ML20038B979
| ML20038B979 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/1981 |
| From: | Michelson C NRC OFFICE OF MANAGEMENT AND PROGRAM ANALYSIS (MPA) |
| To: | Fraley R Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20038B978 | List: |
| References | |
| NUDOCS 8112090388 | |
| Download: ML20038B979 (24) | |
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1.DV 171881 MEMORANDUM FOR: Raymond F. Fraley, Executive Director Advisory Comittee on Reactor Safeguards FROM:
Carlyle Michelson, Director Office for Analysis and Evaluation of Operational Data
SUBJECT:
LICENSEE EVENT REPORT (LER) RULEMAKING In*its affimation of SECY 81-494, the Commission directed the staff to proceed expeditiously to:
1.'
Defer rulemaking that would establish the Integrated Operational Experience Reporting System (IDERS);
2.
Develop a proposed rule that would modify and codify the existing Licensee Event Report (LER) reporting requirements and would assure consistency with 10 CFR 50.72 which covers the icraediate reporting of sicjnificant events; 3.
Recommend a revised LER rule for Comission approval before the end of 1981; 4.
Endorse the Institute of Nuclear Power Operations (INPO) plan to assume re:ponsibility for the management, funding, and technical direction of the Nuclear Plant Reliability Data System (NPRDS);
5.
Coordiaate closely with INP0 to minimize. duplication between the LER and the NPRDS systems and between subsequent NRC and INPO analysis of NPRD data; 6.
Encourage INPO to assure that the HPRDS recebes, processes, and disseminates the reliability data needed by industry and the HRC to support probabilistic risk and reliability assessment programs; and 7.
Closely monitor the process of INP0's management of the NPRDS and after INPO takes over the system, provide the Comission with semi-annual status reports on the effectiveness 6f INPO management of HPRDS and the responsiveness of HPRDS to NRC needs.
It is anticipated that these actions will produce an efficient and effective system for the collection of operational safety data. For individually significant events, the modified LER system will provide improved descriptions of the entire i
event. This narrativt report will provide the basis for indepth engineering evaluations by the staff and by other interested parties. The revised RPRD System, under the raanagement and technical direction of INPO, will provide relia-
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b.111ty data needed to support various NRC and industry probabilistic risk and reliability programs.
In September 1981, the general cor. cept cf the new LER requirements were discussed with the LER Subcomittee and with the full ACRS as part of a briefing on the current status of AE0D activities. We have now completed a draft of the p'roposed j
LEP rule :nd a dr:ft of the ".cgulattry Guide.
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Specifications reporting requirements associated with Reportable O'ccurrences.
i I request that the, ACRS review these documents and provide their coments to us.
As part of this review, we would be happy to brief the appropriate ACRS Sub-comittee, presumably the Operating Reactors Subcommittee and, if desired, the full ACRS.
4 To comply with the Comission schedule which requires the proposed LER rule be forwarded to the Comission before the end of 1981, it is essential that any meetings with ACRS be held in'early December.
If you have any questions or coments concerning this matter, please call me or Fred Hebdon (x24730) of my staff who has. discussed the ACRS review of these documents with Richard Majors of your staff.
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Carlyle Michelson, Director Office for Analysis and Evaluation of-Openational Data
Enclosure:
As stated cc w/ enclosures:
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Revision 3 50.73 Licensee Event Report System (a) Reportable Events.
The holder of an operating license for a nucl. ear power plant (licensee) shall submit a Licensee Event Report (LER) for any event of the type descr. bed in this paragraph within 30 days (,IE favors 15 days, this issue remains to be resolved] after the start or discovery of the event.
Such events are reportable regardless of the plant mode or power level and regardless of the Safety Class or significhnce of tN itructure, system, or component that initiated the event.
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-(1) Any event resulting in manual or automatic actuation or the need for such actuation of any Engineered Safety Feature (ESF), including l
the Reactor Protection System (RPS).
Actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during surveillance testing or normal reactor shutdown need not l
l be reported.
(2) Any instances of personnel error, equipment failure, procedure
- violation, or discovery of design, analysis, fabrication, construction, or procedural inadequacies th'at alone could prevent the fulfillment' i
of the safety function of structures or systems that are needed to:
l (1) shut down the reactor and maintain it in a safe shutdown condition, or 1
(ii) remove residual heat, or i
(iii) control the release of radioactive material.
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(3) Any event caused by a failure, fault, condition, or action which '
demonstrates an undesirable interdependence between essential structure, components, and systems.
Essential structures, com-ponents, and systems are those needed to:
(1) shut down the reactor and maintain it in a safe shutdown c'ondition, or (ii) remove residual heat, or (iii) control the release of radioactive material.
(4) Any event for which plant Technical Shecifications require shutdown of the nuclear power plant. or for which a plant Technical Specifica-tion Action Statement is not met.
(5) Any event that results in the nuclear power plant not being in a contrell'ed condit}on or that results in an unanalyzed condition.
(6) Any act of nature, event, or act by personnel, that explicitly.
threatens the safety of the nuclear power plant or site personnel in the performance of duties necessary for the safe operation of the plant or the security of special nuclear material, including instances of sabotage or attempted sabotage.
Inreats of violence that are not substantiated by the licensee need not be reported.
(7) Any radioactive release that requires the evacuation of a building.
(8) Any radioactive effluent release where:
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(i) The quantity of radioactive materials in liquid or gaseous effluents released from the site exceeds the limits specified in the~ Techn1 a1 Specifications.
(11)
The q'uantity of radioactive material contained in a liquid or gas storage tank exceeds the limits specified in the Technical Specifications.
(iii)
The quantity of radioactive materials in gaseous waste from the primary coolant system to the gaseous radwaste management system exceeds the limits specified in the Techr.ical Specifica-tions (BWRs only).
(9)
The quantity of radioactive materials released during an unplanned offsite release is more than 1 curie of radioactive material in liquid effluents, more than 150 curies of noble gas in gaseous effluent-s, or more than 0.05 curies of radiciodine in gaseous ef fl uent s.
(b)
Conte _nts.
The Licensee Event Repoi't shall contain:
(1) A brief abstract describing the major occurences during the event, including all component or system failures that contributed to the event and any significant corrective action taken or planned to prevent recurr.ence.
(2) A clear, specific, narrative description of what occurred so that knowledgeable readers conversant with the design of commercial nuclear power plants but not familiar with the details of a parti-
~cuiar plant can understand the complete event.
The narrative description shall include the following specific information:
)
(i)
Plant operating conditions before the event.
(ii)
Status of failed structures, components, or system before the I
event.
T (iii)
Dates and approximate times of occurrences.
(iv)
The failure mode, mechanism and effect of each failed component.
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(v) The Energy Industry Identification System component functio.n identifier and system name of each component or system referred to in the event description.
(vi)
The functioI of the component or system in which the failure occurred.
For failures of components with multiple functions, the licens'ee shall include a list of systems or secondary functions that were also affected.
(vii)
For each failed component, the number of functionally redundant components failures of components with multiple functions, the licensee shall include a list of systems or secondary functions that were als~o affected.
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The Energy Industry Identification System is defined in:
IEEE Std P803/P803A Recommended Practices for Unique Identification in Power
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Plants and Related Facilities - Principles and Definitions.
IEEE Std P805 Recommended Practice for System Classification in Nuclear Power Plants and Related Facilities.
Copies may be obtained from the Institute of Electrical and Electronics Engineers, United Engineering Center, 345 East 47th Street, New York, N.Y.10017.
A copy is available for inspection at the Commission's Public Document Room,1717 H Street NW, Washington, D.C.
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Operator actions that affected the course of the event, including operator errors and/or procedural deficiencies that contributed to the event.
(ix) Automatically and manually initiated rafety systcm responses.
(x) The manufacturer and model number (or other indentification) of each component that failed durir.g the event.
(xi)
The number and types of workers exposed and the dose received by each worker as a direct result of a reportable event that results in a total occupational exposure that exceedsfive man-
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rem.
The. licensee nom *>Tinclude ' exposures incurred in corrective action and clean up..
(3)
An assessment of the safety consequences and implications of the event.
(4) A description of any corrective actions planned as a result-of the event, including those to reduce the probability of similar events occurring in the future.
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(5)
The name and t'elephone number of a person within the Licensee's organization who is knowledgeable about the event and can provide additional information concerning the event or the nuclear power plant characteristics.
(c) Supplemental Information.
The NRC staff may require the licensee to submit specific additional information and assessment beyond that required by paragraph (b) of this
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section, if the staff finds that such supplemental material is necessary for complete understanding of an unusually complex c. significant event.
When such a request is made in writing, the licensee shall submit the l
requested information and assessment as a supplement to the initial LER within the time period specified by the staff.
(d)
Submission of Reports.
Licensee Event Reports shall be prepared on form NRC-XXX and submitted i
to the following recipients within 30 days (IE favors 15 days, this issue remains to be resolved] after the discovery of the event covered in the report:
l (1) The Director of the appropriate hRC Regional Office as shown in Appendix D to Part 20 of this Chapter.
(2)
The Director, Division of Technical Information and.
Doc.umert Control, U. S. Nuclear Regulatory Commission, Washington, D. C.
20555.
(e) Report Legibility.
The reports and copies shall be of sufficient quality to permit legible l
reproduction and micrographic processing.
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(f)
Exemptions.
Upon written request from a licensee, including adequate justification, or at the initiation of the NRC staff, the Executive Director for Operations may, by a letter to the licensee,' grant exemptions to the reporting requirements under this section.
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..o (g) Reportable Occurrences The-requirements contained in this section replace all requirements to report " Reportable Occurrences" as defined in individual plant Technical Specifications S
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1 Revisien 3 11/16/81 Regulatory ' Guide 1.XXX l
t LICENSEE EVENT REPORT SYSTEM h
A.
-INTRODUCTION s
Section 50.73 of 10 CFR' Part 50, " Licensee Event Report System" requires that each licensee-authorized to operate a nuclear power plant provide I
written reports of specific operational safety data associated with events at the nuclear power plant.
In addition to the reporting requirements contained in Section 50.73, reporting requirements are also included in other sections of Part 50; in other Parts of Title 10 Chapter I, Code'of Federal Regulatio'ns; and in ' license Technical Specifications. Reporting requirements applicable to various types of NRC licensees, including identification of the proper. NRC addressee or addresses, and designation of the number of copies required, are compiled in Regulatory j
Guide 10.1, " Compilation of. Reporting Requirements for Persons Subject to NRC Regulations."
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B.
DISCUSSION i
l The Nuclear Regulatory Commission collects data regarding the operational experience of nuclear power plants under provisions of 10 CFR 50.73 in order l
to provide a detailed description of those events that have sufficient safety significance to warrant immediate study.
The Licensee Event Report (LER) is intended to be a detailed narrative description of safety significant events. The LER,provides the basis for the careful study of more serious events that might be precursors to serious
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~ accidents. The LER contains a detailed description of the event and planned corrective action.
If the NRC staff decides that the event is especially significant from the standpoint of safety, the staff may request that the
-licensee perform an engineering evaluation of the event and provide a detailed description of the results of that engineering evaluation.
C.
REGULATORY POSITION In addition to. other applicable reporting requirements of Title 10, Code of Federal Regulations, the following program provides'an acceptable, basis to the NRC staff for meeting the requirements for providing written repors of operational safety data.
1.
Licensee Event Report's
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To meet the requirements of Section 50.73, " Licensee Event Report," the licensee should report the information listed below as soon as possible following an event, but in no instance later than 30 days (IE favors 15 days, this issue r mains to be resolved after the start or discovery l
of the event.
The Licensee should submit as complete a report as possible within the thirty day period and augment that report as analysis of the -
event progresses. The licene,ee should state in the LER if follow-on reports.
l are planned.
The licensee should send copies of the report to the Director of the appropriate NRC Regional Office, as shown in Appendix D to Part 20 l
of 10 CFR; and to the Director, Division of Technical Infonnation and Document Control, Office of Mainistration, U.S. Nuclear Regulatory Commission,:
i Washington, D. C. 20555.
The report should consist of original documents or l
copies that are of sufficient quality to permit legible reproduction and micrographic processing and should be completed using the form specified I
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-in Appendix A to this guide.
Instructions for completing the Licensee Event.
Report (LER) form are contained in NUREG-xxxx [to be issued separately at
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a later:date].
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4 The purpose of an LER~ is to provide the staff with a detailed description l
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of the event and, if required by the staff, a detailed documentation of the
. engineering evaluation performed by the -licensee as a result of an event.
i a.
Reportable Events The licensee will prepare an LER for those events or conditions that meet one or more of the criteria contained in 50.73(a). The criteria are based primarily on the nature, course, and consequences of the event. Therefore, i
events that meet the criteria should be reported regardless of the plant-operating mode or pwer level; and regardless of the Safety Class or signifi-l cance of the component, system or structures involved.
In trying to develop 4
l criteria for the identification of events reportable as LERs, the' staff has concentrated on trie consequences of the event as~ the measure of significance.
Therefore, the reporting criteria do not, in general, specifically address classes of initiating occurrences or causes of the event. For example, Ithere is no requirement that all operator errors be reported.
However, many events, reportable by these criteria will have been initiated by operator errors.
The following discussion restates each of the requirements contained in
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50.73(a) and clarifies the intent of the criterion:
(1) Any event resulting in manual or automatic actuation or need for such actuation of any Engineered Safety Feature (ESF), including the Reactor Protection System (RPS). Actuation of an ESF, including e
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the RPS, that results from and is part of the preplanned sequence during surveillance testing or normal reactor shutdown need not be reported.
This requirement is intended to capture events during which an ESF -
actuates or fails to actuate. This criterion is based on the premise that the ESFs are provided to mitigate the consequences of an accident and, th,erefore, (1) they should work properly when called upon, and (2) they should not be challenged unnecessarily. The staff is interested both in events where ab ESF was needed to mitigate the consequences of an event (whether or not the equipment performed properly), and events where an ESF operated unnecessarily.
Operation of an ESF as part of a planned test or operati,or.al evolution need not be report'ed.
However, if during the test or evolution the ESF actuate in a way that is n.ot part of the planned procedures, such actuation should be reported.
For example, if the normal reactor shutdown procedure requires that the control rods be inserted by a manual reactor trip, such a reactor trip would not be reportable.
However, if conditions develop that require an automatic reactor trip, such a reactor trip should be reported.
The fact that the designer planned that an ESF actuate automatically during an event does not eliminate the need to report that actuation.
The actuations that need not be reported are those that are initiated for reasons other than to mitigate.the consequences of an event (e.g., at the discretion of the plant opeators as part of a planned procedure).
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(2) Any instances of personnel error equipment failure, procedure violatio,n er discovery of design, analysis, fabrication, ' construction, or procedural t
inadequacies that alone could prevent the fulfillment of the safety i
fur.: tion of structures or systems that are needed to:
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(1) shut down 'the reactor and maintain it in a safe shutdown f
condition, or (ii) remove residual heat, or (iii) control the release of radioactive material.
This criterion is also based on the assumption that the ESFs are intended to mitigate the consequences of an accident.. While Criterion 1 above applies to actual demand for actuation of the ESFs, Criterion 2 covers an event where an ESF would have failed to perfonn its intended function if it had been required to actuate. The event should be r'eported regardless of the situation, condition, or failure that caused the structure or system to be unavailab'le. This criterion does not include those cases where a system or component is removed from service as part of a planned evolution, in accordance with an approved procedure, and in accordance with the licensee's Technical Specifications.
For example, if the licensee removes
- part of a system from service to perfom main.
tenance, and the Technical Specifications permit the resulting configu.
ration, and the system is returned to service within the time limit specified in the Technical Specifications, such an action should not be reported under this criterion.
If, however, the licensee takes a component out of service or returns a component to service in a manner that results in a configuration at the system level that is not permitted by the licensee's Technical Specifications, such an event
6-should be reported.
In addition, if, while the component 'is out of
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service, the licensee identifies a condition that would have prevented the entire system from performing its intended function (e.g., the j
licensee finds a set of relays that'is wired incorrectly), that condition should be reported.
l The licensee 1must use engineering judgement to decide if a failure or
_ operator action that disabled one train of a safety system.and might have, but did net, affect tile redundant division, constitutes an event that "could prevent" the fulfillment of a safety function.
If a i
component fails by an apparently random mechanism it may not be re-l portable even if the. functionally redundant component could fail by the same mechanism. To be reportable, the failure must indicate a l
condition where there is a reasonable doubt that the fun'etionally redundant division would remain operational until it complet[its safety l
function.
For example, if a pump fails because of improper lubrication, and engineering judgement indicates that 'there is a reasonable expectation that the functionally redundant pump would have also failed before it completed its safety function, then the failure is reportable.
(3) Any event caused by a failure, fault, condition, or action which demonstrates.
an undesirable interdependence between essential structures, components or systems.
Essential structures, components, and systems are those needed to:
(1) shut down the reactor and maintain it' in a safe shutdown 4
condition, or (ii) remove residual heat, or (iii) control the release of radioactive material.
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The intent of this criterion is-to identify those events where a single failure or group of failures affects redundant or independent portions
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of systems that are important to safety.
Such events can identify previously unreccgnize.d common cause failures and systems interactions.
9 To be reportabie, the event must result in the inability of more than one train or, channel of the affected system to perform its intended.
function. An undesirable interdependence is one that produces a negative' (i.e., nonconservative) synergism which causes a reduction in the ability of either systems or component to perform its intended safety function or causes either system or component to perfonn an action which negatively affects the public health and safety.
In addition, the staf f is increasingly concerned about the effect of a loss or degradation of what had been previously assumed to be non-essential inputs to safety systems. Therefore, this criterion also includes those cases where a service or input which is necessary or essential to the reliable or long-term operation of a safety system is lost or degraded.
Loss or degradation of such services or inputs l
are not reportable if they do not degrade the operation of the safety system.
Th,e failure should be reported only if the service or input '
is lost or degraded at the point of interface between the service or support systems. The failure need not be reported if they affect inputs to systems that are not needed for safety.
This criterion also includes discoveries of undesirable interdependance in which the initiating event is causally linked to the failure of one division of a safety system required to mitigate that initiating event.
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It is just as serious for a common cause failure to precipitate a demand for a safety system and fail one of its divisions as it is to fail the redundant divisions but not trigger the initiating event.
If we model
.an unacceptable accident as (1) an initiatin~g event (2) a failure of challenged safety division A, and (3) a failure of challenged safety division B, then any two of the three constituent events occurring or potentially occurring due to a common interdependence and are reportable.
Finally, the licensee must use engineering ju'dgement to d'ecide when an operator action constitues an undesirable interdependence. Any time an operator operates a component, he could conceivably operate all the
" functional redundant components.
However; to be reportable the operator must actually operate or attempt to operate components in more than one division of an essential system and the result of the act' ion must be undesirable from the perspective or protecting the health and safety l
of the public. The components can be functionally redundant (e.g.,
l two pumps in different trains) or not functionally redundant (e.g., the operator stops a pump in Train "A" and mistakenly shuts the pump dis-charge valve in Train "B").
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(4) Any event for which plant Technical Specifications require shutdown of the nuclear power plant or for which a plant Technical Specification Actien Statement is not met.
This criterion is similar to Criterion 1 abo,ve.
However, in this criterion,the shutdown is a manual shutdown required by the Technical Specification, rather than an automatic reactor trip. The intent is to i
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capture those events where the ' licensee is required to shutdown the plant because it cannot meet the requirements of the Technical Specifications.
For the purpose of these reporting requirements,
" shutdown" is defined as the point in time where the Technical Speci-fication requir'es that the plant be in hot shutdown.
If the condition is corrected before the time limit for reaching het shutdown, the event need not be reported.
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It should be recognized, however, that the i:riterion states, "[a]ny event for which plant Technical Specifications reouire initiation of immediate shutdown..."
(emphasisadded). Therefore, this criterion includes events where the. licensee should have shutdown the reactor because of a condition that violated the Technical Specifications, and either (a) did not recognize until later review that the situation violated the Technical Specifications and, therefore, did not' shutdown; or (b) did not recognize entil later review that the condition existed and, therefore, did not shutdown.
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Thus, operation with a condition that is prohibited by the Technical Specifications should be reported.
In addition, if a condition that would have required a plant shutdown exists for a period of time longer than that permitted by the Technical Specifications, it should be report ed, even if. the condition was not discovered until after. 'the g
allowable time had elapsed and the condition was rectified immediately after discovery.
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j In addition, the licensee shall. report events where an Action Statement contained in a Limiting Condition for Operation is not met.
For Action Statements that give the licensee alternatives '(e.g., repair a specific component or achieve hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) the Action State-ment is met if either alternative is met (e.g., the component is repaired i
or the plant is in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />). Failure to comply with Surveillance Requirements are not considered to be failures to meet an.
Action' Statement.
(5) Any event that results in the nuclear power plant not being in a controlled condition or that results in an unanalyzed condition.
The intent of this criterion is to capture those events where the
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plant was in an uncontrolled or unanalyzed condition.
For example,
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small voids in systems designed to remove heat from the reactor core which have been previously shown through analy=is not to be safety--
significant. would not be reportable. However, the accumulation of voids that could inhibit the ability to adequately remove heat from l
the reactor core, particularly under natural circulation conditions, would constitute an uncontrolled condition and would be reportable.
I In addition, voiding in instrument lines that results in an erroneous l
l indication that causes the operator to not understand the true condition of the plant is also an uncontrolled condition and should be reported.
The staff recognizes that the licensee must use engineering judgment U
l and experience to determine whether an uncontrolled or unanalyzed condition existed.
It is not intended that this criterion apply to minor variations i
in individual parameters, or to problems concerning single pieces of:
l equi pment.
At any time, one or more safety-related component is likely f
I to be out of service--either due to test, maintenance, or a not-yet-rectified fault.
Any. trival single failure or glitch in performing surveillance ' tests could produce a situation in which two or more, ofter unrelated, safety-related components are formally out of service.
i Technically this is an unanalyzed condition.
However, such events should be reported, only if they involve functionally related components or if they reflect significantly compromised plant safety.
Finally, this criterion also includes material (e.g., metalurgical, chemical) problems that cause_ abnormal degradationr of fuel cladding, RCS pressure boundary, or the containment.
(6)
Any act of nature, event, or act by personnel, that explicitly threatens to the safety of the nuclear power plant or site personnel in the performance of duties necessary for the safe operation of the nuclear plant or the security of special nuclear material, including instances of sabotage or attempted sabotage.
Threats of violence that are-not substantiated by,the licensee need not be reported.
This criterion is intended to capture those events where the plant is threatened or damaged by an act, condition, or natural phenomenon, and the threat or damage challenges the ability of the plant to continue to operate in a safe manner (including the orderly shutdown and maintenance of shutdown conditions).
The licensee must decide if a phenomenon actually threatened the plant.
For example, a minor brush fire in
12 a remote area of the site that was quickly controlled by fire fightin,g i
i personnel and, as a result, did not present a threat to the plant should not be reported.
However, a major forest fire, large-scale flood, or major earthquake that present a threat to the plant should be reported.
This criterion is also intended to capture acts by site personnel s
and acts by personnel offsite that intentionally threaten or actually damaged the plant.
The licensec must decide if the act actually threatened the plant.
For example, threats of violence that are not substantiated by the licensee (e.g., bomb threats) need not be reported.
(7) Any radioactive release that requires th evacuation of a building.
In-plant releases should be ' reported if they require evacuation of rooms containing systems important to safety or rooms which may require access for test, maintenance, or conduct of emergency procedures.' Precautionary evacuations of rooms that subsequent evaluation determines were not required need not be reported.
(8) Any radioactive effluent release where:
(i) The quantity of a radioactive materials in liquid or gaseous effluents released from the site exceeds the limits specified in the Technicai Specificaticns.
(ii) The quantity of radioactive materials contained in a liquid er gas storage tank exceeds the li'mits specified in the Technical
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l-l (iii)
The quantity or radioactive materials 'in gaseous waste from the primary coolant' system to the gaseous radwaste management system O
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exceeds the limits specified in the Technical Specifications (BWRs only).
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This criterion,is intended to capture single events that cause the controlled release of a significant amount of radioactive material to offsfte areas.
"Significant" is based on the limits contained in plant Technical Specifications. Such events should be reported regardless of how the release occurred.
Criterion (8)(1) applies only to the Technical Specification limit that applies directly to the quantity of radioactive material in the gaseous
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RADWASTE Management System.
It is intended to capture those events where the quantity of radioactive material from the reactor coolant system approaches the design basis capacity of the gaseous radwaste management system.
Such events are frequently indicative of significant fuel cladding failures..
i (9)
The quantity of radioactive materials released during an unplanned l
offsite release is more than I curie of radioactive material in liquid effluents, more than 150 curies of noble gas in gaseous
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effluents, or more than 0.05 curies of r6diciodine in gaseous ef fl uents.
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This criterion is intended to capture those events that cause an unplanned or uncontrolled release of a significant amount of radio-active material to offsite areas.
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1 b.
Report Content and Format The licensee should prepare the LER in sufficient depth so that knowledgeab1e' readers conversant with the design of commerical nuclear power plants, but not familiar with the details of a particular plant, can understand the complete event (e.g., the cause of the event, the plant status prior to the event, and the sequence of occurrences during to the event).
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The licensee should gather and record information for en LER in a structured l
and comprehensive manner and should'present the information in a clear and l
and concise manner.
The licensee should include the following sections in each LER:
(1) An Abstract:
The licensee should provide a brief (C50 character maximum) abstract which describes the major occurrences during the event, including all actual component or system failures that contributed to the event, all relevant operator errors or procedure violations, and any significant corrective action taken or planned as Thi. requirement is intended to give LER data a result of the event.
e base users a brief description of the event that can be used to identify events of interest.
l (2)
Narrative Statement: The licensee should include in the LER a clear, specific narrative statement of exactly what happened
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during the entire event so that readers not familiar with the details of a particular plant can understand the event. The licensee should emphasize how the plant responded, and how systems components and operating personnel performed.
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problems should not te covered.in excessive detail.
Characteristics.,
of a plant that are unique and which influence the event (favorably or unfavorably) should be described. The licensee.should also describe the event from the perspective of the operator; for example, what the operator saw, did, perceived, understood, or misunderstood.
The licensee should incluoe the following specific information in the narrative description:
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(a)
Plant operating conditions [e.g., pcwer level] before the event.
All Technical Specification Action Statements in effect immediately before the event and all surveillance tests or maintenance activities In progress should be included if they contributed to the event.
(b) ' Status of failed structures, components, or system before the j
event.
Only those componcnts that contributed to the event I
need be included.
(c)
Dates and approximate times of occurrences.
(d) The failure mode, mechanism, and effect of each failed component.
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(e)
The Energy Industry Identification System component function identifier and system name of each component or system i
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l The Energy Industry Identification System is defined in:
l IEEE Std P803/P803A Recommended Practices for Unique Identification in Power Plants and Related Facilities - Principles and Definitions.
IEEE Std P805 Recommended Practice for System Classification in Nuclear Power Plants and Related Facilities.
Copies may be obtained from.the Institute of Electrical and Electronics Engineers, United Engineering Center, 345 East 47th Street, New York, N.Y.10017. A copy is available for inspection at the Commission's Public Document Room,1717 H Street NW, Washington 0.C.
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referred to in the event description.
They should be in'cluded in parentheses following the first referer::e to the component or i
system.
(f) The function of the component or system in which the failure occurred.
For failures of components with multiple functions, i
the licensee should include a list of systems or secondary
. functions that were also af fected.
l (g) For each failed component, the number of functionally redundant components installed in the plant, including the degree of diversity and their availability during the event. A relatively narrow definition of " functionally redundant" is intended.
For l
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l example, if a feedwater pump fails, the licensee. should. report the number of ' additional feedwater puinps, not the total number of l
pumps. Also, this requirement does not include' fur.ctionally i
l redundant components that provide secondary redundancy.
For example, if a HPSI pump fails the licensee should include any other HPSI pumps. The licensee need not include charging pumps which ca,n be used to perform a similar function.
(h)
Operator actions that affected the course of the event, including operator errors and/or procedural deficiencies that contributed to the event.
l (1) Automatically and manually initiate.d safety system responses.
l (j) The manufacturer and model number ('or other identification) of each componerit that' failed during the event.
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(k)
For each component. failure that is reportable to the Nuclear, j
Plant Reliability Data (NPRD) System, and that contributed to j
the event, the NPRD-2 (Report of Engineering Data) and the f
NPRD-4 (Report of Failure) reference number in parentheses i
following the first reference to the component failure. The licensee should review the NPRD-2 for each component identified in an LER to ensure that it is complete, accurate, and up to -
'date.
A revised NPRD-2 should be submitted to the NPRD System if any information is found to be inappropriately omitted or in error.
(1)
The number and types of workers exposed and the dose received by each worker as a direct result of a reportable event that resul'ts in a total occupational exposure that ex'ceeds five man-rem.
The licensee need not include exposures incurred in cor-rective action and clean up.
l 50.73(b)(2)(xi) describes an element to be included in a report of an event that meets one or more of the criteria contained in 50.73(a).
50.73(b)(2)(xi) is not a criterion to be used to, decide if an event is reportable.
..erefore, if the occupa-tional exposure directly related to an event exceeds 5 man-rem but' the event does not meet any of the criteria contained in 50.73(a), the event is not reportable.
In the context of this item, the " types of workers" refers to work and job functions [e.g., reactor operations and surveil-lance, inservice inspection, routine maintenance, special s
maintenance, waste processing, and refueling]. The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLD, or film badge measurements using the same procedures and assumptions'used to prepare the annual' report of personnel (including contractors) receiving exposures greater than 100 mrem /yr.
(3)
Safety Assessment. The LER should include an assessment of the actual and potential safety consequences and implications of the event. This assessment requires judgment on the part of the licensee.
The staff recognizes that any event, no matter how trival, could pose a serious threat to the public health and safety under totally dif ferent operating conditi.ons.
The intent is to obtain an assessment of whether the incident would have been more severe under reasonable and credible alternative conditions.
For example, if an event occurred while the plant was at 15% power and the same event could have occurred while the plant was at 100% power and, as a result, the consequences would have been considerably more serious, then the licensee should c
l assess those consequences. As another example, if an event occurred l
while the plant, was shutdown and the same event could have occurred ~
l while the plant was at full power and, as a result, the consequences would have been considerably more serious, then the licensee should assess those consequences.
(4)
Corrective Actions. The licensee should describe in the LER any corrective actions planned as a result of the event, including actions to reduce the probability of similar events occurring in the future..
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This is not to say that for every event that occurs there must be
'100% assurance that the event will never occur again.' Many events are postulated to occur with some frequency throughout the life of the plant. However, if an event occurs.that requires corrective actions, the ' corrective actions should be described.
(5)
The lice.nske should identify, on the LER form, the name and telephone number of a person within the Licensee's orgnization who is know-ledgeable about the event and can provide a'Bditional information con-cerning the event or the plant characteristics.
c.
Supplemental Information The NRC staff may require the licensee to submit specific additional information an:! assessment beyond that required by Paragraph (b) of this section if the staff finds that such supplemental material is necessary for complete understanding of an unusually complex or significant event..
When such a request is made in writing, the licensee should submit the requested information and assessment as a supplement to the initial LER within.the time period specified by the staff. Usually a written report will not be required in lessthan 15 days from the date of the letter requesting the information.
d.-
Reportable Occurrences 10 CFR 50.73 (g) str.tes that the reporting requirements contained in Section 50.73 supersede the reporting requirements in plant Technical Specifications that are associated with " Reportable Occurrences".
The reporting requirements that.are superseded by Section 50.73 are those
0 reporting requirements contained in the. Technical Specification sections that are usually titled " Prompt Notification with Written Followup" and " Thirty Day Written Reports" The reporting requirements that have been superceded are also described in Regulatory Guide 1.16, Revision 4, " Reporting of Operating Information-Appendix A Technical Specification", Paragraph 2, " Reportable Occurrences".
2.
Reporting P,ersonnel Each licensee should ensure that the person preparing an LER has experience and training consistent with the complexity and significance of the event (i.e., the person preparing the LER should be able to understand the event, and sfiould be able to prepar.e an understandable report).
3.
Quality Assurance Each licensee should establish written quality assurance procedures for LER preparation and for ensuring the systematic review of LERs by the management personnel responsible for plant operations and sa'fety. These procedures should ensure that followup reports are submitted in accordance with commitments made in the original report or when the original report is found to be technically
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incorrect or incomplete.
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licensee Event Report Form Facility Code:,
Docket Number 10:510101ol l Jj Event Date:i IeiI LER number i-y Page: w YYMMDD year sequential revision number number Report Date: is t l-l l i Total number of pages submitted:-
YYMMDD Other facilities involved: Facility 1 1 1 ) [
Docket no. ioisicioici i i g Facilitya i i i i Docket no. no,s,nicio, i i i Facilityi i eii Docket no. no,sioioin,,, i Applicable 50.73(a) Paragraph (s): 30; 0; 3D: 4D; sg 60 O ag; '
Licensee contact:
Name -
Position -
Phone Number - (
)
Area Code Abstract (limit to 850 characters):
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Licensee Event Report Form (Continuation)
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