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"I' January 5,1989 pt MEMORANDUM FOR:
Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research FROM:
R. Lee Spessard, Director Division of Operational Assessment Office for Analysis and Evaluation, of Operational Data
SUBJECT:
DIVISIONAL REVIEW OF THE PROPOSED RULEMAKING-NOTIFICATION OF INCIDENTS As requested in your memorandum of December 16, 1988, I have reviewed the proposed rulemaking regarding notification of events.
In general, I believe the proposed rule achieves the intent expressed in the Office of Enforcement memorandum of July 9, 1987, however, the following specific comments are provided.
7 No realistic estimate has been made as to the increased number of telephone 1.
reports to the NRC Operations Center that will result from the proposed
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changes to 10 CFR 30, 40, and 70, nor the effects on the Agency's ability a@
to respond to more safety significant reactor events.
Due to the large number of licensees involved, even a small increase in the number telephone reports received (e.g., even just one from each licenst each year), will have a substantial impact on the Headquarters Operation Officer's ability to effectively and expeditiously evaluate and respond to events.
At present, the number of incoming calls is frequently such that some are deferred until they can be addressed or until backup assistance can be called in.
An increase resulting from the proposed changes would further complicate the H00's ability to assess, classify and appropriately I
respond to events that require the NRC response organization to be activated.
'? In view of the above, I recommend that the basic need for telephone
, reports be reconsidered or, as a minimum, that a reevaluation be made of
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events that would fall into this category.
Following this, an assessment l
should be conducted as to the estimated number of calls that would result L
and their potential impact on the agency's response capability.
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Licensees should not be required to report the actuation of an alarm,
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absent other reasons for reporting. This could result in a large number of reports with little or no safety significance, e.g., spurious alarms, or
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informational alarms.
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Regarding the 30-day written report, it is recommended that reference 0
be made to Section (a) or (b) as a basis for a written report rather than the fact that an event occurred which required notification to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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/' January 5, 1!'89 If you have any questions regarding these comments pleasa call Gary Zech at x24193.
8 R. Lee Spe sard, Director Olvision of Operational Assessment s
Office for Analysis and Evaluation of Operational Data cc:
Joseph J. Mate, RDB/DRA