ML19341A604
| ML19341A604 | |
| Person / Time | |
|---|---|
| Issue date: | 12/22/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-45FR6793, REF-10CFR9.7, RULE-PR-50, RULE-PRM-80-23 NUDOCS 8101270275 | |
| Download: ML19341A604 (9) | |
Text
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NUCLEAR REGULATORY COMMISSION l
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In t:be.Mt:ter of:
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M AFFIRMATION SESSION 80-56: SECY-80-525
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PROJECT FOR OPEN GOVERNMENT FOIA APPEAL:
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ff SECY-A-146 A - PETITION FOR RECONSIDERATION S
OF COMMISSION TYRONE DECISION; SECY-80-507 - INTEGR ATED OPER ATIONAL EXPERIENCE REPORTING SYSTEM:
SECY-80-501 - PROPOSED RULEMAKING ON 10 CFR 50 RE EMERGENCY RESPONSE PLANS FOR NUCLEAR FACILITIES; DENIAL OF ruTcoucunoe'ocTvvinu rna OTnECTED CERTIFICATION - DIABL8 CANYON DATE: December 22, 1980 pAggs: 1 thru 7
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Washington, D.
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400 vi.gisia Ave., S.W. Washing.=n, D. C. 20024 Talaphena: (202) 554-2245 18 3 0 J 9 7 0 2.M l
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1l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
3 Public Meeting 4
AFFIRMATION SESSION 80-56:
e 5
PROJECT FOR OPEN GOVERNMENT FOIA APPEAL; h
SECY-A-80-146A - PETITION FOR RECONSIDERATION
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6 OF COMMISSION TYRONE DECISION; i
R SECY-80-507 - INTEGRATED OPERATIONAL EXPERIENCE R
7 REPORTING SYSTEM; 3
SECY-80-501 - PROPOSED RULEMAKING ON 10 CFR 50 l
8 RE EMERGENCY RESPONSE PLANS FOR NUCLEAR FACILITIES; d
DENIAL OF INTERVENORS' PETITION FOR DIRECTED
=
9 CERTIFICATION - DIABLO CANYON g
10 j
11 Nuclear Regulatory Commission, B
Commissioners' Conference Room, y
12 1717 H Street, Northwest, 5
Washington, D.C.
y 13 Monday, 22 December 1900.
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The meeting of the Comnissioners was convened, 2
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pursuant to notice and vote, at 3:55 p.m.
16 j
W BEFORE:
y 17 ;
E JOHN F. AHEARNE, Chairman E
18 ;
PETER A. BRADFORD, Commissioner 5
JOSEPH M.
HENDRIE, Commissioner 19 i aM ALSO PRESENT:
20 ;
Samuel J. Chilk, Leonard Bickwit, Irwin B.
21 Rothschild, and Martin G. Malsch.
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DIS P A m Sis is an u=off' d=1
=ansc=1pc of a. =ned g of -Ja U 1:ad States Nuciaar lagulacory Cocaission held on. n o - o., b. - 22, 1980 in tha Commission's. officas at 1717 E Scraec, N. W., Wash 1=g en, D. C.
Da meeti=g was open en public atuandanca and obserracion.
. Mis.==="?t has sac been :sviewed, corrac:ad, or edi ad, and it any contain,inac d=.
Da c=ansc=1pc is incandad solely for sacaral i=for=a:1onsi purposes.
As providad.by 10 C21 9.103, 1: is sac pa== cf -de formal or informal record of decision of de mat:ars disc =ssed.
Zzpressions of opinion in -dis =anscripe da sec sacassa:ily reflac: final deca==1sations or beliads.
No 71==dd"? or othar paper may be. filed. v1=h the Commission. in any p scaeding as -da rasul: of or add =assed. a any statsmane or arguman conca1=ad, harnis, excepc as da Con =sission may authe:f.:a.
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2 CHAIRMAN AHEARNR:
Okay, Sam?
3 MR. CHILK:
The first paper is SECY-80-525, Project 4
for Open Government FOIA Appeal, in which the Commission has 5
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unanimously approved the recommendation of the General e
6I Counsel to send a draft letter to the petitioner indicating R
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7 classified material has been withheld -- the classified has A
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been withheld, and the unclassified has been placed in the 4
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Public Document Room.
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2 10 Commissioner Bradford deleted a sentence on page 6z h
II two of the letter, to which all of you have concurred, would 3
N I2 you --
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g 13 COMMISSIONER BRADFORD:
Except the General Counsel.
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I4 The General Counsel has --
5j 15 MR. CHILK:
Except the General Counsel.
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I6 MR. ROTHSCHILD:
We have added a couple of words h
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to solve our problem, which I believe you have seen?
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IO COiMISSIONFR BRADFORD:
I've just been told of then, s
"g 19 i and they sound fine to me.
n 20 MR. ROTHSCHILD:
It's just a little technical --
2I COMMISSIONER BRADFORD:
A technical fix?
i 22 MR. ROTHSCliTLD :
We just needed to explain what
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our standards are.
1 24j MR. CHILD:
Would you all then approve it as l
25 amended?
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ALDERSON REPORTING COMPANY, INC.
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I COMMISSIONER BRADFORD:
Aye.
2 CHAIRMAN AHEARNE:
Aye.
3, COMMISSIONER HENDRIE:
Aye.
4li MR. CHILK:
The next one is A-80-146A, a Petition g
5 for Reconsideration in the Commission Tyrone decision in which 51 6l the Chairman, Commissioner Hendrie, Commissioner Bradford R
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approved the order; Commissioner Gilinsky has abstained and e
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does not object to this going on this afternoon.
Would you d
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please affirm your votes?
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- y 10 CHAIRMAN AHEARNE:
Aye.
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II COMMISSIONER BRADFORD:
Aye.
3 Y
I2 l COMMISSIONER IIENDRIE:
Aye.,
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MR. CHILK:
The third one is SECY-80-507, Integrated a
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14 Operational Experience Reporting System, in which the Chairman 15 has approved the paper; Commissioner Gilinsky has approved it; j
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16 j Commissioner Bradford and Hendrie have also approved it.
The A
l 17 Chairman commented that the staff should examine the possi-I 18 ;'
bility of interim operations -- improvements that could be u
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e-t 19 l made to assist in examining the operational experience while 5
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the proposed rule is being developed.
Would you please 21l affirm your votes?
i 22 !
CHAIRMAN AHEARNE:
Aye.
23 '
COMMISSIONER BRADFORD:
Aye.
t 24 CHAIRMAN HENDRIE:
I would like to make a comment.
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25 In voting to go ahead with this, I would like the Secretary's I
ALDERSON REPORTING COMPANY. INC.
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note to show that I expect the staff to seek input from the 2
Institute of Nuclear Power Operations, as well as other 3
appropriate organizations in the formation of the new 4
Information Reporting System.
INPO had written us a letter 5
j af.d said:
Hey, you've told us we would confer on this sort n
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of thing; I do not regard the vote here as saying, no, we're R
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not going to confer.
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All we are saying here is that we're not going to d"
9 make the NRPDS -- if I've got the initials right --
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z 10 CHAIRMAN AHEARNE:
You do.
E II COMMISSIONER HENDRIE:
-- mandatory; but in fact 3
I I2 will seek to develop a consolidated, a more effective and 3
5 13 i consolidated system, and what precisely that is remains to be
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CHAIRMAN AHEARNE:
Well, since we're commenting,
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h I7 l out with a proposal to examine the issue; it's not clear wnst 5
3 18 we will make mandatory.
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COMMISSIONER HENDRIE:
Oh, just so.
Just so.
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20 l CHAIRMAN AHEARNE:
And second, we'have been l
21 consulting with INPO, and the letter that we have received 22 f doesn't describe the full story.
23 '
COMMISSIONER HENDRIE:
That well could be.
I have 24 l no way of knowing.
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25 CHAIRMAN AHEARNE:
All right.
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ALDERSON REPORTING COMPANY INC.
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MR. CHILK:
Would you please affirm your votes?
1 2
CHAIRMAN AHEARNE:
Aye.
3 COMMISSIONER HENDRIE:
Aye.
l 4I COMMISSIONER BRADFORD:
Aye.
e 5
MR. CHILK:
Thank you.
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6; The next one is SECY-80-501, Critial Mass Project, E
7 a Petition for Rulemaking on 10 CFR Part 50, in which the Al 8
Commt.ssion has approved the proposed notice, including changes d
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9 recommended by the Chairman on pages 11 and 12, and the change z
Oy 10 recommended by Commissioner Bradford on page 5.
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11 WouLi you please affirm your --
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12 l CHAIRMAN AHEARNE:
I think there is still a question
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MR. CHILK:
There is a question as to who signs l
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2 15 the thing.
The Chairman has voted for the staff to sign it --
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16 CHAIRMAN AHEARNE:
Well, the EDO.
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17 i MR. CHILK:
-- the EDO to sign.
18 l 5
Commissioners Bradford and Gilinsky have preferred l
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19 l the Secretary to sign.
Commissioner Hendrie has indicated he 5
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20l' could go either way.
21l CHAIRMAN AHEARNE:
Then, in a sense, I guess we l l l
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might as well have the Secretary sign it.
I was trying to j
i 23 point out that following 1. 40 (o) that it would have been 24 j appropriate for it not to even have come to the Commission --
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25j MR. CHILK:
I would like to say "so ordered," before l"
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- l ALDERSON REPORTING COMPANY, INC.
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1, we change our minds.
I 2 l' CHAIRMAN AHEARNE:
Yes.
1 3,
(Laughter.)
1 4, I MR. CHILK:
Would you please affirm your votes?
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5 COMMISSIONER BRADFORD:
Aye.
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6 CHAIRMAN AHEARNE:
Aye.
R 5
7 COMMISSIONER HENDRIE:
Aye.
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8 MR. CHILK:
I think the General Counsel may have d
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another matter he desires to bring before you.
Y 10 (Laughter.)
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11 CHAIRMAN AHEARNE:
We will give the General Counsel 3
j 12 l a minute to find out whether or not he does.
i 13 l MR. BICKWIT:
I think the Commissioners are aware E
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of this.
If not, there is going to be some difficulty, b
E 15 (Showing document to the Commissioners.)
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g 16 j CHAIRMAN AHEARNE:
Yes.
I had no problem with the l
17 i petition.
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18 j MR. BICKWIT:
It is a petition for certification --
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CHAIRMAN AHEARNE:
Well, let's see.
I need a vote, x
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i 20 though, and this is to bring up on less Enan one week's notice 21 !
an order in the matter of Pacific Gas & Electric Company.
22 I All in favor of that, say "aye."
i 23 '
COMMISSIONER BRADFORD:
Aye.
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l 24 CHAIRMAN AHEARNE:
Aye.
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l 25 CO!HfISSIONER HEMDRIE:
Aye.
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1 COMMISSIONER BRADFORD:
I'm not sure Joe's " ave" i
2 had quite the right ring to it.
3 CHAIRMAN AHEARNE:
Oh, cone on, now.
We're not 4l coing to start paying attention to the quality of "yes's" and
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5 "no's."
2n 8
6 (Laughter.)
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CHAIRf%N AHEARNE:
Okay, General Counsel.
X 5
a MR. BICKWIT:
The Joint Intervenors have filed a a
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motion for petitioning for directed certification with respect Y
10 to Diablo Canyon.
The Commissioners are aware of this matter, E
i 11 and what the order we have drafted would have the Commission
<t ci 12 deny this motion.
And I understand the Commissioners are E
13 ;
agreeable to that.
E E
14 MR. CHILK:
Would you please affirm the votes?
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15 CHAIR'!AN AHEARNE:
Aye.
t 16 l COMMISSIONER HENDRIE:
Aye.
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i CrMMISSIONER BRADFORD:
Aye.
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5 18 MR. CHILK:
That, I believe, concludes the Eb 19 affirmations.
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20 CHAIRMAN AHEARNE:
All right.
I 21 !
(Whereupon, at 4 :02 p.m.,
the affirmation session 22 l was adjourned.)
23 24 '
25 i
-- OLDERSOM BEBOSSTO%G COXPQ@$% MCo
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s, NUCLEAR REGULATORY COMMISSION i
This is to certify that the attached proceedings before the
.s in the matter of: AFFIRMATION SESSION 80-56 Date of Proceeding:
December 22, 1980 Docket Number:
Place of Proceeding:
Washington, D.
C.
i were held as herein appears, and that this is the original transcr.ipt thereof for the file of the Commission.,
Jane N.
Beach Official Reporter (Typed)
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Offi ial Reporter (Signature)
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UNITED STATES November 14, 1980 NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SECY-80-507 CONSENT CALENDAR ITEM For:
The Commissioners From:
William J. Dircks Executive Director for Operations
Subject:
INTEGRATED OPERATIONAL EXPERIENCE REPORTING SYSTEM
Purpose:
This paper seeks Commission approval of a Federal Register Notice (Enclosure 3). The notice endorses the following actions:
(1) defer rulemaking that would make the Nuclear Plant Reliability Data System (NPRDS) mandatory in its present form; (2) develop for Commission review and approval, an Integrated Operational Experience Reporting (IOER) System by combining and restructuring the NRC Licensee Event Report (LER) System and the NPRDS; and (3) develop for Commission review and approval, a proposed rule and supporting guidance to implement the 10ER program.
Issues:
1.
Whether present infonnation including that obtained in response to the Commission's issuance of an Advanced Notice of Proposed Rulemaking (45 FR 6793) justifies making NPRDS mandatory in its present form.
2.
Whether the existing voluntary NPRDS and the LER system should be combined, improved, and made mandatory in or-der to support NRC needs for operational experience data.
==
Introduction:==
The accident at TMI focused attention on the importance of an effective understanding and feedback of operating expe-rience. Studies of the TMI accident (e.g., Rogovin, Kemeny) emphasized the importance of collecting and evaluating oper-ational experience.
In addition, other studies, particularly a study by the ACRS (NUREG&l2, Review of Licensee Event Reports), identified weaknesses in the existing program and recommended corrective actions. Based on the recommenda-tions contained in these reports, and on its own analyses, the staff believes that the reporting of operational data needs major revision in terms of scope, content, and method of reporting.
CONTACTS:
E. W. Weiss, SD
-)D W c3 443-5913 F. J. Hebdon, AE00
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pn r r UNITED STATES
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WASHINGTON, D. C,20555 OCT 2 91980
- l MEMORANDUM FOR: Carlyle Michelson, Director, Office of Analysis and Evaluation of Operational Data FROM:
Harold R. Denton, Director, Office of Nuclear Reactor Regulation
SUBJECT:
RECOMMENDED IMPROVEMENTS IN LICENSEE REPORTING REQUIREMENTS
REFERENCE:
Memnandum from C. Michelson, Director, AE00 to NRC Office Directors, dated April 14, 1980.
Subject:
Integrated Operating Experience Reporting Program In response to the reference memorandum of April 14, 1980, a memorandum was issued to all of the NRR Divisions on May 28, 1980. The memorandum requested the various NRR Branches. to identify, within their area of responsibility, where improvements are needed in the infomation provided in Licensee Event Reports (LER's).
In addition, the NRR needs for the Nuclear Plant Reliability Data System (NPRDS) have been identified.
Improvements and needs for each of these systems (LER's and HPRDS) are discussed separately as follows:
NPRDS In order to perform systematic reliability and risk analyses of nuclear. power plants and their safety systems, we need reliable ~ statistical data concerning component / system failure rates from operating nuclear power plants. We, there-fore, need the kind of infomation and service supplied by the NPRDS. However, for this information to be statistically significant and useful, it is necessary to ensure consistency and adequate sample size by making the reporting by nuclear power plants to the NPRDS mandatory. In addition to component failure rate data, infomation concerning system status (standby versus nomal opera-tion), cause of failure, repair time, inadvertent ESF actuations and failures per demand is important to reliability and risk analyses perfomed within NRR and should be included in the NPRDS.
LER SYSTEM There was a wide range of response from the NRR Branches to the request for input on the LER system; and, to varying degrees, most found that some improve-ment in the LER reporting system was m:c;sary. These recommendations for improvement lie basically in two categories:
1.
The events that should be reported and, 2.
given that a report must be provided, what informaticn should be included in the report.
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~ C. Michelson For category 1 we have identified certain event areas for which there seems to be no specific requirement for a written report which we deem to be necessary.
These are as follows:
A.
All reactor trips should be reported whether they result from condi-tions caused by failure of safety related or non-safety related equip-ment or are caused by maloperation or transient conditions. Reactor trips which are a known, or purposed, consequence of a test need not be reported in an LER.
B.
Inadvertent actuation of engineered safety features whether caused by-human error or equipment malfunction.
C.
Transients caused by maloperation or equipment failures for which oper-ator action is necessary to avoid actuation of reactor trip or c'gineered safety features.
D.
Events or failures which are reportable under power operation are not necessarily reportable under other modes of plant operation. If these events or failures are independent of the operating mode nnd are not an expected result of a test or maintenance procedure, the event should be reported under any made of operation. The significance of such an event is independent of the operating mode, and itz cccurrence in a non-power mode should not be a basis for not reporting the ~
event.
(Further consideration should be given to this item as to the amount of information to be gained, percentage of time repre-sented, difficulty it presents to the licensee and whether it will provide insight into situations and potential perils during shutdown modes.)
E.
Power System related failures.
1.
Offsite power failure: partial or complete or degradation, dura-tion, root cause, effects, operation of emergency sources, and corrective actions.
2.
Onsite AC emergency power (D/G) failure: root cause, effects, duration and corrective actions.
3.
DC power system failure: partial or complete or degradation, cause, effects, duration, and corrective actions.
4.
D/G and turbine auxiliary systems failure: root cause, effects, duration and corrective actions.
In the past, for operating reactors, the information described above was often lacking or not reported at all due to no technical specifications or reporting requirement specifically addressing these situations.
. Tab A
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OCT 2 9 loSO C. Michelson ~
For category (2) above seural of the recommendations were echoed repeatedly among the various branches. While admittedly NUREG-0161 does provide for most if not all of the subjects of these recommendations in its description of what should be in an LER, there is a severe deficiency in the submittals. There is wide variation in the detail and uniformity of the information provided and the clarity with which it is presented. The following recommendations are indicative of deficiencies in the present reporting system.
A.
Additional space for an expanded event and probable consequences descrip-tion should be provided. The description should include significant sequences throughout the course of the event such as routine and emer-gency operator actions, automatic system actions, disablements or failures, and safety limits exceeded.
It should discuss any abnormal status of affected systems, power supplies (instrument and power equip-ment buses) and power supply load configurations when appropriate.
l B.
Initiating event or root cause evaluation; this should not only state the root cause but describe the reasoning behind the choice. This should include nature and root cause of any procedural deficiencies and personnel errors.
C.
Specific information on failed components should be provided such as:
manufacturer, type, model number, etc.
D.
A description of the repetitive nature of the event or failure should be provided. All previous similar events or failures *sho*ild be identi-fied whether previously reported or not.
E.
An acceptable list of acronyms should be provided for the various plant system functions to avoid as much as possible different names for the same function (such as decay heat removal vs residual heat removal or auxiliary feedwater'vs emergency feedwater).
F.
The generic implications of a failure or event should be evaluated as it relates to other plant systems / equipment or to other plants.
G.
An expanded description of the corrective acticns should lib provided including any interim or stopgap measures. The description should be sufficient to allow staff to assess continued operation when neces-sary.
H.
Code words describing Human Factors problems should be provided in the list of Key Words in NUREG-0161.
I.
The auxiliary / emergency feedwater system should be listed as a specific function becausa of its importance.
J.
Consiceration should be given to providing a coded system related to the Standard Fomat which wculd allow events or failures to be classi-fled in such a way that any particular branch may request from the data bank events or failures related to their area of responsibility.
Fr.closura 2 Tab A
D OCT 2S 19S3
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C. Michelson '
/
It is our conclusion that improvements in the above areas are necessary in the near future-to reduce the time required to process LER's, to improve the data bank for reliability and risk assessments and, ultimately, to improve the reliability of systems and components important to reactor safety.
In the longer term, however, f.mplementation of a comprehensive mandatory NPRD System along with a complementary change in LER reporting requirements should, result in a substantial reduction in the quantity of LER's issued. The LER's which could and should then be eliminated are those related solely to compo,
nent reliability, which the NPRDS would already be designed to accommodate.
As an example, component failures leading to degradation of containment isolation capability would not be reported in an LER. Rather these would go into the NPRD system data bank to be used to assess component, subsystem, and system reliability on a routine basis once the on-line computer processing system analyzing and flagging these data are developed and implemented, and once the National Reliability Evaluation Program has been implemented. This reduction in the more routine type LER's will free the staff to concentrate on items of more immediate safety significance, such as items which may not have been anticipated in the design reviews or may represent deviations from licensing requirements. These changes, representing better coordination of the two reporting systems, should result in an overall improvement in the processing and analysis of operational experiences and assessment of needed safety improvements.
In addition to the above described recommendations, there is a concern that the present reporting requirements in water chenistry do not provide for timely reporting by the li.censee of any significant relaxation in the non-conservative direction of chemistry limits or sampling frequency. Such a requirement should be formulated and established.
It has also been suggested that it would be beneficial to establish an approach which would be similar to the FAA/ NASA system of reporting "near misses." Such a system could be useful in obtaining information on reactor 4
operation anal;gous to the near miss or other information important to safety which would not now be required to be reported under the LER system.
However, this might need to be separate from the LER system to encourage re-porting without attribution. Such a system should be given consideration as to how it could be implemented and as to its practicality and probability of j
success.
~
Haro d R. Danton, Director nOffice of Nuclear Reactor Regulation cc: NRR Divsfon Directors
, Tab A
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SSINS #0720 AUG 2 81980 MEMORANDUM FOR:
E. C. Wenzinger, Chief, Reactor Systems Standards Branch, Division of Engineeri.ng Standards, SD FROM:
E. L. Jordan, Assistant Director for Technical Programs, Division of Reactor Operations Inspection, IE
SUBJECT:
INPUT FOR NPRDS COMMISSION PAPER As indicated in a memorandum to files by Eric Weiss dated July 29, 1980, we committed to submit input to you regarding IE needs for upgraded NPRDS and LER systems which would be used in a comission paper. Our input 1s enclosed.
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P?
ard. Jordan, Assistant Director for/ chnical Programs Divis on of Reactor Operations Inspection Office.of Inspection and Enforcement
Enclosure:
LER & NPRDS Needs l
l CONTACT:
R. W. Woodruff, IE 49-28180
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LER & NPRDS NEEDS
.I.E Licensee Event Reports (LERs)
Although Regul'atory Guide 1.16. Revision 4, was issued for coment in August, 1975, and has not been fonnally issued for use, it is generally being followed by licensees. The LER system as described by Revision 4 is oriented toward reporting violations or near violations of technical specifications, specifically safety limits, limiting safety system settings, limiting conditions for operation, i
and surveillance requirements. These LERs often involve failure of safety-related components.
Where component failures are involved, the LER identifies the component, l
the prime supplier, and the manufacturer. The LER does not necessarily 1
identify the component model and serial numbers and any modifications to the component by the manufacturer, intermediate contracters, prime supplier, or licensee. Further, the LER does not necessarily identify the cause of component failure.
IE reviews LERs to determine the plant specific and generic safety significance of the events described. Based on these reviews, the frequency with which a specific kind of event occurs, and its potential impact on public safety, IE may perform additional licensee, nuclear steam system supplier, or vendor inspections and may issue an order, bulletin, circular, or information notice.
The LER system is essential to rapid and efficient performance of some of IE's functions. However, improvements to the LER system are needed. At present licensees submit written LERs within 14 days or 30 days depending on the significance of the event.
Further, some 14 day reports are so important that they are reported to Congress (abnormal occurrence reports) whereas others are not.
In addition, the importance of 30 day reports range from major to minor. Regulatory Guide 1.16, Rev. 4, needs to be revised to address abnormal occurrence reports as a subset of LERs and to provide a more effective means of categorizing the safety significance of LERs.
Regulatory Guide 1.16 should also be revised to set forth requirements for reporting model and serial ~ numbers for failed componets as well as any modifications to the component which may be relevent to the failure.
If model numbers are documented, IE can determine the extent to which the model is used within the industry, and if serial number are documented, IE can determine whether changes in the manufacturing process have impacted i
the reliability of the component.
Nuclear Plant Reliability Data System (NPRDS)
- NPROS, on a voluntary basis, collecis failure data on safety-related components.
This system overlaps the LER system for a large subset of events.
For the sake of efficiency, this duplication of effort should be eliminated by restricting LERs to reactor incidents involving sequences of events, continuing to restrict NPRDS to single failure events, and making NPRDS mandatory.
If this is done, then IE must receive those NPRDS reports that it now receives under the LER system and IE must receive them in the same time frame.
F.nclosure 2 Tab B
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION E
j WASHINGTON, D. C. 20655
...../
AUG 151980 MEMORANDUM FOR:
Robert B. Minogue, Director Office of Standards Development FROM:
Carlyle Michelson, Director Office for Analysis and Evaluation of Operational Data
SUBJECT:
INPUT TO THE COMMISSION PAPER ON NPROS AND NRC'S REPORTING REQUIREMENTS Enclosed for your information is a statement of AE00 use and need for NPRDS-type information. It is our thought that our statement and those of the other offices would be placed in appendices to the paper as supporting documents to general discussion and conclusions in the paper.
In addition, we are developing background discussion and a description of the combined NPRDS and LER reporting system. This information is still being re-fined.and it should be available for forwarding to you about the end of the month. It is our intent to prepare this information in the fann and manner that it can be directly incorporated into the paper. Thus, we believe the original schedule for the paper's completion should not be affected.
If you have questions, or wish any additional information please contact Fred Hebdon in my office.
Carlyle Michelson, Director Office for Analysis and Evaluation of Operational Data
Enclosure:
J As Stated cc:
C. Berlinger R. Bernero R. Hartfield E. Jordan M. Medeiros M ]L D
2 M ird ao by-L%Y c.nclosure 2 Tab C s
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AE00 REPORTING REQUIREMENTS - NEED FOR NPRDS TYPE INFORMATION
. 1 AE00 has been established and directed to perform in-depth and comprehensive analyses of reactor operational experience.and data and to feedback the lessons of experience to other NRC regulatory activities (e.g., licensing and I&E) and to licensees, industry,'and the public. Consequently, AE00 is establishing procedures and systems to identify and study: (a) individual and often infrequent events which have potential or real significance in terms of plant. performance and public safety; and (b) frequent and usually less significant events and failures which may collectively signify a significant trend or pattern which warrants attention or action.
The comprehensive and in-depth analyses required of AE00 have indicated a need for a number of revisions in requiremen'ts for infonnation and data to be supplied by licensees. In order to focus on significant events and incidents warranting individual and in-depth study by AE00, a number of modifications to the Licensee Event Report (LER) system are indicated. Basically, they are: clear and specific specifications of which events need to be reported; additional technical narrative describing the sequence of the. event; and unique and consistent identification of the equipment involved.
In addition to the revised LER reporting requirements, it is clear that the scope and level of detail of AE00 analysis and evaluation activities require detailed component engineering information and data not contained in LERs.
Such information and data are generally the type now being routinely supplied to the NPRDS by some licensees. Specifically, AE00 requirements for NPRDS-type information are associated with:
(1) Access to the comprehensive and detailed NPRDS Engineering Base.
This engineering information is needed to support AE00 analysis and evaluation activities on LERs and to assure a proper understanding of the significance and implications of an event. The Engineering Base would be used to:
(a) Obtain. technical and proc'urement details on the components in-volved in the in-depth engineering analysis, including the manufacturer, model number, safety class, use in the system, and specific cata such as materialf8and maximum operating pressure and temperature.
'(b) Relate and study specific events in terms of past failures of the specific components involved, including the failure modes and causes of past failures.
(c) Achieve a capability to quickly and precisely determine where the same component is used in other plant systems or to determine which other plants u:e the component (by manufacturer and model number).
. Tab C
Important factors in determining significance of an equipment malfunction are the total number of components involved, the sensitivity of the systems using the-component, and the total number of plants affected.
(2) Access to specific component failures and related surveillance and testing data inherent in the NPRDS. These data are unique and are needed by AE00 in order.to conduct the following analyses and evaluations:
(a)' Trends and patterns of component and system failures and malfunctions. The AE00 watchlist system (see enclosed list) for trend and pattern identification depends upon component level failure data for those items whose failure could poten-tially affect public health ano safety. Specifically, watch-list component performance concerns (500-649) and deficiencies and human performance concerns (750-849) fall directly within the type of component failure information reported under NPRDS.
(b) Correlation of surveillance and testing requirements with opera-tional experience. AE00 has been requested to perform such a study to support the formulation of regulatory requirements.
However, definitive and sufficiently complete data to perform such a study can only be developed using the NPRD System.
AE00 is well aware of the numerous deficiencies and problems existing in the present NPRDS. However, improvements.can be accomplished which will correct these deficiencies and which will provide the data and information required by AE00. The type and detail of information :now required of participants in.the NPRDS are unique and needed in order to conduct the assessments noted above.
A key problem has been the lack of consistent and widespread implementation of the NPRDS by licensees, and unless such participation is achieved, the resulting data and information will have only limited value. AE00 analyses will result in valid and accurate determinati'ns with regard to significance and implications o
of events and failures only if such analyses are based upon sufficiently complete and accurate data. Consequently, we have concluded that mandatory participation is the only practical approach to achieve the needed widespread and consistent implementation by licensees. Many revisions are needed, however, to eliminate redundancy with other NRC reporting requirements and to assure proper under-standing and implementation of the reporting requirements.
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UNITED STATES i
g NUCLEAR REGULATORY COMMISSION 3
<j WASHINGTON, D. C. 20555
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AUG 151980 MEMORANDUM FOR: Eric W. Weiss Reactor Systems Standards Branch Division of Engineering Standards Office of Standards Development THRU:
Robert M. Berr.ero, Director Probabilistic Analysis Staff Office of Nuclear Regulatory Research FROM:
William E. Vesely, Section Leader Probabilistic Analysis Staff Office of Nuclear Regulatory Research'
SUBJECT:
INPUT FOR NPRDS COMMISSION PAPER As we agreed in our meeting of July 16, 1980, I've enclosed seven paragraphs describing needs for NPRDS. If you have any questions, please do not hesitate to call me at 74505.
f f )ly W111 ram E. Vese ection Leader Probabilistic Analysis Staff Office of Nuclear Regulatory Research cc:
C. Berlinger, NRR E. Boyle, MPA R. Dennig, RES R. Hartfield, MPA F. Hebdon, AE00 J. Heltemes, AE00 M. Medeiros, SD E. Wenzinger, SD R. Woodruff, SD
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NPRDS NEEDS 1.
To evaluate acceptability of existing reactors and new reactor designs from the standpoint of calculated accident probabilities and calculated public risks, it is necessary to use prob b11tstic, risk analysis approaches to perform these calculations. Using risk analysis approaches would significantly improve the licensing and regulatory process since accident probabilities.and public risks would be explicitly calculated and would be explicitly used in the decision making process, something which is not generally done now. These risk analysts approaches require i
component failure rate data as input and NPRDS ts the only data system capable of giving the variety and detati required in the component failure rates for risk evaluations. NRC i
programs are underway to develop codified, applicable risk approaches and acceptable risk criteria and NPRDS is required to supply the needed failure rate data.
2.
In order to expiteitly evaluate impacts of safety issues and regulatory decisions on accident probabilities and public risks, it is necessary to quantify these accident probabilities and risks.
These quantifications, which utilize risk and reliability approaches, incorporate the effects of design, component reliabilities, human errors, operational environments, and procedures. These quantifications will allow regulatory decisions to be focused on public risks and dominant risk contributors. In order to perform these quantifications, component failure rate data are absolutely necessary, and NPRDS is the only data system in which this kind of data is able to be explicitly and comprehensively collected on a plant by plant basis. Ongoing NRC programs are deffning the specific areas where risk analyses are to be applied and NPRDS is needed to carry out these applications.
1 3.
NPRDS is necessary to respond to the strong recommendations of the Kemeny report, the Rogovin report, and the TMI Lessons Learned Task Force to evaluate the probabilities and risks of accident scenarios. The evaluation of accident scenario probabilities is necessary to identify and rank the dominant contributors to accident probabilities and risk. The evaluation of accident d
scenario probabilities can be performed on a plant specific basis, and in a comprehensive manner only if component failure rate data collected throught the NPRDS is available. The LERs do not and t
can not provide the detail and accuracy in failure rates capable of being obtained from NPRDS.
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s NPRDS NEEDS CONT.
4 NPRDS is necessary to revise presently established component test intervals and allowed downtimes in nuclear reactors in order to maximize safety system reliability and minimize public risk. Safety system reliability can be calculated as a function of component test intervals and downtimes using reliability approaches and component failure rate data. Detailed and reasonably accurate component failure rates are needed for these calculations and are obtainable only from the kind of collection system in.NPRDS. Ralfability approaches have not 6een generally used in the past for establishing test intervals 1
, and allowed downtimes because of the lack of applicable failure rate data. Consequently, the presently established test intervals and downtimes do not explicitly account for the impacts on safety system reliability and hence public risk. Reliability approaches have been developed, and NPRDS is required to apply ~these approaches and correct the present situation.
5.
NPRDS is necessary to quantify the impacts of human errors on safety system failure probabilities, accident probabilities and public risk. To quantify the impacts of human errors, component failure rate data, as well as human error rate data, must be used to calculate the overall accident probabilities and public risks in order to place the human errors in context. NPRDS is the only data source capable of giving detailed component failure rates so that detailed risk analyses can be perfonned which allow detailed treatments of human errors. These detailed, quantified treatments of human errors will identify human errors which most contribute to risk and will quantify effects of proposed changes on risk.
NRC programs in human error data collection and modeling develop-ment are underway and NPRDS is required to supply the component failure rate data.
6.
NPRDS is necessary to quantify risk implications from failure data recorded at nuclear reactors. Keneny, Rogovin and the GA0 all declared the NRC need to more systematically analyze data for risk implications. The LERs are critical for systematically analyzing data for accident precursors. As a complement to LERs, NPRDS data are necessary to evaluate implications on cal-culated accident probabilities from; 1) individual component failures, 2) time trends such as component wear-out, and
- 3) common cause and human error frequencies - all of which cannot be obtained from the LERs. Data analysis techniques and software are being developed, and NPRDS is reqtired to supply the necessary failure rate input. Tab D
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NPROS NEEDS CONT.
7.
NPROS is necessary for the completion of the IRE 9/NREP programs in which public risks from specific nuclear reactors are calculated and are evaluated for needed improvements. The IREP/NREP programs are critical to regulatory and Itcensing utilizations since they are the first programs to calculate individual plant risk profiles and to explicitly identify risk outliers. For the detailed system unavailability and accident probability evaluations planned for the longer term phase of IREP/NREP, detailed plant specific component failure rates are required which are obtainable only from the collection system in NPRDS and not from LERs.
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
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AUG1 4 1980 4
i TO:
Ed Wenzinger, SD FROM:
Richard A. Hartfield, Chief, L0EB, MPA
SUBJECT:
MPA has several roles in the analysis and use of operating and failure data.
To a large extent MPA is a service organization, in charge of maintaining various data bases and producing both special and routine reports using these data bases and other sources of infonnation. MPA has prime responsibility for the Licensee Event Report (LER) file, the abnormal occurrence reporting system and the bimonthly power reactor events document.
It is mainly in connection j
with the last two programs that MPA has a need for NPRDS type information. To fulfill our role as a service organization, our needs, as outlined below, would r
be best served by a mandatory NPRDS, with changes that include features not now installed.
As part of the abnormal occurrence program, MPA reviews all Licensee Event Reports (LERs) to determine whether or not an abnormal occurrence (A.O.) has happened. The abnormal occurrence program often is the trigger for initiating NRC corrective action. NPRDS will serve as an.important input to the A.O.
program by assisting in establishing whether or not a generic problem is in-volved. NPRDS is very useful for tMS purpose since it was designed to be a component and system failure reporting system.
Power Reactor Events (PRE) is a document that feeds back operating experience to licensees and the industry so that all can benefit from the experience.
NPRDS data will be reviewed and analyzed and PRE articles will be prepared to highlight failure experience and the f.ciTectiw &cticrs t: hen to reduce or eliminate the problem. The analysis of NPRDS data will provide the nuclear industry with an additional source for feedback of operating experience.
In our role as a service organization, we note data user requirements when asked to provide data searches. Many times MPA is asked for detailed component engineering data to supplement the information in the LER reports. That complete detailed engineering infonnation would only be available to us if NPRDS were
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to be made mandatory. Also, since the LER file was not cre&ted as a statistical data base, NPRDS would be the sole source for statistical / reliability data.
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s Ed Wenzinger SD.
The changes MPA would recomend for NPROS are those recomended by the NPROS Working Group. In particular, we think that demand data (success data) and human ermr data should be collected by NPRDS.
If you have any questions on this memo, please contact me on X27834 or E. L. Boyle on X27724.
N O f (A/\\
L R ohard A. Hartfield, Chiek LOEB, MPA cc:
E. L. Boyle
'f J. L. Crooks R. A. Hartfield Tab E i
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 November 7' 1080 SECY-80-501 CONSENT CALENDAR ITEM For:
The Comissioners From:
Robert B. Minogue, Director Office of Standards Development /k fl S
Lvu '
Executive Director for Operations [/y
, Thru:
Subject:
CRITICAL MASS ENERGY PROJECT, ET AL. PETITION FOR RULEMAKING ON 10 CFR PART 50 PERTAINING TO EMERGENCY RESPONSE PLANS FOR NUCLEAR FACILITIES
Purpose:
To obtain Comission approval of the response to the Critical Mass Energy Project petition for rulemaking.
j Category:
This action paper concerns a petition for rulemaking in a major policy area.
Discussion:
On May 9,1979, Michael H. Bancroft, Esq., filed a petition for rulemaking with the NRC (Docket No. PRM-50-23) on behalf of Critical Mass Energy Project and fourteen other citizen organizations. The petition requested that the Comission amend its regulations to improve the licensees and govern-mental ability to cope with radiological dangers following a nuclear accident.
The petition proposed a number of specific rectirements to be incorporated into the NRC regulations. The petition " renewed and supplemented" a etition submitted by the Public Interest Research Group p(PIRG) and others in 1975, which was denied by the Comission in July 1977.
A Notice of Filing of Petition for Rulemaking was published in the Federal Register on June 6,1979 (see 44 FR 32486).
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Prior to that time, the staff had already begun to reconsider t
the role of emergency planning in assuring the continued protection of public health and safety in areas around nuclear power plants.
On July 17, 1979, the Comission began a rulemaking proceeding on the subject of emergency planning and issued an Advance Notice of Proposed Rulemaking, 44 FR 41483. That Advance Notice stated that in its rulemaking the NRC was "also interested in receiving coments on all other aspects of emergency planning, including issues raised in the Critical Mass /PIRG petition..." Id at 41484.
All the proposed requirements in the petition were considered in the emergency preparedness rulemaking process.
Many portions of the requirements proposed in the petition were incorporated into the final rule; some were not. Thus, the
'3 Contact F. Lomax, SD
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443-5966
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