1987. As a result of
our review we find that your response asked questions, which we shall
address herein. The information in this letter was discussed with your
Messrs. G. Trevors and D. Tarczom, by telephone, on September 16, 1987.
Although you admit not reporting the isolation of the reactor water clean up
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(RWCU) system, you state your belief that ti.is was not reportable because it
was only a failure to follow procedures.
You cite NUREG 1022, Supplement 1,
Question and Answer 2.7 as the basis for this position. We note that this
reference states, inter alia, " . . . whether it is reportable depends upon if
it results in a condition covered by the rule." The resultant condition, in
this case, was a RWCU system isolation; this is an actuation of an engineered
safety feature (ESF). The regulations (10 CFR, Part 50.73) state that ESF
actuations are reportable.
NUREG 1022 also discusses this in detail. We also
,
understand that you were conducting a test when the RWCU isolation occurred;
however, RWCU isolation was not a desired result of the test. We additionally
note that this occurrence should have been reported under the provisions of
10 CFR 50.72 at the time of occurrence.
Your letter also cited Question and Answer 11.3 of Supplement 1 to
NUREG 1022. This concerned the issue of a disagreement between an inspector
and the licensee as to whether or not an LER is required. The answer given is
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that the regional office will provide the staff position.
Your letter
requests this office to provide such a position in this instance.
The
issuance of the violation constituted the regional office position, for
inspectors do not issue violations; the region issues them.
,
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You further stated that you would submit an LER within 30 days following
receipt of the Region IV position.
This position was provided by telephone to
your Messers. Trevors and Torczom on September 16, 1987.
In summary, we find that additional information is needed. Specifically, we
request that you inform us of your corrective actions, planned or completed,
to provide appropriate training in reporting requirements (10 CFR, Parts 50.72
and 50.73). We also expect that the licensee event report on this event would
address the reasons that the surveillance test was not successfully performed
and remedial actions taken.
Please provide the supplemental information within 30 days of the date of this
letter.
Sincerely,
/$
L. J. Callan, Director
D vision of Reactor Safety
and Projects
cc:
Guy Horn, Division Manager
of Nuclear Operations
Cooper Nuclear Station
P. O. Box 98
Brownville, Nebraska
68321
Kansas Radiation Control Program Director
Nebraska Radiation Control Program Director
bec distrib. by RIV:
RPB
DRSP
RRI
R. D. Martin, RA
Section Chief (RPB/A)
D. Weiss, RM/ALF
RPSB
RSB
MIS System
Prcject Inspector, RPB
RIV File
R. Hall
RSTS Operator
W. Long, NRR Project Manager
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COOPER NUCLEAR STATION
Nebraska Public Power District
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September 2, 1987
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SEP ~ 81987
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U. S. Nuclear Regulatory Commission
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Document Control Desk
Washington, D. C.
20555
Subject:
Response to IE Inspection Report No. 50-298/87-18
Gentlemen
This letter is written in response to your letter dated August 4, 1987,
transmitting Inspection Report No. 50-298/87-18. Therein you indicated that
one of our activities was in violation of NRC requirements.
The following is the statement of the violation and our response in accordance
with 10CFR2.201:
Statement Of Violation
Failure to Report as Required by 10CFR50.73
10CFR50.73(a)(2)(iv) requires the licensee to submit events as licensee
event reports (LERs) for, "Any event or condition that resulted in manual
or automatic actuation of any Engineered Safety Feature (ESF) . . . ."
Contrary to the above, an ESF isolation of Reactor Water Clean Up (RWCU)
occurred on May 5, 1987, which was not reported as an LER.
This is a Severity Level IV violation.
(Supplement II) (298/87108-01)
Reason For The Violation
Based upon the alleged violation provided in Appendix B, Paragraph 4 of the
Inspection Report, the District acknowledges NRC assessment that closure of
RWCU H0-15 constitutes an event to be reported as a Licensee Event Report
(LER). Previously, based upon District evaluation of the situation and our
understanding of the reporting requirements pres'cribed in 10CFR50.73, the
conclusion had been reached that valve closure occurring, subsequent to
satisfactory completion of actuation circuitry surveillance testing did not
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constitute an event or condition that resulted in manual or automatic
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actuation of an ESF. Instead, the closure occurred when a procedural step was
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not correctly executed during system restoration, not as a result of logic
initiation and subsequent valve actuation. In accordance with the response to
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Question 2.7 provided in NUREG 1022. Supplement 1, procedural violations are
not necessarily reportable. Therefore, believing this to be a procedure
violation only and not an ESF actuation, the situation was not reported as an
LER.
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. September 2, 1987
Page 2
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Corrective Steps Which Have Been Taken And The Results Achieved
As provided for in NUREG 1022, Supplement 1, in the response to Question 11.3,
the District understands that where there may be a disagreement regarding LER
submitta1' requirements, we will be advised of the NRC Region IV position and
proper action to be taken.
In light of the foregoing explanation,.the fact
that a non-conformance report was previously written against the event,-and
the NUREG provided provisions regarding disagreements that may arise, the
District requests that Region IV Office re-assess their position and advise us
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as to their determination. Based upon our understanding of reporting time
limits provided in the response to Question 14.2 (NUREG 1022, Supplement 1),
we would then have 30 days from the date of your response to submit the
required LER, prior to being considered in violation of LER reportinp;
requirements.
Corrective Steps Which Will'Be Taken To Avoid Further Violations
The Station Operations Review Committee (SORC) will continue to evaluatt those
events that~ appear to be questionable under the deportability requirements of
10CFR50.73 utilizing guidance provided in 10CFR50.73, NUREG~1022, Supplements
to NUREG'1022, and other documents, as applicable, such as Generic Letter 87-09.
In the future, if,-after initial SORC review and evaluation, che
deportability requirement for an event is questionable, the NPPD Nuclear
Licensing and Safety Department will be contacted for guidance and
interpretation. In all situations, however, it is assumed that the g.tidance
provided in NUREG 1022, Supplement 1. Question 11.3, is valid and that, should
a disagreement regarding LER submittal requirements arise, the District, where
necessary, will pursue the NRC Region IV position, including proper actiors to
be taken by the District.
With respect to the cited incident, SORC will review the guidance to be
provided by NRC Region IV, in committee, and will utilize said guidance when
evaluating the deportability of future similar events.
Date When Full Compliance Will Be Achieved
Full compliance will be achieved, via LER submittal, within 30 days following
receipt of the NRC Region IV position.
Sincerely,
G.
. Trevors
Division Manager -
Nuclear Support
GAT:GRH:ya
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cc:
S.' Region Office
Region IV
Resident Inspector
Cooper Nuclear Station
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