ML20236C040
| ML20236C040 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/19/1987 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CNSS876115, NUDOCS 8710260465 | |
| Download: ML20236C040 (2) | |
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- GENERAL OFFICE -
Nebraska Public Power District
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.CNSS876115 October 19, 1987 q
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U.S. Nuclear Regulatory Commission j
Attention: Document Control Desk 9
Washington, DC 20555
,1 Gentlemen Subjects' NRC Report Requirements (10 CFR Parts 50.72 and 50.73)
References:
- 1) Letter from L.
J.
Callan, NRC Region IV, to G..A.
- Trevors, NPPD, dated September 18, 1987,- Response 1to Reference.2)
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- 2) Letter from C.
A.
Trevors to NRC Document Control Desk, j
dated September 2,
1987, " Response to IE Inspection. Report 1
No. 50-298/87-18"
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s
- 3) NRC Inspection Report 50-298/87-18, dated August 4, 1987 J
In Reference 1), you requested that we inform you of our corrective actions, either planned or completed, regarding training in reporting requirements as prescribed in 10 CFR Parts 50.72 and 50.73.
This supplemental information was to be provided in addition to a Licensee Event Report (LER) associated j
with a Reactor Water Cleanup (RWCU) System isolation event. that occurred during surveillance testing on May.12, 1987.
As a result, LER 87-022, Unplanned closure of Reactor Water Cleanup System < Isolation Valve MOV-MO-15 Due to Personnel Error During Surveillance Testing, was submitted on October 15, 1987.
The concerns noted in Reference 1),
which you requested be addressed, were incorporated into the LER.
In Reference 2),
we advised that we did-not consider the RWCU problem experienced on May 12, 1987, to be reportable as an -LER, based. upon' our understanding of (1) the LER reporting criteria. prescribed in 10 CFR Part-50.7 d (2) the guidance provided in NUREG 1022 and related supplements.
Note, ho ever, that the NRC was notified of this situation on May 12, 1987, at 2 : 22 P.M.... within four hours 'of the event occurrence,--in accordance with the immediate. notification requirements prescribed by.10CFR50.72.
lWhile not specifically mentioned in Reference. 3), the NRC Inspector noted. (while i on site),
the evaluation activities which had been performed and.'the documentation of related discussions in SORC meeting. minutes. regarding the RWCU problem and its potential deportability. The extent to :which' these activities were carried out, which included a thorough review of 10 CFR'Part-(foJ1' o'ving 0.73 and NUREG 1022, is evidence of 'our awareness of the importance of k
the LER reporting criteria.
However, we also felt that the
_ 7 questionable nature of the deportability 'of this specific problem was,. in-part, indicative of a' lack of clear, prescriptive guidance within 10CFR and l
the NUREG regarding this particular circumstance.
In general,. we believe
}
that the-existing guidance' regarding LER reporting ' requirements _. associated with Engineering Safety Feature (ESF) actuations'could be better clarified.
8710260465 871019-PDR ADOCK 05000298" S.
CNSS876115 October 19, 1987 Page 2 l
In order to avoid future situations wherein our understanding of the reporting l
requirements differs from the NRC's, we fully agree that we must be made l
aware of and better understand the NRC's interpretations of the pertinent I
regulatory requirements.
This consideration was addressed in Reference ~ 2)
'I in the paragraph entitled, " Corrective Steps Which Will Be Taken To Avoid Further Violations".
Additionally, in response to your request in Reference l
1), we will assess the availability of training materials and/or services that may be responsive to this consideration, such that we achieve a thorough 3
I understanding of NRC applications of LER reporting requirements.
This assessment will be completed within 30 days of this correspondence.
If suitable materials and/or services can be located, we would expect to complete the upgrading of the knowledge level of required personnel in this area within l
the next 90 days.
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If you should require any further information regarding this subject, please l
contact Mr. G. R. Horn at Cooper Nuclear Station, i
I Sincerely, l
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Division Manager c-)
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