ML24003A929

(CN 98-020) IP 90712 In-office Review of Written Reports of Nonroutine Events at Power Reactor Facilities

ML24003A929
Person / Time
Issue date:	12/31/1998
From:	NRC/NRR/DRO/IRIB
To:	NRC/NRR/DRO/IOEB
Shared Package
ML23248A198	List: ML24003A922 ML24003A923 ML24003A924 ML24003A925 ML24003A926 ML24003A927 ML24003A928 ML24003A929
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Download: ML24003A929 (1)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C . 20555--0001 NRC INSPECTION MANUAL PECB INSPECTION PROCEDURE 90712 IN-OFFICE REVIEW OF WRITTEN REPORTS OF NONROUTINE EVENTS AT POWER REACTOR FACILITIES PROGRAM APPLICABILITY: 2515 FUNCTIONAL AREA: ENGINEERING (ENG) 9071 2-01 INSPECTION OBJECTIVES To determine the following through a systematic review of applicable written reports of nonroutine events:

01.01 Additional inspection effort or other NRC response is warranted.

01.02 The licensee's corrective actions as discussed in the report appear appropriate .

• 01 .03 Information reported by the licensee satisfies reporting requirements.

01 .04 The event involved activity or facility operation that is in violation of technical specifications. license conditions. or other regulatory requirements .

01.05 The event involved operation of the facility in a manner that constituted an un reviewed safety question as defined in 10 CFR 50.59Ca)C2).

01 .06 The event results in issues that could have generic implications.

01.07 The event is appropriate for classification as an Abnormal Occurrence in accordance with Section 208 of the Energy Reorganization Act of 1974.

90712-02 INSPECTION REQUIREMENTS 02.01 Review the written report and determine the following:

a. If further actions are required in the light of previous NRC actions following prompt notification (if prompt notification was made) .

b. Reporting requirements (type of report and timeliness) have been met.

c. The report is adequate to assess the subject event (defect in a component or activity, failure to comply with a regulatory requirement. or construction deficiency).

Issue Date : 12/31/98 90712

ct . The causes appear to be accurately identified and properly documented.

e. Corrective actions taken and/or planned appear appropriate to correct both

• the subject event . defect. failure to comply or deficiency. and the cause.

f. The generic applicability to other components. similar systems . structures or activities within the facility or licensed operation has been considered.

g. The event is a repeat of. or causally linked to. a previous event.

h. Consult the appropriate sections of the UFSAR. as necessary.to determine if the report described operation of the facility in a manner that constituted an unreviewed safety question per 10 CFR 50.59(a)(2).

i. The nonroutine event report contains information that can apply generically to other plants or licensed activities within the region.

Determine if NRR action (in particular. issuing an information notice or bulletin) is warranted or has already been initiated . Forward matters which have potential generic applicability to Events Assessment. Generic Communication. and Special Inspection Branch . if not done already.

02.02 Determine if onsite inspection follow-up of the event is appropriate in accordance with IP 92700 .

90712-03 INSPECTION GUIDANCE General Guidance Each regional office should establish instructions for conducting an in-office review . These instructions should address the timeliness of the review . For most cases . the review should be completed within 90 days of issuance of the report. Using this procedure (IP 90712) a regional or resident inspector can perform this review . Certain event reports may be selected for on-site follow-up using IP 92700 . Either a regional or resident inspector may conduct such follow-up .

"Event Reports" include all written reports of nonroutine events for which reporting requirements are provided in the license conditions . the technical specifications . or Title 10 Rules and Regulations such as. 10 CFR 73.71 . 10 CFR 50 .73. 10 CFR 50 .9. 10 CFR 2201 through 2206 or 10 CFR 50.55(e).

Enter the licensee's report into the region's tracking/reactor program system to ensure follow-up and closeout . All licensee written reports of non-routine events shall have a documented closeout in an inspection report .

NOTE : The minimum acceptable statement for documenting the closeout 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 .

Documentation of an event review will close out the particular event report in a traceable manner . and summarize the findings in an inspection report in accordance with Manual Chapter 0610 . If more than one inspection is necessary

• to complete event follow-up . the report for the last such inspection should 90712 Issue Date: 12/31/98

reflect final close out. Some long term corrective actions may be treated as regulatory commitment. and subject to programmatic verification of licensee's commitment management system. The inspector may use judgement to refer to the licensee* s corrective action system for completion of corrective act i ans of mi nor

• to low safety I risk significance. However. for corrective action items of a long-term nature that have substantial risk and safety significance, such as certain design changes, the regional management should decide if future inspection to ensure completion is necessary .

The documentation should distinguish between those reports followed up onsite and those reports closed out based on in-office review with no further action necessary. The writeup should clearly state that the conclusion is either from direct inspection or licensee provided information. However. it is insufficient to document the licensee* s version of the text and use it as a basis for enforcement conclusions involving a Notice of violation or escalated enforcement action. Follow the guidance in the Enforcement Policy/Enforcement Manual for citat ion of non-escalated enforcement actions.

When the staff decides to perform only an in-office review of an LER with no on-site follow-up, the reasoning used to arrive at that decision should be documented in the inspection report. The level of detail shall vary depending on the significance of the report and the results of the inspector's in-office review. The documented reasoning should include the factors reviewed. For example: generic implications, causal linkage to other events at the plant. and an assessment of the licensee's root causes should be included. For reports involving minor issues where no new performance problems. information or performance perspective are identified. the closure should be correspondingly brief and state that only minor issues were involved. For reports where the licensee performance issues had already been inspected as an event follow-up, a cross reference to the inspection report that documented the inspector's assessment may be adequate for closeout.

The above documentation guidance does not replace or change the authority in IMC 0610 to not discuss minor enforcement issues in a report.

This inspection procedure does not apply to:

a. Licensee 10 CFR Part 21 notifications. IP 36100 provides inspection guidance for reviewing and assessing licensees' 10 CFR Part 21 programs.

b. The licensee* s prompt (telephone) not if i cat i ans concerning events at operating power reactors. IP 93702 provides inspection guidance for responding to prompt notifications.

c. Periodic and special reports such as an annual operating report or an in-service inspection report. IP 90713 provides guidance for inspector review of these reports.

d. The review of periodic . routine. or regularly recurring reports or events.

such as reactor building integrated leak rate tests, startup of reactor.

and the annual operating report.

e. On-site inspection of an LER where IP 92700 provides guidance for such inspection and documentation .

• Issue Date: 12/31/98 90712

Specific Guidance 03 .01 report review - The inspector should consider the following during review of the written report :

a.

b.

c.

No inspection guidance .

No inspection guidance.

10 CFR 50 .73 and NUREG 1022, Rev 1. Event Reporting Guidelines 10 CFR

50. 72 and 50 . 73. provide the requirements and the guideline for the content of the report. Also 10 CFR 50 .9 delineates the requirements for completeness and accuracy of information provided to the Commission by a licensee. If the report is not complete , not understandable, or contains inaccurate information . contact the licensee . Obtain a commitment for a corrected report if the information reported to the NRC is found to be significantly in error or incomplete . Document the review in an inspection report with what was found and what was requested of the licensee . The inspector should determine the threshold of significance of errors. including omissions. for which a corrected report is required.

For errors of lesser significance. it may be sufficient to discuss the error with the licensee to ensure that future reports are accurate. If a corrected report is submitted . the inspector should review it in accordance with this procedure.

The revised report must supersede the previous report. must be a complete entity, and not contain only supplemental or revised information.

d. No inspection guidance .

e.

f.

g.

No inspection guidance.

No inspection guidance .

Identifying repeated or causally linked events requires significant amount of work . Thus. each regional office should refer to its tracking/reactor program system (RPS) entries and inspectors* knowledge including that of the resident inspectors for events at this facility . Judgement should be applied to not follow minor issues .

h. Refer to Inspection Manual part 9900, 10 CFR 50 .59. Guidance on the Requirements Related to Changes to Facilities. Procedures and Tests (or Experiments) .

i. Action by NRR may be appropriate when the event has substantial safety significance or generic applicability . When a regional office desires technical or other assistance from NRR or another NRC office , a task interface agreement (TIA) may be processed to define participant responsibilities for resolving the matter.

The NRC allows alternate methods for reporting defects that might also be required under 10 CFR Part 21. The alternate reports include 10 CFR Part 50 .55(e) reports or licensee event reports (LERs) submitted in accordance with 10 CFR 50.73. Therefore. persons reviewing nonroutine event reports should promptly notify the Events Assessment. Generic Communications Branch (PECB) , NRR, of matters that are perceived to have substantial

• safety significance and/or generic applicability, and forward to PECB for 90712 Issue Date : 12/31/98

its review the reports received by the region and any other relevant information that supports this determination . See IMC 0970, "Potentially Generic Items Identified by Regional Offices," for further guidance in this area .

• 03 .02 The event should be followed up during onsite inspection (per IP 92700) if, in the inspector's judgement, questions exist regarding the following :

a. Accuracy of the circumstances described in the report.

b. Possible noncompliance.

c. Adequacy of the licensee's corrective action ( proposed or actually taken).

d. Need for onsite follow-up for other reasons .

NRR may also request that certain types of event reports be inspected at the site. In addition, onsite follow-up may be performed for the following :

a. Written follow-up reports required by 10 CFR 50.73 for nonroutine events (licensee event reports).

b. Written reports (construction deficiency reports) required by 10 CFR 50.55(e).

9071 2-04 INSPECTION RESOURCES Direct inspection resources necessary to complete this inspection procedure are estimated to be 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for each reported event .

END

• Issue Date: 12/31/98 90712