ML20238C454
| ML20238C454 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/02/1987 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-1022 CNSS876042, GL-87-09, GL-87-9, NUDOCS 8709100118 | |
| Download: ML20238C454 (2) | |
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( Nebraska Public Power District CNSS876042 September 2, 1987 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
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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 le a Severity Level IV violation.
(Supplement II) (298/87108-01)
Reason For The Violation Based upon the alleged tiolation provided in Appendix B, Paragraph 4, of the Inspection Report, the District acknowledges NRC assessment that closure of RWCU M0-15 constitutes an event to be reported as a Licensee Event Repert (LER). Previously, based upon District evaluation of the situation and our understanding of the reporting requirements prescribed in 10CFR50.73, the conclusion had been reached that valve closure occurring subsequent f.o satisfactory completion of actuation circuitry surveillance testing did not constitute an event or condition that resulted in manual or automatic actuation of an ESF.
Instead, the closure occurred when a procedural step was not correctly executed during system restoration, not as a result of logic initiation and subsequent valve actuation.
In accordance with the response to Question 2.7 provided in NUREG 1022, Supplement 1, procedural violations are not necessarily reportable. Therefore, believing this to be a vocedure violation only and not an ESF actuation, the situation was not reported as an I
LER.
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1Documant' Control Desk September 2, 1987-Page 2 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 submittal requirements, we will be~ advised of the NRC Region IV position and
. proper action to be taken.
In'lightoftheforegoingexplanation,thefacg that a non-conformance report was previously' written against the event, and,
.the NUREG provided provisions regarding disagreements that may arise, the,
n, District requests that Region IV Office re-assess their position and advis# ust as.to their determination. Based upon'our understanding of reporting time limits provided in the. response to Question 14.2-(NUREG 1022, Supplement 1),,
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we would then have 30 days from the date of your response to submit the a'
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required LER, prior to being considered in violation'of LER reporting requirements.
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, Corrective Steps Which Will Be Taken To Avoid Further Violations The Station Operations' Review Committee (SORC) will-continue to evaluate those
~j eventr> that-appear to be' questionable under the deportability requirements of
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/10CFR50.73. utilizing guidance provided-in 10CFR50.73, NUKEG 1022, Supplements I
to.NUREG 1022, and other documents, as applicable, such as Generic Letter 87-09.
In the future, if, after initial SORC review and. evaluation, the deportability' requirement for an event is qt.estionable, the NPPD Nuclear Licensing and Safety Department will be contacted for guidance'and I
interpretation. In all situations, however, it is assumed that the guidcuce
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provided in NUREC 1022, Supplement 1, Question 11.3, is valid and that, should a disagreement regarding LER submittal requirements arise, the District, where i
necessary,'will pursue'the NRC Region IV position, including proper. actions to l
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 j
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. A. Trevors Division Manager -
Nuclear Support GAT:GRH:ya-j cc:
'U.
S. Region Office 1
Region IV Resident Inspector Cooper Nuclear Station l
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