ML061280620

Letter to Tim Hope Implementation of NUREG 1022 Revision 2 Guidance Regarding the Reportability of Loss of Shutdown Cooling

ML061280620
Person / Time
Site:	Columbia
Issue date:	05/08/2006
From:	Howell A NRC/RGN-IV/DRP
To:	Hope T Region IV Utility Group (RUG IV)
References
IR-04-004, IR-05-004, NUREG-1022, Rev 2
Download: ML061280620 (3)

Text

May 8, 2006Tim Hope, RUG IV Chairman4200 South Hulen Drive Suite 630 Fort Worth, Texas 76109

Subject:

IMPLEMENTATION OF NUREG 1022 REVISION 2 GUIDANCE REGARDING THEREPORTABILITY OF LOSS OF SHUTDOWN COOLING

Dear Mr. Hope:

Thank you for your letter, dated February 28, 2006. In your letter, you referenced NRCInspection Report 05000397/2005004 for the Columbia Generating Station, which documentedthe closure of Unresolved Item (URI) 50-397/04-04-07 related to the reportability of loss ofshutdown cooling events under 10 CFR 50.73(a)(2)(v)(B). Your letter also indicated that the closure of this URI stated that two events determined by Columbia Generating Station as notreportable in accordance with the Reporting Guidelines of NUREG-1022, Revision 2, "EventReporting Guidelines 10 CFR 50.72 and 50.73," were in fact considered reportable as a loss of safety function in accordance with the reporting guidance and as safety system functionalfailures (SSFFs) within the Reactor Oversight Process performance indicator (PI) protocol. The report also stated that the NRC concluded that the licensee had misinterpreted therequirements of 10 CFR 50.73(a)(2)(v)(B) and the guidance provided in NUREG-1022,Revision 2.In your letter, you stated that the Regional Utility Group (RUG) IV members' position on thistopic from a generic standpoint is that RUG IV does not believe that the specific instances citedin the inspection report constitute a reportable loss of safety function under 10 CFR 50.73(a)(2)(v)(B). You also stated that, in submitting this position, RUG IV wanted to convey that its primary concern and focus is on consistency in regulatory implementation by thelicensees and the consistency of NRC enforcement of the regulatory guidance. You indicatedthat, regardless of the final position taken on this issue, providing additional clarifying guidance in NUREG-1022 on this subject should be considered by the NRC.While we believe that your letter provided no information beyond that which was alreadyconsidered by the staff in addressing this issue in the subject inspection report, the NRC currently plans to review and evaluate NUREG-1022 in Fiscal Year 2007 to determine whetheradditional clarification is needed with respect to this and other reporting issues. As part of this process, the NRC plans to obtain stakeholder input.

Tim Hope- 2 -Thank you for providing your feedback. Should you have any questions regarding ourresponse, please contact Mr. Claude Johnson at 817-860-8148.Sincerely, /RA/Arthur T. Howell III, DirectorDivision of Reactor Projects cc:B. Mallett, RIV T. Gwynn, RIV Z. Dunham, RIV P. Hiland, NRR R. Laura, NRR S. O'Conner, OEDO Tim Hope- 3 -bcc:L. Owen (RAI 06-166 input)SUNSI Review Completed: __CEJ___ ADAMS: Yes G No Initials: _CEJ___ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveS:\DRP\DRPDIR\Letter to Tim Hope - Rug IV Response.wpdML061280620RIV:C:DRP/ADD:DRPNRRD:DRPRCCEJohnson;mjs;dlfAVegelRALauraATHowell IIIKDFuller/RA//RA/E-CEJohnson/RA//RA/ 4/27/065/1/064/27/065/1/065/2/06D:DRP signATHowell III /RA/5/8/06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax