ML20244C870
| ML20244C870 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/09/1984 |
| From: | NRC, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20237J194 | List:
|
| References | |
| FOIA-87-87, FOIA-87-A-14 92700, NUDOCS 8403230288 | |
| Download: ML20244C870 (7) | |
Text
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/p. ncy*s UNITED STATES i 'i >. - ( 7 7, NUCLEAR REGULATORY COMMISSION r
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OFFICE OF INSPECTION AND ENFORCEMENT t
f Washington, D.C. 20556 s
INSPECTION AND ENFORCEMENT MANUAL i
DEPER INSPECTION PROCEDURE 92700 ONSITEFOLLOWUPOFWRITTENREPORTSOFh0NROUTINE EVENTS AT POWER REACT 0R, FACILITIES PROGRAM APPLICABILITY: 2512, 2513, 2514, 2515, 2525 92700-01 INSPECTION OBJECTIVES For nonroutine events selected for onsite followup, to determine whether NRC licensees have taken corrective action (s) as stated in written reports of the events and whether responses to the events were adequate and met regulatory requirements, license conditions, and commitments.
92700-02 INSPECTION REQUIREMENTS 02.01 Nonroutine Event Review.
Verify the nature, impact, and cause of the nonroutine event; actions taken or planned by the licensee; and other information of significance.
02.02 Safety of Operation.*
Based upon the review conducted in Inspection Requirement 02.01, determine:
a.
Whether the event involved activities or facility operation in violation of the Technical Specifications, license conditions, or other regulatory requirements.
b.
For facilities licensed under 10 CFR 50, whether the event involved operation of the facility in a manner which constituted an unreviewed safety question, as defined in 10 CFR 50.59(a)(2).
02.03 Reactor Trips. For reactor trip events, verify that:
a.
The licensee's program was followed for insuring that unscheduled reactor shutdowns are analyzad and that a
- This section includes written event reports that affect operating f acilities and written event reports of conditions or equipment defects at plants under construction that may af fect safety of operating plants.
Issue Date: OR/1 VR4 k b ? 5$lk ? Y h
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ONSITE FOLLOWUP OF WRITTEN REPORTS OF NONROUTINE EVENTS 92700 02.03a AT POWER REACTOR FACILITIES determination was. made that the reactor could be restarted safely.
b.
The licensee's system for recording, recalling, and displaying data and information to permit diagnn & g the causes of unscheduled reactor shutdowns prior t1 restart p
was operational.
02.04 Corrective Action. Determine whether:
~
a.
Corrective actions stated in the report are app"opriate to correct the cause of the event,' defect, or failure to comply.
b.
Corrective actions have been completed, are
- progress, or are planned as stated in the report.
c.
For actions not yet completed, responsibility for assuring their completion has been established (where
- possible, determine the estimated completion dato).
d.
Corrective actions include consideration of generic implications to other
- systems, units, or facilities for which the licensee is responsible.
02.05 Reporting Requirements.*
Ascertain that reporting requirements
~
have been met by determining whether:
v a.
The report is timely,
- accurate, and adequately describes the event, defect, or failure to comply, b.
The safety implications and significance stated in the report are consistent with details of the event, as deter-mined in Inspection Requirement 02.01.
i c.- The cause is accurately described.
d.
The licensee plans to submit a
corrected report if information included in the report is found to be significantly in error.
02.06 Licensee Review and Evaluation. Determine whether:
a.
The event was reviewed and/or evaluated as required by the condition of license, specifications, QA program, adminis-trative controls, or other requirements.
- These inspection requirements need not be completed for every event selected for followup, but should be inspected periodically to verify proper functioning of the licensee's administrative controls.
Issue Date: 08/13/84 :
v ONSITE FOLLOWUP OF WRITTEN REPORTS OF NONROUTINE EVENTS AT PCWER REACTOR FACILITIES 92700-02.06b b.
Review and evaluation of the event:
1.
Were based on complete and factual information.
2.
Included assessment of repeated
- events, generic implications, personnel erro'r,
and procedural adequacy.
3.
Resulted in icgical cone sions with regard to cause, significance, and associated corrective actions.
c.
Personnel within the licensee's organization were notified of the event as required by the technical specifications, regulations, QA program, administrative controls, or other requirements.
02.07 Documentation a.
Document the onsite followup and closecut of all written reports (including those closed during in-office review per Inspection Procedure No.
90712) in an inspection report.
generic concern or a need for other followup action is If a identified, inform IE,
- NRR, other regional
- offices, or other licensees as appropriate.*
b.
Document information about poor performance by a licensed Operator or Senior Operator and send a separate memorandum identifying the Operator (s) to the Regional Operator Licensing Branch or.to the Operator Licensing Branch (OLB),
A copy of the inspection report should also be sent to tiB.
92700-03 INSPECTION GUIDANCE 03.01 General Guidance a.
This procedure (IP 92700) applies to those nonroutine events selected during in-office review per IP 90712 for onsite followup.
The in-office review may have been done by either a region-based or resident inspector and the onsite followup may be conducted by either a region-based or resident inspector, b.
Pursuant to IE Hanual Chapter (MC) 1105, nonroutine event reports judged by the Region 31 Offices to require onsite followup are to be inspected in accordance with this inspection procedure prior to closure.
The inspection requirements are general in nature; requirements that do
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- A separate manual chapter, 0970, " Generic Issues," is being prepared.
' Issue Date: 08/13/84 l
l
p ONSITE FOLLOWUP OF WR8TTEN REPORTS OF NONROUTINE EVENTS
'4 AT POWER REACTOR FACILITIES
~92700-03.0lb-not apply to' the particular report being reviewed should be omitted.
c.
Reports falling under this inspection proceuure will
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normally be required because of conditions of the license or permit, or by the rules, regulations, and orders of the Commission, d.
IE may request that a specific nonroutine event written report or a category of such reports be inspected; however, it.is expected that for the majoritg of nonroutine events the cognizant first line supervisor and inspector will determine whether or not a site inspection will be pe r-formed. Onsite inspection may be performed for:
1.
Written followup reports of n6nroutine events (Licensee Event Reports) required by 10 CFR 50.73.
2.
Written reports (Construction Deficiency
_ Reports) required by 10 CFR Part 50.55(e).
3.
Written reports required by 10 CFR Part 21 (Defects i
or Noncompliance and submitted by the facility or determined by others to be applicable to the facility.
1 03.02 Specific Guidance a.
Inspection Requirement 02.01.
The extent to which the inspector should independently verify circumstances of the event will be a matter of judgment based on:
1.
The complexity of the event; 2.
The lict see's past record for reliability and completeness of event reports;
-l 3.
The nature of questions, if any, identified during l
in-office review of the written report and; 4.
Radiological and/or public health and-safety j
concerns.
{
i b.
Inspection Requirement 02.03a.
Review the licensee's program for post-trip reviews, which was approved by NRR, as part of the post-Salem ~ Anticipated Transient Without Scram (AWS) generic requirements (Section 1.1 of Generic Letter 83-28); based upon this review, interview licensee personnel-and review documentation and records to ascer-tain that the program was followed.
Issue Date: 08/13/84 )
I
/
ONSITE FOLLOWUP OF WRITTEN REPORTS OF NONROUTINE EVENTS AT POWER REACTOR FACILITIES 92700-03.02c l
c.
Inspection Requirement 02.03b.
Review the licensee's program for diagnostic data on unscheduled reactor shut-downs, which was approved by NRR, as part of the post-Salem ATWS generic requirements (Section 1.2 of Generic Letter 83-28); based upon this review, examine records and inter-view personnel to ascertain that the data were recorded and used.
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-:r.
d.
Inspection Requirement 02.04 1.
Corrective actions should generally include action to eliminate the cause or to mitigate consequences, action taken to correct the specific fault or failure (maintenance,
- repair, replacement, procedure
- change, special administrative control, etc.) and action taken to reduce the probability of or to prevent recurrence d
(design change, personnel
- training, maintenance prac-tice, work controls, etc.).
These aspects of correc-tive action apply in varying degrees to a specific event; inspector judgment is needed for this determination.
2.
The inspector should request that significant changes in the licensee's corrective action from that stated i
d in the report be documented in an updated report to the Commission.
j e.
Inspection Requirement 02.04c.
If the licensee has an approved procedure for maintaining a tracking system that j
includes a field for noting " responsibility for completing
{
the corrective action," then the inspector should determine I
by sampling whether such responsibility has been documented in this tracking system.
f.
Inspection Requirement 02.05.
Regulatory Guide 10.1 gives a compilation of reporting requirements for persons subject to NRC regulations.
In
- addition, required content and timing of certain types of written event reports related to this inspection procedure are specified in the following references:
Operating Reactors Technical Specifications j
i 10 CFR 50.73 i
10 CFR 73.71 10 CFR 21.21(b)(3)
Defects and Noncompliance Construction Deficiencies 10 CFR 50.55(e)(3)
.c.
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Oh51TE FOLLOSUP OF WRITTEN REPORTS OF NONROUTINE EVENTS l
9_2_700- 0 3. 02 f AT POWER REACTOR FACILITIES Theft or Loss of Licensed l';.,FR 20.402 Material Radiological Incidents 10 CFR 20.403 Overexposure, Radiation /
10 CFR 20.405 Contamination Levels 10 CFR 71.61 Packaging g.
Inspection Requirement 02.06a.
Inspedtion Procedure fio.
90714 and Change Notice 83-11, dated September 13,
- 1983, require review of the licensee's nonroutine event I
reporting program when required to determine that licensee's management, administrative controls system, and organization exist and are functioning for investigating, reporting, reviewing, and assuring correcti,a actions and followup of events and incidents.
h.
Inspection Requirement 02.06b.
If inspection activity identifies significant incorrect information in the report, j
the licensee should submit a corrected report to the NRC.
t The revised report will replace. the previous. report; there-fore, the revised report should be a complete entity and not contain only supplemental or revised information.
If j
c i
it is determined that incorrect information was reported or if the licensee frequently reports incorrect information, enforcement action may be appropriate.
The threshold of significance of errors, including omission, above which a
(
corrected report is
- required, involves inspector judgment and should agree with considerations for citi n-i see for failure to report.
i.
Inspection Requirement 02.07a.
Documentation of event review in an inspection report serves to close out the particular event report in a traceable manner.
If more than one inspection is necessary to complete event follow-up, final closeout should be reflected in the last such inspection.
Significant corrective action items of a long-term
- nature, such as certain design changes, should be tracked to c'ompletion.
NOTE:
The minimum acceptable statement for documenting the closecut of a written event report should either:
(a) state that onsite inspection was performed and summarize the findings, or, (b) state that the event was closed out based on in-office review.
~
Issue Date: 08/13/84 '
E I
ONSITE FOLLOWUP OF WRITTEN I
REPORTS OF NONROUTINE EVENTS AT POWER REACTOR FACILITIES 92700-03.02]
j.
Inspection Requirement 02.07b 1.
Significant information concerning the performance of an individual licensed Operator or Senior Operator may have a
decisive role in licensing actions of the Regional Operator Licensing Branch or the -Operator Licensing Branch (OLB), NRR.
Therefore, each inspec-4 tor should ensure that, }be
- appropriate group is aware of those events where the performance of a ?icensed Operator may affect the s 4fety of the facility.
2.
In general, poor perfo;mance by a licensed individual is evidenced when:
(a) The individual's action clearly demonstrates inattention to duties or disregard for require-
- ments, including technical specifications and operating procedures; (b) Ine individual takes (or fails to take) a required action that results in significant actual or potential safety consequences; i
(c) There is repetitive noncompliance with regulatory requirements; or l
(d) The facility licensee deems that the individual's removal from licensed duties is required.
These situations parallel those in which enforcement action against the individus1 may be invoked (IE Information Notice No. 79-20).
END t
1 Issue Date: 08/13/84