DCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations

Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations

ML20212G247
Person / Time
Site:	Diablo Canyon
Issue date:	09/20/1999
From:	Womack L PACIFIC GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR36291, RTR-NUREG-1022, RULE-PR-50, RULE-PR-72 64FR36291-00021, DCL-99-123, NUDOCS 9909290173
Download: ML20212G247 (4)

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. Electic Company 90CKc, r,ta Lawrence F.Womack Diablo Canyon Power Plant ear scal Services Avila h CA 93424 3 E 27 A10:51 as s4s wm September 20,1999 OR:

PG&E Letter DCL-99-123 - Abb ,

i Secretary DOCKET NUMBER U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 PROPOSED RUlm PR so s 7.:.

Attn.: Rulemakings and Adjudications Staff M2%

, Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 4 Diablo Canyon Units 1 and 2 C_omments on orooosed rule 10 CFR Parts 50 and 72. "Reportina Reauirements for Nuclear Power Reactors." and Draft NUREG-1022. Revision 2. " Event Reportina Guidelines - 10 CFR 50.72 and 50.73"

Reference:

Federal Register Volume 64, No.128, Pages 36291-36307, dated

' July 6,1999 Dear Secretary; PG&E appreciates the effort that the NRC has put into revising 10 CFR 50.72 and 10 CFR 50.73 and allowing for industry involvement. Specifically, the table top exercises, held on November 13,1998, as discussed at Reference page 36291 were of great benefit and allowed for an open exchange of information. PG&E supports the NRO's position to reduce or eliminate the reporting burden associated ,

with events o, ..itle or no safety significance. The proposed rule has made progress I g;-

toward this goal. However, there are specific portions of the rule and associated NUREG-1022, Revision 2, that detract from this goal and if implemented may increase the reporting burden of the licensee. This proposed rule was reviewed

- collectively by several utilities (AmerenUE, Wolf Creek Nuclear Operating Company, Pacific Gas and Electric Company, STP Nuclear Operating Company and TXU Electric). Our areas of concern include:

9909290173 990920 PDR PR SO 64FR36291 PDR h0

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Rulemaking end Adjudication' Staff PG&E Letter DCL-99-123 L'  ; September 20,1999

' Page 2 l' Sionificantiv Dearaded Components Most significant is the recent addition of a new reporting criterion for Significantly Degraded Component (s). PG&E finds the new criterion as written to be unclear in focus and subject to widely varying interpretation.

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The attempt to capture items'(components) which are seriously degraded,

' but not necessarily enough to render a system inoperable, is far below the current reporting threshold and represents a significant increase in licensee

- burden. Further, even if an operability statement is added to the criterion, as suggested at the tabletop, held on August 3,1999, PG&E believes that a component degradation significant enough to render a system inoperable

- would be captured by other reporting criteria, making this now criterion redundant and unnecessary.

In addition, the new criterion as discussed by the staff at the table top exercise on August 3,1999, appeared to have been added primarily as a data collection mechanism for motor operated valves. This is contrary to the stated objectives of the proposed rule which focuses on events of risk and safety significance. If component data is needed, there are other resources

. available to the NRC to obtain the information such as maintenance rule reports and the Equipment Performance Information Exchange (EPIX).

PG&E recommends that the new criterion not be added to the rule. As discussed at the table top, held on August 3,1999, significant component degradations that are risk and/or safety significant will be reported under other criteria such as loss of a function, common-mode failure, Part 21, or as a Technical Specification violation.

ESF Actuations The addition of a specific list of systems which must be reported as Engineered Safety Features will increase reporting by plants whose licensing basis does not include those specific systems. PG&E recommends a return to the pre-1998 practice of relying on each facility's Final Safety Analysis Report (FSAR) and shift to a risk-informed approach when such criteria are fully developed. As part of the effort to risk inform Part 50, this section should be changed to be more risk informed.

. Invalid ESF actuations are still included in the proposed rule change reporting

. requirements for'the written LEA. PG&E recommends that the existing clarifications for not reporting certain invalid actuations be retained in the

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Rulemiking and Adjudication Staff PG&E Lctt:r DCL-99-123 September 20,1999

- Page 3 guidance. Actuations that need not be reported are those initiated for reasons other than to mitigate the consequences of an event. Specifically, actuations when the system is already properly removed from service, that are part of a planned evolution, that occur after the safety function has already been completed, or single component actuations of complex systems, which do not by themselves mitigate the consequences of significant events, are not reportable.

LER Information The scope of information requested for human performance events has increased by shifting from " personnel error" and the implied " root cause" to

" human performance related problem" and " contributing factors." It is more appropriate to require discussion of personnel error root causes.

PG&E recommends deletion of the new criterion,10 CFR 50.73 (b)(3)(ii),

which requires a discussion of emergency or operating procedures that could have been used to recover froin an event be included in a LER. The proposed rule change would result in a large amount of additional information that would be of minimal use. The safety consequences discussion would be cluttered with hypothetical failures and speculated plant responses.  !

Historical Limitations '

PG&E supports the new historical reporting limitation for operations prohibited by the plant's Technical Specification and conditions that could have prevented fulfillment of a safety function, but believes this limitation should be. applied to the whole rule.

In addition to the general comments above, PG&E endorses the comments submitted to the NRC by the Nuclear Energy Institute (NEI).~

Sincerely, f

l./ $

Lawrence F. Womack

Rulemaking and Adjudication Staff PG&E Letter DCL-99-123 September 20,1999 Page 4 cc: Steven D. Bloom Ellis W. Merschoff David L. Proulx Diablo Distribution

. Robert E. Post (NEI)

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