ML20055J363

Provides Summary of Licensee Position,Region II Position & Results of Review Re Reporting of Events Under Requirements of 10CFR50.73 at Plant.Actuation of ESF Logic W/O Component Operation Also Reportable,Unless Equipment Removed from Svc

ML20055J363
Person / Time
Site:	Hatch, Vogtle
Issue date:	07/12/1990
From:	Rossi C Office of Nuclear Reactor Regulation
To:	Lainas G Office of Nuclear Reactor Regulation
Shared Package
ML20055J362	List: ML20055J361 ML20055J363
References
NUDOCS 9008020150
Download: ML20055J363 (3)

Text

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• [as u1 kq UNITED STATES NUCLEAR REGULATORY COMMIS$10N j

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! W ASHING TON, D. C. 70666 s  %,

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• ...*l July 12,1990 l '

MEMORANDUM FOR: Gus C. Laints, Assistant Director for Region !! Reactors Division of Reactor Projects 1/11 '

Office of Nuclear Reactor Regulation FROM: Charles E. Rossi, Director Division of Operetional Events Assessment Office of Nuclear Reactor Regulation

SUBJECT:

GUIDANCE FOR THE REPORTING 0F EVENTS UNDER THE REQUIREMENTS OF 10 CFR 50.73 AT THE HATCH NUCLEAR PLANTS, DOCKET NOS. l

50-321 AND 50-366  ;

- PLANTS,DOCKETNO$.ANDATTHEV0GTLEELECTRICGENERATING 50-424 AND 50-425. j Region !! recently requested guidance from the Office of Nuclear Reactor Regulationonthereportingrequirementsof10CFR50.73(a)(iv). This memo .i provides a sumary of the licensee's position, Region II's position, and the results of a review of this matter conducted by OEAB. The position expressed ],

in this response has the concurrence of AEOD who has cognizance for the j 10 CFR 50.72 and 50.73 reporting requirements.

, Georgia Power Company (GPC) issued an Interoffice Correspondence (1433C) on i 1

June 11 1987 entitled "Reportability Position Paper for 10 CFR 50.73 Re- l ports"Insupp,ortof10CFR50.73. This paper provided guidance to the i company's operations personnel concerning reporting requirements. The utili- '

ty's position is that there is not a valid Engineered Safety Features (ESF) actuation unless the appropriate parameter sensor, the initiation logic and I theactualactuationcomponent(valve, pump, fan,etc.)areallthreesubject- .

ed to the signal which caused the actuation. In other words, if a signal were l inadvertently inserted in the logic portion of the circuitry downstream of the sensor, and resulted in an actuation of one or more components in a safety system, the event would not be reportable.

The position of Region 11 is that if, for any reason (except expected respons-es for testing) the ESF components are caused to operate, then an ESF actua- 1 tion did occur. Region 11 further states that the quantit l subjected to the signal or the reasons for the actuation except (y of circuitry for responses l te testing) are imaterial. I

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OEAB agrees with the position of Region II. Sections IV and V of NUREG 1022 J contain a restatement of the guidance contained in the Statement of Consider- '

ation for the LER rule. A review of these sections, examples provided in Appendix C of NUREG 1022, and Supplement 1 and 2 to NUREG 1022 was performed.

These documents were compared to the position paper developed by GPC, From this, it is evident that the licensee has inferred meaning that is contained neither in 10 CFR 50.73 nor in NUREG 1022. These inferences have enabled the t

licensee to define an ESF actuation which supports a more restrictive reporting i criterion (i.e.,leadingtofewerreports).

9008020150 900731 PDR ADOCK 05000321 P PDC

1' July 12,1990 i

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2 The following examples demonstrate the licensee's misinterpretation of the

rule, i

!) In the ' Synopsis of Reporting Philosophy *, the licensee introduces the i concept of ESF subsections. These various subsections are briefly discussed

' and their role in an ESF actuation tre described. The licensee then states:

'The above concepts were apparently the foundation of the LER rule". No basis is provided to support this supposition. Furthermore, neither 10 CFR 50.73 nor i NUREG 1022 discuss the various subsections defined by the licensee.

(re) port) events that have a nuclear safety significance".The The following licensee further a

paragraph is an excerpt from Section IV of NUREG 1022, and provides a i restatement of the guidance for 10 CFR 50.73 from the Statement of Consideration.

, 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 - '

j based primarily on the nature, course, and consequences of the events.

Therefore, the LER rule requires that events which meet the criteria be l reported regardless of the plant operating mode or power level, and regardless of the safety significance of the components, systems, or i structures involved. In trying to develop criteria for the identifice-tion of events reportable as LERs, the Comission has concentrated on the i potential consequences of the event as the measure of significance.

l Therefore, the reporting criteria, in general, do not specifically l ed#ess classes of initiating events or causes of the event. For exam-pie, there is no requirement that all personnel errors be reported.

However, many reportable events will involve or will have been initiated by personnel errors.

If the criteria were based only on the consequences of the event, then it may be correct to state that the intent of the rule is to report events that have safety si reported)gnificance . However,(implying the criteriathat arethese are the also based ononly eventsand the nature which need course of to be the event. Therefore, although an event may not have consequences that are safety significant, the nature or course of the event may meet the criteria required for reportability. Moreovr . it is clearly stated that events which meet the criteria of 10 CFR 50.73 are to be reported regardless of the apparent safety significance of the components systems or structures involved. TheseeventsmayhavesafetysignifIcancein,theaggregate.

Ill) Afinalexampleofthelicensee'sincorrectnarrowingofthereporting requirements of the rule is demonstrated by the statement The objective of the ESF reporting requirements of 10 CFR 50.73 is to report those events where the

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July 12,1990

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ESF was challenged, requiring the ESF system to respond to a sensed condition, l'

either valid or spurious". The following paragraph from Section V of NUREG 1022 specifically addresses 10 CFR 50.73 (a)(iv):

This paragraph requires events to be reported whenever an ESF actuates either manually or automatically, regardless of plant status. It is based on the premise that the ESFs are provided to mitigate the conse-quences of a significant event and, therefore, (1) they should work prop.

erlywhencalleduponand(2)theyshouldnotbechallengedfrequentlyor

unnecessarily. The Comission is interested both in events where an ESF was needed to mitigate the consequences (whether or not the equipment performed properly) and events where an ESF operated unnecessarily.

Clearly, the objective of the ESF reporting requirement is to re> ort th,,se events where the ESF was challenged. The condition that the 'ES: system respond to a sensed condition, either valid or spurious" is not included, nor

! can it be inferred. In fact it is stated that the ESFs should not be

challenged frequently or unne,cessarily and that the Comission is interested 1 in events where an ESF operated unnecessarily.

J In sumation, a review of 10 CFR 50.73 and the current guidance in the NUREG 1022 series cocument does not support the assumptions and definitions provided by the licensee in their Interoffice Correspondence *Reportability Position Paper for 10 CFR 50.73 Reports". ESF actuations should be reported (except those expected actuations that resulted from and were part of the preplanned sequenceduringtestingorreactorvperation). No exceptions are stated in the rule nor in NUREG 1022 for signals which are inserted midway in the logic portion of the circuitry, in addition we note thet actuation of the ESF logic without component o

open) is also reportable,peration unless equipment (e.g.,, is properly an RPS removed actuation from service. when RTBs are We should also like to point out that (except for verb tense) 10 CFR 50.72

, (b)(2)(ii) is identical to 10 CFR 50.73 (a) liv). Therefore, the ar

conclusions ., resented above would apply to 10 CFR 50.72 (b)(2)(ii)guments  ; and any and ESF actuation reportable per 10 CFR 50.73 should have been reported to the 0>erations Center within four hours. Should you have any further questions in tiis matter, please contact me directly.

harles E. Rossi, Director i

Division of Operational Events Assessment j Office of Nuclear Reactor Regulation l cc: W. Russell, NRR L. Reyes, Rll

! D. Crutchfield, NRR S. Collins RIV

S. Varga, NRR J. Rosenth51 AEOD I

T. Novak, AE00 W. Kane, R1 M. Williams, AEOD E. Greeman, RII G. Zech, AE0D Re Zimerman, RV

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