ML20053A068
| ML20053A068 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1981 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1932, NUDOCS 8205240509 | |
| Download: ML20053A068 (9) | |
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MINUTES OF THE ACRS SUBCOMMITTEE MEETING 0N REACTOR OPERAT D S
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DECEMBER 8, 1981 3
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The ACRS Subcommittee on Reactor Operations held a meeting on Decemb in Room 1046, 1717 H Street, N.W., Washington, DC. The purpose of the meet-ing was to review a proposed rule dealing with the Licensee Event Report (LER) ^@
System. This proposed rule (10 CFR 50.73) was brought to the Reactor Operations Subcommittee and full Committee for comments prior to receiving Commission ap-proval to release this proposed rule for public comment.
The meeting was en-tirely open to the public.
Notice of the meeting was published in the Federal Register on Monday, Noverrber 23, 1981. A copy of the notice is included as Attachment A.
A list of attendees for this meeting is included as Attachment B.
The schedule for the meeting is included as Attachment C.
A list of all ref-erence material for this meeting is included as Attachment D.
A complete set of meeting handouts has been included in the ACRS Offi:e files.
The Designated Federal Employee for this meeting was Mr. Richard K. Major.
CHAIRMAN'S OPENING PEMARKS Mr. Mathis, Subcommittee Chairman, opened the meeting and noted the purpose of the meeting was to discuss a proposed rule and regulatory guide dealing with the Licensee Event Report (LER) System prior to its being presented to the Commission for their approval to be published for public comment.
He also noted that representatives from the Institute of Nuclear Power Operations (INPO) were present and would present their comments on the pro-posed rule and regulatory guide.
NRC STAFF INTRODUCTION - J. Heltemes, Deputy Director, AE0D The LER rule will modify and codify the LER reporting system.
It is hoped that the rule will produce consistent requirements applicable to all plants.
Another aim of the rule is to produce fewer LERs, but to improve the quality and detail of the reports submitted. The NRC Staff believes that the total level of effort required to comply with the new LER requirements will be no greater than the total level of effort required to comply with the existing LER requirements.
It is expected that the total number of reportable events will decrease by approximately 50%.
However, the amount of effort required to prepare an LER will increase.
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REACTOR OPERATIONS NRC STAFF BRIEFING ON THE PROPOSED LER RULE - Fred Hebdon, AE0D Mr. Hebdon explained some of the problems with both the current LER system and the NPRDS (Nuclear Plant Reliability Data System).
Troubles with the present LER system include the fact that the reportable scupe does not in-clude all events of interest; event descriptions are often limited in scope and depth; and the reportable scope includes components only while in technical specification service (e.g., equipment failures during plant shutdown are not reported).
Probelms with the NPRDS include the fact that the reportable scope is subject to varying interpretations, the reportable scope does not include all components of interest, and utility participa-tion is low.
INP0 will assume responsibility for funding and technical direction of the NPRDS in January 1982.
NPRDS is designed to produce a data base on component and system reliability.
INPO will evaluate utility parti-cipation in NPRDS during their routine management and plant audits.
It was noted that the abnormal occurrence reporting system will not be affected by the LER rulemaking.
Mr. Ward asked the Staff if NPRDS will be able to track human reliability or software errors made in programing. The reply was it would net unless it had in impact on component reliability.
Subcommittee members stressed this sort of information would be worthwhile to record. Mr. Hebdon did note that events that adversely affect the plant are reportable in the LER system no matter what the initiating cause. A software error that adversely affected the plant would likely show up in the LER system.
Mr. Ward-also wondered why it was more important to have a data base on equipment failures than on personnel failures.
He asked if someone has come to the conscious conclusion that equipment failures are a greater risk to the public health and safety than personnel failures.
The Staff responded that it was not a conscious decision, and noted some discussions with INF0 about the possibility of developing a system analogous to NPRDS associated with the operator's performance.
4 REACTOR OPERATIONS SQHEDULE FOR RULEMAKING The NRC Staff presented the current schedule for rulemaking to the Subccmmittee.
The current schedule for rulemaking is as follows:
- 1) Proposed Rule to the Commission - December 1981
- 2) Public Comment Period and Evaluation of Comments - Begin early 1982
- 3) Final Rule to the Commission - August 1982
- 4) Final Rule Issued - October 1982
- 5) Final Rule Effective - Late 1982 REVIEW BY THE COMMITTEE TO REVIEW GENERIC REQUIREMENTS The NRC Staff outlined the plan for review by the NRC's Committee to Review Generic Requirements (CRGR). The Committee to Review Generic Requirements has not reviewed the proposed rule at this time.
They did recommend the proposed rule go forward to the Commission, and that appropriate offices prepare an outline of various existing and proposed reporting requirements associated with reportable occurreces and a plan to assure their coordination.
The CRGR will review the actual content of the rule after the public comment period when they have the benefit of industry comments,.but before the rule is submitted.to the Commission in final fonn.
PR0p0SFD PLAN TO ASSURE C0 ORDINATION Before submission of the fiial LER rule, AE0D and IE will ensure that the reporting rquirements of'10 QFR 50.73 (the LER rule) and the revised 10 CFR 50.72 (notification of significant events); NUREG-0654 (Criteria for Preparation ar.d Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants); 10 CFR 73.71 (Reporting of Physical Security Events) are consistent.
The LER rule and the notification of significant events will be combined into a single rule.
The Staff will publish a revised 10 CFR 50.72 and the final 10 CFR 50.73 in a combined package that cross references the requirements.
Soon a, ter the issuance of the final LER rule, NRR will administratively revise all plant technical specifications to remove the requirements associated with " reportable occurrences."
P REACTOR OPERATIONS BITERIA INCLUDED IN THE PROPOSED RULE THAT DEFINE THE EVENTS REPORTABLE THROUGH THE LER SYSTEM There are nine situations,which will require an LER be written. These are:
- 1) Any event resulting in manual or automatic actuation or the need for such actuation of any Engineered Safety Feature (ESF), incuding 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 be reported.
- 2) Any instances of personnel error, equipment failure, procedure violation, or discovery of design, analysis, fabrication, construction, or procedural inadequacies that alone could prevent the fulfillment of the safety function of structures or systems that are needed to:
a) Shut down the reactor and maintain it in a safe shutdown condition, or b) Remove residual heat, or c) Control the release of radioactive material.
- 3) Any event caused by a failure, fault, condition, or action that demonstrates an undesirable interdependence associated with essential structures, components, and systems.
Essen-tial structures, components, and systems are those needed to:
a) Shut down the reactor and maintain it in a safe shutdown condition, or b) Remove residual heat, or c) Control the release of radioactive material.
- 4) Any event for which plant technical specifications require shutdown of the nuclear power plant or for which a plant technical specification action statement is not met.
- 5) Any event that results in the nuclear power plant not being in a controlled condition 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 per-sonnel 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 l
sabotage.
Threats of violence that are not substantiated j
by the licensee need not be reported.
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- 7) Any radioactive release that requires the evacuation of a i
building.
g REACTOR OPERATIONS 8) Any radioactive effluent release where:
a) The quantity of radioactive materials in liquid or gaseous effluents released from the site exceeds the limits specified in the technical specifications.
b) The quantity of radioactive material contained in a liquid or gas storage tank exceeds the limits specified in the Technical Specifications.
c) With respect to boiling water reactors only, the quantity of radioactive materials in gaseous waste transferred from the primary coolant system to the gaseous radwaste management system exceeds the limits specified in the technical specifications.
- 9) Any event for which 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 effluents, or more than 0.05 curies of radioiodine in gaseous effluents.
COMMENTS FROM INP0 - Steve Rosen Director of the Events Analysis Department of the Institute of Nuclear Power Operations In general, Mr. Rosen believed that the proposed rule was an improvement over the existing LER system.
He noted INPO and AE00 have had a series of three meetings to discuss the proposed LER system.
The proposed LER system requires reporting of any event which results in an unplanned actuation of any Engineered Safety Feature, including the Reactor Protection System.
INP0 believes these events should be trended and analyzed, but should not be singled out as events of special significance.
INPO notes l
that reactor trips are already being reported by the licensees in Monthly Reports to the NRC as required by Regulatory Guide 1.16, " Reporting of Operating Information." INP0 feels that ESF actuations that occur as part of an unplanned sequence, are still within the design envelope of the plant.
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They are' anticipated operational occurrences, and INPO sees no need for reporting them unless they deviate from a normally expected sequence.
INP0's intent was to reduce the number of LERs.
INP0 also noted that the criteria in 10 CFR 50.72 and the proposed 10 CFR 50.73 are roughly the same. However, 10 CFR 50.72 has a one hour reporting re-quirement and 10 CFR 50.73'has a 30-day requirement.
It was recommended
REACTOR OPERATIONS,
that 10 CFR.50.72 should be modified to reduce the one hour reporting requirement to those events truly requiring immediate notification.
It was recommended that some 10 CFR 50.72 requirements be dropped.
INP0 suggested additional reporting requirements for events which involve more than one personnel error or procedural deficiency, and either a component failure or design / analysis deficiency or fabrication / construction oeficiency in structures, systems, or components needed for safe shutdown and maintenance of safe shutdown, removal of residual heat,.or the control of the release of radioactive material.
It was felt by INP0 that requiring the reporting of the Energy Industry Identifification System (EIIS) component function identifier and system name of each component or system referred to in the event descriptions is a great burden on licensees.
EIIS is not widely used in the industry.
As an alternative INP0 is working toward improving the NPRD system identi-fication numbers, and if absolutely required, would prefer to use those number,.
INPO objects to NRC requiring information in LERs that is already available in FSARs and technical specifications.
In reporting LERS licensees are asked to exercise judgment However, a formalized LER rule would allow NRC to, in effect, judge a licensee's judgment, and could result in NRC issuing a fine.
INPO would like NRC to recognize the extent of the potentially subjective engineering judg-ment required in the licensee's process of complying with the require-ments of the LER rule.
NRC should incorporate into the rule their.in-tent to enforce the rule in a flexible manner.
INPO believes th6t re. quiring licensees to include NPRDS report numbers as part of the LER reporting system will be viewed by utilities as an attempt to make NPRDS mandatory without the weight of a rule.
INP0 feels this requirement has the potential to damage INP0's program to establish a comprehensive event reporting system, including the NPRD systen, outside the regulatory framework.
o REACTOR OPERATIONS Mr. Rosen of-INP0 noted that there are two failure data bases in NPRDS.
One is a component failure data base and the other is a system failure data base.
He explained that the system failure data base is in need of additional attention.
RESPONSE TO INP0 COMMENTS - F. Hebdon, NRC Staff Mr. Hebdon of the AE0D Staff made a response to the INP0 comments.
Mr. Hebdon explained there has been a good dialogue between INPO and the NRC Staff on the proposed rule already.
He also said that during the public comment period INPO and any other interested party will have the opportunity to make additional comments.
Mr. Hebdon explained that the recommendation that some requirements of 10 CFR 50.72 (immediate reporting requirements) be deleted from the LER rule would be referred to IE which is the NRC office most concerned with this requirement.
Regarding INP0's suggestion that not all ESF actuation need be reported and that they are already reported in monthly operating reports, Mr. Hebdon made the points that monthly operating reports do not contain the detail required by AE0D and that the Staff wants to stress that ESF actuation is an abnormal event.
Concerning adding a requirement to report multiple errors / failures, Mr. Hebdon noted they are very concerned over this aspect of reporting.
However, he noted the INP0 suggested criteria would not add much to the currently proposed LER requirements, and such events would be re-portable under NPRDS. The Staff feels requirements for reporting multiple failures are already in place.
Both the Staff and INP0 agreed that a technical specification timed condition should not be reported if the condition is cleared before the action limit (e.g., shut down plant if technical specification is not corrected in six hours) is reached.
i REACTOR OPERATIONS a As far as not requiring the use of the Energy Industry Identification System (EIIS) for labeling failed components, Mr. Hebdon explained that what the Staff was after was a conshtent system for identifying failed components.
He noted the EIIS was available ar.d met Staff requirements, he also said the Staff was not locked in to this system and would remain flexible.
Mr. Hebdon explained that the Staff's requirement to report the function and functional redundancy of failed complonents is to allow LER readers without access to plant SARs to understand the significance of a particu-lar event.
It is felt that this would be much less of a burden on the reporting utility which is familiar with their plant than on a lot of other readers.with less familiarity with a particular plant.
Mr. Ward cautioned the Staff not to burden the operators of a plant with trying to perfect a data base at the expense of managing the day-to-day operations of the plant.
He urged the Staff to reach a balanced com-promise between those two objectives.
The INP0 comment concerning NPC making a statement on its intent to enforce the rule in a flexible manner was discussed. NRC is afraid such a statement would cause considerable confusion and noted that to their knowledge no licensee has ever been fined or had an enforcement action made against them for a deficient LER.
Licensee's are simply requested to augment deficient reports.
Regarding the requirement to report the evacuation of individual rooms in the plant, the Staff explained that the intent was only to repor.t those cases caused by actual high radioactivity in the arca, not pre-cautionaiy evaucations.
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Mr. Hebdon noted that the Staff's requests for reporting NPRDS reference numbers en LERs that are also reportable under NPRDS is an attempt to be able to use the data base of both systems. He said it was not an attenpt to make NPRDS mandatory.
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REACTOR OPERATIONS.
CONCLUSIONS The Subcommittee was generally of the opinion that this rule should be released for public comment.
Following the public comment period the ACRS would have an opportunity to review the rule again in its final form after the resolution of comments. The "for comment" proposed rule will be presented to the full ACRS during the December 1981
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meeting.
The meeting was adjourned at 5:40 p.m.
NOTE:
For additional details, a complete transcript of the meeting is available in the NRC Public Document Room, 1717 H St., NW, Washington, DC 20555 or from Alderson Reporters, 300 7th St., SW, Washington, DC, (202) 554-2345.
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