ML20154R331

Procedure RP 1105A Repts of Nonroutine Events

ML20154R331
Person / Time
Issue date:	04/01/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154R302	List: IA-85-836, Discusses Differences Between Interpretations of 10CFR50.55(e) Re Reportability of Items/Events within 24 H. Region IV Encourages Permittees to Rept Soon After Identification If Analysis Will Continue for Extended Time ML20154R298 ML20154R317 ML20154R326 ML20154R331 ML20154R343
References
FOIA-85-836 RP-1105A, NUDOCS 8603280309
Download: ML20154R331 (6)

Text

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RP 1105A REGION III MANUAL S REGION III PROCEDURE 1105A i

I REPORTS OF NONROUTINE EVENTS Scope f

The purpose of this Procedure is to provide the method for screening /

evaluating, tracking, and closing out licensee's nonroutine event reports in accordance with MC 1105.

Procedure

1. General All licensee communicatiqns of reportable nonroutine events will be reviewed within RIII to insure appropriate dispositioning. The lead reviewing group will determine the safety significance of the event, the appropriate action by the region, whether additional verbal or written infomation is required, whether the cause and corrective actions have been adequately identified, and whether appropriate notifications have been made.

All one hour, four hour, and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notifications will be screened at the time of notification to determine the need for additional inspection. <

All written reports will be screened within 10 working days from the date i of receipt.

All followup inspections should be completed within 6 months of the date

. of notification (except in the case where the licensee's corrective action extends past that time; see RP 1220 for further guidance).

l The Section Chief or alternate will review and initiate appropriate l notifications and preparation of Daily Reports, PNs, A0s, and Press '

Releases in accordance with applicable procedures.

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a. Reactors I The disposition of each nonroutine event report for reactor

, facilities will be tracked using the Event Notification fom of RP 1310A to note and track events notifications received by the Duty g

oA Officer. Also, any 73.71(c) notification that fulfills 10 CFR Part 21 should be tracked with a similar form.

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4 CD b. Safeauards 73.71(c) and Other Security Related Events All reports of security related events are to be recorded on the gn Physical Security Safeguards Event Notification Fom (SNF). Sequen-tvf

@gg tial event nucbers will be assigned by the Physical Security Section of DRSS. All SNFs are to be forwarded to the Chief, Physical Security g Section for tracking and followup. The Physical Secur' Section will complete the computer input form (Physical Securit, 'afeguards Event Notification), and forward it to the Information Management-Section (IMS) for the Safeguards Report updating.

Contact:

Nick Chrissotimos Revised 04/01/85

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'C RP 1105A i

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. c. Fuel Facilities and Material Licensee All nonroutine reports F.ssociated with fuel facilities and material licensees are to be recorded on the Fuel Cycle and Material Licensee Event Reports computer input form and the forms forwarded to IMS for Event Report updating. -

2. Initial Notification For those reports associated with a power reactor complete Attachment 1 for each 50.55(e), AE0 or Part 21 report and submit to DRMA-IMS.

- 3. Receipt of Written Reports

a. Upon receipt of a written report-from a licensee, the section having functional responsibility for the licensee initiates a Report Evaluation Form (Attachment 2).

b. For reports associated with power reactors complete a RIII Tracking System Form A for LERs, AEO, and other reports required by Tech Specs and reports required by 10 CFR Part 21 and Part 50, Paragraph 50.55(e). The resident inspectors will initiate input to the RIII Tracking System for LERs.

c. For 73.71(c) and other security events initiate an input for Physical Security Safeguards Event Notification tracking system.

d. For fuel facilities and material licenses events, initiate an input form on the Fuel Cycle and Material Licensee Event Report tracking system.

4. Review of Written Reports

a. Tre section having functional responsibility for the licensee shall ar. sign the responsible reviewer. If assistance is required in the etaluation, the Section Chief will make the appropriate request by  ;

crafting a memo to the appropriate division for signature of the l Director with concurrence of the Branch Chief. This will be noted on the evaluation form (see Attachment 2 for Sample Memorandum).

Update the appropriate regional tracking system to indicate any change in review responsibility,

b. The assigned reviewer shall complete the rest of the Report Evaluation Form and other requirements.

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RP 1105A i ---

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5. Followup Action and Closure

a. The reviewer shall indicate what actions were taken for disposition.

b. The reviewer shall update the RIII Tracking Systems.

c. The status of all outstanding licensen reports should be reviewed quarterly by the responsible Section Chief.

Responsibilities

1. Reactor Facilities

a. Division of Reactor' Projects 1

(1) Has the lead responsibility to insure that all nonroutine i reportable events are dispositioned. The senior resident l inspector is responsible for the initial review, evaluation, l and determination of operational significance of all ?.ERs. l He will normally request assistance of DRS or DRSS in evaluating any report where substantive problems have been identified in specialist areas. l (2) Will coordinate the followup of all events with DRS or DRSS as appropriate.

(3) The Technical Support Staff (TSS) will maintain a general knowledge of the LER reporting requirements, will provide or resolve interpretations of these requirements to others

, as requested, and will serve as the point of contact for l all correspondence and communication between the Region and the AEOD. TSS will also coordinate the forwarding of all generic issues, Part _21 reports, 50.55(e), LERs, etc. , to headquarters and other regions.

b. Division of Reactor Safety

. Willsupportgydonrequest.

l c. Division of Radiation Safety and Safeguards (1) Will Support DRP on request.

(2) The Physical. Security Section will coordinate the disposition of all Part 73.71(c) reports for DRP.

(3) Has the lead responsibility for determination of reportability of security events.

Revised 04/01/85

RP 1105A i

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2. Fuel Fac'111 ties and Material Licensees Division of Radiation Safety and Safeavards

. The Nuclear Materials Safety and Safeguards Branch has the '

responsibility to ins'ure that all nonroutine material li~ cense.

reportable events are dispositioned.

. The Emergency Preparedness and Radiological Protection Branch has the responsibility to insure that all nonroutine fuel facilities reportable events are dispositioned.

3. All Licensees .

Division of Resource Management and Administration

. The Information Management Section (IMS) has the responsibility for inputting all nonroutine report data in Regional Computer Tracking Systems, maintaining data base and retrieving information.

References

1. IE MC 1105, Reports of Nonroutine Events

2. RIII RP 1110A, Preparation and Updating Abnormal Occurrence Reports

3. RIII RP 1120A, Preliminary Notifications

4. RIII RP 1125A, IE Bulletins and Information Notices

5. RIII RP 0945, Issuance of Press Releases

6. IE Procedure 907128, In-office Review of Event Reports

7. IE Procedure 927008, Licensee Event Follow-up

8. IE Procedure 92715B, Review of Part 21 Reports

9. IE Procedure 927168, Part 21 Report Follow-up

10. RIII RP 0527, RIII Tracking System

11. RIII RP 1220, Verification of Licensee Actions

12. Regulatory Guide 10.1 Compilation of Reporting Requirements for Persons Subject to NRC Ragulations, Revision 4, October 1981, Appendix A

13. NUREG-1022, Licer.swe Event Report System Attachments:

1. Report Evaluation Form

2. Sample Memo for Requesting Assistance 4

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REPORT EVALUATION FORM /RIII TRACKING SYSTEW -

SITE NEW ENTRY MODIFY

ITEM MUPSER  : TYPE: PERSON WHO IDENTIFIED

: CODE: ITEM (NAME): (16,)

DKT Y Y X X 'X X  : X :

:  :  : /:  :  :  :  :  :  :  :  :  :  :

:  :  :/ :  :  :  :  :  :  :  :  :  :  : PERSON ASSIGNED (NAME):(106)

LER (68) (100)

LER EVENT DATE (32) LER REPORT DATE_(29) REVISION RESPONSE DUE DATE

: : : : : :  :  : a : : : :  : :  :  : : :. : : :

Y Y M M D D Y Y M M D D Y Y M M D D FOLLOWUP DUE DATE (38) INTERIM REPORT NO.(95): CLOSEOUT REPORT NO. (121)

Y Y M M D D  : INSPECTOR (NAME):  :

l BRIEF DESCRIPTION:(31)

D0 NOT TYPE PAST

Tiil5 POINT

1. MODULE 92700 REQUIREMENTS:

2.01 2.02 2.03 2.04 2.05 2.06 (Rx TRIPS)

2. ASSISTANCE NEEDED (YES/NO) DATE/ ADDRESSEE OF REQUEST:

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3. OTHER FOLLOWUP (HEADQUARTERS, ENFORCEMENT, PART 21, ETC.):

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4. REMARKS:

l COMPLETED BY: DATE: _

Attachment 1

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RP 1105A Revised 04/01/85 l

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SAMPi.E MEMDRANDUM MEMORANDUM FOR: DDirector, Division of Reactor Safety ODirector, Division of Radiation Safety and Safeguards

! FRON: C. E. Morelius, Director, Division of Reactor Projects

SUBJECT:

REQUEST FOR ASSISTANCE (AITS No. (only if not in RIII Tracking System))

t Attached is a copy of a (telephone report) (written report) of an event at .

1 l As discussed between and of our respective staffs, we understand that you plan to i

, C. E. Morelius, Director Division of Reactor Projects i

cc: DRP Section Chief DRP Branch Chief 2 Senior Resident Inspector

~DRS or DRSS Branch Chief DRS or DRSS Section Chief i

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t rs Attachment 2 RP 1105A Revised 04/01/85

h- A?R 00 235

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MEMORANDUM FOR: James M. Taylor Director -

Office of Inspection and Enforcement 'h FROM: Robert D. Martin, Regional Administrator, Region IV p,g

SUBJECT:

ASLB MEMORANDUM AND ORDER: PHASE II HEARINGS ON '[-

QUADREX REPORT ISSUES IN RE HL&P Enclosed for your information is a memorandum and order from the Atomic Safety and Licensing Board dated February 26, 1985, which takes issue with the staff's interpretation of IE Guidance dated April 1,1980, on 10 CFR 50.55(e).

-Construction Deficiency Reporting.

The Board's memorandum and order pertains to the issue of the reportability in whole or in part of the Quadrex Report by Houston Lighting and Power. In dealing with that issue, the staff had determined that the critical issue raised by the

, report in terms of Section 50.55(e) was whether significant deficiencies in final design were uncovered and thus focused its review on whether Quadrex revealed significant deficiencies in final design as approved and released for construction.

See paragraph 5, Criteria For Reporting, subparagraph a, of the IE Guidance.

However, the Board said that by " treating every design not released for construc-tion as not sufficiently significant to be reported, the staff has effectively eviscerated the requirement of 10 CFR 650.55(e)(1)(i) that a construction permit holder report significant QA breakdowns in design engineering."

In addition, the. Board was critical of the Staff's " failure to properly evaluate reportability under 10 CFR 650.55(e)(1)(i) . . . of the Quadrcx Report's so-called

' generic' findings." The staff had declined to evaluate the reportability of any of the " generic" items on the grounds that those items were based solely _on the individual discipline findings, the reportability of which it did evaluate, and hence the " generic" findings did "not represent new findings." The Board held that this was not proper since a " generic" finding could be greater than the sum of its parts; i.e., it may document a significant QA breakdown where no component discipline finding rises to that stature. Thus, the Board took the position that "for purposes of ascertaining the existence of a significant QA breakdown for reportability under 10 CFR Q50.55(e)(1)(i), the ' generic' findings should have been considered apart from, and in addition to, the discipline-findings." While the IE Guidance may be susceptible to such an interpretation, we do not believe that it is by any means as clear as it might be. ,

RIV RC RA/SW, WLBr wn:jd R W ftin 4[/J/85 /) /85 QhY YY

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n. 0213&5 Memo.to James M. Taylor In light of the above, we believe that the subject guidance may need to be reviewed for possible updating. Please let us know if we can provide any additional information or oackground.

ORIGirtAt SIGNED tY FU33ERT D.f!'RTN Robert D. Martin Regional Administrator cc:

V. Stello, EDO Thomas E. Murley, RA, RI

. J. Nelson Grace, RA, RII

, James G. Keppler, RA, Rlli John B. Martin, RA, RV bcc:

P5 Check RPDenise DFHunter EHJohnson

/ .J Lieberman, OELD E. Reis, OELD

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