ML19350B698
| ML19350B698 | |
| Person / Time | |
|---|---|
| Issue date: | 03/05/1981 |
| From: | Weiss E NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| NUDOCS 8103230393 | |
| Download: ML19350B698 (9) | |
Text
.
fa aeovy
- /
fo, UNITED STATES 8 (*, p
'i NUCLEAR REGULATORY CGT.H.ilSSION A s 1 f lt,,
,g 5,. -
wA:;mNoTon o. c. 2csss
%f..Gr f :y
'v e o-s
...J
/A March 5, 1981
/,fg
)
'\\
4 MEMORANDUM FOR: The Files FROM:
Eric W. Weiss s
4 Reactor Systems Standards Branch
_ #4 Office of Standards Development
SUBJECT:
MEETING Willi INPO REGARDING 10ER SYSTEM This memorandum records for the files some of the key points raised in a meeting betwgen the NRC staff and the Institute of Nuclear Power Operations (INP0) regarding the proposed Integrated Operational Experience Reporting (IDER) System.
Date:
February 24, 1981 Time:
10:00 A.M.
Place:
P-422, Phillips Building, Bethesda, Md.
' Attendees:
R. L. Hauter, INP0 F. J. Hebdon, AE00
- B. J. LaScala, INPO
- C. J. Heltemes, AE00
[
B. L. Cohn, INP0 C. Michelson, AE00
- S. Rosen, INP0
. E. Boyl e AEOD G. Gower IE J. Crooks, AE0D E. Blackwood, IE E. Adensam, NRR R. Dennig, RES J. E. Knight, NRR 4
E. Weiss, SD P. Hungerbuhler, NRR
- part-time
Background:
_ By letter dated January 22, 1981, to Hauter, Fred Hebdon had invited INPO to participate in an informal meeting with the NRC staff in order to help with the early developnent of the 10ER System. INPOrepresentatives(hereafter referred to in this memorandum as simply INPO) were given copies of the draft proposed rule by members of the NRC staff.
NRC staff began the' meeting by bri.efly describing the back-Openi-g Remarks:
ground and events that have led to the current status-of the IOER System's This discussion of the background included mention of the development.
Comission's instruction that the NRC staff proceed as fast as possible in the.
development of an 10ER System (i.e., that the Commission was quite adament that there be no schedule slips). As noted in the meeting, the current status of the development of the 10ER System is that the 10ER Task Group has prepared rough drafts'of the Commission paper, the proposed rule, the statements of consideration, and a very rough draft of the Regulatory Guide that would accompany the rule. The 10ER Task Group plans to send these drafts to the appropriate NRC offices soon. A copy of the drafts will also be sent to INP0
(
i and NSAC for coment at the same time they are sent to the NRC Offices. It was emphasized that participants in.the development of the I0ER System,such as INPO, g
would receive drafts as soon as they.were developed. Therefore, it must be f
81032303 Y h
To: The Files March 5,1981
/'l i
realized that the drafts will not remain static; the drafts will change as comments inside and outside the NRC are factored into the draft documents.
It was also emphasized that there would be many iteiations and revisions of these documents before a final rule would be issued. It was emphasized'that INP0 comments would be appreciated very much at each stage of the process.
The NRC staff described the three parts of the draft 10ER System:
Engineering Data Report (EDR)
Reliability Data Report (RDR)
Engineering Evaluation Report (EER)
INP0 expressed doubts about the legality of requiring the submission of an RDR via a computer terminal The INP0 representatives indicated that this was, in their opinion, a complicated area of-law and they questioned the legal precedent. INP0 also expressed concern about the cost of a computer terminal used to input the RDR data.
INPO also doubts that a utility would permit direct entry of RDR data via computer terminal when there may be criminal or civil penalties involved if incorrect data is submitted, and, thus hard copies may also be necessary.
NRC staff responded that the computer terminal data entry was included in this draft of.the proposed rule in order to reduce the reporting burden and paperwork
. associated with the RDR and in order to improve the quality of data submitted.
[_
If it can be shown that this type of data entry poses a high burden on the
.\\
licensees, the NRC would consider removing the requirement from the rule and allowing submission of paper forms. NRC staff noted that most licensees will
'"~
want to access the data base and, therefore, will have a computer terminal anyway. Also, the computer terminal will eliminate the cumbersome process of
- having to return incorrectly completed forms by mail in order to correct minor typographical errors.- The terminal will cue the ' data entry thus reducing the burden on the data entry personnel who would otherwise have to study and comply with a detailed manual-for data entry. (Note: Subsequent to the meeting, NRC legal counsel gave the informal opinion that the use of computer terminal for data' entry is not only a valid legal requirement but appears to be consistent with the. latest Administration guidance and the recently enacted Paperwork Reduction Act of 1980, PL 96-511.)
~
INPO raised' the question of whether the Sequence Coding and Search Procedure (SCSP) was a driving force behind the 10ER System. NRC staff responded that it was not'and that the-10ER would exist with or without the SCSP.
-INPO asked if plant drawings would be part of the 10ER System. The NRC staff indicated "no".
Development of a technical drawing and plant information file is a completelyLseparate activity.
'y :
a
-,~m
To: The Files March 5,1981 INP0 wanted to know the NRC estimate of the number of-components and systems
'\\
covered by the EDRs. The NRC staff responded that the number of components of data would be about 7500-8000 per plant. This would be an increase of about 2500-3000 per plant over that required by the present NPRDS. However, this expansion in scope is consistent with changes to the scope of the NPRDS already under consideration by the NPRDS subcommittee.
The data from the existing NPRDS can be translated to the new IOER System, so old data need not be discarded.
Reportable Scope:
Discussion at this meeting then turned to the reportable scope of the 10ER System. NRC staff explained that the national standards used to define the reportable scope of the 10ER System were, in general, the same standards used to define the scope of the NPRDS. The one chief addition to the reportable scope is the " auxiliary supporting features" and Safety Class 3.
INP0 expressed concern about the plant-unique systems analysis.
INP0 thinks that there ought to'be flexibility in the scope based upon systems analysis.
NRC staff responded that there is flexibility for such analysis; the rule provides for exceptions to be granted by the EDO. In order to sharpen the definition of system boundaries the NRC staff plans to take full advantage of the work that is being done by the NPRDS Subcommittee and by the IEEE Working Group that is establishing a UNID System.
INPO expressed skepticism about having the EDO grant exceptions fearing that it may be too cumbersome a mechanism in view of the number of systems involved.
NRC staff said they would consider alternatives if they could be identified, but H E00 did seem like the right level of authority because NRR, AE00, IE, RES aad other offices may each feel that certain data gathered by the 10ER System, is more useful than other data collected by the system. Further, it has been the staff's experience that the E00 has been an efficient and expeditious handler of minor amendments' to rules.- If there is something that is cumbersome about rulemaking it is the formalisms such as a Connission Paper that can delay expeditious treatment of minor matters.
INPO made the observation that to a certain extent experience with use of a data collection system such as NPRDS helps to define its reportable scope more than do the associated national standards. INPO emphasized that if the 10ER System is to succeed then it ~must not be _ too drastic a change from the NPRDS.
If the charjes mandated by the 10ER System are too drastic, all of the experience with the NPRDS will be lost and there will be substantial confusion, in fact, chaos. An INPO representative warned, "You cannot allow all of these NRC divisions to say, 'wouldn't it be nice to -collect this and wouldn't it be nice to collect that?'"
INPO observed that the contemplated 10ER System was very complex and it should not be too ambitious in its first incarnation, otherwise people will not understand how to comply.
(-~
To: The Files March 5,1981 NRC staff explained that the development of the 10ER System is going through a careful iterative process that will identify the requirements of the various offices involved and not overstep the bounds of what is reasonable to include in the system. NRC staff explained that it is being very open in this process by giving INP0 the earliest drafts.
Further, in response to INP0's concerns that the IOER System could result in the imposition of increasing more stringent and ultimately unreasonable requirements, the staff indicated that this concern should be at least partially allayed not only by the NRC's openness but also by the use of rulemaking instead of some other techniques such as technical specifications or branch technical positions. Rulemaking offers some assurance to INP0 and others that the NRC Staff will not only hear their point of view but that the NRC Staff will not easily or unnecessarily ratchet new re-quirements on the licensees.
INPO requested that the NRC take a look at the work done by the NPRDS Subcommittee and,see if it covers auxiliary systems, and the NRC staff said that it would.
Engineering Data Report:
The discussion at the meeting focused next on the Engineering Data Report (EDR).
INPO observed that it did not see any reference to an NPRD-type data form in the proposed rule. The NRC staff answered that it had not gotten to the point in' the development of_ the 10ER _ System requirements that it had devised such a fann; it was a level of detail that would come after the NRC staff had developed the rule.
The NRC Staff then made a number of observations about the 10ER System:
The EDR would use both the NPRD identified and the UNID identifier.
The rule, the regulatory guide and some yet-to-be-developed instruction manual represent a hierarchy of detail. All real requirements must be in the rule, but increasingly more detailed explanations would be provided in the guide and
' the manual. System " Demands" have been deleted from the proposed rule although they were contemplated in the draft rule used for purpose of discussion at this meeting. The chief additions to the EDR over the present NPRD are (1) the UNID identifier and (2) the identification of Override Features, specifically.those features that can restore a system under test or maintenance to service upon demand for the system.
In a brief colloquy regarding use of computer terminals, to input data, INPO said it makes sense to have terminals in the plants to permit the licensees to use the data base, and'that is one of the chief reasons for having the capability for remote access.and data entry.
% @F 4
u s
m..
To: The Files March 5,1981 Then INP0 made one of its principal points that was repeated at various points throughout the meeting. INP0 does not think that a statistical data base belongs in a regulatory process which is based on punitive enforcement, and did not want its participation in the meeting to be misinterpreted to mean that it supports the concept of a mandatory 10ER System collecting statistical data.
INP0 believes it can improve utility participation in NPRDS and that a rule will just exacerbate the present situation. INPO says that it has been very successful in persuading the Chief Executive Officers of utilities to do things that are in the best interest of everyone involved. In general, INP0 remains fundamentally opposed to mandatory statistical data reporting.
i.
Failure Reports:
The, discussion at the meeting then turned to the failure data reports portion of the 10ER System that is called the Reliability Data Report (RDR).
The ROR actually includes more than just failures per se; RDR includes improper equipment configuration. The NRC staff explained this distinction and a number of others including how human errors are to be captured by 'the RDR.
The staff and INP0 discussed the question of how much engineering ' judgment would be involved in the IOER System. INPO thought the 10ER System requirements were not prescriptive enough. The NRC staff believed that no matter how precise a rule is written, some engineering judgment will be involved. The staff noted that additional guidance-in the form of examples and explanations will be
(
in the supporting regulatory guide, and the NRC staff requested INFO assistance in selecting particularly illuminating examples for the guide. (Note - at the v
time of this meeting, the drafting of the associated Regulatory Guide had not been completed.)
INP0 questioned whether common-cause failures should be part of the RDR.
NRC staff responded that they should be to the extent that they are known at the time of the submission of the RDR. EER's will, of course, focus more directly on common-cause events and failures. INPO suggested that a computer program could supply common-cause entries to the RDR's.
l Another major point made by INP0 was that the definition of " incipient" failure would greatly expand.the scope of the 10ER System. INP0 understood the objectives of the staff, but was concerned thatinclusion of " incipient" failures would greatly add to.the burden and it would be very hard to get consistent reporting. NRC staff asked INPO for estimates of what it might 4
cost to'run the NPRDS if it were made mandatory. INPO indicated that the only information available was as the result of the January 1980 Advance Notice of Proposed Rulemaking (ANPRM). - The industry responded to the questions in that ANPRM with estimates that " varied all over the ballpark."
To: The Files March 5, 1981 INP0 questioned the "30-day" requirement in the proposed 10 CFR 50.75 (e),
in view of corrective maintenance requirements. NRC staff responded that the "30-day" limit was consistent with the present LER practice, but time periods were still being studied.
INP0 thinks that QA checks of the data are necesst ey and important. NRC staff agreed and plans to have a number of QA checks built into the computer softwa re. NRC also notes that a certain amount of natural QA will result from the NRC and the industry using the data, reading the report:; and so forth.
Engineering Evaluation Report (EER)
The NRC staff began this discussion by outlining the basis for the EER.
The.EER is a consequence-oriented report as opposed to the Regulatory Guide 1.16 requirements, only some of which are consequence oriented.
INP0 questioned th'e "5 man-rem" reporting requirement contained in the proposed 10 CFR 50.76(b)(9).
INP0 thinks that there is a certain circular nature to this whole section. An " event" definition depends on the nine criteria in 50.~76(a). NRC accepted the criticism of the circular nature and noted that the intent of the radiation exposure criteria is largely covered by the existing LER criteria. The NRC staff agreed to reconsider the definition of
" event" in the "5-man-rem" requirement. The NRC staff explained that it was
(
not the intent of the "5 man-rem" requirement to pick up preventive maintenance.
The NRC staff explained that the 10ER System requirements will not modify or affect reporting under 10 CFR Part 20.
INPO also questions the meaning of the word " potential" in 50.76(b)(6) relative to such events as earthquake. The NRC staff agreed to clarify the intent of the section.
Proposed Criteria 50.75(a)(3)
Because of the presence of Carl Michelson, the discussion then returned to one of the criteria for submitting an RDR. He had been instrumental in suggesting the need for this type of reporting criterion and he explained the basis' for the proposed 10 CFR 50.75(a)(3).
INPO contended that the criterion will capture nothing that is not already captured by some other-criterion.
The criterion reads "All system level failures that cause the interruption of a non-essential service or input to a safety system." He explained that in the
. less than perfect world, there have been a number of instances where the loss of non-essential services had serious implications. - The NRC staff agreed to
-re-examine the wording to see if it-could be improved.
.A To: The Files thrch 5,1981 Final Points of Discussion INPO questioned how the NRC staff had reached the conclusion that the I0ER System would result in little if any additional reporting burden. The NRC staff responded that this was a goal and not a conclusion. The staff emphasized, however, it was strongly committed to achieving this objective.
For example, the NRC staff plans to take a random sample of LERs in order to more precisely determine the reduced number and see how many EER's would be required.
Teadditional _ scope of the 10ER is not intended to use up more than the hresources made available by the increased efficiencies gained as a result of the improvements in the 10ER, such as the elimination of overlap between the LER and.NPRDS,_ the reduction in the number of LER's, and careful attention to
.the reporting requirements. The staff noted a recent change in the draft of tne EER portion of the system requires only the abstract, event description.
- and corrective action be reported for all events meeting the EER criteria.
Then, for a select few, the most significant events, the staff would request
- the detailed engineering analysis called for by the rule.
.,2 Eric W. Weiss Reactor Systems Standards Branch Office of Standards Development
,u.
[
.. Distribution. Lis t cc:
Enclosure:
Distribution List b
(
'N 9
L..
mm m
.m.
. m.
.. -..Z..
1
'i..
g 4%
i, 2.m : s a
,dd U l' l'
A
.e oh : p 3
g
,,1 Cr ~p l
- A
' ' d e N ; O& ';n W1.
4 7.,Js to re o h
P' Vt f ti'la U
Fi R Part W 1 re B i g '.
d e Torr.atc, Cy '
S m u o'm/Cm/* -. m hops of dumtic productun. c.
'd'htions in m '
e r v.M N-C"r
.W.
. nder
.e Apcuhural me t;ng
- *g3 ions of 7 a n1. whid c'es
. m o u a 1,y:
& ment Act of 1937 as c.
dp P t before '
- d"C' IS d' a d in.iny r u.,eri s m,p,
, C. 631-C4). The propal w as f
ac sha!! Le publish < d in j yj,,y,g,yg,7, rero nt ended by the IIop
.tv ix B to this part the nore the
-[;ntics in which tomato crop Dated pnury 7.1981.
A ministrative Committee.
pm m.,w,,,.u
,, c,,
& pmM ME wmy h 6
. ara nce
". l Le offered.
m,.oem n, m em.aring rnarlctino. ar is bawd upon a
%n September 26.195
. c Daard of reccmmendatic f the Committee.and
,j
, stars of the red <
Crop fr.nurance f
the folfow% estimates for the "I. oration opp-.ed additional Agricu!tural f.*rghtling Scrvice rnarke$st year beginning August 1.1981.
- U. tics in d '
4 tomato crop insurance MrTotal dcmestic const.mption of be o '.ed.nis proposed rule is 7 CF3 P#)91 r.500.000 pounds of hops:
/
(. nj, to update the list of those (2) minus imports of10SYt000 pounds '
1 i.V, ties as contained In 7 CFR Part 438.
lieprof Domestic Production; of hops to result in domestic g g, oposed S: tab!c Quantity and consumption cf U.S. hops of 31.000.000
' O;
.3 s bn n determined that this artic A!!otment Percentage for th
.31-82 peunds:
arket!ng year (3) lus total exports of 41.000.000
(
@3 mend the list of countics where L
!o crcp Insurance win be ref'.ed AGENCY:Agriculatura.arketing pounus of hops to equal 72.
000 1
ly Ns not constitute a revicw io r.ced.
Service. USDA.
pounds total usage of U.
ps:
Urency, clarity, and effer.eness of Actron:Prcree rule.
(4) plus 1.500M0
. s to adjust for E
'G
.a provisions of wc!ght loss of h processed into p'
k.: e regulations under etary's Memorar.:n No.1055. and SutmAnr is rule would establish the pellets and.ract:
w:
? ~ proving Gover..gnt Regulations qu@ of hops that may be freely (5) pl
.000.000 pounds as an j
a a.N 4-
[11R 50088).
at review will be mWted from the 1981 crop.h action infory adjustment; and
,h
. - Wd - sr to the 'uN t rs.eew f aca enact the nnrtctir; crder for wl rS r : dim
- cnt of 1.779.375 q :> 'j
~ domestic hops to promote orderly pounds to provide for adequate sup.es 4
Inarketing conditions..
should some producer allotment ofbe 1
h h. 'pur,ed Rule DATE: Comments due January 2
.'l fully produced.
h
' g Under the proposal. th. alable '
)O
}
i ADDECSCES:Ccmments Sho" e sent g,
accordingly, pursuant to th.uthority to:Ifearing Clerk. Room #'7 South gannty for 6e pa ~. marketing year 4
.j Duilding. U.S. Departy)nt of cr :tained in the Federal Cr Insurance wu 82 spands.
l :e. as amended (7 U.s 3t 501 et seq.).
Agriculture, Wasp Fton. D.C. 20250.
- F"
- P'
"8' rederal Crop Inse.nce Corporation
?
130 perce is ccmputeo by suot-- ing Two copics of - written materials
- n
- - 3 gmm t h
- rrposes to revise. d reissue Appendix should be s' mitted, and the shall be s Iab!ejuanti41.". 35 e
s to be Tomat. rop insurance Per. s for additanal alle'..ent bases f-made n able nu c c. n at
'8 '
Amendme. No.1.
the o' e of the flearmg Chrk during sr heps of the Fuggle
..icty pursuant M
Eq.!ations TR Part 438] as rc
.ar busmess hours.
to i 991.0a[b) and
.138(c) and dividing the rerr ader by 59270.000 M
4 OR FURTHER INFORY Atl0N CONT pounds the tr of all other allotment
'f Appendix B-Counties Des,y;nat; d for J.S. Miller,Chlef Specialty C bases'.opesalis as follows:
N s
C.nning and Processing Tomato Cr Branch. Fruit and Vegetab' ivision.
The m 7, 1:surance-7 CFR Part 433 AMS, USDA. Washing D.C. 20:50
^.219 Anotment precentage and
@q l
' In a ccordance with the pr-s!ons of 7 (202) 417-5053.The ~.al lmpact
. b!e quant!ty for hops during the CTR 438.1 the fo!!owinI nties are Staternent descri'..g the options
.a consa.cred de.oping this proposal e market;ng year beginning August 1. P as y
dm.gnited for cannin
.id processing
{ j !=.ato crop insurap.
Is avail?.e on request from J.
. i!!ct.
ciarketing year begmnina egust 1.1981 4
e the impact implementing each o.on The a,Jotment percentage,. ig the g,
sum erNTAnyinFOnuAT:.This d'U l'
- P"C'"I' '
O S W'
- E [('*
~ h",If#"
pr',osal has been revies under qu ntity shall be - 279.375 pounds.
g I Wred Sauer -
DA pf0Ced'fCS ESt~.iShed in Datei Jant 12.1981.-
'Q
{,5'"
M rJer Yr.la,
, Secretary's Me mor oum 1955 to D.S.K 4
g "o
Implement Exec.ve Order 1314 and Ar ah ctor. Fruit end l'eptc*!e
%J 5
has not bcen assi' icd "significant".
Mon M
' j De propo is bcIng published with -
m ue renes et U
O.*
less tha a 00-day ccmment period euwa coog uto-os-as
@M TW o"r beca' e handlcts and growers s. soon -
p'N N ""
',2 be..aking preparations for F.dling and O
[#
owing 19a1 crop hops.
. refore, they NUCLEAR REGULATORY L
h;f i
N s.r,0s.sta. Pub 75-430. 52 Stat. r2. as must know soon as po. ole what COMMISSION :
e
, *=nded p U.s. isos.1516J1 salab!c quantity an dotment E2 markettng
.r so they can plan their g]
gg g@y I
%S. r1Y.crion wi:1not hase a precentagg will b ifective for the 1901-10 CFR Part 50 eMeent impact eper.ifict!!y en ar-p or
, owJty devetepment; therefo. resfew as operatwns cordingly.
pg rmired t'y OMB Circu'ar A-95.s Ec
. ased quantity and allotment ACCNcr.Nuc! car Regulatory n '-s t
h;;ficable.
percent, gehould be established in Commission.
M l
NM L
P00R ORIGINAL
~
' $q a
- wuj w
Q
% h@ f. g; m g v 9 m = T; y ga m e"N maeh n+%+ mtw y % % + #
ws,.
gmy 1-v
_ gg e e_
?W# 1
.r m
' ggq
_ m 7 ; g
,4 '
j%, c j d r.p s.g gf f:Q }y!-
.w.w'ZY Q)h
- $&e e + 7m v _
- v i
%W % ' 3% %lr - 4 p
" " 'g
.e..
.y-R h ~ 'M w,,??
2
,y
~
9t2 rederal Reg ict /, c1. 4G. No.10 / De! 1. l.
L L
_=.m==r====2==
a ct: rent inh r.ts to
<, of t
tenotc Advance nothe of propm d accepted industry generati d t !a
.2 e s.
cquipnent, utilitit s ha e intt p ted ps
- 7. D
- ing wb a il niical i
na r. Ming: response to comments.
there claues ddferently w!mn as are insMbt t
a era suman After resicwing cer,ents dmrmining sp cincally whit h 8 Rr!/ ag current f aib s to p:cdons wnconing aT.cndments to NRC components shou!d be irtladed in the tesung.
rqula!Icns that would require puwer NPRDS. For examp!c. the number of
- 9. IssMng Abnermal Om.rrence reactor licensacs to submit data to the components reported by various plants Nuclear Phint acliability Data System varies from 1500 components per plant Reports.
- 10. Issuing Operating Experience
[NPRDS). tne NRC has decided to defer to almost 5000 components per plant.
Journal of " Power Reactor Events."
rulemaking that would make NPRDS 2.The procedures manual for NI>RDS mandatory in its present form. The NRC is not sufficiently detailed or specific Licensee Event Report Systcm (LER) p!ans instead to deve!op a single (nough to ensure consistent repoiting of N " * "fE'Ud*"
Y 3#
8 reporting system by combin!ng and engineering data and failures.
submatcd in calendar year 1979 nnd the of NPRDS does not number is espected to steachly increase restructuring the NPRDS and the NRC's 3.The scor own reporting system, the Licensee include all component, ofintc rest (e g.,
as new plants be,n em,aMn.
Event Reports (LERs).The new report. g ASME Safety Class 3 components, Reuew f *heye 1ERs mdicates a m
s3 stem will be cal!ed the "htegrated balance-of-plant system, vessel number of deficiencas and 0,nerationalExpericace Reporting internals, and ccitain si.cs ef pipes and sh rkommgs such as:
"'p n nt and system codings are COER) System." The NRC is seeking valves).
I'
- 4. Data on successes are not int usknt and nonuniform.
ge: eral comments on an IOER system adequately reported. Consequently,
- 2. Ody a suge fauure can be,te the concept at this time.The NRC will request rnore detailed comments on the failure rates are afficult to determine included in the coded fitids despi forthcoming proposed rule when details accurately' fact tat a smgk esent my inMe of thi system are developed.
- 5. Participation is low and, thus, data m re than one component failure.
cf t eifa rm is h
cAn.s: Comments rcteind Ar \\
h.
va at'- m,rs 8.
3en 2.1981, will be considered if it is. ferc
- 6. Alarge percentage of the data orienU kQ compdcrked data practical to do so,but assurance of
. reported to NPRUS duplicates that processir:g of a single component failure i
consideration cannot be given except as reported to the LEID system.
rather than towr.rd.a technical, to comments filed on or before Mt.rch 2, 7.There is no consistency n engmedmg analysis of the event.
i equ!pment and system identification 4.ne scope does not include all Cencral commer.ts may be from plant to plant as reported to systems import ant to safety, for W 1-sent to: Eric W. Weiss, Office of NPRDS. Consequently, data are difficult example. failures of so called ADDRcSS:
Standards Develnpment, U.S. Nuclear to correlate accurately, "consafety" systems le g., mest centrol
- 8. Data on test / maintenance air systcms) that chaHenge safety Regulatory Commaswn. % ashmston, un2vai! ability are not adequately sy stems are not included. As a result, D.C. 20555.
events ofinterest are escaping the roa F1JRTHER INFCRM ATION COflTACT:
reported.
The NRC staff, on the ethee hand, has system.
Eric W. Weiss (301) 413-5913.
ident!Ued a strong need for probabilibtIC 5.%e scope covers components only SUFFLNEtiT ARY INFCRM ATION:The and detailed engineering data similar to while in technical specification (i.e.,
O present Nucle at Reliability Data System that reported to NPRDS.The staff need normal) service, and defects found
[NPRDS)is a voluntary pregram for the ' for probabilistic and detailed during nontechnical specification reporting of reliability data that was engineering data is asrociated with the inspections or during shutdowns are not y'
, j described in the Advance Notice of following types of activities:
reported. For example, no LER is I
Proposed Rulemaking (ANPRM)
- 1. Performing probabdistic risk required for failure of a low pressure h,
published on January 30,1930 (45 FR '
assest.nent calculations of accident coolant injection pump while l>
6793).That ANPRM also described the.
probabilities and public risks.
~
- transferring water from the torus to the historicalbackground for the proposal to
- 2. Revising component test intervals radwaste system, or fai!ure of a charging
?
make the NPRDS a mandatory system.
and allowed downtimes.
pump being used to hydrostatically test
%e ANFRM invited public comments
- 3. Quantifying the impacts of hurnan a pipe weld repair on 21 specific features being considered
- 6. Many events that are not
- 4. Identifying trends and patterns in individurdly significant are reported, for a' proposed rule.
crrors.
Although these events may be important g
To date 44 public ccmment Iciters
. operating experience.'
because of their frequency of occurrence '
M d.
have been received in responsa to the
- 5. Obtaining detailed component or because they indicate trends and Q
ANPRM. A detailed anal sis of the engineering information.
patterns.they tend to distract from the 3
comments is available for inspection N.J and copying at the NRC Public
'Desenbed in NRC Regulatory Cc1Jc1R fCw significant events that require A
Document Room 171711 Street NW.,
Erponds of Omug MetWAppediz A detailed engineering analysis of indepth lk([
Washington, D C.%e predominant
"$'I 8 f,'
[
),pyg,
' study. For exampic, a high percentage of l
LERs tend to be concerned with theme in the comments was an overwhelming opposition to making nJ.bteirae us.Nate.c Reg rory instruments out of calibration.
comminion. wa wan, o c. rens.nc t.ER participation in NPRCS rnandatory.
entcm was desetopeJ io pmaJe a centrataco -
Consequently, the staff has recognized I'
received and all the technicalIssues
- /fl"'""j'
- (;.g,ra,-
that major revision of the LER system is After considering the comments also warranted.
involved. the NRC finds that the NPRDS irrmed Report.bte occunvr.ces. must t.c trported to as now implemented docs not fulfill ucmpgies a st.nn kna rw. mar Intga,mg (Operational Expcn.
the hRC es rtpred by teshnical sper.bhans ted ence NRC objectives because of a number of a a munt ntwt fmm the Report IOER) System.
H" pee unt m fundamental deficiencies:
Aduwry Comrattee on Reactor S.fgards to the in order to obta.m the necenary
- 1. Although the reportable scope as commi,,;,,,-Kedew of uance r. cat repoes improvements in the LER and NPRDS defined relics on the use of existing (tro-tr8F NrRrc m:. september me.
(i P00R ORIGINAI.
~
, er -
s.
~ = - -
m
~
!ct / Vol. M ','c
..iry 15,1N1 / T,
s 3313
.m g
(
e d-
.'aff Fns m tepta'.h 7
/ i;wnLiion ACTION: IMr I me for co:r n i nts g, pri ' ; ; m,'
u de r!r p d wnu / My a imsed w uld be pre unmi '
., Ned on NFR5!.
(
report;ng program Thr Integrated Brplatory CuMe < ~ % LER's and I
1 og iatEnallhpeQ r:r.e Rt;)crting the NI RDS t3pc fMi e repc-ts.
SWN A h, * 'I P'"P"5"d(IOLR) Sp?cn would:
In deu !cping the integated reporting Rule k nq FRNf) w a$ published in
- 1. Redac I ER repuiting by sptem. the deficiencies out!!ned for the O
"' D "
I" chminating the requ!rement for LER NPRD and the LER systems would be
- 9P malfanttions cm cred by the NPRDS.
specifically addressed. Far example:
AI"i. inns Dayctp"W" which reports for most con:ponent failures or p
- 1. In order to assure consistent
'f The NRC would require LERs only for identification of components and
- y"cjjcfj'" c(3f[,
thme wmponent failures or.
syst< ms, the Regulatory Guide to be g
ma! functions that are of major safety derclep. d will incorocrate a suitable bod} skin tear str.v ~ The FAA has cor tc nt fe c t oIb b
en fr te n e i nt s
s e!
d s ubstantially improved by requestm.ga tnhnied'y deta%d and comprehensive by TVA for nuticar p! ant components S
Afarch 1.19r. to al!ow commenters t me
- eport suitable for engineering rcs few.
'"'d 5}[RDS-type reports would be i
m S-t co:aplet their responses.
- 2. NI nus, the !.ER s) stem, w hich was not DATrs:
.e new deadline for com: rents designed to produce rdiability data, wquired for fai!nres of all equipment is Mar-1.1981.
w ould no longer attcmpt to provide a "P ^ ""
- 4 ncal, mohng ADD SScS: Scad comments on the basis for equipment reliability studies; watu. wa m Mr. e c];
e nnat wW simplified data prr gsed rule in duplicate to: Tedcra the NPRDS, which is designed to mAas e rap n
fation Administration. Neithue l
produce such reliability data, would entry and winputerized data processing.
e Info manen n sucass rates w H se ion, Office of the Regional Cc. sel, I
perform this service.
required to permit the determmab,be Attention: A!rworthiness Rules socket.
- 2. Require the reportira ofless on of significant component failures er minnt appropriate and accurate failure rates.
Docket No. 60-NW--t%AD, tr 0 East iaddat c',uts by rncons of a 1 pe.
3 ^" ' 9 0 d 'n3 d4Id fi!C* Sd3ddf IO gg n,gg, g m,
3 computer-oriented form. The reportable that now included in NPRDS, wdl be Wahington 98108.
scope, howcver, would be extended to contmued.nese files contain ron rusrHcn INrcanAT-9 cont ACT:
include all systems and components that information on each component % the hfr. Richard IL Yarge Airframe Dranch, are important to safety including,
reportable scope, includmg ANW-120S. S attle.ircraft I
selected support and service systems manufacturer, model number, and Certification Area frice FAA and components.The reporting fo m enhcal operating and dimensional Northwest Rqi 9010 East Ef arginal would be simplified for case of data paramaters. The LER and NPRDS Way S S.ule. Washington 93t08, entry by nonen pncering personnel and reports x:l! be linked by reference to the telephone ('.) 767-251tk would allow failure rates to be engineering file for im o!ved SUPPLE W TARY INFORMATioec The determined to support NRC and industry components.
Federa mtwn Administration issr statistical /probabilistic studies.
.N'e f Proposed Ru!cmaking (>
3M 4 on Nos ember 10,1980, pro s, FR Schedt518 y
%us, for signifn ant events, an LER mg and associated component failure The NRC plans to develop the def a!!s a m Aira ortHnges D;rective
.ich reports would be submitted. For less of the proposed Integrated Operational ould rpqu,re penodic ultrae nic i
signifkant Incidents and failures, only a Fxperience Reperting (IOER) System.
Inspection, and repair as r essary, of component failure report may be publish the details as a proposed rule, Boemg hfodel 727 cold b..ded upper necessary. The clear intent is to and imite comments on that proposed b'ody skin tear straps..ese straps i
eliminate duplication between the two rule. ne NRC estimates that the perform a structural silsafe function in
{
systems.We espect that there would be proposed rule will be av.dlable far the 727 cabin pres <.re vessel.
no significant increase in the~ resource's - public comment in July 1981.
Doeing and th. ir Transport needed to implement this system over ~
Deed at Washpon. D C. this rth day of
^88 C "UC" UI merica believe that the that needed to properly impicment the pnuary.1m1.
safety of the ab'in pressure vessel can present LER and NPRD systems. Further.
For the & clear REgu!atory Correnission..
be assured y other,less f nancially, we believe ll at the Implementation of burdesorr.. rr.ethods than those the revised LER system is a natural jb function and is easily within the S""#CO #l## C0*###'I" propose to be made mandatory in the NPRM ocing has nrgued that Service -
I capability of the site engineering groupa th'W"N N"*"I Dulb al 727-53-82, on which the -
estabbhed to review operating -
s w coscru m s
pre,osed AD is based. should be.
experienc4 hus, no changes appear -
necesssry th organization for cach plant
'_ r.ssessed in the light of the ten year i d
ersice experience which have eh acd site to impicment the revised system. _
DEPARTME.4T OF TR
- SPORTATION since it was originally publishe c!n2 -
and there shou!d be no signif,1 cant needs is currently making such a rer :.essment for training.
Federal Aviat!on ministration as a comment to the NPRh ocing has The revised reporting requirement would be imp!cmented through rule-14 CFR Part 3 soucited service experie
.e data from making to assure uniform requirements, domestic and foreign 7 e operators, and is evaluating possib' additional tests to efficient utilization of staff resources, IDocket No.
NW-89-AD]
and adequate review and comment The Verify the capabili y of a partially regtdation would contam the pnnciples Airwort.necs Directives; oeing djsbonded tect rap. %e additi d to complete th,onal or critona licensees would use in Mode,27 Serics Airp!a s.
time is reque is effort.
neFAA co.;nizes a need for better
-l deciding whether an LER or a failure AC CY: Federal Avir on guideline or proper malntenance of 727 '
report is required. Additional details on As ministration (FA.. DOT.
tear st
,s and considers reassessment POOR ORIGINAL w.w.w w g e=*W
'ee,M-d-Ne==tig-M" fp]7 M*9d
%M-