IA-86-729, Denies Util 841213 Request for Exemption from Requirements of 10CFR50.73, LER Sys. Postponement of Reporting Suppl to LER Permitted Only When Similar Reportable Items Discovered During Review

Denies Util 841213 Request for Exemption from Requirements of 10CFR50.73, LER Sys. Postponement of Reporting Suppl to LER Permitted Only When Similar Reportable Items Discovered During Review

ML20215L545
Person / Time
Site:	Columbia
Issue date:	01/22/1986
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Martin J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
Shared Package
ML20215L519	List: IA-86-729, Denies Util 841213 Request for Exemption from Requirements of 10CFR50.73, LER Sys. Postponement of Reporting Suppl to LER Permitted Only When Similar Reportable Items Discovered During Review ML20215L516 ML20215L545
References
FOIA-86-729 NUDOCS 8610290088
Download: ML20215L545 (2)

Text

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%,*****/ JAN 2 21985 Mr. J.D. Martin WNP-2, Plant Manager Washington Public Power Supply System P.O. Box 968 Richland, Washington 99352

Dear Mr. Martin:

By letter dated December 13, 1984, you requested an exemption to the reporting requirements contained in 10 CFR 50.73, " Licensee Event Report System." Based on our review of the details of your request, it does not appear that an exemption is necessary.

Subsequent to the issuance of 10 CFR 50.73, the NRC issued two documents (NUREG 1022, and Supplement I to NUREG 1022) that clarified the intent of the requirements contained in 50.73. Supplement 1 to NUREG 1022 was writ-ten in a question-and-answer format. The following question from Supple-ment I seems to cover your situation:

Question 14.13: "We sometimes test components such as valves and snubbers over a period of several weeks. During this period we may discover a number of inoperative components. Do we have to submit each failure as an LER or can we submit multiple failures in one LER?

Answer: For similar failures that are reportable under 50.73 criteria and that are discovered during a single test program or activity, report all failures that occurred within the first 30 days of discovery of the first failure on one LER. However, the 30-day clock starts when the first reportable event is discovered. State in the LER text (and code the infonnation in Items 14 and 15) that a supplement to the LER will be submitted when the test is completed. Include all the failures, including those reported in the original LER, in the revised LER (i.e., the revised LER should stand alone)."

This question and the associated guidance provided in the answer appear to address the concern described in your exemption request. Although no exemption is necessary in this case, I would emphasize that postponement

{ of reporting to a supplemental LER is permitted only with respect to similar reportable items discovered during your reviews. To the extent that you discover other different types.of reportable items during the course of your reviews, these items must be reported in accordance with 10 CFR 50.73. More-over, to the extent that any of the items you discover during your reviews 02 8 861023 REPKA86-729 PDR i

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• meet the immediate notification requirements of 10 CFR 50.72, these items must be reported in accordance with that regulation. Please contact Fred Hebdon (301-492-4480) in the Office for Analysis and Evaluation of Operational Data if you have additional questions concerning this matter.

Sincerely, (SignesWilliam J.Direks William J. Dircks Executive Director for Operations Dis tribui. ion DCS VStello, DEDROGR AE0D, CF HDenton, NRR AEOD, SF JMartin, RV PTB, CF AToth, RV PTB.SF ERossi, IE FHebdon, AE0D DEisehnut, NRR TIppolito, AEOD GHolahan, NRR CJHeltemes, AE00 SRosen, INP WDircks, ED0 EDO Reading file JR0E, DEDO EDO 00213 TRehm, A0/EDO M ieberman, ELD l

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