ML20035C752
| ML20035C752 | |
| Person / Time | |
|---|---|
| Issue date: | 04/05/1993 |
| From: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9304090058 | |
| Download: ML20035C752 (5) | |
Text
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4.
APR 5 1733 MEMORANDUM FOR:
Edward G. Greenman, Director, Division of Reactor Projects FROM:
Cynthia D. Pederson, Chief, Reactor Support Programs Branch
SUBJECT:
REVIEW 0F DRAFT INSPECTION PROCEDURE 93702 AITS ITEM NO.93-159 Per your request, my staff has reviewed draft inspection procedure (IP) 93702,
" Prompt Onsite Response to Events at Operating Power Reactors." We appreciate the opportunity to comment on this procedure.
In general, the draft IP provides insufficient guidance to the resident inspectors on assessing the potential emergency preparedness aspects of a reportable event, as well as incomplete and outdated guidance regarding the residents' role as the initial onscene members of NRC's incident response organization. Although one section of the IP indicates that it is only applicable to reportable events that do not warrant a departure from NRC's normal response mode, a number of the IP's required inspection tasks imply otherwise.
Specific comments, which are more than editorial in nature, are in the attachment to this memorandum.
We will be happy to meet with you or members of your staff to discuss our comments. Additionally, if you or your staff disagrees or chooses not to incorporate our comments, we would like a meeting to discuss our comments.
" Original signed by Cynthia D. Pederson" Cynthia D. Pederson, Chief Reactor Support Programs Branch
Attachment:
As stated cc w/ attachment:
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Attachment SPECIFIC COMMENTS ON DRAFT IP 93702 Section 02.01 Section 02.01 should be revised to also have the resident (s) make the 1.
following initial determinations: whether the licensee classified the event in accordance with the emergency action levels (EALs) in its emergency plan; and, if the event met an EAL's criteria, whether notification of state and county officials was completed, per the requirements of 10 CFR 50.47 (b)(5),10 CFR 50.72 (a)(ii)(3) and 10 CFR 50 Appendix E, Paragraphs IV.D.1 and IV.0.3.
The awareness and responses of state and county officials to an abnormal plant condition depend on whether the licensee declared an emergency in accordance with its EALs. The aforementioned CFR references illustrate the importance the NRC regulations place on promptly notifying state and county officials of declared emergencies. Since state and county officials, as well as NRC, have the responsibility to protect public health and safety, it is important that the resident inspector make initial assessments of the adequacy of a licensee's emergency classification decision and associated notification (s) to state and county officials.
Section 02.01 should also be revised to have the resident (s) make an 2.
initial assessment of the adequacy of the content of the licensee's event report, whether or not the event was classifiable as one of the four emergency classes listed in 10 CFR 50 Appendix E, Paragraph C.
In contrast to state and county response organizations, NRC's responders may be activated whether or not a licensee reported an event as meeting the criteria of one of the four emergency classes. However, the NRC's response will depend to some extent on the quality of the information in the licensee's event report. Therefore, as the initial onscene members of HRC's incident response organization, the resident inspectors should assess the quality of the information provided by the licensee to the NRC's headquarters operations officer (H00).
Section 02.01 should be revised to have the resident (s) make an initial 3.
assessment of onshift personnel's notifications to the licensee's duty i
officer and/or plant management in accordance with licensee policies and procedures. The resident should then give NRC management, through the H00, an initial assessment of the tdequacy of licensee management's response to the reportable event, whether or not the event has been categorized as one of the four emergency classes.
j 4.
Items 02.01.d through f should be revised to indicate that senior regional and headquarters management would have lead responsibility for evaluating the need for or continued NRC response to an event, in accordance with NRC's Incident Response Plan and NRC's directives i
regarding augmented inspection teams (AITs) or incident investigation teams (IITs).
3 Attachment' Section 02.02 1.
This section should be revised to accurately reflect the resident i
inspectors' interfaces with an AIT or an IIT. As written, this section implies that the residents would largely be responsible for determining which event-related information should be compiled, even if subsequent evaluation would be performed by others, such as an AIT or an IIT.
Preferable guidance in this section would be for the residents to assure that the licensee compiles all records related to the event.
2.
Section 02.02.e should state that this collected information should be provided to and discussed with regional radiation specialists.
3.
Section 02.02.e.l(a) should be revised to delete "MPC Factor" since it is not applicable to revised 10 CFR 20.
4.
Section 02.02.e.l(b) should be revised to delete " Direct" since it could confuse readers.
i 5.
Section 02.02.e.2(a) should be revised to state individuals names should l
not be released publicly since names and exposures are 10 CFR 2.790 information.
General Guidance l.
This section shculd be revised to also refer to the "Honitoring Mode" of NRC's incident response, where appropriate.
2.
Although the second paragraph states that IP 93702 applies only to actions to be taken during the " Normal Mode", as described in NRC's Incident Response Plan, many of the " inspection requirements" listed in Sections 02.01 and 02.02 do not imply plant events only associated with a normal response mode.
If IP 93702 is intended to only be applicable to events associated with NRC's normal response mode, this should clearly be indicated at the beginning of the IP. The residents' IP that is-relevant to NRC's other response modes should be referenced.
3.
The third paragraph should be revised to better indicate that regional management will have the lead responsibility for determining the appropriate followup inspection strategy if the resident inspector (s) is (are) away from the site.
i 4.
The fourth paragraph should be revised if not deleted. The paragraph is l
poorly worded.
2
Attachment Specific Guidance 1.
Section 03.01 should be revised to also refer to " Monitoring Mode",
where appropriate.
2.
The second paragraph should reference a relevant regional policy, rather than provide a partial list of reportable events warranting prompt 7
followup by resident inspectors.
3.
The third paragraph should be revised or deleted. As written, the paragraph implies that NRC has no meaningful role in assessing plant safety prior to a restart. While the licensee has a lead responsibility, NRC'i has a responsibility to assure the public's health and safety and should become involved in the restart decision making i
process, as needed.
4.
Section 03.01 includes 'a list of six items which apparently constitute inspection guidance to the residents on prompt onsite actions to be accomplished following a reportable event. The following aspects of each item should be re-evaluated:
a.
The referenced NUREG 0845 is a 1983 document cescribing NRC's Incident Response Plan.
It includes an obsolete version of the NRC's event notification worksheet and an associated, multi-page listing of supplemental plant information needs, which apparently is the "some important parameters to observe" that is mentioned in item 03.01.a. The guidance of item 03.01.a should be evaluated to determine if the supplemental information listing found in a 1983 NUREG remains appropriate guidance to the' resident inspectors.
b.
The guidance in item 03.01.b is incomplete, since it does not indicate that the residents should review the licensee's performance versus all procedures whose implementation was relevant to the reportable event.
I c.
Relevant notification requirements referenced in item 03.01.c should also include 10 CFR 50.47(b)(5) and 10 CFR 50 Appendix E, t
Paragraphs IV.D.1-and IV.D.3.
d.
Item 03.01.d should be revised to indicate that the residents should immediately notify their management of any concerns regarding event categorization, as one of the emergency classes or as a one or four hour non-emergency, as well as any concerns on the adequacy of event notification to the H00 or to state and county officials.
e.
Item 03.01.e should be revised to more clearly indicate the priority associated with restoring redundant equipment needed to maintain the plant in a safe, shutdown condition.
References to
" components that failed or mis-operated" and " restoration of 3
b Attachment safety systems" imply that IP 93702 is also applicable to events which may warrant an AIT or an IIT.
f.
Item 03.01.f incorrectly implies that the-resident (s) will unilaterally evaluate the-licensee's analysis of a reportable event prior to restart.
5.
Section 03.02 incorrectly implies that the resident (s) will be solely-responsible for collecting, reviewing and analyzing all records relevant to any reportable event that required a plant shutdown. Although-the last sentence of the paragraph states that an "in-depth inspection of licensee actions or identified problems should be performed using the applicable inspection guidance", the IP provides no references to the inspection guidance'on assessing the numerous categories of potentially relevant information collected per inspection " requirement" 02.02.
i Inspection Resources
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The statement that the resident (s) would normally need only six hours of i
i inspection time to complete this IP should be reevaluated in view of the numerous information gathering and assessment tasks, as well as communications with NRC management, that are specified in Sections 02.01 and 02.02.
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